After reviewing these proposed regulations, I specifically support:

• The requirement for written informed consent for surgical procedures
• The requirement that any student performance of surgery be included in the consent
• The requirement that the supervising veterinarian be present in the operatory at any time that a student is performing surgery

However, these proposed regulations would still permit vet students to practice with patients before their fourth year without a requirement that owners give their consent.   Posting a notice which states that students are working in a veterinary office is insufficient.    Any situation in which a student will be performing a task, which ordinarily requires licensure, must require the owner’s specific consent.  Without this change, I remain opposed to expanding the possibility of student preceptorships before the fourth year.     

One final comment -- this requirement that owners be informed and provide their consent is important not just to owners but also to veterinary practices.   If a student practices on an animal and the owner is not satisfied with the care and then finds out that a student performed the task and not the licensed veterinarian, that owner is going to feel like he/she has been deceived and his/her response is likely to be more extreme.   I think that any veterinarian who does not specifically ask clients for their consent for student practice is going to end up alienating clients and damaging their practice.