8 April 2005

AMENDMENTS TO LEGISLATION GOVERNING ARTIFICIAL INSEMINATION IN CATTLE: VETERINARY SURGEONS ACT 1966

Thank you for the opportunity for FAWC to comment on proposals to amend the Veterinary Surgeons Act 1966 to permit properly trained and competent non-veterinarians to inseminate cattle artificially.

FAWC broadly welcomes the proposals to tidy up the existing anomaly in the law, with the caveat that training and qualification is a strict requirement to ensure operators are competent to carry out AI in cattle.

There appears to be a duality in the way that grandfather rights are proven. On the one hand it is sufficient to produce a certificate of attendance at training and on the other a signed letter from a veterinary surgeon certifying an operators competence is required. We would favour the latter, more rigorous evidence.

The training schedule described in the consultation would appear to cover the necessary elements. However, it might be better to focus on the learning outcomes. This will help when training providers are delivering courses and doing assessment. So, for example, under health and safety “Participants must be able to: List the main health and safety risks associated with handling cattle, etc.” and “Participants must have: Demonstrated the ability to work with cattle in a way which minimises the health and safety risks to themselves and others.”

Without adequate teaching competency the delivery of courses and, therefore, their effectiveness could suffer. It is important to be assured of the teaching competencies of all those involved, including the veterinary surgeons, both in directing and delivering courses. Likewise the competence and skill of the supervising veterinarian and instructors in carrying out AI would need to be assured to support the objective of the training.

It should be made clear that the OVS has overriding responsibility for the welfare of animals in the slaughterhouse and this must extend to the selection of animals used for training. Those undertaking courses in the slaughterhouse need to be aware that rules relating to handling of animals are stricter than those on farm, e.g. no twisting of tails. There must be sufficient, suitable pens, or preferably AI stalls.

With regards to “rest” at the slaughterhouse a fixed rest period does not take into account the variations in animals and journey time or quality. The issue must be “fitness” to be subjected to the procedure, in addition to the anticipated stress of normal handling for slaughter. A pragmatic approach might be for the attendant OVS, after having carried out ante-mortem inspections, to decide, in conjunction with the plant operator, what animals may be used. Suitable guidance might be issued through the MHS operations manual.

The option of doing nothing, with any possibility of deregulation so that neither training nor qualification would be necessary, would be completely unacceptable because of the potential for animal welfare to be greatly compromised.

FAWC Secretariat