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2F. Treatment of Animals by Non-Veterinary Surgeons
1. The Veterinary Surgeons Act 1966 (Section 19) provides, subject to a number of exceptions, that only registered members of the Royal College of Veterinary Surgeons may practise veterinary surgery. 'Veterinary surgery' is defined within the Act as encompassing the 'art and science of veterinary surgery and medicine' which includes the diagnosis of diseases and injuries in animals, tests performed on animals for diagnostic purposes, advice based upon a diagnosis and surgical operations which may not necessarily form part of a treatment. These restrictions are in the interests of ensuring that animals are treated only by people qualified to do so.
2. A veterinary surgeon must be aware of the exceptions which allow non-veterinary surgeons to treat animals, in particular:
Physiotherapists, osteopaths and chiropractors
Other complementary therapists
Veterinary students
3. Veterinary students, as part of their clinical training, are required to undertake acts of veterinary surgery.
4. The Veterinary Surgeons (Practice by Students) (Amendment) Regulations 1993 identify two categories of student, full time undergraduate students in the clinical part of their course and overseas veterinary surgeons whose declared intention is to sit the MRCVS examination within a reasonable time. The Regulations provide that students may examine animals, carry out diagnostic tests under the direction of a registered veterinary surgeon, administer treatment under the supervision of a registered veterinary surgeon and perform surgical operations under the direct and continuous supervision of a registered veterinary surgeon.
5. The College has interpreted these as follows:
a. 'direction' means that the veterinary surgeon instructs the student as to the tests to be administered but is not necessarily present
b. 'supervision' means that the veterinary surgeon is present on the premises and able to respond to a request for assistance if needed
c. 'direct and continuous supervision' means that the veterinary surgeon is present and giving the student his/her undivided personal attention
Veterinary nurses
6. The Veterinary Surgeons Act 1966 (Schedule 3 Amendment) Order 2002 extends the exceptions to include qualified veterinary nurses whose names are on the List of Veterinary Nurses maintained by the RCVS and student nurses. Student nurses are those enrolled with the RCVS for the purpose of training at an approved centre or practice.
7. Under this exemption the privilege of giving medical treatment and carrying out minor surgery, not involving entry into a body cavity, is given to:
a. listed veterinary nurses under the direction of their veterinary surgeon employer to animals under their employer's care. The directing veterinary surgeon must be satisfied that the veterinary nurse is qualified to carry out the medical treatment or minor surgery (see paragraph 3)
b. student nurses under the direction of their veterinary surgeon employer to animals under their employer's care. In addition medical treatment or minor surgery must be supervised by a veterinary surgeon or listed veterinary nurse and in the case of minor surgery the supervision must be direct, continuous and personal. The medical treatment or minor surgery must be given in the course of the student's training
8. A veterinary nurse or student veterinary nurse is not entitled independently to undertake either medical treatment or minor surgery.
9. In considering whether to direct an RCVS listed veterinary nurse to carry out 'Schedule 3' procedures, a veterinary surgeon must consider how difficult the procedure is in the light of any associated risks, whether the nurse is qualified to treat the species concerned, understands the associated risks and has the necessary experience and good sense to react appropriately if any problem should arise. The veterinary surgeon must also be sure that he/she will be available to answer any call for assistance, and finally, should be satisfied that the nurse feels capable of carrying out the procedure competently and successfully.
10. When a veterinary nurse is negligent the liability is likely to rest with the directing veterinary surgeon.
Farriers
11. Both veterinary surgeons and farriers are involved in the treatment of horses' feet. While veterinary surgeons are exempt from the restrictions in the Farriers Registration Acts 1975 and 1977, farriers are not exempt from the restrictions in the Veterinary Surgeons Act 1966, and may not carry out procedures deemed to be acts of veterinary surgery.
12. There is no clear demarcation line between veterinary surgeons and farriers in the exercise of their professional responsibilities, so that much depends on individuals and the relationship between them. Decisions as to whether a particular procedure should be performed by one or the other is a matter for consultation and co-operation. Veterinary surgeons should make every effort personally to discuss cases with farriers.
13. Farriery consists of trimming and balancing the equine hoof prior to and the fitting of conventional or surgical shoes, and where a veterinary surgeon requires particular work from a farrier this should be specified in personal contact between them.
14. A farrier must not normally penetrate sensitive structures, cause unnatural stress to the animal, make a diagnosis or administer drugs. If he feels that either the veterinary surgeon is treating the animal incorrectly, or that a further condition is present requiring treatment, he should notify the veterinary surgeon or advise the owner to call in the veterinary surgeon. If a veterinary surgeon considers that a farrier's work is inadequate he should contact the farrier directly. Neither should make detrimental comments about the work of the other unless in the course of a formal complaint to their regulatory bodies, the Royal College of Veterinary Surgeons or the Farriers Registration Council.
Physiotherapists, osteopaths and chiropractors
15. The Veterinary Surgery (Exemptions) Order 1962 allows for the treatment of animals by physiotherapy, provided that the animal has first been seen by a veterinary surgeon who has diagnosed the condition and decided that it should be treated by physiotherapy under his/her direction.
16. 'Physiotherapy' is interpreted as including all kinds of manipulative therapy. It therefore includes osteopathy and chiropractic but would not, for example, include acupuncture or aromatherapy (see Part 1I, paragraph 2, Your responsibilities in relation to the treatment of animals by non-veterinary surgeons).
Other complementary therapists
17. All other forms of complementary therapy in the treatment of animals, including homoeopathy, must be administered by veterinary surgeons. It is illegal, in terms of the Veterinary Surgeons Act 1966, for lay practitioners however qualified in the human field, to treat animals. At the same time it is incumbent on veterinary surgeons offering any complementary therapy to ensure that they are adequately trained in its application.
Faith healing
18. Faith healers are required in terms of the Code of Practice of the Confederation of Healing Organisations, to ensure that animals have been seen by a veterinary surgeon who is content for healing to be given by the laying on of hands.
Animal behaviourism
19. Behavioural treatment that includes acts of veterinary surgery must be undertaken by a veterinary surgeon.
Pathology
20. Diagnostic veterinary pathology is covered by the definition of veterinary surgery and is legally undertaken only by veterinary qualified pathologists. The generation of objective numerical clinical pathology data (for example blood biochemistry and haematology) is acceptable only if it excludes diagnostic interpretation. Surgical and post-mortem pathology is inherently diagnostic and is fully within the legal definition of veterinary surgery.
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