With respect to all invested parties, I strongly oppose this change. Intravenous catheter placement should be limited to licensed veterinarians, licensed veterinary technicians and students (enrolled and in good standing) of either accredited degree program. While laboratory animal medicine uses different nomenclature, there are specific tiered training programs through ACLAM to ensure proper academic and practical training for performing various medical procedures in the medical research realm, in support of and in addition to site-specific IACUC protocols.

As a small animal veterinarian, formerly a kennel assistant, veterinary assistant, receptionist, overnight emergency clinic employee, farm hand, lab animal caretaker, lab animal technician, and lab animal clinical coordinator, I have experienced both sides of this debate. I understand the dilemmas that have resulted in this proposed rule change. I have no doubt there are places where IV catheters are being placed by non-licensed personnel now, and it will continue whether this rule is changed or not. However, I have the choice whether or not to work in or support this type of establishment.

I have a vested interest in protecting my license, as do licensed technicians. I have the responsibility of not allowing a student to perform such tasks until I am convinced they understand the implications on the animal(s) (and of their "future license") if there are complications with the IV catheter placement, including subsequent use and monitoring of the catheter.

This comes into sharper focus considering the variety of ways we use these medical devices. We are not just talking about "grand-fathering" in staff capable of placing a "tube in a vein". We are talking about a rule change with no detailed minimal threshold for parameters of training and written competency for the person to perform the procedure. More is required of a person to get a driver's license. We are talking about lowering the standard in the field of medicine, to allow a person without formal documented training or licensure to place a sterile catheter inside the blood vessel of a living being.  A port through which drugs will be delivered, with the potential for not only infection and pain, but even loss of limb or life, whether intentional or not. A vehicle for delivering not only fluids, but controlled substances, anesthetic drugs and last, but not least, chemotherapeutic drugs.

Although the proposed rule change indicates this would ONLY be allowed by trained staff, there would really be NO concrete way to establish legally whether any person working or volunteering in a facility should or should not be performing this procedure. If training began immediately, an employee or volunteer could potentially be placing IV catheters on their first day. As long as the veterinarian verbally attests that training has taken place, they would be practicing within the confines of the rule. This scenario may seem like an exaggeration, but I assure you, I have witnessed similar situations. The difference in whether this is outlandish and reckless versus being completely reasonable depends on the trainee's background. It would be completely reasonable for an employer to expect a new hire veterinarian or licensed technician to place a catheter on day one. Under the rule change, a worse case scenario exists. An owner (private or corporate) could hire at minimum wage (or select an unpaid volunteer), provide a written Standard Operating Protocol, and upon review of the SOP, a new volunteer or staff member could begin placing catheters. Having worked in private practice, lab animal, and corporate veterinary practices, I have experienced the full range of "on the job" training, from dangerously inadequate to outstanding. 

While I sympathize with the unlicensed technicians with 20+ years of experience, if they really want to continue to perform this duty legally, the personal sacrifice needs to be made to get the accredited education, to get licensed, and have some legal liability on their own shoulders. I don't advocate practicing in fear, but I do believe the licensed technicians bare the ethical weight of "do no harm". They understand the potential ramifications on themselves and the supervising veterinarian in a way that is an abstract concept for unlicensed staff. I know and greatly respect people that have been in this field for a long time who have intentionally decided to pursue or not pursue becoming licensed. Some are very experienced and completely capable of placing an IV catheters, but have chosen to NOT have this responsibility at work any more. There is a conscious decision- Do I want to sacrifice the time and money to become licensed? Do I want to do the required annual continuing education? Do I have the time, energy and ability to stay current on the latest advances in veterinary medicine? Because this is not about reading or talking about how to do a specific procedure once and then going on to do it in the future without any necessary follow-up or contingency attached to the action.

Our licensed veterinary technicians have made the sacrifice (past, present, and future) to get the education, jump through the hoops to take the licensing exam, and continue their education to stay licensed. They deserve to be valued and to be held accountable, the awesome responsibility and privileges of their profession guarded. Relegating this responsibility to any staff member, depending on the situational definition of "trained", may benefit a few, but overall it will be irreversibly detrimental to veterinary medicine.