I am signing this petition in regard to the OMAFRA’s request for feedback to the Modernization of the Veterinarians Act, Ontario. As an animal owner, I am grateful for this opportunity as it appears that this Act will better define veterinary medicine in Ontario and will outline specific activities that would only be allowed to be performed by a licensed veterinarian (or delegated to a veterinary technician). However, I have some concerns about the proposed authorized activities. The list has the potential to forbid service delivery by non-veterinarians currently being utilized by myself and many other pet owners in Ontario, thereby impacting the care and health of an animal.

I believe the list of proposed authorized activities (i.e., those activities that only a vet can perform) has the potential to have a negative effect on my ability to access to services performed by non-veterinarians, such as Animal Physiotherapists, Animal Chiropractors, Animal Acupuncturists, and others. I also feel the authorized activities list could have a negative effect for animal breeders and the agricultural industry.

There are six specific areas of concern within this section that I feel need to be addressed.

1. "Making or communicating a diagnosis, identifying a disease, disorder, dysfunction or condition as the cause of an animal’s signs and presentation".

Other professionals make diagnoses and are competent in doing so.

• Animal physiotherapists provide diagnoses about nerves, bones, joints, muscles, tendons, ligaments, fascia, etc. based on their physical examination. In fact, physiotherapists train veterinarians in physical therapy on animals and on how to make physical therapy diagnosis.
• Dog trainers may provide a 'diagnosis' of a dog's behavioural issues, and subsequently make training recommendations to improve behavior.
• Dog groomers may make a 'diagnosis' that a dog has full anal glands or a rotten tooth and may aid in remedying the situation or referral of the animal to a veterinarian.
• An equine dentist may diagnose a horse as having teeth that need to be floated or a tooth that needs to be extracted.
• A chiropractor may diagnose a spinal dysfunction that needs to be treated. They also train the veterinarians in spinal manipulation and how to make a chiropractic diagnosis.
• An acupuncturist may make a Traditional Chinese Medicine diagnosis prior to creating a treatment plan.
• A massage therapist may make a diagnosis of muscle tension, injuries, etc. and based on his/her diagnosis, treat accordingly.
• Ranchers, farmers, ranch/farm workers, or feedlot workers may make a diagnosis related to herd health issues (scours, foot rot, pink eye, ringworm, joint infection, etc.) that would require drugs to treat, even in the absence of a veterinary diagnosis.

Is there not a way to allow others to make their own diagnoses (within their scope) while reserving a Medical Diagnosis as a restricted activity for veterinarians?

2. “Performing an assessment to determine the fitness or soundness of an animal, or a group of animals, on which it is reasonably foreseeable that a person will rely on the assessment"

Again, many other people in the animal health industry are currently engaged in this practice. E.g. Physical therapists, chiropractors, massage therapists, etc. with 'animal specific' training. They perform these assessments within their scopes of practice to help determine if an animal is fit to compete in an event, progress an exercise program, or return to normal activities.

A non-veterinarian assessment evaluates things that a traditional veterinary examination does not. Most national equine or canine sporting teams will travel with an animal physiotherapist, chiropractor, and/or massage therapist to provide assessments and treatments to the animal athletes. Will the proposed Act hinder the ability of non-veterinarian allied animal health practitioners to continue to function as they have been?

Physical therapists, chiropractors, and other allied animal health practitioners should be given further exemptions to perform an assessment to determine the physical fitness or soundness of an animal or group of animals. This falls within the scope of what they know and do as well.

3. "Performing a procedure below the dermis."

Other persons are performing activities that fall into this category.

Acupuncture and dry needling are within the scope of practice for trained physiotherapists, chiropractors and acupuncturists. They are able to apply their professional knowledge and skills to animal patients. 

• Farm, ranch, or feedlot applications are also impacted by this clause, as neighbours and friends (not employees of the animal owner) may be castrating, branding, or giving shots to animals at various times in the year.
• Animal transport personnel may be required to tag or tattoo an animal that is going for slaughter.
• A friend or mentor of a breeder might be asked to assist in microchipping or tattooing puppies as required by the registry bodies (i.e Canadian Kennel Club)

I would support a clause that is specific to surgical procedures being an authorized activity, but not wording such as this that restricts activities that are currently being performed by non-veterinarians.

4. "Applying or ordering the application of a form of energy prescribed by the regulation under this Act."

This sentence is far too broad and limits the ability to provide a full spectrum of treatment options.

As written, it would include forms of physical therapeutics utilized by physical therapists, chiropractors, and others e.g., Class 4 LASER therapy and Shockwave therapy.

• The wording also impacts less physical forms of energy and might be taken to interpret such things as energy medicine (i.e. reiki, healing touch, Qi Gong, etc.).
• Should the intention of the sentence be the ordering or application of procedures such as MRI or CT imaging, radiographs, or radiation therapy, then the wording should be improved to clarify this intention.

5. “Putting an instrument, arm, hand, or finger, i. beyond the external ear canal, ii. beyond the point in the nasal passages where they normally narrow, iii. beyond the larynx, iv. beyond the opening of the urethra, v. beyond the labia majora, vi. beyond the anus or cloaca, or vii. into any other natural or artificial opening into the body”

• Animal breeders may have a friend or mentor who would help them in breeding scenarios (vaginal swabs for cytology, semen collection and insemination, and/or manual / digital examination of the vagina as it pertains to the impregnation or birthing their animal(s). This could involve putting a appendage beyond the labia major.
• A dog groomer may need to express anal glands or clean the ears.
• A horse groom might need to clean the penis sheath of a horse as part of routine equine husbandry.
• A non-employee (i.e. a neighbour or friend) might be called to help birth a calf, foal, lamb, or kid, and as such might put an arm beyond the anus or labia major.
• Consideration should be made for scenarios, situations, or occupations where this authority could restrict professional practice, have a negative impact on animal health, or lead to poor animal management. The exemption list should be expanded.

6. “Performing a procedure on or below the surfaces of the teeth, including the scaling of teeth and occlusal equilibration”

• Equine Dentists have been performing techniques such as these for over 2 decades.
• Pet Groomers and others are currently performing non-sedation teeth scaling in small animals. It should be an option for animal owners.
• Animal owners should have the right to choose to acquire services for their animals from non-veterinarians who practice these techniques.

7. “Prescribing, compounding, dispensing, or selling a drug”

This authorization would make it illegal for a pharmacist to compound a medication and/or fill a prescription directly for an animal owner. An owner may need or want to use a pharmacy to acquire a medication a) if the veterinary clinic does not have the drug available, b) if a medication needs to be compounded, or c) to save on cost.

The exemptions list needs to be expanded to account for scenarios whereby a pharmacist or medical dispensary is used instead of a veterinary clinic at the discretion of the owner and/or the veterinarian.

As an animal owner, I would like to have greater freedom of choice to make decisions about my animal’s health. My animal is my property after all. While I applaud the decision to update the Veterinarians Act, I wish to see the Ministry address my concerns.  

Read More
THE PROPOSED VET ACT:
https://cvo.org/Public/Public-Consultations/Modernizing-the-Veterinarians-Act.aspx

THE REQUEST FOR CONSULTATION
https://www.ontario.ca/page/consultation-veterinarians-act-ontario

What else can you do to help?
Send your suggestions and feedback in one of two ways: 

By email: vetact.omafra@ontario.ca

By surface mail:
Comments on the Modernization of the Regulation of the Veterinary Profession
Ontario Ministry of Agriculture, Food and Rural Affairs Food Safety and Environmental Policy Branch
1 Stone Road West, 2nd Floor S.W
Guelph, Ontario N1G 4Y2

** c.c. your MPP (if in Ontario) **