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More wheel re-invention

In 2008 the training and behaviour industry overwhelmingly agreed that it needed regulating. At that point there were around ten organisations that represented trainers and behaviourists and even then that was widely regarded as a confusing situation to clients and outsiders. All of them were working to their own idea of what was needed to be qualified to practice. The CAWC report 2008 stated that this situation ‘may have important negative consequences for the welfare of both companion animals and their owners and the public at large if they reduce uptake of basic or competent services’. With the support of the major animal welfare charities, the veterinary profession and many of the organisations that took part in discussions to remedy the situation, ABTC was formed.  The purpose of ABTC was and still is, to set and maintain the standards of knowledge and practical skills needed to be a qualified trainer or behaviourist, maintain a national register of appropriately qualified practitioners and to promote humane methods for the welfare of animals in their work.

Despite the level of support that ABTC immediately attracted there was resistance from some quarters, there were those that did not agree with the emphasis on positive reinforcement and the KCAI scheme felt that they were best placed to become the focus of standards for the industry. Additionally, a register of people signing up to abide by an industry code of conduct was set up aiming ‘to unite all practitioners’. In the space of six months in 2009/10 we witnessed the creation of ABTC and three other groups with their own notions of how to promote industry-wide best practice. The industry that was crying out for a regulator to bring clarity and structure to the profession was evidently more interested in promoting self-interest than high standards and now there was a second tier of confusion in existence.

Since 2010 the number of organisations representing trainers and behaviourists has grown to approaching thirty, arguably more than doubling the level of confusion applied to the sector at that level but as if that were not enough those claiming some form of regulatory role for the sector has also grown. In common with the other organisations their purposes vary depending on the opinions of their architects and by 2018 there were now five of them competing with ABTC whose purpose was decided by industry. The additions included another ‘national’ register and a syndicate of organisations aiming to provide ‘a new dynamic of unity’ which was now becoming a recurring theme.

In the light of the sixth such organisation failing to make a significant impact, many of those responsible for creating it are now trying again with a seventh, calling themselves a Charter. Re-using  some of the same claims made last time they are offering ‘for the first time a clear, unified voice’ (Fact check – untrue, sounds very familiar) and ‘for the first time an independent oversight structure’ (Fact check – untrue, ABTC is governed by an elected Board of Trustees). The huge irony that surely cannot be lost on most people is that one of the aims of the group is to tackle the partisan nature of the sector but its creation is actively compounding that very issue. What is much more worrying is that this group is deliberately ignoring the issue of standards of knowledge, education and training needed to be competent to practice, leaving that issue to the membership organisations to decide what is best and thereby undermining the call for standards in the sector. So long as members agree to abide by a code of conduct they can become ‘qualified’ any way they see fit. This marks a serious backwards step eroding the hard won progress over the last ten years in establishing the need for a comprehensive set of standards that already includes all aspects of ethical working.

Of the now seven such groups there still remains only one with any legal status and answerable to a higher authority (ABTC is responsible to the Charity Commission and the Scottish Charity Regulator), the remainder are run by informal committees that are often self-appointed or in one case, just one person. One states that it is a limited company but a search at Companies House shows that the company was dissolved several years ago.

The organisations competing with ABTC’s position in the industry have one thing in common, they are offering ways to avoid the hard work of becoming part of a truly regulated profession and I continue to be amazed at the effort people will apply to achieve that. They want to be regarded as professionals but do not want to take part in all the associated requirements of a regulated profession (see my last blog). Could you imagine the mayhem if vets could choose between seven organisations running their profession and most of them were not concerned in how they became qualified so long as they promised to use ethical methods? The fact remains that ABTC is the only organisation recognised by the veterinary profession and supported by government.

No matter how it is packaged and promoted as being different or new, the charter is a clear case of the re-invented wheel but sadly this wheel has some crucial spokes missing. It is no wonder that anyone wanting to make a career out of training and/or behaviour services is completely baffled when they start looking into how to become qualified and the mess that the sector continues to create for itself.

Where are we now with regulation?

In December 2018 I made a prediction (see my blog ‘What it is to be regulated’) that failed to come to fruition due to the Brexit debacle. Up until the Covid-19 crisis took hold things were slowly getting back on track at the end of 2019 after being severely delayed by the impact Brexit had on the RCVS, now the whole process is back ‘on ice’ while higher socio-economic problems take priority. Very few trainers and behaviourists have any work at all at the moment and I doubt that all will survive the shutdown unscathed, whatever emerges in the future will also take a while to re-establish as a thriving industry. There will however, still be people with pets and still a need for training and behaviour work and some would suggest the need for trainers and behaviourists will be greater. It is predicted that we will experience more cases of anxiety issues once owners start getting back to work and there will be many puppies that have not been able to experience the breadth of socialisation they would have done in different circumstances. Couple an increased need with the forecasted levels of unemployment and subsequent lack of ability to pay for such services, self-employed trainers and behaviourists competing for the business under the spectre of potential reappearance of the virus and it doesn’t take much imagination to picture an industry in turmoil for a while. Regulated services will be more important than ever.

As we are all stuck at home with our internet devices for company some of the ABTC scheduled meetings and decision making are continuing and constructive work continues. Social media has helped keep people’s social interactions going and provides a positive outlet in many instances but inevitably its less constructive characteristic is there too. Rumours and fake news spread quickly at all levels. Some of the old myths about ABTC are doing the rounds again and no doubt being accepted as gospel by many, here are two examples:

Myth 1: You cannot be an ABTC behaviourist without a degree. Absolutely not so. In many cases a degree will only cover some of the academic requirements and further study may be required anyway but the important phrase is ‘degree level of study’. There is a growing number of privately delivered programmes at the correct level but be aware that they do not all qualify in terms of covering all the topics required or being of sufficient length (100 credits at level 5 and 120 credits at level 6). For the less academically inclined there is even a process of APEL (accreditation for prior experiential learning).

Myth 2: You have to go through ASAB assessment for CCAB to become an ABTC behaviourist. This has never been the case, for sure it is an option that some choose and one organisation uses it for their membership process. But any organisation can create a process of assessment that demonstrates that all their full members have their skills properly assessed and have the required knowledge and understanding to be equipped to competently carry out the work.

So what is happening about regulation right now? A number of schemes have been attempted to provide alternatives to ABTC over the last ten years and another is about to launch shortly but most largely avoid the qualification issue choosing to place their emphasis on ethical methods instead. This is fine as far as it goes and is no different to ABTC in that respect but they miss the point of regulation. The latest scheme is no different and is claiming that ‘for the first time the dog training industry will have a clear, unified voice’ and ‘Most importantly everything will be supported by an independent oversight structure – the first time this has been put in place within the industry’, this is, of course, far from the case. I lose count but it must be the fifth or sixth such scheme and as with all the others it does not do everything that ABTC has been doing for the past ten years.

There are five crucial elements to any regulatory framework and any organisation that does not meet them all falls short of the mark, they are:

  1. Governance must be independently accountable and transparent
  2. Defined technical competence based on a standard body of knowledge (academic requirements).
  3. Defined technical competence based on a standard of performance criteria (assessment of skills)
  4. Complaints and disciplinary procedure must be in place.
  5. Standards of ethical personal and business practice including customer service, financial probity and advertising must be adhered to.

ABTC is the only organisation that meets all these requirements and remains poised to go through the RCVS accreditation process when circumstances permit. This will be the single most important step so far in the industry’s development, it is not just important, it is essential because it is an absolute requirement of formal Defra recognition that any such regulatory body is independently accredited. Nothing short of this will be accepted. Any scheme that does not meet these requirements, no matter how well intentioned, is simply misleading people and creating more confusion in an industry that is crying out for clarity.

The course accreditation minefield (continued)

Compass was one of the first course providers in the Animal Care Industry to go down the route of having its courses accredited by a regulated awarding body over 20 years ago. Since then much has changed in the academic world of accreditation. The questions we have been asked over the years have also changed as students have become more aware that an advertised course may not be exactly all it is presented as.

The process of achieving accreditation has become steadily more involved over the years with more and more hoops to jump through and corresponding additional cost. Costs have to be passed on to the students and a growing number of course providers have decided that the benefits do not justify the cost and effort involved and have abandoned formal accreditation, some have turned to unregulated accreditation bodies which confuses potential students even more (see my last blog) but others have simply given up altogether in favour of keeping costs and burdensome administration down.

Those course providers who remain with an Ofqual regulated Awarding Body have two choices for accreditation, they can adopt Customised Qualification status for their courses or Regulated Qualification status. Already I can hear the majority of readers losing the will to carry on with this blog but if you are interested in the subject the difference is important.

Both types of qualification go through essentially the exact same process of checks to ensure they meet the high level of quality required by Ofqual in terms of content and delivery. They must reach the level of study claimed which indicates the difficulty and depth of the course and they are allocated a Total Qualification Time (TQT) figure to indicate the length of the course. TQT is often quoted in ‘credits’ with one credit equalling 10 hours so, to give you a benchmark, the TQT of a GCSE is usually around 120 hours or 12 credits while each year of a three year degree is typically 1200 hours or 120 credits.

So far there is absolutely nothing to distinguish between Customised and Regulated qualifications but there is one crucial difference. When an organisation submits a qualification for Regulated status through their awarding body it relinquishes its intellectual property rights, in other words it no longer owns the course. Customised qualifications remain the property of the course provider who produced it. In giving up ownership the now regulated course is given an identifying number and appears on a register of regulated courses published by Ofqual, customised qualifications do not have such a number and do not appear on the register. The process of appearing on this register does not alter the value or purpose of the course in any way.

A question I am constantly asked is ‘is your course a recognised qualification?’ and my answer is to ask ‘recognised by whom?’. For qualifications to reach their potential they must attract industry recognition to be of any real value other than just for personal interest. It is possible to have a regulated qualification (registered by Ofqual) that is not recognised by industry. In this case Ofqual is saying that the course meets educational requirements but industry says it falls short of their requirements. Equally, a customised qualification that does not appear on the Ofqual register may be recognised by industry as fulfilling all the requirements of industry. The reasons that industry might reject a regulated qualification range from incorrect content (not covering required topics) to inadequate level or too low a TQT value (the course is too short). Courses that are produced by industry tend to meet their requirements exactly because they are written to satisfy their own requirements whether they are regulated or customised qualifications.

For further reading see: https://ofqual.blog.gov.uk/2016/06/14/when-size-does-matter/

Superficial routes to appearing professionally qualified

Having watched the animal training and behaviour evolve for over twenty five years I have watched dubious ways of creating an apparently professional profile mushroom out of all recognition and some things go full circle back to the days when virtually no courses were properly accredited. Everyone seems to be chasing the cheap, quick fix when none actually deliver genuine results.

At one point course accreditation was an important factor in demonstrating quality but slowly many course providers have found that the profits that are lost by not being accredited is not enough to justify the extra effort and cost involved in maintaining accreditation. This leads to a business decision to drop external quality checks leaving them free to lower their standards and make more money. Equally I notice the rise in businesses offering accreditation services that are not regulated and therefore of the same standard as others. UK Rural Skills for example are not a regulated awarding body, unlike NCFE, Lantra Awards and others who are regulated by Ofqual, the government Office of Qualifications and Examinations Regulation.

Unregulated awarding bodies are cheaper, conduct far fewer checks and controls on course providers and are not overseen by a higher authority but the course provider can legitimately say that their courses are accredited which makes it look as if their courses are on a par with those who are properly regulated. It also means that the provider can artificially inflate the levels of their courses to make them a more attractive purchase, this explains the widening selection of apparent level 5 and 6 courses. It does mean that the students looking for the right course need to be aware that such courses are not recognised as valid when compared with properly regulated accreditation. Another organisation that is of little or no value in our sector is the CMA, this stands for Complementary Medicine Association, it is an American business that displays articles on subjects such as Men’s Health and Natural Beauty yet is presented by at least one Dog Training Education provider as a governing body that provides ‘Global Recognition’ for their course. Forgive my scepticism but how this adds any value whatsoever to their course provision escapes me.

Of more significance now is the ever increasing number of logos people and organisations can collect and display to create an air of industry recognition and professionalism. To the un-initiated such an array can look impressive because they do not understand which of them has any real value and which are simply bought with little or no checks or monitoring. Self-declaration of expertise is valueless, for example, anybody can declare that they will not use force when training dogs for instance but there are many other ways of causing stress or mistreating a dog and if someone is not properly educated and trained the chances are such practices are quite likely to take place despite the good intention of the person with the flimsy validation.

For years I have also warned people about the bogus post nominal letters that some course providers say their students can use to make themselves look well qualified but still that practice continues. Ofqual describe this practice as a ‘misleading representation’. The people that proudly display such letters have no idea that they are actually advertising the fact that they are poorly qualified, the unsuspecting pet owning public buy into the charade as well because they don’t know any better. In mainstream education the use of such post nominals is seen as laughable. What is really alarming is that many people wanting to be dog trainers and behaviourists put their money and efforts into this without understanding that they are being misled, they genuinely believe that they have real and meaningful credentials.

In 2008 the training and behaviour sector unanimously agreed that regulation was needed (it is probably the only topic that attracts total agreement) but actually that is not quite what many want. What has emerged is a desire to appear regulated with minimal effort or controls, in other words, freedom to do whatever each organisation sees fit in the way of education of its members in the most profitable way. The latest trend is to equate a code of conduct with professionalism but this is only a part of what it takes to be a professional and simply signing up to a code of practice camouflages the more important issue of thorough education and training to produce competent practitioners.

Latest progress towards regulation

As we approach the 10 year anniversary of the decision to form the Animal Behaviour and Training council the sector is coming close to a major milestone in the recognition of a formal regulator. It is a topic that has divided opinion and raised emotions since the CAWC report was published in 2008.

 

As things stand there are far more regulatory requirements to sell burgers than deliver training and behaviour services to our pets, this cannot be right and has to change. The irony is that the majority of people involved in this work agree that regulation is required but many don’t want anything that is going to impact on the way they operate and that is the root of the problem of voluntary self-regulation. Without any compulsion to take part in regulation only those who least need it get involved, those with the lowest levels of knowledge and training simply avoid being a part of it.

 

Everybody believes they an expert, nobody wants a system that is going to mean undertaking further education and assessment and they don’t want to be told what they can and cannot say on their websites because it is only others that need such interventions. Organisational loyalties play a large part for many as well with clearly identified ingroups and outgroups (see social identity theory) and conspiracy theories abound as a result.

 

On 29th October a meeting to consider the question of regulation again was attended by about 175 interested people, it was hosted by the All Party Parliamentary Dog Advisory Welfare Group at Westminster. I say ‘again’ because it is something that was first considered around twenty years ago and has had regular airings since. The mood at the meeting reaffirmed the general agreement with the principle of regulation and we went on to hear opinions and some new proposals for such a structure although this has been done several times before. We are now at the stage when some of the people learning about this topic were still at school when the process started and are not fully aware of the work that has gone into reaching the point we are at now. We have now gone full circle and are starting to go over ground that has already been discussed tried and not succeeded before.

 

Since 2009 there have been five different attempts to bring practitioners together under one regulator but none have enjoyed the steady growth and progress seen by ABTC. No other has the support of the veterinary profession, no other represents as many practitioners and no other operates a fully comprehensive system of ensuring that trainers and behaviourists are suitably qualified and competent to practice. It operates the only independent complaints and disciplinary process and is now poised to be accredited by the RCVS in early 2020.

 

If you are interested in another blog on the subject  go to https://www.bva.co.uk/news-campaigns-and-policy/bva-community/bva-blog/integrating-qualified-trainers-and-behaviourists-into-the-vet-led-team/

What it is to be regulated

Since 2009 there have been many attempts to unify the training and behaviour sector behind regulations aimed at raising its practitioners into a truly professional status. Most attempts have been well motivated but nearly all have failed to understand what it means for a work related roles to be properly regulated.

The first requirement is to identify the work roles that are going to be regulated, what the scope of those roles is and any limitations to them, in other words, what people will be qualified to do.

The next requirement is to establish standards for those roles. There is a convention that dictates how a formal work related standard is written. It breaks down what people need to know (Knowledge and Understanding) to carry out the task and also what they need to be able to do (Skills). The knowledge and understanding also needs to be taught at an appropriate level of education.

There needs to be a clear code of practice/conduct that all practitioners declare they will abide by. This must be accompanied by a system of policing by an independent body, simple self declaration without any form of monitoring and control or ability to impose sanctions if the code is contravened has very little value whatsoever.

There must be a credible, independent governing body and the over riding principle for all its activities is transparency. It is essential for the management to adopt systems that independently confirm that all requirements are being met at all stages, not just for the practitioners and the organisations that represent them but also the governing body itself. This must be a ‘live’ system that continually verifies the performance of all concerned.

Only one governing body has satisfied all of the requirements creating a comprehensive framework that details every aspect of what it is to be a qualified practitioner and what is required to remain qualified. It is no coincidence that the veterinary profession and major animal welfare charities have come together in their support of the system operated by the Animal Behaviour and Training Council (ABTC) and none of the others.

This begs the question ‘why have the other attempts failed to gather the same level of support?’ The answer is not the same for each, although there are some common themes. The foremost failing is the unwillingness of most organisations that represent trainers and behaviourists to surrender authority to an independent governing body. They all regard their autonomy more highly than a common set of comprehensive rules to abide by and more importantly, be judged against. Comprehensive rules and standards frequently undermine an organisation’s ability to make unsubstantiated claims of expertise and recruit members by promising professional status based on minimal requirements, all of which undermine commercial advantage. When commercial advantage is put ahead of animal welfare and professional standards there is something seriously wrong with the organisation’s operational ethos.

The past nine years has seen seven systems (including ABTC) with the aim of bringing the sector together, the irony that seems to escape the architects of each scheme is each one further divides the sector and adds to the confusion. The latest attempt is a charter for dog practitioners which is also bound to fail to attract institutional support, largely because it mimics some that have failed before but it also aims to allow organisations to operate independently without the strict control of a regulator.

There is a misconception that self declaration of expertise or qualifications (both at individual and organisational level) is adequate – it is not. There is a misconception that calling something a ‘National Register’ or ‘Charter’ gives it some kind of authenticity or authority – it does not. There is a misconception that signing up to a code of practice that is not enforced adds value – it does not.

With the exception of ABTC, most of the numerous cooperatives and groups that claim to deliver some form of regulation actually represent little more than a marketing tool for those on their lists of people or organisations and the approach has been somewhat desultory. Being a registered charity, ABTC is also the only one of these organisations that is a legal entity, the remainder have no status in law. Inevitably they seem attractive to people in search of some form of professional validation as they make bold claims and sound impressive, they are also generally easy and cheap to join with few, if any, checks. This demonstrates a clear case of getting what you pay for, remember, if it seems cheap and easy and offers much, there is probably a very good reason. Many people are being misled into investing money, time and energy into membership of organisations and schemes that will soon be shown to be of very limited value.

As the RCVS closes in on bringing para-professionals under their regulatory umbrella I predict that by the end of 2019 the training and behaviour sector will be clearly polarised. There will be those professionally qualified and formally regulated practitioners under ABTC at one end of the spectrum and the remainder who will be consigned to a category of the unregulated and unvalidated, no matter what professional status they claim.

The next step towards regulating training and behaviour

Since the formation of ABTC in 2010 those who do not want to be involved have made much of the lack of legislation to regulate animal trainers and behaviourists as their reason for not engaging. It is true that successive governments have not had the appetite to introduce such legislation but each has encouraged voluntary self-regulation of the sector and the only such body referenced by Defra is ABTC.

Clearly, given the number of organisations that still resist coming under the ABTC umbrella and meeting their standards, there is still work remaining to establish comprehensive regulation but the next step is now on the horizon.

As far back as 2004 the RCVS has called for the regulation of para-professionals and since then they have been looking at ways to facilitate that. In 2007 VetNet LLN was created to support progression from vocational areas into veterinary and animal related professions. A more specific project within VetNet LLN aimed at examining the potential for such regulation amongst trainers and behaviourists gave rise to a working party from the sector in 2009, this working party subsequently transformed into the ABTC the following year.

In 2016 the RCVS created the Exemption Orders and Associates Working Party to review the activities of certain allied professions. They have created a set of principles on which the inclusion of additional exemption orders to the Veterinary Surgeons Act should be based and have subsequently created a set of recommendations for revising the existing exemption orders, creating new ones and removing defunct orders. They also created two models of ‘association’ with the Royal College to allow allied professionals to come under their regulatory umbrella under the remit of its Royal Charter, as is currently the case with veterinary nurses. Initially the focus was on Farriers and Dentistry but that has now expanded into the Manipulative Therapies and crucially, Training and Behaviour.

With roots in VetNetLLN and having long since enjoyed the support of the veterinary profession, ABTC has now had a very positive meeting with the Working Party to discuss formal association with the Royal College under these plans. The exact mechanism of such accreditation is currently being finalised and the process should be available to start early in 2019.

Once this level of formal association with the RCVS has been established there will be clear water between those regulated by ABTC and those who choose to operate under a less formal status. It is expected to further influence government recognition and could also have implications for the insurance industry.