These proposed regulations are significantly better than what was contained in the Notice of Intended Regulatory Action. 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

The change regarding owner consent is still insufficient. A notice posted in the office that students are working in that location is not the same as consent, and is not an adequate alternative to consent.

Veterinarians are not required to accept students into their offices for practical experience. If they choose to do so, they need to confirm that the owner understands the situation and agrees to the student’s involvement. 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.