11/11/2017
RCVS has recently tried to stop the petition on Care2 in support of Veterinary Homeopathy, as they state that Veterinary Homeopathy is not banned by their Position Statement published the 3 November 2017. Here is the situation aptly explained by Mark Elliott BVSc VetMFHom MRCVS MLIHM PCH DSH RSHom.
Mark Elliott has sat on both the Advisory Committee (now called Standards) and the Preliminary Investigation Committee of the RCVS, and of the latter he was appointed Vice-Chairman for some years. He was an elected Member of RCVS Council for 12 years, retiring from Council in 2015.
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Why the recent RCVS statement of Complementary and Alternative Medicines (CAM) is effectively a Ban on vets using these therapies in practice?
By Dr Mark Elliott BVSc VetMFHom MRCVS MLIHM PCH DSH RSHom
In response to a recent on-line petition the RCVS has called for it to be taken down as it says it has not banned Homeopathy.
So what does its recent statement actually say and mean? This is my take on the matter.
The RCVS has made a statement that it is clear effectively bans all Vets from practicing any form of medicine or treatment that it deems not to have a recognised evidence base, and/or sound scientific principles. A key point in the statement is that it makes clear that any delay or denial of treatments the RCVS recognises as fitting their criteria could precipitate a welfare issue. In doing so it implies that Vets may face disciplinary action if they use any treatment that delays or denies medicines they do approve of, and by extension logic suggests owners of animals using CAM therapies, even if from an holistic vet, will also be in the frame when one considers the intention of the Animal Welfare Act legislation.
The RCVS does not make clear to anyone what it deems to be a recognised evidence base, nor what are sound scientific principles so the statement leaves even that open to interpretation. This leaves any defence an individual Vet might advance if a case I taken against them at the mercy of the Disciplinary Committee, which is the court in which cases against Vets accused of serious professional misconduct are heard.
The Disciplinary Committee judges cases based on the Law of the land, and the RCVS Code of Conduct; it is appointed by, instructed by and overseen by RCVS Council (albeit through an arms length process).
The Code of Conduct is not itself subject to Competition Law and so a monopoly exists which the RCVS is charged to regulate responsibly. Many would say it has lost the moral integrity to so discharge its duties in this debate now in making and publishing the statement of 3rd November 2017.
The RCVS singles out Homeopathic treatment as a particular consideration and makes statements it cannot substantiate at this time, and which contradict its own Science Committees comments earlier in their debate. However, there are many commonly used therapies that also fall under the definition of CAM, including Acupuncture, Herbal Medicines, Laser therapy, Chiropractic, and Nutraceuticals to name a few. All widely used in practice, and in the last RCVS Manpower survey the number of Vets using one or more types of CAM claiming a speciality were around 4%, this is likely now to be many more as demand has been growing. Widening the debate one quickly realises that key financial pillars of the profession – Continual re-vaccination, promoting neutering as a health benefit, promoting food sold in practices as of particular benefit etc. are all now among those issues that might now be exposed to further debate as they do not fit the RCVS criteria of being evidence based or based on sound scientific principles as well.
There are also many commonly used therapies in mainstream practice that don't have a recognised evidence base, may be innovative and in development, and may be even just the use of drug combinations that have not been fully trialled and tested for efficacy and safety, but experience says they work. These may now all need looking at.
The Statement identifies prophylaxis as a particular concern. It states “Veterinary Surgeons should not make unproven claims about any treatments, including prophylactic treatments”. This is particularly topical in light of the on-going accusations that some in the profession are profiteering by insisting on annual re-vaccination of pets (and horses) in the absence of evidenced need, with the Vets defence being often that protocols are based on marketing authorisations for vaccines, whilst ignoring the fact that these only require minimum durations of immunity to be shown – so arguments for are actually based on a lack or lack of examination of the evidence. How does the RCVS view this issue now? Are they now duty bound to investigate the profession as what evidence is available supports much longer intervals between vaccinations, and that re-vaccination may not need doing at all?
Prophylaxis is in fact much wider than the vaccination debate though. It encompasses such practices as the use of antibiotics to prevent possible infection, as well as the more responsible use of herbal and botanical substances in farming to reduce reliance on those same antibiotics (widespread across Europe and growing in the UK) to hit government targets. Do these initiatives all now have to stop? Massive use of pesticides on pets to prevent possible, even at times arguably improbable, illness from infection is another issue, and that itself has potential for impacts on human health and well-being from repeat exposure, quite apart from worries over the insect declines now causing international concern.
It is clear the statement is ill-considered and ill-conceived, and understandably the public has interpreted it is such a way that it considers the RCVS Council to be led by the nose by vested outside interests, and that it is influenced by bias within its ranks. Whether it is or not, that is not for me to say, but it is for the RCVS to answer in my opinion as current Council Members are commenting widely now on this matter on forums and Social Media. Maybe publication of all declarations of interest of Council Members on-line would help alleviate concerns, or maybe it would not.
The British Association of Homeopathic Veterinary Surgeons has published a statement that covers many very important points and raises more questions the RCVS must answer. These include how and why it felt the need to issue this statement without appropriate consultation with stakeholders including the public and those of its members directly and adversely affected by their pronouncements. Why it has stepped outside its remit to get involved in debates over differences of scientific opinion? Did it use funds for the “extensive legal advice’ in a manner compliant with its remit? How it will compensate those affected by this change - arguably most practices in the UK now, but very certainly the Homeopathic using ones? How will this statement not stifle innovation and research of new unproven therapies to benefit animals? How it can seek to override UK and EU legislation that provides for (and requires in some circumstances – eg Organic farming) Homeopathy to be available? And perhaps more notably why has RCVS not changed the Code of Conduct if it so strongly believes its position is tenable – reports of their debates on this issue suggest that it is precisely because it fears exactly the points I raise - of the rest of the professions practices being closely examined, as the rules would apply to all.
One has to suspect that this statement is in fact a prelude to a Code change, and should that follow then CAM will no longer be available in the UK for animals as no Vet is going to be able to work every day looking over their shoulder expecting to get disciplined, even struck off, just for trying to care and do their best for the patient. Medical options will become extremely limited, and animals may even have to be euthanased as therapies have to be denied to them.
If one has any doubt that I am wrong then I quote sitting RCVS Council Member Chris Barker, who posted on Vetsurgeon.org on Monday 6th November
“Perhaps a little clarification to help... Homeopathic remedies have a recognised legal status under the Veterinary Medicine Regulations, courtesy of an EU Directive. However much we may disagree with this nonsensical 'equivalence', it sits there enshrined in current Law. And thereby restricts the freedom of the RCVS, as regulator of our profession, to act; it cannot declare their use 'illegal'. There will be the opportunity post-Brexit for representation to be made to the Veterinary Medicine Directorate to require the remove of this anomaly.
What this statement does is to establish the limited circumstances in which the College might consider the use of homeopathic remedies to be 'rational', as complementary, not alternative therapies. Disciplinary action could now be considered by the PIC if the use of homeopathic remedies delays the use of a medicine which has proven scientific benefit in a particular condition. However the action would be pursued on the basis of the welfare argument; the Code of Conduct does not, and at present cannot, forbid their use entirely.”
The RCVS statement is then a complainants charter, encouraging the RCVS and others who seek to destroy CAM therapies to seek out and find cases against CAM Vets, and in particular Homeopathy prescribing Vets, where whatever is meant by an RCVS recognised treatment has been denied or delayed, irrespective of the facts that any treatment may not work every time even in the most perfect clinicians hands. Chris’s post is in my opinion a clear statement of the intention of the RCVS Council.
If and when a case is brought before the Disciplinary Committee, and the Vet convicted, then it will be game over for CAM.
So in my opinion the recent RCVS CAM statement is a ban in all but name, and the intention of RCVS Council is clearly a future complete ban anyway. It removes clinical freedom from Vets, and precludes owners making a fully informed choice as to treatment options available.
Notes:
Mark Elliott has sat on both the Advisory Committee (now called Standards) and the Preliminary Investigation Committee of the RCVS, and of the latter he was appointed Vice-Chairman for some years. He was an elected Member of RCVS Council for 12 years, retiring from Council in 2015.
Mark runs an Integrated Medical practice in West Sussex, using Homeopathy, Acupuncture, Herbs, Laser therapy and conventional pharmaceutical medicines as appropriate for his patients. More information can be found on www.markelliott.co.uk
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