Here is a little more detail to add to my last blog on the subject of forthcoming regulation.

Following the recent Defra consultation concerning the review of the Veterinary Surgeons Act (1966) the prospect of trainers and behaviourists becoming regulated is now very much on the agenda and ignoring what’s coming is no longer a viable strategy. Although much of the detail still has to be worked out the consequences will inevitably be far reaching whatever the regulatory structure looks like. It will have an impact on all practitioners who engage in what is being called Allied Veterinary Professions (AVP), these are activities related to animal health care that are not in the realm of vets and vet nurses, this includes other activities such as all Musculoskeletal therapies, Farriers, Dentists as well.

Detail is short at this stage but principles are fairly clear. For sure there will be one set of standards to adhere to for each of the roles within each AVP, one regulatory group for each AVP and one central set of registers listing practitioners for each AVP. Currently this is thought to come under the umbrella of the RCVS. As things stand in the behaviour and training sector there are several organisations or registers claiming some form of voluntary regulatory role, but only one of them will have a function as part of the regulatory structure once regulation is introduced, the remainder will cease to have a purpose and will likely be redundant.

Behaviourists and trainers will need to be on the regulated register in order to practise which means they will need to be assessed as meeting the standard associated with their role both in knowledge and understanding and competence. They will also be limited to that role so if they are assessed for Training Instructor they will not be permitted to undertake behaviour work unless they are on that register too. In addition to being on the register there is still discussion around being licenced to practise.

Thinking beyond how this will affect individuals it is highly likely to have a direct impact on the methods people use too. If things go as expected it would mean that the professional standards will rule out the use of any form of aversive methodology. This would include choke chains, prong collars and remotely operated devices as well as aversive techniques that do not entail the use of devices. This will obviously create an issue for those ‘balanced’ trainers out there and those who still advocate the use e-collars.

Organisations that represent practitioners will not avoid significant repercussions either. They will not be able to assess their members’ knowledge or competence against the relevant standard to get them on the relevant register unless their policies and procedures for practitioner assessment are approved by the regulator. This will be determined by a rigorous assessment process. If they cannot assess their members it must bring into question their continued purpose as well.

Regulation will also have a direct impact on course providers as only courses approved by the regulator will contribute towards an individual becoming qualified to practise. Something I have emphasised many times before is that any courses that are not approved (including courses that are Ofqual regulated) will not serve a purpose other than perhaps as CPD.

At this stage nothing has been finalised but what I have described is based on real discussions that are under way now, it is certainly not scaremongering and should be considered seriously. How long this will take to implement and what the final system will look like in detail is not known yet but the political impetus behind it has gathered pace and the only organisation in discussions with Defra about the way ahead for behaviour and training is ABTC.

What does it mean to be a certified (or certificated) practitioner?

The first thing to make clear is that there is no difference between certified and certificated. Certified is a verb and certificated is an adjective but they both indicate the presence of a certificate that declares something is true. They should indicate that the individual has successfully been assessed as being competent by going through a certification scheme. As there are currently no accredited certification schemes in the animal behaviour and training sector the short answer to this question right now is ‘not a lot’.

What is a certification scheme?

A genuine certification scheme is a very detailed affair with a wide range of conditions that need to be met, the scheme is owned and administered by the certification body. Each role being certified must have a single standard against which all individuals are assessed. The quality of the assessment and a whole host of associated procedures must be clearly documented and then, in order to be recognised as a genuine scheme the certification body must be accredited by an independent organisation with the authority to do so. The overall purpose of certification of persons is to determine whether an individual has met specified knowledge criteria and recognise their competence to perform a task or job. Knowledge and competence go hand in hand but they are different and the two terms should not be confused. A certification body has the responsibility to ensure that only people who demonstrate competence are awarded competence certification.

What does it mean for a certification body to be accredited?

Accreditation formally recognises that an organisation has the infrastructure and skills to carry out work to specified standards, this recognition must be provided by an authoritative body. UKAS is the National Accreditation Body for the United Kingdom. They are appointed by government, to assess and accredit organisations that provide services including certification of persons against specific requirements. UKAS operates under a Memorandum of Understanding with the Government through the Department for Business and Trade (DBT). It is DBT policy to recommend the use of UKAS accredited conformity assessment services whenever this is an option. DBT will only recognise accreditation of UK based conformity assessment bodies that has been granted by UKAS.

Accreditation determines the technical competence and integrity of organisations offering testing, verification and certification services (collectively known as conformity assessment). In short, UKAS ‘checks the checkers’. It is already being used by Government as an effective market-led tool for delivering policy.

BEIS has advised certification representative organisations in the UK that the only ‘authoritative statement’ of competence, that has public authority status, providing the last level of control in the conformity assessment chain is from the UK’s sole national accreditation body, UKAS. ABTC is currently progressing through the UKAS accreditation process and once successfully completed it will be the only organisation that will be able to award individuals certification that means something.

The status quo I am referring to is the state of regulation of the animal behaviour and training sector where those who advocate the use of positive punishment are countered by those who argue that such practices are harmful and unnecessary. Without a single regulator that is recognised by government that situation is not going to change because each time they review the situation one side says one thing and the other side says the opposite and both insist they are right. The government is obliged to listen to everybody and little changes as a result, that is democracy at work.

This situation has existed for the past 25 years and what we have is a wide selection of voluntary organisations claiming some form of regulatory role but none are currently in a position to be formally recognised by government.

It would appear to be a simple problem to solve as one side of the argument appear to be promoting treatment of animals that is in breach of the Animal Welfare Act and the other side are not. Unfortunately the part of the act that deals with suffering uses the word ‘unnecessary’ and proving that certain methods cause unnecessary suffering in legal terms is not at all easy in most cases. What the government are faced with is two factions making opposite cases so it is little wonder that nothing changes and harmful practices effectively get the green light to continue hurting animals.

There is a simple solution that will tip the balance of influence heavily in one direction and that is for one of these regulatory bodies to satisfy the requirements so that the government can recognise it as an authority on the subject. The key to achieving this is for that body to be accredited by the UK Accreditation Service (UKAS) as advised by the Department for Business and Trade. UKAS is appointed by the government as the only National Accreditation Body and is recognised by the British government to assess the competence of organisations that provide certification services. It is also government policy to recommend the use of UKAS accredited conformity assessment services whenever this is an option.

There is only one such body in the animal behaviour and training sector that is anywhere near becoming UKAS accredited and that is the ABTC. Getting on board and supporting that move is the only way there is going to be any success in marginalising those who happily sacrifice animal welfare by punishing their animals in the name of training. Simply signing up to codes that do not permit such methods is applauded but in itself that is having little or no effect in the struggle to overcome bad practice, it is simply maintaining the status quo. The process of achieving UKAS accreditation by ABTC is already underway and progressing well. Once complete it will be the only scheme qualified to call the practitioners it represents ‘certified’ and the only body that the government can recognise in the animal behaviour and training sector.

This blog is going away from my normal theme of education and regulation to talk about something else that a relatively select audience might find useful. It is not my aim to tell you about diabetes in dogs (I am not a vet) I just wanted to add an owner’s perspective if it is something you are being faced with. There are several good websites that explain the condition and what to look out for, the PDSA have good information at https://www.pdsa.org.uk/pet-help-and-advice/pet-health-hub/conditions/diabetes-in-dogs#contents-link-6  

When our ‘Frank’ was eight years old we noticed that he started to drink a lot and then apparently lose control of his bladder, producing a lot of fluid. It all seemed to happen over a short period of time. A visit to the vet for a blood test confirmed our fears, he had become diabetic. Initially it was a shock and although we have had many many dogs over the years this was new to us, we did not know what the future held for him or us but it was a steep learning curve and we had to learn very quickly.

The first few weeks were spent getting used to feeding him twice a day 12 hours apart followed by injecting him with insulin. The dose was slowly increased until we stabilised his blood sugar at a healthy and steady level. Once that was done the worst was over, he looked and behaved like there was nothing wrong with him.

We questioned what effect it would have on him in the long term and were told he should have a normal life as long as the regime was maintained. We were also told some shocking statistics about the number of dogs that get put to sleep (PTS) because of their diabetes. The main problem is the commitment required by the owners and many cannot adjust their lifestyle to accommodate the dogs needs or are not insured and cannot afford the vet bills. Apparently 50% of dogs are PTS on diagnosis and a further 35% don’t get past 3 months. The average life expectancy of the remaining 15% is 2 years from diagnosis and the common factor in nearly all cases is the inability of the owners to cope with the dog’s needs, for whatever reason. Our Frank is now 14 and rapidly approaching the sixth anniversary of his diagnosis, he has been injected about 4,000 times. He is now an old dog and has outlived many others of his breed, any of his health issues are related to ageing not his diabetes. It sounds easy but it has taken a lot of dedication and determination for our beloved boy.

Some tips:

Don’t worry if you forget an injection (believe me it will happen), hyperglycaemia is less serious in the short term than hypoglycaemia (too much insulin) which can be a veterinary emergency.

Keep the needle at a low angle to ensure you inject under the skin rather than in the muscle which can be painful.

Move the injection site around or you will get a thickening of the skin at the injection site.

Keep the diet and exercise regular and unchanged, you may need to weigh the food until you know that it is the same each time. Regular routine is key to success.

Remember, food increases blood sugar, insulin and exercise reduce it.

The latest trend in accreditation is for providers to elect for Ofqual regulated qualifications in the misguided belief it makes for a superior course. The process in terms of the checks and monitoring is the same as courses that are accredited by an Ofqual Regulated Awarding Body. The differences are subtle and the main one is of little benefit to anyone over 21. I wrote the following in a blog in 2017 and it still holds true:

Of the many questions I get about the accreditation of courses that are available in the Animal Care Sector (particularly relating to behaviour) is the topic of providing a springboard to a university course. There is an awful lot of mis-information on the subject, most of which revolves around the subject of applying for university through UCAS – The Universities and Colleges Admissions System.

The formal process of applying for a university place through UCAS is largely designed to cater for school leavers and anyone under the age of 21. If you do not fall into this bracket UCAS Tariff Points (associated with Ofqual regulated qualifications) are of much less importance. Mature students (those over 21 and generally all of those studying to become a behaviourist) have a more flexible set of opportunities and universities have the ability to judge your suitability based on experience and a broader spectrum of education that might be better suited to the chosen degree course. The following paragraph is taken directly from the UCAS website – Tips for mature student applications:

Don’t worry if you don’t have the right qualifications – just ask universities and colleges whether you can meet the entry requirements in a different way.

You could get accreditation for life and work experience.

Accreditation of prior learning (APL) is essentially credit awarded for wider learning evidenced from self-directed study, work or training.

In short UCAS Tariff Points are far from the be all and end all they are often made out to be. This goes further, just because a qualification is on the Tariff, does not mean a university will accept it. Therefore, it’s really important to check the entry requirements for the course you’re interested in.

There are only a certain number of qualifications on the Tariff. A university may accept a qualification even if it isn’t on the Tariff, so it’s best to check with them to see if they will accept your qualification. Remember, lots of universities do not use Tariff points.

So, how do courses get onto the Tariff? Put simply they need to appear on the Qualification and Credit Framework (QCF) which is a list of courses approved by Ofqual for delivery in mainstream colleges. It also opens the possibility of the course provider drawing on government funding to deliver it. The downside for course providers is that they must give up the intellectual ownership of the course and it becomes available to any other college to deliver.

The whole subject of accreditation has changed dramatically in the last twenty years and is still changing. Initially there were no privately provided courses that came with any form of Ofqual based accreditation, then slowly it became the mark of quality until now the choice of courses (and range of quality) is bewildering. The next development is for the training and behaviour sector to be regulated, many of my readers will understand that this process is now quite advanced. The introduction of regulation will mean that courses and their content will have to meet strict criteria and the vast majority of courses will not meet those requirements and it will not matter whether they attract UCAS Points or not.  I predict that, in the not too distant future, an awful lot of people will be very disappointed with choices they have made and money they have invested based on advertising promising that they will become ‘qualified’ behaviourists.

It seems that the business of the animal training and behaviour sector being formally recognised as a profession is taking forever and it is true to say that there have been significant delays as a result of Brexit which was swiftly followed by the Covid pandemic. The net result is that progress is about two years behind schedule but the positive news is that talks with the RCVS have re-started. For those who are not aware of what is coming, there is a new Veterinary Services Act being developed that will replace the Veterinary Surgeons Act (1966). Part of the new act will be dedicated to para-professional activities (also referred to as ‘allied professions’), behaviour and training being one such activity.

In order to be included, any para-profession must meet many criteria to demonstrate that they are regulated to a sufficiently high standard to be recognised by the RCVS and that they would be confident in linking them to their Royal Charter. There are some key issues in the process of regulation that must be met including a clear set of standards that define what educational and skills requirements are to be met by each role, how those standards are assessed and independently assured on an ongoing basis, there must be a single disciplinary process, there must be a register of all qualified practitioners, there must be evidence of strong and effective governance along with many more requirements.

Being qualified cannot be self-declared, each individual will need to be formally assessed as meeting all the criteria.

Currently the behaviour and training sector is a mosaic of different organisations doing their own thing to a spectrum of different abilities and requirements and while there is undoubtedly some overlap in what each does there is no coherent structure and therefor the sector cannot be regarded as a single profession. The only organisation that provides the detailed infrastructure of such a profession is the ABTC and this is why they are discussing the way ahead with the RCVS for inclusion in the forthcoming legislation.

ABTC are well aware of their critics, most of whom are allied to other systems that have appeared over the last 10 years to try and provide an alternative form of regulation. It is unlikely that any of these systems will offer a suitably rigorous and acceptable level of governance to be considered for the moves that are coming which is why ABTC are the focus of attention. ABTC has already attracted the support of the veterinary profession and all the major animal welfare charities. It is also the only ‘Council’ (this is a legally sensitive term that requires permission of the appropriate Secretary of State to be used in a name, the organisation should normally be a local authority, an independent advisory body, a deliberative assembly, or a governing, supervisory or representative body of an activity, trade, business or profession).

There are still more steps in the process and metaphorical hoops to jump through but change is coming that will elevate the status of trainers and behaviourists that embrace it.