Response to the Proposal to Modernize the Veterinarians Act

Dear Ministry,

The NFU-O is pleased to submit feedback on 23-OMAFRA001 A Proposal to Modernize the Veterinarians Act. The NFU-O is an accredited farm organization representing thousands of sustainable farmers in Ontario and has advocated for farmers across Ontario and Canada since 1969. Members work together to achieve agricultural policies that ensure dignity and income security for farmers, while protecting and enhancing rural environments for current and future generations. Our diverse membership includes many small to mid-scale livestock producers that have been consulted on this proposal. 

NFU-O members share the concerns of the government that access to veterinarian care in Ontario can be difficult. NFU-O recognizes the new “Collaborative Doctor of Veterinary Medicine (DVM) program” as a step to remedy this problem and urges further investment to increase the number of veterinarians, including currently licensed veterinarians, being trained and incentivised to work with large animals, and more specifically trained to work with animals raised for food. We also recommend the government create a better mechanism for recognizing and accepting accreditation and foreign training credentials of immigrant veterinarians, and provide incentives and training for large animal care.

There is a decreasing number of vets in the province overall, but this is particularly problematic in small rural communities and northern communities where farmers do not have access to a vet and may need to trailer their animals over an hour to visit a vet. The new incentives offered by the Ministry for graduating veterinarians to practice in rural communities is a good start to remedying the problem of accessing veterinarian care in rural and northern communities. We encourage a similar incentive program for current veterinarians, trained in large animal or food animal care.

The NFU-O provides the following recommendations on “A Proposal to Modernize the Veterinarians Act: Discussion Paper”:

Scope of Practice
Overall, the NFU-O agrees with bringing veterinary technicians within the scope of professional oversight, having them acknowledged and regulated under the Act together with veterinarians, and formally recognizing that veterinary care is delivered by a team and that the skills of veterinary technicians contribute to the delivery of care.

We also agree with providing exemptions for alternative care providers, including physiotherapists and acupuncturists, and other care providers that provide services such as massage, pregnancy screening, ear tagging, teeth filing, and other non-invasive procedures to be part of an animal’s care without veterinary oversight. NFU-O recommends pursuing all avenues to allow procedures to be performed by as many trained care providers as possible, including providing funding for the creation of training programs to certify alternative care providers to perform many of these routine and non-invasive procedures. This would help alleviate the burden on veterinarian care in the province, and support the creation of a team of care providers for food animals.

NFU-O is concerned that the initial discussion paper states, “It is anticipated to be the case that an animal owner (such as a farmer), a member of the animal owner’s household, or a person employed for general agricultural or domestic work by the owner of the animal would continue to be able to treat an animal owned by the owner.” The continued ability for farmers to have control of care for their livestock is integral to the future of livestock farming in Ontario. NFU-O seeks a guarantee that farmers will continue to be able to diagnose and treat their own animals.

We would also ask that the Act loosen regulations to allow veterinarians to prescribe needed medications without a prior farm visit. The regulation currently does not allow a veterinarian to provide care or prescribe medication for your animals unless they have been on your farm at least once annually. This is particularly challenging for small farm operations that do not always have a need for a vet to be on their farm annually, but when the need arises, they cannot access care or necessary medications.

Oversight and Authority
The NFU-O agrees with increasing the number of non-veterinarian public-interest appointees on the Council, incorporating a broader range of perspectives into the decision-making process, as well as including representation from veterinarian technicians. We would also recommend that representatives are included from the agricultural sector.

We also agree with the statement in the initial discussion paper, “Enabling the Council to make regulations (subject to the approval of the Lieutenant Governor in Council upon prior review by the Minister) providing exemptions for some regulated health care professionals and other qualified practitioners to support veterinary professionals by applying their skills and expertise in animal care can increase the amount of animal care being performed.” However, the NFU-O seeks an indication that farmers would fit into this category of “other qualified practitioners.”

Farmers and their team of care providers are essential in the raising of animals for food on Ontario farms.

Sincerely, 

Max Hansgen,
President, National Farmers Union – Ontario