AVA lodges submission on Draft WA Veterinary Practice Amendment Regulations

Regulating all animal health service providers, including veterinarians, paraprofessionals, and non-veterinary practitioners, is essential to ensuring animal welfare and consumer protection. The AVA has lodged a submission in response to the Western Australian Department of Primary Industries and Regional Development (DPIRD) draft Veterinary Practice Amendment Regulations (VPAR), highlighting key concerns about the proposed regulatory framework.

The AVA acknowledged the intent of the draft regulations to improve oversight of veterinary practice in Western Australia. However, significant concerns were raised regarding the apparent regulatory imbalance between registered veterinarians and non-veterinarians who are authorised to perform acts of veterinary medicine. The proposed VPAR introduce a disproportionate increase in regulatory burdens for veterinarians while allowing non-veterinarians to conduct veterinary procedures without equivalent oversight. This inconsistency raises serious issues related to risk management, animal welfare, and professional accountability.

The AVA's submission emphasises that acts of veterinary medicine should be performed by registered veterinarians to maintain high standards of animal welfare and consumer protection. Where non-veterinarians are authorised to undertake veterinary procedures, they must be appropriately trained, licensed, and subject to strong regulatory oversight. The AVA is particularly concerned that the draft regulations weaken these principles, particularly in large animal practice, where non-veterinarians may be permitted to perform procedures without adequate supervision or safeguards. Such an approach risks lowering animal welfare standards for production animals compared to companion animals.

Another key issue raised in the submission is the shift from a professional discretion-based model to a compliance-heavy regulatory framework. Veterinary professionals manage risks through their education, training, and professional judgement. However, the proposed VPAR contain a prescriptive approach that increases administrative burdens without clear benefits to animal welfare. This model contrasts with best practices in other health professions, where professional discretion remains integral to effective service delivery.

The AVA's submission also highlights additional concerns, including:

• The lack of clarity around the legal and professional liabilities of veterinarians supervising non-veterinarians;
• The potential economic impact of increased regulatory requirements on veterinary service accessibility, particularly in rural and remote areas;
• The importance of a regulatory model that supports service provision and workforce sustainability rather than imposing restrictive oversight.

The AVA strongly urges DPIRD to reconsider aspects of the draft VPAR that impose unnecessary regulatory burdens on veterinarians while failing to ensure adequate oversight for non-veterinarians performing veterinary procedures. A balanced approach, incorporating professional accountability and outcome-based regulation, is essential to maintaining high animal welfare standards and supporting the veterinary profession.

The AVA's submission provides a detailed analysis and recommendations to ensure that veterinary regulations in Western Australia align with best practices in veterinary medicine and uphold the highest standards of animal welfare. The AVA remains committed to working collaboratively to refine these regulations in a way that supports veterinary professionals, safeguards animal welfare, and maintains public trust in the profession.

The full AVA submission can be found here.