EDV Research Papers

Dentistry procedures for horses can be performed using power tools.  The use of power tools by persons without appropriate training introduces risk of harm to horses.  The paper argues that where the power tools are used, those procedures should be restricted to performance by veterinarians with appropriate training.  Despite this risk, some Australian jurisdictions have lifted the practice restriction or have legislated to allow lay persons (non-veterinarians) to use power tools.  This paper reviews the legislation in New South Wales, Queensland and ACT.  It traces the risks and arguments and concludes that the practice restriction is necessary.

Keywords
equine; dentistry; horses; legislation; non-veterinarians; animal welfare

Abbreviations

AVA, Australian Veterinary Association; AVMA, American Veterinary Medical Association; MacIntosh, Veterinary Surgeons Board of Queensland v MacIntosh [2010] QCAT 601;

NI2009-652, Health Professionals (ACT Veterinary Surgeons Board Standards Statements) Approval 2009 (No 1): Notifiable Instrument, NI2009-652, 8 December 2009;

NSW VPR, Veterinary Practice Regulation 2013 (NSW);

VSA NSW, Veterinary Practice Act 2003 (NSW);

VSA QLD, Veterinary Surgeons Act 1936 (Qld)

 

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Introduction

Within this paper, the term lay persons refers to persons who are not veterinarians.  ‘Veterinarians’ includes registered veterinary surgeons and veterinary practitioners as they are described in different Australian jurisdictions’ legislation.  The practice of equine dentistry using power tools refers to the use of powered drills.   Some of those are similar in size and appearance to those used by carpenters for drilling into wood and metal.  Usually the power tools are fitted with long extensions to allow grinding of the horse’s back teeth, and require considerable skill and practice for effective use.  The power tools are noisy, cause considerable vibration and the process usually requires the horse to be adequately sedated with restricted drugs.  Legally, that sedation can only be performed by a veterinarian, such as is required under the Health Act 1937 (Qld); Health (Drugs and Poisons) Regulation 1986 (Qld) s 180.  Once sedated, the horse does not usually object to procedures performed by the operator.  If the animal is not adequately sedated there is significant risk of additional harm to the animal, and injury to the operator and assisting humans.

 

In 2010, the Queensland Civil Administrative Tribunal heard expert evidence regarding the harm that can ensue at the hands of inadequately trained persons performing equine dentistry using power tools.  That case was Veterinary Surgeons Board of Queensland v MacIntosh [2010] QCAT 601.  Four horses, Zander, Silver-Smith, King and Cyrus suffered significant injuries.  In 2009 Zander was euthanased.  At paragraph 22 of that case, the Tribunal declared ‘that the use of a power rasp/file in the hands of an individual not properly trained with these instruments can cause irreversible harm to animals putting their welfare at significant risk’.  The Tribunal also stated that the regulation that permitted what was originally intended to include only manual rasping and filing of horses teeth ‘may need to be revisited’.  It is disturbing that the regulation has not been modified.  Of equal concern is that both New South Wales and the ACT have introduced regulations to permit lay persons to use power tools in equine dentistry once the horse has been sedated by a veterinarian.

The equine dentistry example illustrates that some new veterinary technologies can significantly increase the risk of harm to animals when employed inappropriately.  This paper suggests that technologies that are potentially dangerous should be restricted for use by appropriately trained veterinarians that are better positioned to identify and ameliorate risks.  From an animal welfare perspective, it appears a matter of common sense that jurisdictions must leave open mechanisms within their veterinary practice or animal protection statutes to restrict the performance of particular, potentially harmful procedures that may be performed upon animals, by persons who are not veterinarians.

Why are the Protections Needed?

This section outlines the key logical arguments against the lifting the lay person practice restriction on the performance of equine dentistry using power tools.

Professor Blood’s Pleas

In his 1985 book entitled Veterinary Law: Ethics, Etiquette and Convention,[1] the late Professor Emeritus of Veterinary Medicine at the University of Melbourne, DC Blood pleaded with the veterinary profession that it should ‘take a firm stand’ against lay persons practicing veterinary procedures.  He described various classes of lay person practices that were common at the time.  These included equine dentistry, physiotherapy, acupuncture, particular treatments for cattle and sheep and the castration of horses.  Blood declared that to remain consistent with the principles of the profession, and when determining which treatment to apply, the primary consideration must be the best interests of the animal.  He stated that lay persons were not in a position to make that determination.[2]

Warnings of Wilson and Walsh

Internationally recognised veterinarian GJ Wilson and Professor of Dentistry LJ Walsh report that specialist water cooled power tools will help to avoid injuries when used appropriately.[3]  However they warn that:

In equine dentistry, the practitioner has no indication of thermal injury from the use of
power instruments. If pulp necrosis were to occur subsequent to the procedure, pulp death and perhaps tooth loss will not be evident for many years. Initially the tooth will become non-vital. This will be followed by eventual pulpal infection and abscess formation.[4]

Veterinary Associations’ Policies Regarding Equine Dentistry

The Australian Veterinary Association (AVA) policy states that ‘[a]ll dental procedures on horses and related species should be performed only by registered veterinarians and be supported by evidence-based medicine’, and that advancements in veterinary medicine require that equine dentistry should be performed only by ‘qualified and skilled veterinarians’.[5]  Cited risks of incorrect procedures include exposed pulps, loss of teeth, bone fractures, and osteomyelitis and abscess potentially culminating in ‘death from complication or for humane reasons’.  In the policy, the AVA states that ‘[h]orse owners are entitled to expect that persons practising dentistry are properly trained, accredited and regulated’.

The American Veterinary Medical Association (AVMA) policy on equine dentistry notes that for all animals ‘[v]eterinary dentistry is a function of veterinary practice because it requires diagnosis and treatment’.[6]  For horses specifically, the AVMA policy states that ‘procedures which are invasive to the tissues’ including ‘removal of sharp points’ and ‘reshaping of teeth’ should be ‘performed by a licensed veterinarian’.  In March 2011, the AVMA reported that in Texas there was a rise in non-veterinarians performing equine dentistry with power tools and a concurrent rise in the use of restricted sedative drugs.[7]  Subsequently the Texas Occupations Code[8] § 4-801-260 was updated.  Equine dentistry may now only be performed by a veterinarian or a licensed equine dental provider who is active and in good standing under the supervision of a veterinarian.  It is the State Board of Veterinary Medical Examiners that may grant the license.  Criminal background checks of applicants are performed.  The scope-of-practice of licensed equine dental providers is limited under § 4-801-262 and importantly, they are held to the same standard of care as a veterinarian under § 4-801-263.  The Code also details particular grounds for license denial or disciplinary action related to equine dentistry, and criminal penalties can apply for violations of the chapter.

Proof of significant harm: Zander, Silver Smith, King and Cyrus

Veterinary Surgeons Board of Queensland v MacIntosh [2010] QCAT 601 (MacIntosh) provides evidence of actual harm caused by a lay person who performed equine dentistry using power tools, under the supervision of a veterinarian who was not an equine dentist specialist.  In that case, a Queensland registered veterinary surgeon and a lay person under her supervision, performed dental treatments on horses owned by other people.  The horses were called Zander, Silver Smith, King and Cyrus.  At paragraphs 3 and 14 of the judgment the Tribunal indicated that the inappropriate use of power tools was a key cause of the harm inflicted upon the horses.

In this case the tools employed included a ‘powered diamond cutting wheel’.  At paragraph 3 the Tribunal outlined the harm that was caused to the horses.  As a result of the inappropriate use of power tools, between 2001 and 2007, Zander suffered dental trauma and pulp necrosis in five of his teeth.  On 13 May 2009 he was euthanased.  Sometime between 2001 and 2007 Silver Smith also suffered dental trauma to four of his teeth with pulp exposure and thermal pulp necrosis.  Between 2003 and 2007 King suffered similar dental trauma to seven of his teeth, with infection in two.  Between 2004 and 2008 Cyrus suffered similar dental trauma, and in 2009 four of his front teeth were dead and had to be extracted.

At paragraph 4 of the judgment it was stated that the veterinary surgeon in this case admitted to supervising the lay person’s use of the power tools.  Under the Veterinary Surgeons Act 1936 (Qld) s 2A(2)(c), the lay person’s acts constituted medical or surgical treatment of horses.  Under the same Act in s 22F(k), supervision by a veterinary surgeon of a lay person undertaking an unauthorised act of veterinary science constitutes misconduct in a professional respect.  The veterinary surgeon was reprimanded, was suspended for three months and was required to give an undertaking to undergo specialist equine dentistry training (see paragraph 24 of the judgment).  The Tribunal did recommend that the veterinary board inform its members (veterinarians) of particular aspects of the evidence put forward by the expert witnesses.

It is unlikely the horse owners, when they contracted the veterinary surgeon’s services, had knowledge of the harm already inflicted by the perpetrators upon the other victims.  The potential latent effects (as described by Wilson and Walsh above) of the ill-performed treatments would not have assisted disclosure.  No related case reports could be found by one of the authors (KH) in regard to cruelty prosecutions.

The Lack of Protections Across Some Jurisdictions

This paper reviews the lack of the protections for animals against potentially harmful lay person practices across the jurisdictions of Queensland, New South Wales and the ACT and specifically in relation to equine dentistry.

The New South Wales Regime

The Veterinary Practice Act 2003 (NSW) (VSA NSW) s 4(1) definition of veterinary science includes ‘any branch of the science or art of veterinary surgery or of veterinary medicine’.  Some of the acts included in that definition are: ‘(a) the examination of or attendance on any animal for the purpose of diagnosing the physiological or pathological condition of the animal’, and ‘(b) the giving of any anaesthetic to, or the performance of any operation on, any animal’ and ‘(e) the doing of any act that is prescribed by the regulations as forming part of the practice of veterinary science’. VSA NSW s 7 includes provisions to enable the advisory committee (appointed by the Minister under Part 2) to apply to the Minister to declare a restrictive act of veterinary science.   Ultimately the Minister will determine whether a recommendation to make the regulation will be made to the Governor.  Under s 7(5) the advisory committee may recommend that persons other than a veterinary practitioner should be permitted to perform the act.  Under s 7(4) there is a positive obligation upon the advisory committee that they must not make a recommendation for a restricted act of veterinary science:

 

unless the advisory committee considers that if such an act were performed on an animal by a person other than a veterinary practitioner it would be likely:

(a) to cause unacceptable levels of harm or suffering to the animal, or

(b) to affect human health adversely, or

(c) to affect domestic or international trade adversely.

 

VSA NSW schedule 1 nominates particular acts that may not be declared acts of restricted acts of veterinary science (they are unrestricted acts of veterinary science).  These include ‘the administration, under the immediate and direct supervision of a veterinary practitioner, of an anaesthetic to an animal’.  It is an offence for any person other than a veterinary practitioner to do any restricted act of veterinary science under VSA NSW s 9.  The maximum penalty is 50 penalty units and/or imprisonment for twelve months.  However s 9(2) provides exclusions to the offence including where ‘(a) the person is the owner of the animal, or (b) the person is an employee of the owner of the animal and the act is done incidentally to the primary duties of that employment’.

The Veterinary Practice Regulation 2013 (NSW) (NSW VPR) s 4 defines the restricted acts of veterinary science.  Section 4(1)(g) declares ‘the performing of any dental procedure other than tooth cleaning on any animal other than a horse’ as a restricted act.  Also declared as restricted acts are ‘the examination of or attendance on any animal for the purpose of diagnosing the physiological or pathological condition of the animal’ under s 4(1)(a).

The following exception to restricted acts under the NSW VPR is alarming particularly in context to MacIntosh, the recommendations of the Tribunal in that case as described above, and the warnings of the broader profession.  It is in relation to equine dentistry using power tools.  Despite the regulations under s 4(h) declaring that ‘the performing on a horse of any dental procedure that involves: (i) making an incision through the skin or oral mucosa, or (ii) extracting a tooth by repulsion, or (iii) entry below the gum line, or (iv) any other activity to maintain or restore correct dental function’ are restricted acts of veterinary science, under s 4(2) the following are excluded from the declaration of restricted acts of veterinary science:

 

(a) cleaning, rasping, grinding or cutting the teeth of a horse,

(b) removing a loose tooth or deciduous tooth cap from a horse,

(c) using a power tool to carry out a procedure to maintain or restore correct dental function on a horse that has been adequately sedated under the immediate and direct supervision of a veterinary practitioner.

 

This means that lay persons may legally use power tools inside the mouths of horses.  Whether or not it was the intent underlying the provision it also appears that the veterinary practitioner may sedate the horse and leave an unqualified person to carry on unsupervised.  This scenario should raise ethical questions for veterinary practitioners.  Firstly, even if the veterinary practitioner does not leave and ensures the horse remains adequately sedated, it is likely that the veterinary practitioner’s presence will lead the horse owner to believe that the veterinary practitioner condones and endorses the services and skills of the lay person, and that the veterinary practitioner was of the opinion that the horse was fit to undergo dental treatment using power tools.  That conclusion seems to be in concert with the NSW VPR schedule 2 which lists the professional conduct rules.  Rule 1 states that:  ‘The basic principles of professional conduct for a veterinary practitioner are: (a)  a primary concern for the welfare of animals, and (b)  the maintenance of professional standards to the standard expected by: (i)  other veterinary practitioners, and (ii)  users of veterinary services, and (iii)  the public.’  There is also a requirement in rule 13 that veterinary practitioners:

 

must ensure that all persons assisting in the provision of veterinary services to animals in his or her care have the skills, knowledge and available equipment to enable them to perform their duties according to current standards of practice of veterinary science, except in the case of emergency.

 

This seems to imply that the veterinary practitioner may reasonably have some responsibility toward the standard of care provided by the lay person to the sedated horse remaining in the veterinary practitioner’s care.  Even if that is not the case, it would seem that basic ethical conduct in a non-regulatory sense, and the veterinary practitioner’s knowledge of the potential for harm, would lead the veterinary practitioner to take particular care or avoid participating in the provision of equine dental services in conjunction with a lay person that performed the procedures.

Some historical records exist as to the equine dentistry provision under NSW VPR s 4(2).  Firstly, it should be noted that it is in conflict with the model veterinary practice code suggested by Dr D Neutze’s 2012 review of the veterinary practice legislation prepared for the AVA.[9]  At page 40, that report recommends that legislation in all jurisdictions should restrict the performance of equine dentistry using power tools to registered veterinary surgeons.  It also suggests that manual rasping should only be performed by a person with Certificate IV training. 

At page 17, the 2013 Regulatory Impact Statement for the NSW VPR[10]  included the following general considerations:

It is considered unacceptable for animals to be exposed to unnecessary suffering or to die as a result of lack of knowledge or skills in those persons who provide veterinary services…

The Act and Regulation ensure that medical and surgical procedures on animals that present a risk to animal welfare or other public interests can only be conducted by competent and accredited operators with knowledge, skills and necessary facilities to minimise these risks.

 

Without the Regulation and its framework of statutory rules to achieve the objectives of the Act, the animal welfare consequences of medical and surgical procedures, misdiagnosis or failure to diagnose could be significant. These potential costs have not been quantified but can be considered to be very large.

 

Seemingly in line with those general considerations, the Regulatory Impact Statement did not recommend the retention of the equine dentistry provision under NSW VPR s 4(2).  A ‘key amendment’ to the regulation was stated as ‘[p]roviding that the use of a power tool to carry out equine dental procedures is no longer excluded from the declaration of restricted acts of veterinary science’ (see pages 1, 6 and 12).  At page 12 it was also stated that:

 

[the] changes are based on animal welfare grounds in that it is considered that the welfare of horses will be better protected and promoted by the use of power tools in equine dentistry being a restricted act of veterinary science. This is consistent with the  objects of the Act.

 

A public consultation period for review of the regulations was stated (at page 3) as to run throughout June 2013.  As per NSW VPA s 7, the Minister ultimately makes his or her recommendation to the Governor about each regulation.   The provision allowing lay persons to perform equine dentistry using power tools has not been removed.

The ACT Regime

Unlike all other jurisdictions, in the ACT veterinary practitioners are not regulated under a veterinary practice statute.  They are regulated under the Health Professionals Act 2004 (ACT).  It is the Animal Welfare Act 1992 (ACT) s 19(1) that provides that ‘[a] person who is not a veterinary surgeon commits an offence if the person carries out a medical or surgical procedure on an animal’.  Various exceptions are provided within that Act and there are particular permissive codes of practice within the Act itself.  Separate regulations may also be made.  The ACT Veterinary Surgeons Board, Health Professionals (ACT Veterinary Surgeons Board Standards Statements) Approval 2009 (No 1): Notifiable Instrument, NI2009-652, 8 December 2009 (NI2009-652) s 11.2 defines ‘act of veterinary science’ as ‘services which form part of the practice of veterinary surgery, and includes attendance, rendering advice, diagnosis or treatment of disease or injury, provision of veterinary certificates, and prescribing medicines for veterinary purposes’.  Section 11.2.2 states that:

 

An act is an ‘act of veterinary science’ if the act were performed on an animal by a person, other than a veterinary surgeon, that would be likely to: 

(a) cause unacceptable levels of harm or suffering to the animal;

(b) affect human health adversely; or

(c) affect domestic or international trade adversely.

 

NI2009-652 s 11.3.3 allows the Board to provide a person with approval to perform the acts prescribed in s 11.2.2.  NI2009-652 s 11.2.3 lists particular ‘acts of veterinary science’.  These include: ‘(h) [t]he performing of any dental procedure other than tooth cleaning on any animal other than a horse’ (where it is done by a non-veterinarian under the immediate direct supervision of a veterinary surgeon), and ‘(i) [t]he performing on a horse any dental procedure that involves;

 

a. Making an incision through the skin or oral mucosa, or

b. Extracting a tooth by repulsion; or

c. Entry below the gum line; or

d. Any other activity to maintain or restore correct dental function.

 

NI2009-652 s 11.3.1 defines acts that are not ‘acts of veterinary science unless administration of restricted drugs or the making of a diagnosis is required for them’.  These include:

 

(e) Scaling, cleaning, polishing teeth where this does not require sedation or local              anaesthetic

(f) Use of machine driven tools for equine dentistry

(g) Cleaning, rasping, grinding or cutting the teeth of a horse,

(h) Removing a loose tooth or deciduous tooth cap from a horse.

 

Two of the above procedures – (e) and (f) are noted with ‘[m]ay be done by a non-veterinarian under the immediate direct supervision of a veterinary surgeon’.

Section 11.3.1 declares the following as not an act of veterinary science:

 

(i) Using a power tool to carry out a procedure to maintain or restore correct dental function on a horse that has been adequately sedated under the immediate and direct supervision of a veterinary practitioner.

 

Alarmingly, and unlike the s 11.3.1 exceptions for acupuncture or chiropractic procedures, the use of power tools on a horse need not be done ‘by a person who has completed the relevant training appropriate to work with animals.’  The same concerns as listed above for NSW apply to this ACT provision that allows lay persons to perform equine dentistry with power tools.  It is also difficult to understand how a lay person’s decision to use the power tools does not require the administration of restricted drugs or the making of a diagnosis.  It also seems it would also be difficult when using power tools to avoid the restriction in s 11.2.3 regarding incisions ‘or any other activity to maintain or restore correct dental function’.

 

The Queensland Regime

The Veterinary Surgeons Act 1936 (Qld) (VSA QLD) s 2A(1) defines ‘veterinary science’ as the ‘science of veterinary surgery or veterinary medicine’.  VSA QLD also provides an inclusive list of what constitutes ‘veterinary science’.  Under s 2A(2) that list includes:

 

(a) diagnosing diseases in, and injuries to, animals, including, for example, testing animals for diagnostic purposes;

(b) giving advice based on a diagnosis under paragraph (a);

(c) medical or surgical treatment of animals;

(d) performing surgical operations on animals;

(e) administering anaesthetics to animals.

 

Section 2A(3) excludes from the definition of veterinary science ‘acts done for animal husbandry or animal dentistry prescribed under a regulation not to be veterinary science’.  Section 25M(1) states that ‘[a] person who is not a veterinary surgeon must not practice veterinary science’.  However under s 25M(2) ‘a person does not commit an offence against subsection (1) if (a) the person practises veterinary science other than for fee or reward’.

The Veterinary Surgeons Regulation 2002 (Qld) s 3(1) lists acts excluded from the definition of ‘veterinary science’.  These include s 3(1)(f) that is ‘filing or rasping a horse’s teeth’.  As stated above, the Tribunal in MacIntosh suggested that s 3(1)(f), permitting the filing or rasping of horses teeth, ‘may need to be revisited’.  Whilst the regulation has not been amended, the Queensland Department of Agriculture, Fisheries and Forestry published a Review of the Veterinary Surgeons Act 1936 (Qld) Background Paper[11] in 2013.  It was compiled by a steering group appointed by the Minister of that department.   A key issue for review was consideration of the regulation of persons who are not veterinary surgeons who perform acts of veterinary science.  The background paper lists a number of arguments for and against practice restrictions being applied to lay persons.  At page 22, it does acknowledge the recommendations made by the Tribunal in MacIntosh and that:

 

Using power tools for filing or rasping significantly increases the risk of exposure of sensitive dentine and the underlying interior pulp cavity. Also, there is a significant risk of thermal damage if water cooling is inadequate when power tools are used.

 

One potential argument canvassed in the accompanying Review of the Veterinary Surgeons Act 1936 (Qld) Information Paper[12] (at page 3) was that:

 

Legislation in Victoria does not prohibit non-veterinarians from practicing veterinary        science – more limited access to drugs and poisons (including anaesthetics) imposes practical limits on what services non-veterinarians can provide and they could be investigated for animal cruelty if there was an adverse outcome resulting from their actions.

 

On page 1 it was stated that the above does not represent the policy of the Queensland Government, but it was one of the ‘main issues being considered by the steering group’.    Reliance on the Health Act 1937 (Qld) to limit the practice of equine dentistry by lay persons using power tools is unlikely to be sufficient for two reasons.  Firstly, the administration of the restricted drugs may be performed by a veterinarian and therefore there would be no offence committed under that Act.  Secondly, even if the State did prosecute a lay person for breach of the Health Act 1937 (Qld) there is no assurance that any agency empowered to prosecute cruelty offences would be notified or take action.  Under Health Act 1937 (Qld) s 18A(2)(b) if proceedings are taken against a veterinary practitioner the Veterinary Surgeons Board of Queensland must be notified, however there is no notification requirement to any other agency.  The case of MacIntosh appears to demonstrate that it is unlikely that coordinated efforts are taken between agencies in order to simultaneously investigate or prosecute offences across different legislation in a concerted manner.  Another key issue canvassed in the Information Paper (at page 4) was the amendment of the Animal Care and Protection Act 1938 (Qld) to ‘deem animal health service providers guilty of an animal welfare offence if pain or injury to an animal may have resulted from them acting beyond their competence or without due care’.  It is unlikely that the penalties and likelihood of enforcement under that Act would deter lay persons from practicing equine dentistry using power tools.  Nothing less than a clear prohibition in the Animal Care and Protection Act 1938 (Qld)or the VSA QLD seems appropriate.

The steering group’s recommendations to the Minister have not been published and there has been no subsequent information forthcoming from the Department as of 17 July 2015.

 

Conclusions

Professor Blood reminded veterinarians, that in each case, the best interests of the animal must direct which treatment is to be applied.  This focus on animal welfare is reflected in recommendations of the broader veterinary community.  It is also reflected in veterinary codes of practice.  Particularly for risk-prone treatments, the best interests of the animal demands a full evaluation of the patient’s overall health and other prevailing circumstances.  As Professor Blood explained a lay person offering a limited service in a particular practice area is not in a position to make that evaluation.  This paper has examined risks associated with equine dentistry.  Particularly where power tools are employed by lay persons there is clear evidence of significant risk.  It is hard to imagine a circumstance where power tools could justifiably be used by anyone but a veterinarian with the appropriate training, knowledge and skills so as to avoid those risks.

Better options for animal and consumer protections must be considered.  Practices that are proven to represent animal welfare risks demand clear definition and practice restrictions.  Without adequate restrictions and the benefit of notification via prosecutions or notifications from veterinary boards, veterinary associations or animal welfare organisations, there will be a lack of timely communication to warn the broader public about incompetent lay person practices.  Lack of information undermines consumers’ opportunities to make informed choices.  It also restricts their ability to fulfil their duties of care to their animals.  Appropriate restrictions will contribute to improved consumer education and outcomes where consumers can better avoid the risk of costly remedial treatments, or worse still, loss of their animals as a result of harm. 

It appears that in some jurisdictions, the restrictions on regulating making power have tipped too far in favouring economic arguments and away from animal protection.  The equine dentistry example demonstrates that this is the case even in the face of expert evidence. This paper suggests that restriction against lay persons performing equine dentistry using power tools must be introduced or reinstated in all Australian jurisdictions.  When making and amending regulations, considerations should include the animal welfare and economic concerns and interests of consumers, the welfare, ethical and professional arguments of the broader veterinary profession, recommendations of tribunals, scientific evidence and the advice of veterinary practice boards and advisory committees.  These interests should not be trumped by the economic interests of the lay persons who benefit from performing the procedures.

 

The suffering of Zander, Silver Smith, King and Cyrus should not have been in vain.
Reform should be supported in beautiful Zander’s name.

 

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