Working with EDTs

RCVS Preliminary Investigation Committee advice to veterinary surgeons working with Equine Dental Technicians (EDTs)

Introduction

1.  In June 2001, the Preliminary Investigation Committee of the Royal College of Veterinary Surgeons advised that it could not determine any public interest in taking action against veterinary surgeons who worked in conjunction with equine dental technicians (EDTs), provided that a number of 'conditions' are met. The RCVS may take action against veterinary surgeons working in conjunction with EDTs who do not meet the conditions. This note confirms and revises that advice.

2.  There are some equine dental procedures that any person may carry out; these procedures have been given the designation 'category 1' procedures. Other procedures may be carried out by trained EDTs; these procedures have been given the designation 'category 2' procedures. All other procedures must be carried out by veterinary surgeons; these procedures have been given the designation 'category 3' procedures. The principle of these three categories of procedures has been followed in consideration of a Ministerial exemption order to allow EDTs to practise lawfully.

The legal position

3.  The Veterinary Surgeons Act 1966 reserves the practice of veterinary surgery to veterinary surgeons, subject to a number of exceptions. The exceptions include minor treatments, tests or operations specified in Ministerial exemption orders.

4.  Generally, dental procedures carried out on horses' teeth are the practice of veterinary surgery and must be carried out by a veterinary surgeon

5.  The removal of small dental overgrowths using manual rasps only and certain other minor procedures are not generally thought to amount to the practice of veterinary surgery. Therefore, these procedures (category 1 procedures) are outside the Veterinary Surgeons Act 1966 and may be carried out by any person.

6.  The extraction of loose teeth and wolf teeth and other certain procedures, are generally thought to amount to the practice of veterinary surgery, but are thought to be suitable for trained EDTs to carry out in certain circumstances under an exemption order (category 2 procedures). However, until there is a Ministerial exemption order, it is a criminal offence for anybody other than a veterinary surgeon to carry out this type of work.

7.  Category 2 procedures also include the use of power tools to reduce focal overgrowths etc; the increased risks associated with the use of power tools are thought to make them unsuitable for use by any untrained person.

8.  Dental procedures other than those in category 1 or 2 (i.e. category 3 procedures) must always be carried out by a registered veterinary surgeon.

9.  Detailed revised and updated information on what should comprise category 1 and 2 procedures has been provided by the British Equine Veterinary Association and the British Veterinary Dental Association; this has been accepted by the RCVS. This is available below.

BEVA advice sheet on equine dentistry (PDF file - 70Kb)

Table summarising equine dental and oral surgical procedures (PDF file - 17Kb)

10. In July 2001 the Department for Environment, Food and Rural Affairs (Defra) published proposals for a Ministerial exemption order to make it lawful for suitably trained EDTs to carry out certain procedures which amount to the practice of veterinary surgery . No such order has yet been made.

Medicines

11. EDTs may not legally purchase or supply any sedatives or other medicines designated as POM-V in the Veterinary Medicines Regulations. Veterinary surgeons may not lawfully supply medicines to EDTs for administration to horses.

12. There is no proposal for the Ministerial exemption order to permit EDTs to prescribe, supply or administer sedatives or other POM-V medicines.

Approval of qualifications

13. In preparation for the making of the Ministerial exemption order, Defra has approved, on the advice of RCVS, training courses and examinations run by (a) the British Equine Veterinary Association in conjunction with the British Veterinary Dental Association and (b) the Worldwide Association of Equine Dentistry.

Advice to veterinary surgeons

14. Until such time as the proposed Ministerial exemption order is made there is no legal basis for EDTs to carry out any procedures which amount to the practice of veterinary surgery (category 2 procedures). In the meanwhile, however, the Preliminary Investigation Committee continues to take the view that it would not be in the public interest to take action against veterinary surgeons on the sole ground that they have worked in conjunction with EDTs, provided that:

a.  the EDT has successfully completed a training course approved by Defra for the purpose of the proposed Ministerial exemption order;

b.  the veterinary surgeon is satisfied that the EDT is competent to carry out the procedures in question;

c.  the EDT carries out only category 1 and 2 procedures (the practice of veterinary surgery that is suitable for trained EDTs to undertake and expected to be permitted by the Ministerial exemption order);

d.  the EDT works under the direction, and if appropriate the supervision, of the veterinary surgeon;

e.  the EDT reports to the veterinary surgeon, in a professional manner, all category 2 procedures carried out on horses under the care of that veterinary surgeon; and,

f.  the veterinary surgeon has informed his or her professional indemnity insurers of his or her involvement with EDTs.

15.  The Preliminary Investigation Committee's advice relates only to action which the Committee might take in discharging its responsibilities under the Veterinary Surgeons Act 1966, for supervising the professional conduct of veterinary surgeons. The advice does not preclude action (including prosecution) by other enforcement agencies. The purpose of the animal related legislation is to protect animals and a prosecution is more likely where there is evidence that animal health or welfare may be put at risk.

16.  This advice will cease to apply as soon as the proposed Ministerial exemption order comes into operation.