The American Association of Equine Practitioners (AAEP), an organization consisting of nearly 10,000 equine veterinarians, submitted its stance to the AVMA before the March 25, 2018, open comment period expired.
“We have not put together an ‘advisory piece’ or anything for the public,” according to Keith Kleine, the AAEP’s director of industry relations, in an email to American Farriers Journal. “Rather, [the AAEP has] issued comments to the AVMA supporting the fact that farriery should remain exempt in the model veterinary practice act.”
The AVMA requested comments after proposing several changes to the MVPA, including the elimination of the farrier exemption. The AVMA has since removed the draft MVPA from its website.
The AAEP joins a number of equine organizations, including American Farriers Journal, that have submitted a comment to the AVMA regarding the farrier exemption.
American Farriers Journal requested that the AVMA include commentary detailing that “the work of farriers is well-established and, therefore, it isn’t necessary to explicitly exempt them from the MVPA.”
The American Farrier’s Association’s statement, written by President Travis Burns, requested that the AVMA “incorporates the statement that ‘farriery exists outside the realm of veterinary medicine’ within the MVPA. This will help prevent state[s] from making rash decision[s] about the oversight of farriery, especially without the aid of organizations such as the American Farrier’s Association.”
“Without hesitation, we remain strongly opposed to the current proposed modifications, specifically relating to the elimination of the ‘art or profession of farriery’ exemption,” the AAPF stated in an email. “In addition, we are unwilling to compromise in our commitment of having farriers recognized for their expertise and professionalism which they offer to the equine industry.”
Further, the AAPF/IAPF offered its membership guidance on submitting comments to the AVMA by suggesting they “cut and paste” one of four options.
“Option 1: I am firmly committed to the professionalism of the art, science, and technology of the farrier profession. I would ask that the AVMA recognize this professionalism which exists in our two professions and retain the exemption for farriery in your proposed Model Veterinary Practice Act of 2018,” according to the statement.
“Option 2: The veterinarian and farrier have enjoyed a long-term relationship and I would hate to see the elimination of the ‘art or profession of farriery’ exemption in your proposed Model Veterinary Practice Act. I would ask that you respectfully reconsider this proposed elimination.
“Option 3: As a professional farrier I enjoy excellent relationships with the veterinarians and horse owners which I work with on a daily basis. We have established platforms upon which we offer a dialogue which ultimately benefits the horses which we serve. Please reconsider the elimination of the exemption for farriery in your proposed 2018 Model Veterinary Practice Act.
“Option 4: I have a tremendous amount of respect for the veterinarians which I get to work with on a daily basis. These same vets have shown me an equal amount of respect for the professionalism which I bring to the overall health of the horses which we work on. I believe making a change like eliminating the exemption for the art or profession of farriery from the proposed Model Veterinary Practice Act would not be a positive step for our two professions. Please reconsider your proposal.”
“The Northeast Association of Equine Practitioners was the first organization to include farriers in our definition of ‘equine practitioners’ and to actively foster the relationship between veterinarians and farriers,” according to a statement attributed to David Dawson, NEAEP’s executive director and CEO. “We are in active communication with multiple professional organizations to present a united voice in support of the current art of farriery exemption. The NEAEP will continue to advocate for the betterment of both professions.”
The AVMA’s MVPA defines “practice of veterinary medicine,” as:
“a. To diagnose, prognose, treat, correct, change, alleviate, or prevent animal disease, illness, pain, deformity, defect, injury, or other physical, dental, or mental conditions by any method or mode; including the:performance of any medical or surgical procedure, or
i. prescription, dispensing, administration, or application of any drug, medicine, biologic, apparatus, anesthetic, or other therapeutic or diagnostic substance, or
ii. use of complementary, alternative, and integrative therapies, or
iii. use of any procedure for reproductive management, including but not limited to the diagnosis or treatment of pregnancy, fertility, sterility, or infertility, or
iv. determination of the health, fitness, or soundness of an animal, or
v. rendering of advice or recommendation by any means including telephonic and other electronic communications with regard to any of the above.
b. To represent, directly or indirectly, publicly or privately, an ability and willingness to do an act described in subsection 16(a).
c. To use any title, words, abbreviation, or letters in a manner or under circumstances that induce the belief that the person using them is qualified to do any act described in subsection 16(a).”
The MVPA is not biding law; however, states use it as a guide when updating its respective Veterinary Practice Acts (VPA).
According to the AVMA, 22 states and the District of Columbia — Alabama, Arizona, California, Connecticut, Hawaii, Indiana, Kansas, Kentucky, Michigan, Missouri, Nebraska, New Jersey, New York, North Dakota, Oregon, South Carolina, South Dakota, Utah, Virginia, Washington, Wisconsin, Wyoming — make no mention of farriers, farriery, horseshoeing or livestock management practices in their respective VPAs. It should be noted that Minnesota licenses racetrack farriers; however, makes not mention of farriery outside of racing.
Sixteen states specifically exempt farriery, horseshoeing, hoof trimming and trimming feet — Alaska, Arkansas, Florida, Georgia, Idaho, Iowa, Maine, Maryland, Mississippi, New Hampshire, North Carolina, Ohio, Oklahoma, Pennsylvania, Texas and Vermont.
Another 11 state VPAs exempt livestock management practices and animal husbandry practices — Colorado, Delaware, Illinois, Louisiana, Massachusetts, Montana, Nevada, New Mexico, Rhode Island, Tennessee and West Virginia.
“At the close of the 60-day review period, a working group will review all submitted comments and forward recommendations to the Council on Veterinary Service for further review,” according to an AVMA news release. “A final draft of the revised MVPA will be sent to the AVMA board of directors for consideration. It is likely the board will ask the AVMA house of delegates to review and approve any revisions.”