1 SOUTH AFRICAN VETERINARY COUNCIL VETERINARIANS RENDERING SERVICES FOR ANIMAL WELFARE ORGANISATIONS GUIDELINES (F) FOR VETERINARIANS (AMENDED MAY 2007) 1. Introduction The purpose of this document is to assist and guide veterinarians involved in rendering services to animal welfare organisations (AWOs) whether on a full or part time basis. All veterinarians are accountable to the Veterinary Council and have to ensure that their conduct complies with the requirements of the Veterinary and Para-Veterinary Professions Act. Several matters concerning animal welfare continue to cause concern amongst the veterinary profession. These are mainly the following: In some cases veterinary services rendered by AWOs are not being limited to stray animals and indigent persons. Regular clients for veterinarians in private practice are being serviced by AWOs, often through their animal welfare assistants (AWAs). This creates conflict between AWOs and private veterinary practices. Veterinarians working for AWOs sometimes experience conflict between the requirements of their employers / contractors and their ethical professional obligations, for example with regards to unauthorised lay persons performing veterinary procedures and / or handling scheduled medication. Veterinarians that want to assist AWOs which do not employ their own vet in their own veterinary facility, are often hesitant to accept the risk of taking veterinary responsibility for AWOs when they cannot effectively supervise the veterinary activities. The intention of this document is to address these and other concerns by considering the rights and responsibilities of veterinarians in animal welfare. 2. The relationship between the veterinarian and the AWO A veterinarian must be contractually employed by the AWO, whether for gain or not, if veterinary services are rendered by the AWO. All veterinary services should be rendered under supervision or direction of the veterinarian and the veterinarian remains directly responsible. If the veterinarian feels that his/her professional ethics are being compromised, the SAVC should immediately be contacted to assist the principal.
2 3. Veterinary facilities at AWOs In terms of the Veterinary and Para-Veterinary Professions Act, no 19 of 1982 and Rules promulgated in terms thereof, only a registered veterinarian may render veterinary services and the place at, or from which, a person practices a veterinary profession, shall comply with the minimum standards for veterinary facilities and shall be registered with Council. AWOs may therefore only render veterinary services (including euthanasing of animals) from registered veterinary facilities. A veterinary facility is only registered if a veterinarian is in charge of the veterinary facility and takes full responsibility for the veterinary activities that take place at the facility. If the principal (registered veterinarian) of the veterinary facility leaves the employ of the AWO, the SAVC should immediately be advised thereof, in which instance the registration of the facility will be withdrawn unless another veterinarian takes responsibility for the facility. If the registration of the veterinary facility is withdrawn, all animals receiving veterinary attention should be transferred to another registered veterinary facility. AWA authorisation to perform certain services will also be withdrawn in the absence of veterinary supervision. The responsible veterinarian should maintain records as required in terms of the Rules. An after-hours service must be available if an AWO facility is registered as a veterinary consulting room, clinic or hospital. The service can be provided by the AWO facility or another registered veterinary facility that agrees to provide such a service. Application can be made for exemption from this requirement 1. 4. Use and supply of medicines The veterinarian employed or contracted by the AWO is in charge of and finally responsible for all medicine acquired, used and supplied by the AWO. AWOs cannot acquire, use or supply medicines without a veterinarian taking full responsibility. AWO staff who are not authorised by the SAVC to perform veterinary procedures may not use medicines without veterinary supervision. Authorised AWAs are allowed to use 1 Rule 40
3 medications under veterinary direction or supervision as determined by the conditions of authorisation. Any AWO employing an AWA who has been authorised by the SAVC to euthanase an animal, or an SPCA Inspector similarly authorised, is able, in terms of the Medicines and Related Substances Control Act, to apply directly to the Medicines Control Council (MCC) for a permit to acquire and use euthanasia medicine independently (without the supervision or involvement of a vet). This permit is granted to the specific AWA or SPCA Inspector, who will take full responsibility for the management and use of the product 2. In terms of an agreement with the MCC, applications for permits by AWAs are submitted to the SAVC for recommendation. Veterinarians who are contracted but not employed by AWOs, are understandably hesitant to accept responsibility for the use of medicines when they are not directly able to supervise such use. The SAVC encourages veterinarians who wish to assist AWOs to build up a relationship of trust with the organisation in order to establish a mutual understanding of needs. It is also advisable to have a contract clearly stipulating the responsibilities of the veterinarian and the AWO. However, veterinarians are not obliged to assist AWOs if they believe that their professional ethics may be compromised in doing so. 5. Effective internal control of medicines There must be adequate facilities for the safe storage of medicines. Only the veterinarian, veterinary nurse or authorised animal welfare assistant should have access to these storage facilites. The Schedule 5-7 medicine supplies must be kept locked and under the direct control of a registered veterinarian. These medicine supplies must be checked and balanced monthly and the register checked and signed by the veterinarian in charge. A register or patient card record of all prescriptions and use of Schedule 1 to 6 medicines must be recorded in terms of the prescriptions of Act 101. In the case of a mobile clinic, a daily register may be kept instead of patient cards. The mobile clinic s Schedule 3-6 medicine supplies must be balanced monthly and signed by the veterinarian in charge on a monthly basis. Only the veterinarian in charge may sign medicine orders for Schedule 1-6 medicine supplies. 6. Certificates and records of vaccination 2 SAVC Newsletter 42, September 2005 (article by Dr Stuart Varrie)
4 Only a veterinarian may sign a certificate. Any such certificate must comply with Rule 5 of the Rules promulgated in terms of the Veterinary and Para-Veterinary Professions Act. Temporary vaccinations administered to animals kept in AWO s kennels, which are indicated on the customary form issued for the information of a new owner collecting animals, are merely records of vaccination and need not be signed by a veterinarian. An AWA may sign a record of vaccination, however a record of vaccination is not a valid travel and / or export document. 7. Fees charged for veterinary services rendered by AWOs As non-profit organisations, AWOs should render veterinary services without profit. 3 The requirement should be strictly interpreted and the service offered should not even be permitted to show a profit to be off-set against losses made in respect of other activities. The service should be non-profitable in itself, with the exception of emergencies. In an emergency situation, a client should not be turned away unless an alternative arrangement has been made for the veterinary treatment of the patient. If the AWO renders the emergency service, the full fee (refer to the Guideline of Tariffs) should be charged if the client is not indigent. Veterinary services may only be rendered at substantially lower fees to indigent persons. It remains the responsibility of the veterinarians who are rendering these services, and are in charge of the AWAs rendering such services, to ensure compliance with this requirement. Clients of AWOs should be appropriately screened before the rendering of the service. All potential clients should either complete a written form or be interviewed, in which case the information should be recorded. The following information should be obtained: Full personal details, including a confirmatory statement that the client is the owner of the patient; Residential address; 3 Document drafted by Prof TW Naudé and Dr A Immelman, agreed to at meeting of 22 February 1991.
5 Employer s details and authorisation to verify remuneration and deductions from the employer; Gross income (together with a copy of a salary slip if employed or pension slip where possible) Expenses Number of animals owned Whether or not the client has attended a private veterinarian in the last three years; and A declaration that the information is true and correct in every aspect and a warning that incorrect statements will lead to the termination of further assistance, the rendering of a full account for services rendered and prosecution. The SAVA s means test (Annexure A) has been approved by Council to be used as a guideline for screening clients. Cognisance has been taken of the fact that the deductions allowed on the means test could benefit individuals in the higher income bracket and the test should be used as a guideline to screen clients. Common sense and discretion, while taking into account specific circumstances, should be employed when screening potential clients. Other factors that should be considered during the screening process, include the location of the veterinary facility, the type of animal and the condition of the animal. Breeding operations should not be supported and litters presented for vaccination should therefore preferably be turned away, or the full fee charged. It is also recommended that all animals presented to an AWO be sterilised. Should the client declare that a private veterinarian has been consulted in the last three years, it is recommended that contact be made with the colleague before proceeding with the case. 8. Animal welfare assistants AWAs may not carry out any procedure pertaining specially to the profession of veterinarian, veterinary nurse or animal health technician unless authorised by Council to do so. These procedures are mainly limited to primary health care activities and euthanasia in some cases. The principal of the veterinary facility where AWAs are employed is expected to monitor them to ensure that they only render services that fall within their authorisation in terms of section 23(1)(c) of the Act.
6 Please refer to the Guideline document for the authorisation of animal welfare assistants for further information regarding AWAs.
7 Annexure A SAVA MEANS TEST GROSS INCOME APPLICANT SPOUSE Salary Pension Maintenance Grant Allowances All other income (specify) TOTAL DEDUCTIONS PAYE/SITE UIF Compulsory Group Insurance Medical Fund Contributions Rent/ mortgage instalments Maintenance School fees TOTAL DEDUCTIONS Number of children NETT INCOME Less R 600.00 applicant Less R 600.00 spouse Less R180.00 per child BALANCE In the event of a positive balance the applicant will not be entitled to assistanc