Letter to BVA

Feedback regarding BVA/RCVS Joint Guidance

Who I Am
Andrew O’Donnell BVSc MSc MRCVS – veterinary surgeon and practice owner. I make this representation on my behalf as both vet and practice owner and not influenced in any way by external factors.

Basis under which I treat the guidance
Niall Connell has made the statement that the guidance released by the BVA and RCVS on 9th April 2020 carries the following weight:

‘’It becomes effective from Tuesday 14 April and supersedes the initial joint guidance we issued with BVA on 25 March’’

This sentence makes it clear that the guidance issued on 9th April is to be viewed as a joint statement updating that of the 25th March, as does the simultaneous timed release of said guidance. The RCVS guidance provides a clear ‘framework’ with little specific situations mentioned whereas the BVA guidance provides detailed applications of this framework to a variety of situations and so they can be viewed as complementary and in no way contradictory or overruling.

It is my opinion that if a regulator makes a joint statement with another professional body, the statements contained in both statements must be taken as if they were issued jointly and severally by both bodies – i.e. both statements must be classed as direct regulatory advice.

I would not like to be the one arguing in court that the RCVS does not approve of the content of the other half of the ‘joint statement’ so it does not apply.

If the RCVS (as appears to be the case) were not aware of the presentation of this advice as a joint statement and did not intend this to be presented this way they should take immediate steps to rectify this misconception.

Comment on RCVS Guidance
The RCVS guidance, in my opinion, clarifies some of the decision-making guidance issued and provides a flowchart to help justify which work is necessary or not necessary. This guidance remains purposefully vague and places most of the onus of decision making on the individual clinician.

In and of itself the guidance is helpful to a limited extent to clarify some decision making. Viewed from a broad perspective it is little more than a detailed way of saying ‘use your clinical judgement as a professional’, which is advice we all abide by every day of our professional lives; and so offers little specific help.

I feel some more situational advice would be appropriate, but also understand the position the RCVS are taking in order not to dictate business rules to the businesses themselves due to a variety of legal and regulatory matters.

The BVA is a private entity over which the RCVS have little formal control and I feel it has been a grave mistake to become deeply involved with the BVA in such a fashion as issuing joint statements as inevitably the interests (and pressure on) a private entity are likely to differ from the regulator of our profession.

Comment on BVA Guidance
The BVA guidance contains a few changes but I will focus on a single one to avoid this becoming too long – the recommendation that we should ‘go ahead’ with adult dog booster vaccines on a yearly basis.

The BVA have justified this as there is a zoonotic potential of leptospirosis and so these vaccinations should continue. They have not conditioned this on any need for disease risk or an overall risk assessment, their whole stated reasoning is ‘leptospirosis has zoonotic potential so we should keep vaccinating’.

The BVA have clearly given a ‘public health’ justification to restart leptospirosis vaccines, assisted by a statement that treating a disease like lepto will breach social distancing more than vaccinating those dogs.

The result is a traffic light system where leptospirosis vaccinations are given a green ‘go ahead’ signal with no conditional information attached to this. This amounts to a recommendation to continue with yearly dog boosters as normal.

A number of people have argued that this is only supposed to be allowed if there is a justified animal health reason and while the BVA guidance contains a lot of concern about how to reduce risk, they illustrate this with examples of what does and does not fall within their guidance. Once of the most obvious examples is that Leptospirosis vaccination (and thus normal dog boosters) is recommended to take place within the framework they have laid out.

To make it clear – this is not ‘vaccinate if it’s needed’, this advice is ‘here’s our guidance to be careful and vaccines are fine within this’.

A simple theoretical possible small risk is not a good justification to allow a well understood very high risk event to take place.

Will the BVA release the data and risk assessment they have comparing the potential public health risk of reduced leptospirosis vaccination against increased coronavirus cases they used to make this decision?

My data is as follows but I am happy to be corrected by the BVAs risk assessment. There are usually between 1 and 3 public deaths from Leptospirosis each year in England and Wales. Each month that passes with no vaccination will result in approximately 8% of already vaccinated dogs lapse their vaccines.

Existing immunity does not end on a yearly basis and previous evidence has shown that a delay of up to 3 months has negligible effect on immunity. This is based both on prior communication with vaccines companies and where there has been supply issues, said companies have issued guidance that 3 months overdue is not a problem.

Thus, we could reasonably conclude that we have a ‘grace’ period of three months before the population as a whole begins to suffer any reduction in immunity and when this does commence, it will be gradual.

On the converse, if we follow BVA guidance as a whole we will be expecting a significantly increased number of journeys and social contacts. Social contacts and unnecessary journeys are the main risk factor of spread of Coronavirus, which is currently at its PEAK of infected people and killing around 1000 people a day.

We may expect something like an extra 500,000 visits to the vet a month if all normal boosters are back on the menu as the BVA recommends.

It will not take much to infect a few veterinary practices and potentially, across the UK, tens of thousands of people visiting the vet for their boosters.

What is the potential increased rate of death in clinical staff and the public from the increased number of vaccinations, compared to leptospirosis?

We have all been taught epidemiology and the exponential spread of disease. The BVA statement that the public health risk of leptospirosis outweighs that of coronavirus is wilfully negligent and dangerous, taking not an apparent single iota of public health and the health of their members into account.

Will the BVA release details of why the Major Employers were aware of this before the general veterinary population?

While we understand ‘major employers’ are stakeholders who are entitled to some special committees, this should not extend to insider information regarding upcoming recommendations to allow a significant business planning or economic advantage; or undue influence on the passing of said guidance.

Will the BVA release minutes of the Major Employers meetings and if not, why not?

Does the Major Employer’s group consist of industry bodies who do not directly represent clinical practice e.g. Pharmaceutical Companies?

Are there any representatives of independent practices on the ‘major employers’ list?

Is there an appointed representative of perhaps a large independent buying group or association allowed to attend or be present at the major employer’s meetings?







Can you simply ignore the rules and make your own?

Of course we can, but to do so leaves certain individual businesses profiting at the expense of public health; and profiting from other veterinary practices choosing to make an effort to do the right thing in quite extraordinary situation.

Should we accept the BVA encouraging businesses to breach public health to gain a competitive advantage over each other? This cannot result in anything other than a race to the bottom, or losing clients hand over fist to those irresponsible enough to advertise gleefully to everyone they can.

Game theory (and specifically the prisoner’s dilemma https://en.wikipedia.org/wiki/Prisoner%27s_dilemma#Economics) can show us that in situations like this, it is often a race to the bottom – and everyone being at the bottom scraping in the mud is a ‘better’ overall outcome than some people acting with noble intentions and some poor.

Should individual vets refuse their employer’s orders

In an ideal world, this would be a good idea. Unfortunately for a lot people the risk of losing your job or other retribution is enough to persuade them to do what they are pushed to do. Equally, the employer may choose to present these choices as ‘morally approved’ by the BVA in coaxing people into going against public health advice.

There are various other concerns but I have addressed the most obvious ones here in order to keep this focused and clear.


Andrew O’Donnell MRCVS