Frcs response to RCVS review.

For farriers to raise concerns with elected Farriers Registration Council representative Peter Baker. Anonymous postings will be deleted.
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Frcs response to RCVS review.

Postby PNB » Sat Jan 21, 2006 12:34 pm


It seems that this is MWN personal view of farriery being integrated into the review of the veterinary surgeons act. Copied from the RCVS web site.

My comments will start at MWN suggested £5000 disiplinary Fine.



I am responding as the Registrar of the Farriers Registration Council, although there has not
been time to have a proper debate in Council on the proposals, and thus my views should not
be taken as a definitive Council response.
At this time the Farriers Registration Council does not wish to commit to asking for farriery to be
included within the new Act, but it can see significant potential benefits from such an approach.
We would, therefore, ask to be included in future debate on the possibility of widening
application of the Act.
As a general principle we would expect farriers to be content to be regulated alongside
veterinary surgeons but not exclusively by veterinary surgeons.
We endorse the concept of separating standard setting from the policing of those standards.
Whether this should be with 2/3 Councils and one Board, or one Council and 2/3 Boards we
would want to debate further.
We endorse the concept of the power to issue a formal warning (paragraph 36) but have some
concerns about this being given to the Preliminary Investigating Committee “by agreement with
the respondent”. Agreement could easily be portrayed as coercion under the threat of the
publicity and cost of a Disciplinary Committee hearing.
We understand the wish to provide complainants with an appeal procedure (paragraph 37) but
we would urge caution. In our experience every unsuccessful complainant is aggrieved, and
unless the grounds for appeal are tightly controlled every unsuccessful complaint will go to a
second hearing.
We note the intention not to seek powers to impose financial penalties (paragraph 4l). If farriery
were to come within the compass of the new Act, we would wish to reopen this debate. Such a
power might not be needed in respect of those who work within practices and partnerships.
However, temporary suspension of sole operatives is a blunt instrument that penalises
customers as much as or more than the suspended individual. Whenever a farrier is temporarily
suspended we get telephone calls from fraught owners asking what they are expected to do with
their horses during the period of the suspension. We would not wish to become involved in the
award of costs but the ability to impose a moderate fine (say up to £5,000) would allow more
directed sentencing. However, we are aware that there are difficulties in magistrates courts over
the appropriate levels of fines and it would be necessary to study the concept further before
introducing it.
Two significant weaknesses with the current Farriers Registration Act are that it makes no
provision for temporary visiting farriers, such as those accompanying polo or event teams, and
excludes trimming when the horse will not finish up shod. These concerns are outside the
scope of this consultation, but we would need to be assured that they could be addressed under
the new primary or secondary legislation.
We hope to involve Council and Registered Farriers in debate on whether we should seek to
come within the terms of the new Act, but we need to decide how best to go about this. We are
conscious that uninformed or misinformed debate could easily lead to people adopting firmly
prejudiced positions, and we cannot afford to lose our existing Act without having something to
put in its place.

sun tzu

Sun Tsu

Postby sun tzu » Sat Jan 21, 2006 6:11 pm

Posting transfered and deleted due to being from an un identfiable souce.

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RCVS Web site, response documents.

Postby PNB » Sun Jan 22, 2006 6:05 am


Thank you for pointing out the location of the responses to the RCVS proposed review, all 60 pages of them, a bit difficult to find mind.

I note the farriery organisations that did respond:-

The FRC contribution was through the pen of the then registrar, some of which made good sense, some of which if taken up is felt would lead to a further feeling of oppression from within the craft. It would seem this initial response was not crafted from the working tradesman's viewpoint. I feel our day will come however!!

The WCF were the only other farrier group to respond, their reply I fear shows a very limited comprehension of the reality of working as a farrier in either the current or the proposed system.

I feel it is sad that my Farriery Association NAFBAE hasn't got a response recorded. Were they invited to make a response??

UKHSU, seemingly the only only effective watch dog group were not consulted at the early response stage of the process. Why was this??

Both of the above instances of absent reports could lead the craft to feel maybe they have again been marginalised!! Is a cloak of secrecy still floating over the working craftsmen?? Something openly denied in a recent recorded response to one of UKHSU's members, a comment which now however seems to have a limited plausibility.

The allied to veterinary services steering group didn't appear to have a global recorded response either. To date it has not been able to establish which of the respondents other than Vet Nurses are actually represented within the steering group!!.

UKHSU were invited at a late stage to put a member forward for steering group, for which we are grateful, a matter somewhat retarded due to our first nominee being deemed unsuitable. The fact is that unless one of our members had seen and reported a three word comment within the late Dec issue of Horse and Hound by the new president of BEVA, UKHSU would still be deluded to believe there were no plans to bring FARRIERY under the RCVS review of the 1966 veterinary surgeons act.

I hope someone from the craft will also read the documents now they have been located, comments would be most welcome before the matter is taken forwards to council.


john ford
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Postby john ford » Sun Jan 22, 2006 11:22 am

Peter, Martin, I must say after reading the posted document that there are some benefits, that could come out of this proposal, although I can’t see why we have to go down this path in order to get another appendix added within the existing 1975 Act. I am not very good at understanding how laws are changed or introduced, except that it seems to me that common sense doesn’t prevail in such cases. Yes I agree that something should be written into the Farriery Act as regards to trimming the horse’s foot, and that a fine of some sort to a farrier who has broken the rules would be far better all round than a suspension from the register. Is it the case then, if we came under this so-called umbrella of the RCVS, that the whole cost of changing or inserting new laws into the 1975 Act would be far less and made easier, than if the FRC tried to do it themselves?

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Postby admin » Sun Jan 22, 2006 12:30 pm


What legislation could you possibly bring in regarding foot trimming? In theory it is desirable but in practice I cannot see that it is possible. But I would be interested to hear any suggestions.

Regarding fines, I think that the stress and expense of disciplinary proceedings is something that is not taken into account. There is no need for suspension from the register anyway in most cases. I would like to see fines for people who make complaints against farriers in order to avoid paying a bill or to settle a grudge.


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Postby PNB » Sun Jan 22, 2006 1:09 pm


That's about the long and short of it. My feelings are that any complaint should be taken forwards by the person complaining and not by the registrar as it seems is done at present, If taken forwards by FRC costs morally must be awarded if the prosecution fails.

Fines, yes fine with me but £5000 that's 3months trading profit, a ludicrous suggestion. Top whack of £250 is more the mark. To suggest £5000 demonstrates a detachment from reality

If all complaints were INVESTIGATED to establish the real reasons they were being bought I feel very few case would be entertained.

The proposed review of the Veterinary surgeons act lays down a much fairer matrix for investigation of complaints.

The current system allows the disavowed to cause honest tradesmen serious problems, is unfair and must be changed. A member of the investigating committee CRAFT member at that, should be tasked to investigate the reasons for any complaint. You are right in saying cost should be met by FRC but only on a voluntary basis as it is unprovided for within the registration act, for proceedings that they bring against registered farriers.

To be discharged of all guilt on a "There is no evidence to support the charge", verdict /result, and still have to foot a £15,000 bill is rubbish. FRC should pay defence costs and proceed against the complainant through the civil courts for malice!!


Sorry I will tidy it up later.

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