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Focus on Brexit 2: just how prepared are we?
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By Josh Loeb and Matthew Limb

What will happen with Brexit? At the time of going to press there were still many unknowns. The legal default was that the UK would leave the EU at 11pm on 31 October, and the government was continuing to insist that a no-deal Brexit was possible.

Parliament will sit this Saturday in what could be one of the most important Commons sessions in the Brexit saga.

In a bid to examine the impact of leaving the EU without a deal, Vet Record last week analysed implications and preparedness across three major areas – trade, medicines and the Irish border (VR, 12 October 2019, vol 185, pp 429-432).

This week, in the second and final part of this series, we turn our attention to workforce, animal travel, animal welfare, and education and research.

For each, we have also identified three questions and provided answers obtained at the time of going to press either from an official source, a government department or expert adviser.

We have also provided a traffic light ‘score’ to indicate our assessment of readiness (with green indicating ‘ready’, red ‘not ready’ and amber somewhere in between).

This is not a definitive judgement, there being so many unknowns, and so much being subjective, but it is based on multiple conversations with different sources close to the issues at hand.

Read on for our in depth assessment of the state of play.

Workforce

Does the UK have sufficient veterinary capacity to cope with a no-deal Brexit? That’s the million pound/euro question – to which the answer is ‘No’.

The UK is already short of vets. So much so that the Migration Advisory Committee put the profession back on the Shortage Occupation List this month.

Under a no-deal Brexit, there are fears that the shortage could get worse, given the UK’s reliance on EU-trained vets. This reliance is particularly notable in the public health sector, where most vets are from outside the UK, the majority from the EU.

Capacity

Defra has not set a target for the number of official veterinarians (OVs) required for the new trading arrangements but estimated last year that the UK needs at least 50 extra full time OVs. In terms of progress towards reaching that level, 400+ vets have done OV training but it is not clear whether this will create sufficient capacity because most OV work is done as extra work on top of general practice.

To be fair to Defra, the department has been working overtime to try and support the market by creating the role of certification support officers (CSOs) to assist OVs and seeking to streamline certification processes. In total in the UK there are about 370 CSOs. Without any clear modelling it’s difficult to gauge whether these measures are enough.

In terms of meeting the veterinary shortfall more generally, there aren’t increased numbers coming in from elsewhere, the UK does not train enough ‘homegrown’ vets and the numbers from Europe are static.

Vet Record spoke to several recruiters last week. They have not seen a sudden upswell of interest among vets from the Anglosphere quintet wanting to work in the UK. They see a possible opportunity to recruit from further afield – one said they are in contact with ‘stacks’ of applicants from countries not traditionally thought of as vet suppliers to the UK, hundreds of whom could potentially be brought in at extremely short notice – but the reality most have not taken the statutory exam and so the RCVS would not register them.

Of course, immigration is just one pathway towards increasing the number of vets in the UK. Another is to produce more ‘homegrown’ vets. There are tentative signs that this is starting to happen. Nottingham Vet School recently doubled its intake. Surrey is soon to become the UK’s eighth accredited vet school and Harper and Keele will open its doors to vet students next year. But all that will take time and the UK needs to increase its vet numbers now if it is to cope with no deal.

In terms of vets from Europe, RCVS data show numbers in the UK have flatlined. After rising consistently year on year for several years before the referendum, the numbers levelled off in the eight months after the vote. Looking at the latest figures, RCVS data show that the number of non-UK EU vets on the register has been broadly static since 2017.

Immigration

The government has indicated that it will bring freedom of movement as it currently stands to an end

The government has indicated that it will bring freedom of movement as it currently stands to an end. It aims to introduce a new immigration policy that would level the playing field for Europeans and non-Europeans from 2021 through a points-based system.

Contrary to some reports, free movement for EU citizens would not end automatically as a result of a no-deal Brexit – parliament would have to explicitly repeal it.

The change in immigration policy could potentially open the door to more non-European vets having the possibility to work in the UK. Singapore, Indonesia and India are among the countries that have been mentioned by some recruiters as places where vets could be sourced. However, it would depend on whether they met RCVS requirements.

Vets are back on the Shortage Occupation List – meaning, from this month, reduced visa application fees for applicants for vet roles and their exemption from the minimum income threshold of £35,000. Employers are also exempted from the requirement to advertise vacancies locally before offering the role to an overseas candidate.

However, as things stand, the process is set to become more bureaucratic for those from the EU .

Under current immigration plans, in the event of a no-deal Brexit, EU nationals arriving in the UK after 31 October who intend to stay for longer than three months and up to three years would have to apply for ‘temporary leave to remain’ on entering the country.

For those already resident at the point of Brexit, the Home Office has launched the EU Settlement Scheme. There are different deadlines depending on the type of Brexit – if it’s a no deal they must apply by 31 December 2020, and this will be extended if there is a deal.

Key questions on workforce Embedded Image

Does the UK have a sufficient number of vets to meet demand?

No. Vets are on the Shortage Occupation List for a reason – an independent group of academics looked at all the data and has officially confirmed that the UK is currently short of vets. Embedded Image

What is the government doing to address the shortage?

Because most vets operate in the private sector there’s a limit to what Defra can do. The biggest shortage is in public health and that is where the department has focused its efforts. It has been trying to make it easier for vets to train as official veterinarians (OVs) by offering free certification training. It has not denied that it has also drawn up contingency plans for the government to recruit OVs directly as a last resort, but there are no details on where these OVs will come from. Embedded Image

Can the UK fast track registrations from overseas graduates?

In theory this is possible but the RCVS has consistently said it will not dilute its standards for registration or change how it processes applications. If there is a recruitment crisis and vets have to be brought in at very short notice from overseas, it would take about 20 days to get them registered. A college spokesperson stressed that it is imperative for the RCVS to uphold the integrity of the register. Embedded Image

Animal welfare

A no-deal Brexit could have ‘very serious consequences’ for animal welfare, according to the BVA. How so? It boils down to trade and the veterinary workforce.

If the UK left the EU without a deal, the country would immediately fall back on World Trade Organization rules, potentially making it harder to restrict imports on animal welfare grounds.

A stretched workforce would also be less able to safeguard animal health and welfare – so the theory goes.

Both the BVA and the RCVS have been careful to make clear that these are potentialities, not foregone conclusions. However, the fact that both organisations have come out against a no-deal Brexit means that they judge the risks from it to be sufficiently high to warrant warning the government.

Imports

Without an overarching UK-EU Brexit deal and the transition period that comes alongside it, the UK’s borders could be opened to a flood of cheap imports from countries with lower welfare standards, for example the USA.

Poor animal welfare would effectively be outsourced

The existence of lower welfare standards in other parts of the world would not, in and of itself, compromise the UK’s domestic animal welfare provisions (it seems unlikely that the UK would choose to weaken its own standards to compete; instead, poor farm welfare would effectively be outsourced).

However, several leading vets have told Vet Record that they perceive there to be moral issues at stake. For example, if a no-deal Brexit meant some UK farming businesses ceased being viable, would these farmers move to quickly downsize their herds by way of a cull? In other words, would healthy animals be killed for no reason? Defra says that it does not anticipate that happening. However, it can hardly be ruled out. After all, the stark reality is that many consumers might well prefer non-British food, produced to lower welfare standards, because of it being cheaper.

That said, although the EU’s animal welfare standards are relatively high compared with other parts of the world, EU membership has also forced UK farmers to compete with countries with lower welfare standards. A prime example here is the UK’s decision to ban sow stalls in 1999, before many of its European competitors chose to go down this route. This is widely believed to have led to an increase in UK imports of pig meat from the likes of Denmark, which did not introduce a ban on sow stalls until 2013.

Brexit could provide the opportunity to enhance welfare standards. Up until now, the UK has been prevented from banning fur products and the importation of foie gras – since doing so would be contrary to the rules of the single market and customs union. Brexit could make such bans possible.

Exports

The UK is unlikely to weaken its own welfare standards but could opt to push the boundaries of what is permitted to boost trade.

By way of illustration, consider sheep meat. The UK is one of the world’s largest sheep meat producers. The vast majority of its sheep meat exports go to countries in the EU. Tariffs imposed by the bloc after a no-deal Brexit could lead to the EU becoming a less economically viable destination. That could, in turn, force the UK to look to replace such lost trade with new trade with non-EU countries.

Last year the UK secured an agreement with Saudi Arabia to export millions of pounds worth of sheep meat – but as Vet Record revealed soon afterwards, the Saudis had stipulated that this meat should all come specifically from animals killed by non-stun slaughter. At the time several politicians and campaigners warned this could be the shape of things to come.

Sentience

The EU’s constitution stipulates that animals are sentient. Many welfare campaigners have argued that sentience must be written into UK law ahead of Brexit.

Defra appeared to have gone quiet on this – until this week, when, in the Queen’s Speech, proposals were outlined that would recognise explicitly in domestic law that animals are sentient. However, questions remain as to exactly how and when all this will be incorporated into domestic law.

Key questions on animal welfare Embedded Image

Would trading under World Trade Organization rules impact on UK animal welfare standards?

Probably not directly. Instead, the concern is that farming sectors would simply wither away. The National Farmers’ Union fears that UK products – such as British beef, cheddar and Welsh lamb – would have less protection because the UK market would be opened up to products produced more cheaply. Any trade bans the UK introduced on the basis of animal welfare could be vulnerable to being overturned by the WTO. Embedded Image

How might the veterinary profession alert the government to any Brexit-related welfare problems?

Both the BVA and the RCVS say they have mechanisms to bring problems to the government’s attention. They meet regularly with Defra through the Future Veterinary Capability and Capacity Project. Issues can also be flagged up through MPs and the press. Embedded Image

When exactly will animal sentience be legislated for?

Defra is still considering the right legislative vehicle for animal sentience. It is unknown when sentience might be incorporated into UK law but it is highly unlikely to happen before the 31 October deadline. Embedded Image

Research & education

Veterinary research in the UK is world leading and the UK’s vet schools and research institutes all benefit from EU funding.

Between 2008 and 2013, the seven vet schools existing at that time attracted almost £22 million between them from EU research bodies.

But there are now huge uncertainties over whether institutions can continue to access vital grants from Europe, recruit high-quality staff and students and maintain international research networks.

Some experts claim a no-deal outcome could ravage UK science for many years.

If a deal is passed, the UK will remain in the EU’s Horizon 2020 research programme and other EU funding schemes that are part of the multiannual financial framework until the end of 2020.

In the event of no deal, ministers have guaranteed to underwrite successful Horizon 2020 grant applications for the full duration of projects, via UK Research and Innovation.

The next EU framework programme, Horizon Europe, is due to start on 1 January 2021 and leaves open the possibility of full UK participation as an ‘associated country.’

Many experts see this as the best opportunity to keep UK research at the top table, and Universities UK is lobbying for ‘full association’ to the programme.

But it is not a given and may be hard to negotiate – especially if there is no deal.

The Russell Group of universities says that if full association to Horizon Europe is not possible ‘there needs to be a fully-funded alternative which can replicate the benefits…as closely as possible.’

Much will depend on if and how the government delivers its funding guarantees to UK research

Much will depend on if and how the government delivers its funding guarantees and commitments for UK research as it comes under pressure to meet other post-Brexit priorities for public funds.

Chris Proudman, the head of Surrey Vet School – which has experts involved in a large European research programme looking at zoonotic food-borne diseases and other emerging threats – has described government indications that it would replace any lost funding arising from Brexit as ‘vague’.

EU students

There is concern that, if it is no longer part of Horizon 2020 and it implements a stricter immigration regime, the UK will find it harder to attract the very best scientists from around the world.

The government announced last month that a ‘temporary leave to remain’ scheme would replace free movement.

EU nationals arriving in the UK before the end of 2020 will be able to apply to stay for three years, until December 2023, in the event of a no-deal Brexit.

But vet schools say the scheme is problematic and will put EU students off applying to train in the UK, as veterinary degree courses normally last five years.

Many EU students arriving after 31 October would have ‘no guarantee of being able to remain in the UK long enough to complete their course,’ said the Russell Group of universities.

The group added that it is ‘crucial’ that no-deal mitigation arrangements are put in place ‘which continue to attract European students and staff as we transition to the new immigration system’.

Susan Dawson, who chairs the Veterinary Schools Council, said: ‘The lack of clarity around the future status of EU students and staff has been difficult for universities. A no-deal Brexit would only compound this.’

A Home Office spokesperson said: ‘There is no suggestion that students on courses longer than 36 months won’t be able to complete their courses.’

Qualifications

Under the EU’s directive on mutual recognition of professional qualifications, veterinary regulators in EU member states must automatically register any graduates of vet schools in other EU member states.

After Brexit, this will cease to apply to the UK. However, arrangements have already been put in place for the majority of veterinary graduates from EU countries to continue to be seamlessly registered in much the same way as before.

Similarly, the UK will need to strike mutual recognition agreement for UK vets. The first was signed with Ireland earlier this month.

Key questions on research & education Embedded Image

Has the UK government guaranteed to replace all research funding lost as a result of Brexit?

Not all. There are guarantees in place around Horizon 2020 funding, but for other types of EU funding it’s less clear what will happen. Embedded Image

Is the UK looking to negotiate continuing access to EU funding post-Brexit?

Vet Record asked the Department for Business, Innovation and Skills but received no reply specifically addressing this question. The answer would be likely to depend on the details of a Brexit deal, if there is one. In a no-deal scenario, continued access to such funding seems unlikely. Embedded Image

What assurances can be given that European vet students at UK vet schools could stay for the duration of their courses?

The Home Office has said there is ‘no suggestion’ that they would not be allowed to stay. Those at undergraduate level and above should apply to continue living in the UK under a specially designated student leave to remain route before the expiry of their three-year temporary leave to remain.Embedded Image

Animal travel

Free movement of people (technically, ‘labour’) is a fundamental tenet of the EU – but harmonisation of rules across the bloc has increasingly come to mean free movement of animals too. Now some friction at borders is set to return.

Pets

Since the early 2000s people have become accustomed to the idea that they can take their pet dog, cat or ferret on a foreign holiday with ease – provided the animal has a pet passport. Individuals can take up to five pets of these species on holiday across the EU under the bloc’s Pet Travel Scheme (PTS) – without the animals needing to be quarantined.

Over the years the scheme’s rules have become progressively less stringent. For example, in 2012 the EU removed the requirement for pets to be treated for ticks before their arrival in the UK – something the BVA has objected to.

But on day one of a no-deal Brexit, the UK would no longer be part of the PTS so in order for owners to travel with their pets into the EU, they will need to meet a number of requirements (see box). The changeover will bring more bureaucracy and, probably, confusion.

In terms of pets travelling into the UK, no major imminent changes are planned, but charities are keen to see the rules toughened up because of the PTS being abused by puppy smugglers and also because of disease risks posed by ‘trojan dogs’.

New rules

UK-EU pet travel requirements are yet to be finalised but Defra says they are likely to include that:

  • Owners must have their pet microchipped and successfully vaccinated against rabies.

  • A blood sample must be taken at least 30 days after the last rabies vaccination, be that a booster or initial vaccination (the result must prove vaccination succeeded).

  • The vet must send the blood sample to an EU-approved blood testing laboratory.

  • Pet owners must wait three months from the date on which the successful blood sample was taken before travelling with their pet.

  • The vet must give the owner a copy of the test results and enter the date the blood sample was taken in an animal health certificate.

This list is not exhaustive. Search the gov.uk website for complete information.

Livestock

UK exports of live animals and animal products can continue in a no-deal scenario

EU member states have now granted the UK ‘national listed status’. This ensures UK exports of live animals (as well as products of animal origin, such as meat, fish and dairy) can continue in a no-deal scenario.

The EU would still require livestock to enter through a BIP. Some welfare campaigners see Brexit as a unique opportunity to ban the controversial practice of live exports altogether – indeed, the Labour party has committed to such a ban, while the Conservatives have pledged to severely restrict lengths of journey times for farm animals post-Brexit.

Horses

Movements of horses from the UK to the EU will become more onerous in a no-deal Brexit.

Currently many have free movement but a no-deal would end that.

Horses currently need an equine passport but in a no-deal scenario they would require both an export health certificate and some, depending on what they are used for, will also need an additional government-issued travel ID document.

All horses will also need to enter the EU through a border inspection post (BIP) approved to handle horses. Aside from the increased bureaucracy, there are welfare concerns. World Horse Welfare has questioned whether route changes due to BIPs might entail longer journey times, and whether EU lairage facilities will be adequate to accommodate horses transported from the UK.

The UK has committed to allowing continued movement of all equine animals from EU member states.

Other animals

The current process for tracking and notifying authorities about commercial movements on animals and animal products will change under a no-deal Brexit.

The UK would no longer have access to the EU’s current system but has in place a replacement system that is ready for use – the Import of Products, Animals, Food and Feed System.

Key questions on travel Embedded Image

Will live exports still be allowed?

Yes, because on 14 October Defra announced that the UK has been granted national listed status, so this practice can continue in the event of a no deal. Embedded Image

Has the government secured listed status for pet travel?

No. Defra says that, whatever form Brexit takes, the EU is likely to treat the UK – initially at least – as an ‘unlisted third country’ for the purposes of pet travel. The UK has been listed for other types of animal movements however. Embedded Image

Are UK vets and owners sufficiently prepared for changes to pet travel?

The signs aren’t looking good. Although Defra has issued advice to owners and is in contact with vet groups, it is difficult to gauge how many owners have made the necessary preparations. Recent survey data showed that many vets already feel ill equipped to answer questions from clients seeking guidance about future pet travel. The Veterinary Defence Society is bracing itself for a spike in claims because the change could cause mix-ups that prompt compensation claims against vets. Embedded Image

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