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Tuberculin Testing revalidation: extension/exemption process

1. The Memorandum of Conditions of Appointment of Local Veterinary Inspectors by the Minister of Agriculture, Fisheries and Food (August 1994 as revised in April 2014) with respect to the authorisation of Official Veterinarians (OVs) to act on behalf of Ministers with effect from 13 July 2015 is partly replaced by the Policy for Authorisation of Official Veterinarians. This policy sets out the training, qualifications and appoitments of Veterinary Surgeons who seek to carry out tasks on behalf of those Ministers and who are not employees of the government.

2. APHA will authorise as an OV any person who:

  • Has one or more Official Controls Qualifications (Veterinary) [OCQ (V)] - accredited qualifications achieved following training and assessment by a government approved supplier (currently Improve International); and
  • Is a Member or Fellow of the Royal College of Veterinary Surgeons (MRCVS); and
  • Is regarded by APHA as suitable for carrying out tasks on behalf of Ministers, taking into account any previous performance as an OV or convictions for offences under animal health or welfare legislation.

3. APHA has introduced revalidation requirement for OCQ(V) Tuberculin Testing [OCQ(V) TT] to provide assurance that OVs are maintaining and continuously improving their competence and applying the same to their work, this has been implemented to meet international standards of work. All the appointed OVs at the time of the introduction of OCQ(V) were granted 'grandfather rights' under OCQ(V) TT in April 2015 and revalidation was set-up to take place before 1 April 2017.

Revalidation criteria were agreed with the approved training provider and involve the following within each two-year revalidation cycle:

  • Minimum of 10 hours of TB related Continuing Professional Development (CPD). This may include completion of 3 hours OCQ(V) TT online revalidation module. For further information on what qualifies as CPD, please refer to the RCVS guidelines. This may include, but is not limited to (further information and examples may be found on the Improve International website):
    • Herd health planning, as it applies to TB, to improve biosecurity, H&S, or to discuss changes to TB policy with clients
    • Practice meetings/presentations
    • Supervising/teaching TB testers 
  • Completing OCQ(V) TT  online revalidation module training and successfully completing the online assessment.
  • Submission of TB testing case logs for a minimum of 250 bovine animals tested on a minimum of three different farms. 
  • At least ten reactions observed (these do not need to in Reactors or IR's).
  • Successful Veterinary Delivery Partner audit, APHA audit, or a nominated peer review of testing.
  • Signed Declarations.

For further information, please see the Improve International website.

4. APHA recognises that the above criteria may be difficult to meet by some OVs. OVs who have extenuating circumstances and are unable to test 250 bovine animals within a two year revalidation cycle may apply for an extension or exemption from the standard revalidation testing requirements. The following circumstances are given special consideration:

  • OVs working in ‘low volume’ TB testing areas.
  • OVs specializing in non-bovine species (e.g. Zoo or pig veterinarians).  
  • OVs on maternity/medical/career break/other leave (greater than 3 months duration). If an OV is not working at the time of revalidation and is not prepared to revalidate whilst on leave, the OV status is eligible for suspension. The APHA OV Team should be notified when the OV plans to commence leave and when they return to work. An additional six months will be given to complete revalidation of the qualification upon the return to work. Failing to revalidate means that the qualification in question will be revoked and the entire OCQ(V) TT will need to be repeated to regain OV status. The date of subsequent revalidation will be unaltered. If the OV does not notify the OV team and fails to revalidate by their due date their status will be expired. The OV may then appeal for retroactive suspension.
  • TB Assessors/Auditor who no longer TB test.
  • If there is another valid reason to seek extension/exemption from the standard testing revalidation requirements, this may be considered by APHA. APHA may make further enquiries and check records, as appropriate.

5. If an OV will be able to fulfil the standard revalidation testing requirements with a six months’ extension then the OV should apply for an ‘Extension of revalidation period’ (extension of revalidation is not available for OVs working in Scotland, please see ‘Exemption from standard revalidation protocol’ below). This will allow an additional 6 months of testing but will not reset the future OCQ(V) TT revalidation cycle date. An application should be submitted in writing to the OV Team (email: OVTeam@apha.gsi.gov.uk) and should include:

  • Declaration that the OCQ (V) TT online revalidation module training and successful completion of the online assessment will be reported to the OV Team within 30 working days from the extension approval date.  Failure to comply with this requirement will invalidate the extension.
  • Declaration that a minimum of 10 hours of relevant CPD will be completed once the OCQ(V) TT online revalidation module training is completed, as per standard revalidation protocol.
  • Case logs, as described in the standard revalidation protocol, of testing completed to date of application for extension.
  • At least ten reactions observed (these do not need to be Reactors or IR's).
  • Successful Veterinary Delivery Partner audit, APHA audit, or a nominated peer review of testing or a declaration that this will be arranged within the extension period.

For further information, please see the Improve International website.

6. If an OV will not be able to fulfil the revalidation criteria with a 6 month extension, then the OV may apply for an ‘Exemption from standard revalidation protocol’.  An application should be submitted in writing to OV Team (email: OVTeam@apha.gsi.gov.uk) and should include the following declarations (a) AND evidence (b):
a.  Declarations:

  • Declaration that the OCQ (V) TT online revalidation module training and successful completion of the online assessment will be reported to the OV Team within 30 working days from the exemption approval date.  Failure to comply with this requirement will invalidate the exemption.
  • Declaration that a minimum of 10 hours of relevant CPD will be completed once the OCQ(V) TT online revalidation module training is completed, as per standard revalidation protocol.
  • Reason the OCQ(V) TT revalidation process cannot be followed (e.g. zoo vet, low volume testing area, leave, etc.).
  • If a previous request for exemption from the standard revalidation protocol was granted.

b. Supporting evidence of testing history (case logs) and satisfactory testing assessment must be included with the application. The type of evidence required is based on the applicant’s reason for requesting an exemption:

  • Case logs of testing completed during the current revalidation cycle.  For additional information on what should be included in the case logs, please see the Improve International website.
    • For exemption due to ‘low volume’ testing area - Case logs of  testing completed to date of application for exemption.
    • For exemption due to Specialist OV status (e.g. zoo vet), this may include small numbers of bovine animals in a specialist capacity – a case log will be required for each test done within the two-year revalidation cycle.  A minimum of 5 case logs with testing occurring on at least 3 separate occasions will be required.
    • For exemption due to TB assessor/auditor status (OVs who do not currently TB test) - An assessment log (minimum of 5 assessments) will be required.
  • Evidence of a satisfactory testing assessment done within the current two year’s revalidation cycle by a peer with a full/revalidated OCQ(V) TT, compliant APHA and/or Veterinary Delivery Partner audit (either individual or LRA audit day).  Specific conditions apply based on the exemption reason:
    • For exemption due to ‘low volume’ testing area - A peer review testing assessment will not qualify for consecutive revalidation cycles.  If the OV does not test 250 bovine animals on a minimum of three different farms within a four-year period (two revalidation cycles), then a testing assessment for the second revalidation cycle will be required by APHA or VDP auditor stating that the OV is compliant with TB testing procedures. Note: OVs audited under the APHA OV audit programme in Scotland (launched in 2013) will not need additional evidence of satisfactory testing assessment for the revalidation cycle ending 31.03.17.
    • For exemption due to Specialist OV status (e.g. zoo vet), this may include small numbers of bovine animals in a specialist capacity.  A per reviewed testing assessment will be required for each revalidation cycle.
    • For exemption due to TB assessor/auditor status (OVs who do not currently TB test) – A declaration not to test and successful completion of a witnessed assessment, either peer reviewed or APHA will be required.

7. When the OV applies for an extension/exemption, the APHA OV Team will assess the application. If supporting evidence is required, the OV Team will request additional information within 10 working days from receipt of the application. Applying for an extension/exemption does not extend the revalidation deadline.  If notification of approval has not been received prior to the revalidation deadline, the OV status is suspended immediately pending approval. It is advisable that an extension/exemption application is made at least one month in advance of the OCQ(V) TT revalidation deadline.  

8. In the case of an OV appealing the decision of the OV Team, the OV must notify the OV team in writing within 15 days of suspension/notification.  The OV must send a copy of the original application and the statement for grounds of appeal which will be forwarded to a Review Panel consisting of two APHA representatives. A decision will be made by the Review Panel within 15 working days and the OV will be notified of the outcome. The OV’s status remains suspended, if revalidation deadline has passed, throughout the review/appeal process.

9. The OV has a right to appeal against the Review Panel’s decision. This must be received at the APHA OV Team within 28 days of receipt of the Review Panel’s notification. The appeal must be in writing detailing the grounds for an appeal. The Review Panel’s decision and grounds for appeal by the OV will be considered by two APHA Veterinary Advisors for Field Delivery (VAFD) from the relevant region. A decision will be made by the VAFDs within 15 working days and the OV will be informed of the outcome. The VAFD’s decision is final.  If the appeal is not granted (extension/exemption application approved), the OV’s OCQ(V) TT is revoked until the full OCQ(V) TT training with ‘Conditional’ OV status is completed.

10. If an OV does not meet the Standard, Extension, or Exemption criteria of Revalidation, then the OV’s OCQ(V) TT is revoked until the full OCQ(V) TT training with ‘Conditional’ OV status is completed.

Contact details

APHA OV Team
Email:
OVTeam@apha.gsi.gov.uk

Address:
Official Veterinarian Team County Hall
Spetchley Road
Worcester
WR5 2NP

Telephone:
03000 200 301

Improve International
Email: 
enquiries@improve-ov.com

Address:
OV Customer Services Manager
Improve International Ltd
Alexandra House
Whittingham Drive
Wroughton
Swindon Wiltshire
SN4 0QJ

Telephone:
0330 202 0380

Website:
https://www.improve-ov.com

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