Farriers Registration Council Paper – ‘Trimming, Farriery and Public Protection’

The RCVS has been invited by Defra to review the current framework of exemption orders to veterinary legislation and to make recommendations as to how they might be improved, and to develop a framework that would promote consistency in exemption orders in future, and perhaps set the conditions for a master exemptions order.

The review addresses a number of areas of veterinary surgery and seeks to identify whether they may be suitable for a lay person to carry out. Within the context of this work a ‘lay person’ is someone who is not a veterinary surgeon.

Some of the key workstrands include:

· Equine Dentistry, category one procedures.

· Equine Dental Technicians (EDTs).

· Equine Physiotherapy.

· Artificial Insemination of Mares.

· Foot and Hoof Trimming.

These workstrands featured in work initiated by Defra under the heading ‘Review of Minor Procedures’ in 2014 and it appears that this work has been passed to the RCVS for consideration. RCVS did not wish to offer a view to Defra on Foot and Hoof trimming without first seeking the views of the FRC; RCVS have therefore asked FRC if they wish to offer comment on foot and hoof trimming for consideration.

At its meeting on 27 June 2018 the Council endorsed the paper ‘Trimming, Farriery and Public Protection’ as a statement of the Council’s position in respect of trimming. The paper has been forwarded to the RCVS for their consideration and is reproduced here for the information of registered farriers. There is of course no guarantee as to how this work will conclude but the Council take the view that it is better to make representation than not, and in any event the FRC may make its own representation to Government in due course.

Trimming, Farriery and Public Protection

A Discussion Paper

The Farriers Registration Council

Issue

The RCVS has been asked by Government to review the current framework of exemption orders to veterinary legislation. One work strand addresses equine hoof trimming and the RCVS have sought the opinion of the FRC.

Purpose

The purpose of this paper is to articulate the FRC’s position in respect of equine hoof trimming, farriery and public protection. The paper shall constitute the FRC’s response to the RCVS and also a statement of the FRC’s position on this issue, which it may use more broadly.

Trimming and Farriery

The FRC contend that farriery is more than the making and fitting of horseshoes, or other hoof care solutions which may use other materials. The FRC takes the view that Farriery is a continuum of three key components: assessment of the equine’s condition and gait; trimming and balancing of the hoof, and the application of a hoof care solution. The FRC contend that trimming sits at the heart of farriery – a sub-standard trim shall not be made good by a first class shoe, whereas a good standard trim may be complemented by a shoe that is of average quality and finish.

The 3 Components of Farriery and the Centrality of Trimming

Assessment of the equine’s condition is conducted, ideally, with the equine owner or other responsible person present; the vehicles for this assessment are usually the walk up and trot up. In simple terms the farrier looks for absence of the normal and presence of the abnormal, and then decides upon the hoof care that is appropriate to the animal consistent with the animal’s pattern of use and frequency. Horseshoes, if fitted, are removed by a farrier (but not by a trimmer) having been checked for rate and pattern of wear, and the hoof capsule is then inspected in detail, this being common to farrier and trimmer.

Trimming and balancing of the hoof should also be a process common to both the farrier and the trimmer, but with discrete outcomes; either a ‘trim-only’ finish, or a trim with a view to fitting a horseshoe or other hoof care solution. Of course a farrier may trim for both outcomes (and has been trained to do so over a 4 year period) whereas a trimmer shall trim solely for an unshod finish

The third component of farriery is the application of a hoof care solution. This is most often a metal horseshoe but may be a synthetic shoe or a solution manufactured from some other modern material. This component is the business of farriers.

Equality of Access to Public Protection

Equines and their owners should be afforded the same levels of protection in respect of trimming as they are in respect of farriery, irrespective of who provides the service. While the FRC holds data in respect of complaints by equine owners in respect of the workmanship (and other professional shortcomings) of farriers, no such data is available in respect of trimmers, there being no comparable body to the FRC for trimmers. Given that the extent of the risk to the equine from both farriers and trimmers is potentially catastrophic, data on dangerous or sub-standard trimming practitioners who have been held to account ought to be available to the public, not least so that the public may exercise informed choice as they can in respect of farriers.

The status quo is unsatisfactory in a number of respects and may be viewed as illogical. The notion that two individuals conducting trimming side by side on a yard, one being subject to statutory regulation and the other not subject to any form of regulation invites ridicule. The FRC accepts that the omission of trimming from FRA was by design, and understands that the Government of the day in 1975 had no desire to criminalise those who trimmed their own horses. But there has been a paradigm shift since 1975 with the emergence of increasing numbers of trimmers as equine para-professionals.

It has been known for a trimmer to damage an equine to the extent that prosecution under Animal Welfare legislation is advanced (e.g. RSPCA v Street, Stafford Magistrates Court, 2 October 2014, District Judge McGiven). The FRC suggests that there is a requirement for some form of regulation in respect of trimming in order to deliver adequate public protection, and that given the proximity of trimming to farriery this might take the same form as the regulation of farriery.

Options for Protecting the Public – Regulation of Trimming

RCVS offers the notion of delivering public protection via an exemption order. While there is some merit in this approach and a regulatory solution could be identified, the FRC takes the view that a more logical approach, noting the centrality of trimming to farriery, is to align regulation of trimming with the regulatory arrangements for farriery.

This approach was proposed to Government as long ago as 2012 by the FRC at the commencement of the work that ultimately delivered FRA 2017. Successive Governments since 2012 have not shown inclination to regulate trimming on a statutory basis, preferring to suggest that trimmers should adopt a self-regulatory solution.

There are a number of approaches to this issue that merit further discussion, and perhaps advancement to Defra for detailed consideration. The FRC offers three options for delivery of public protection in respect of trimming.

View 1 – Self-Regulation. This approach has been the preferred approach of successive Governments since 2012. We are unaware whether trimmers have offered any concrete proposals since 2012, and we are unclear as to whether there is any prospect of proposals being advanced in the short to medium term. The FRC has in recent times hosted a visit by the National Association of Cattle Trimmers who appear to have a rigorous and effective model of self-regulation, which may merit detailed consideration as a possible model for equine trimmers. A self-regulatory solution would deliver a measure of public protection and reassurance, although self-regulation may be viewed by some members of the public as being inherently less effective and lacking ‘teeth’.

View 2 – Partial Integration of Trimmers under FRA. Under this approach trimmers would be added to the register of farriers mandated under FRA in a discrete part of the register, similar to the current arrangements for temporary and occasional service providers from the EU/EEA in Part 5 of the Register. The discrete part of the register would be mandated under a clause added to Section 7 of FRA and be subject to a standard for trimming. A set of National Occupational Standards (NOS) for trimming has previously been taken into use by Lantra (published in April 2010), and so one of the essential ingredients for effective regulation, a standard against which to hold to account, is already in place. This model would deliver improved levels of protection for the public, hold public confidence and deliver the professional ‘status’ sought by some trimmers.

View 3 – Full Integration of Trimmers under FRA. Under this approach the regulation of trimming, whether for the subsequent fitting of a shoe or otherwise would be treated identically. There would be a common Register to which trimmers would be added and a standard for trimming agreed by both trimmers and farriers will be required. Noting that farriers are introducing a bespoke trimming competence (which shall be subject to assessment) into the new standard apprenticeship as part of the Government Trailblazer programme, achieving convergence with the extant NOS ought not to be insurmountable. This approach would deliver a ‘one standard’ level of protection to the public and enable trimmers to gain the professional status they seek.

What Next?

RCVS will wish to assess the views and options set out in this paper, and may choose to offer them to Defra; the FRC stand ready to engage further with the RCVS should that be desired. The FRC views set out in this paper may be advanced to Defra as part of its own further engagement with Government in due course.