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Although I’m a veterinarian, my interest in health isn’t limited to just animals. I’m a human practitioner too, and I’m human myself! My interest in human health therefore has both a professional but primarily a personal aspect to it. I’ve heard some people waxing lyrical about how good Borax is for people and how much the Boron it provides is beneficial. Not wanting to take this as read I started to do a bit of research. On the face of it, what was being said seemed to be starting to stack up.

It’s always better to increase a food source than supplement if at all possible. Form and thus bioavailability are usually much better – sometimes because of what else is in the food source that aids absorption as much as the nutrient itself. Hence, I did a search to find which parts of my carnivore diet I might need to think about increasing.

That was when I got my surprise – animal food sources are virtually free from boron and it’s almost exclusively found in plants. It got me thinking… We know that humans evolved as hypercarnivores and that the introduction of agriculture and the increase of plants in the diet shrunk the human brain. Ergo, if the food source we evolved eating, which by definition must be our optimum diet, is virtually free of boron then the requirement for it can’t be very much at all and will be satisfied by the carnivore diet. So why are people and the research reporting such benefits from supplementing with borax?

Boron modulates vitamin D, oestrogen, and calcium metabolism in ways that matter for aging bones and inflamed joints but although my diet has virtually no boron in it I don’t experience the symptoms associated with low boron such that adding borax would make a noticeable difference to my health.

Then it struck me. Boron is required at a higher level in the vast majority of the population because they eat plants as a significant part of their diet. Boron is the diet’s requirement, not the individual’s.

It got me thinking about whether there are other nutrients for which this is true too, and then – if it’s true for people, what about our animals?

What if a “nutrient requirement” isn’t a property of the animal - but a property of the diet the animal is being fed?

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We’ve been trained to think of vitamins and minerals like fixed tolls on a highway. Every dog needs X g/mg/µg per kg body weight of whatever nutrient. For example, every cat needs 10 mg to 50 mg of taurine per kilogram of body weight daily. The numbers sit in textbooks tables as if they’re laws of physics, discovered by neutral measurement and that is how they are described by nutritionists and pet food companies who use these tables and research behind them to justify what they do. I’m not saying they’re totally worthless – clearly there will be some use and at least ballpark figures that might be useful for some situations, but they aren’t as set in stone as we’re told. It doesn’t make the diets formulated by tables scientific – it just makes them manipulated. If the figures were really that scientific and exact then all diets would be formulated to exactly the same composition and they’re not. To add another spanner in the works, there’s individuality in terms of nutrient absorption and utilisation too – so nutrition is far more than nutrient levels and provision.

One of the big problems with these nutrition textbooks and tables is that they’ve been composed by observing animals eating an industrial diet of extruded kibble built on grains, legumes, and plant protein. There may well be some tables now that include some “raw” food data, but as I’ve mentioned before, there’s a wide spectrum of raw food these days which includes anything from zero plant ingredients to over 50%. As we can now see with just boron, the requirement for carnivores will vary depending on whether they consume plants within their diet on a regular and significant basis.

In other words, nutrient requirement is a moving target that depends entirely on what else is in the bowl, but they can’t make tables to cover that, so in true reductionist reality and style they look at nutrients in isolation and think they can then throw them all into a bowl based on requirements derived from isolated research to make a “complete” diet that’s of course totally grounded in “science”.

They use the same flawed rationale to tailor a diet to a breed or individual in order to justify a premium price.

Vitamin C: The textbook case

Boron isn’t the only example of this. Vitamin C is another example that has had it’s history selectively told. The Royal Navy seamen got scurvy because their diet was based primarily on grain-based ships biscuits whereas the officers who ate primarily meat didn’t get scurvy. Fruit with vitamin C solved the problem for the sailors and that’s the bit we all get told to justify using vitamin C levels in food as leverage to promote fruit.

Dogs and cats don’t even need dietary vitamin C- they synthesize their own ascorbate in the liver. But the rate at which they must synthesize it is not fixed.

Vitamin C and glucose are structurally similar and compete for the same cellular transporters (the SVCT and GLUT systems). When blood glucose runs chronically high, which is exactly what a high-carbohydrate kibble produces, glucose crowds ascorbate out of the cells. The animal’s own synthesis has to work harder just to hold tissue levels steady. This is why the ships biscuits tipped the sailors into scurvy. I’ve been on my carnivore diet for 3 years now and I don’t need to routinely supplement vitamin C.

So, a dog eating 40–50% carbohydrate (typical of commercial kibble) is running a permanently elevated demand for the very antioxidant that a RMB-based raw-fed carnivore produces effortlessly at baseline.

The requirement didn’t change. The diet inflated the demand.

Boron, Magnesium, Zinc, Calcium: the anti-nutrient tax

This is where it gets more complicated because it’s not just glucose competition. It’s antinutrients and sequestration.

Plant ingredients - especially grains, legumes, and seeds—contain phytates and oxalates that bind minerals into insoluble complexes and carry them out in the stool. This is not fringe thinking. It’s basic chemistry.

• Phytate binds zinc and magnesium. A grain-heavy diet can cut zinc bioavailability by half or more. Zinc doesn’t act in isolation in the body either so there are knock-on effects to copper, enzyme activity and more.

• Oxalate binds calcium. Spinach, sweet potato, and other plant ingredients common in “premium” kibbles and some “raw” diets actively steal calcium from the animal.

• Phytate-driven magnesium depletion then blocks vitamin D activation, cascading into apparent “deficiencies” that are really just mineral theft.

Now read a pet nutrition textbook. It will tell you a dog needs a certain mg of zinc per 1,000 kcal. What it won’t tell you is that the number was derived, in practice, by observing dogs eating phytate-laden plant diets and finding how much zinc you have to add back to prevent deficiency symptoms.

The requirement table is a damage report, not a biological constant.

Feed that same dog a raw meaty bones and organs diet - zero grains, zero legumes, zero phytates - and the actual zinc requirement collapses. Not because the dog changed its demand, but because you stopped the diet stealing from it.

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The flip side: Nutrients that only exist in the food we’re told to avoid

For every nutrient whose “requirement” is inflated by plants, there’s another whose deficiency is created by excluding animal ingredients in favour of plant ingredients.

• Taurine is practically absent in plants, but abundant in heart and muscle meat. Dilated cardiomyopathy in pet carnivores is a disease of plant-based or legume-heavy diets, not a mystery deficiency. It is simply not present in the wild where there is a sufficiency of the evolutionary diet.

• Preformed Vitamin A (retinol) - plants provide beta-carotene, which dogs and especially cats cannot convert well to retinol poorly or not at all. Liver is the best source.

• Vitamin D3 is the animal form of vitamin D of which there are multiple forms. Cats cannot use plant D2 effectively.

• Heme iron, K2, DHA/EPA, creatine, carnitine, choline are all essentially animal-only nutrients that are naturally present and bioavailable in a carnivore-appropriate RMB diet and in sufficiency such that when the individual is satiated all other nutrients are naturally present at the correct amount. The idea that tables can calculate this for every nutrient is wishful thinking at best, but usually arrogance to think humans know better and can improve on nature. Dream on!

The “balanced” commercial diet has to synthesize and inject these back in as supplements, because the base ingredients—corn, rice, pea protein, plant oils—contain none of them. The fortification list on a kibble bag is not evidence of balance. It’s an admission of what the raw ingredients lack.

What’s wrong with the textbooks?

The nutrition tables whether NRC, AAFCO, or FEDIAF were not compiled by studying thriving animals fed raw meaty bones and organs. They were compiled from:

1. Purified-diet experiments on lab animals eating synthetic, often plant-based or semi-purified formulations.

2. Practical feeding trials on commercial kibble from the 1950s onward.

3. Extrapolation from human RDAs and rodent data, not from carnivore physiology.

Every single requirement number therefore carries an unstated assumption that the baseline diet is the standard industrial one. The tables are internally consistent within the feeding model within which they have been constructed. They describe how much supplement you must add to a grain-based food to keep a dog from breaking down. They tell you almost nothing about what a raw-fed carnivore actually needs, and there’s no distinction between levels required to survive and levels required the thrive, not that kibble-fed carnivores can ever thrive compared to how they would do on a proper RMB diet.

This is why the “raw diets are nutritionally unbalanced” talking point is so circular. The definition of “balanced” was built around kibble. Measure a raw diet against a table designed for kibble, and of course it looks deficient because you’re grading a steak against a rubric written for corn that includes all the nuances of antinutrients and false requirements I’ve pointed out – created by inappropriate other ingredients. Just because a table says you can nutritionally compensate for what I consider to be an inappropriate ingredient, it doesn’t miraculously make that inappropriate ingredient become appropriate.

The two kinds of “requirement”

Taking a step back to look at the big picture and the whole thing resolves into two clean categories:

Type A — Requirements inflated by plant/antinutrient load: examples of which are

• vitamin C (glucose competition)

• magnesium (phytate binding + glucose-driven loss)

• zinc (phytate binding)

• calcium (oxalate/phytate binding)

• boron (compensating for mineral and hormone dysregulation)

Type B — Nutrients only reliably available in animal tissue: examples of which are

• taurine,

• retinol,

• vitamin D3,

• vitamin K2,

• DHA/EPA,

• heme iron,

• creatine,

• carnitine,

• choline

This insight is uncomfortable for the pet food industry, especially those pushing for vegan diets for carnivores. The “essential nutrient” framework was built by observing animals eating a diet that manufactures its own deficiencies. Change the diet to the proper ancestral species-appropriate diet and the entire requirement table shifts - often dramatically downward.

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The cat Is the most obvious proof

Cats are obligate carnivores meaning their entire physiology with its high protein requirement, taurine dependence, inability to synthesize arginine, poor beta-carotene conversion, and need for preformed D3 is a living refutation of the idea that “complete nutrition” can be engineered from grains and plants.

A cat fed a species-appropriate raw diet of meat, organs, and bone needs essentially no supplementation. A cat fed a grain-and-legume kibble needs a chemical cocktail sprayed on top just to survive. Same animal. Same “requirements.” Radically different outcomes.

The difference isn’t in the cat. It’s in the food and in the textbooks that refuse to acknowledge the distinction.

Summary

There’s a gap between what nutrition tables claim and what carnivore biology actually demands. The requirement was never the animal’s. It was always the diet’s.

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The immediate assumption is usually, “My dog has had a stroke.”

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Introduction

In my previous two articles, I explained how chronic ear infections can become trapped in the middle ear, even after the outer ear appears perfectly healthy. Unfortunately, in a small number of dogs the problem doesn’t stop there.

If the signs are missed or not recognised for what they are and inflammation or infection progresses beyond the m…

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The UK is currently reporting a significant rise in equine influenza (EI) activity, with laboratory-confirmed outbreaks reported across England, Scotland and Wales since late March/April 2026. Current figures from Equine Infectious Disease Surveillance (EIDS) suggest over 50 confirmed outbreaks across …

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Bovine colostrum is the first milk produced after cows calve. As with all baby mammals, it is important that a calf gets plenty of colostrum in the first few hours after birth so that maternal antibodies can cross the gut into the blood before that pathway closes. This protects the calf during its early life whilst its own immune system is developing.

Ho…

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This article is a little different from my usual veterinary ones but relevant to how we treat our animals too. Mainstream clinicians often point the finger at complementary and alternative medicine saying there’s no science behind what we do, whilst the military use exactly the same principles of frequency interaction, only weaponised…

Since the end of W…

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Mainstream veterinary medicine, has a tendency to view the body as a collection of isolated parts that are mostly addressed based on symptoms rather than looking at the root cause. The holistic perspective recognises that the body does not operate in silos. All parts of the body are highly integrated to form a complex syste…

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Our dog and cat carnivores evolved consuming animal‑derived fats, not plant oils.
In the wild, their omega‑3 intake came exclusively from marine and prey tissue, not seeds or leaves. There are 2 primary omega‑3 fatty acids in animal tissue:

1. EPA (eicosapentaenoic acid) and

2. DHA (docosahexaenoic acid)

A plant‑based precursor (ALA, α‑linolenic acid) is virtually absent from animal and fish flesh and even when provided, it is poorly converted to the long‑chain forms, although it has some anti-inflammatory properties itself. Flaxseed which is often quoted as a great source of ALA also comes with cyano-compound anti-nutrients. The amount of flaxseed oil that must be consumed in order to achieve the high enough levels of ALA that can fight cancer means that the cyano-compounds are hepatotoxic. For this reason, the Budwig Diet is not safe. Proponents of it never mention about the cyano-compounds and the liver-damaging after-effects of doing this diet.

In the biologically normal diet of dogs and cats, EPA and DHA are the dominant omega‑3s utilised.

As already mentioned, there is inefficient conversion from ALA but not to the same extent in both species. Dogs have limited Δ6‑desaturase enzyme activity, which is needed to elongate ALA to EPA to DHA, and cats have almost none. This means that cats cannot synthesize DHA endogenously, whilst dogs can convert some ALA to EPA, but far less to DHA (<5%). Hence, dietary DHA (and to a slightly lesser degree EPA) must be supplied preformed from animal or marine sources.

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Natural ratios in prey

Small wild fish, rodents, and birds typically yield an EPA:DHA ratio between 1:1 and 2:1 in their fat stores which is similar to the ratio seen to optimize brain development in mammals. This is one of the contributing factors as to why vegan/vegetarian diets for carnivores will result in a smaller brain.

Many commercial pet foods rely on flaxseed, canola, or soybean oil as a source of omega-3, providing ALA without DHA/EPA, resulting in a functional deficiency even when labelled “omega‑3 enriched”. If the source is plant‑based, it does not translate into DHA enrichment in tissues, and in many cases, the label won’t tell you what the omega-3 source is. Without marine oils (fish, krill, or algal DHA), pets may show normal skin coat but suboptimal neural, retinal, and reproductive health over time.

EPA and DHA both reduce inflammation, but in a different but complementary way. EPA reduces inflammation directly, whereas the more DHA there is present within the cell membrane structure, the more resistant it is to inflammation.

The following table clarifies the distinction between EPA and DHA.

There is also a mechanistic distinction and difference between them both too.

• EPA competes directly with arachidonic acid (AA, omega‑6) for cyclooxygenase (COX) and lipoxygenase (LOX) enzymes, thereby reducing inflammatory eicosanoids like LTB₄ and PGE₂. This results directly in fewer cytokines and less inflammation/swelling.

• DHA doesn’t just suppress inflammation; it resolves. DHA is the precursor for resolvins (D‑series), protectins, and maresins, all of which actively turn off inflammation after the initial response. These mediators signal macrophages to clear debris, inhibit neutrophil infiltration, and stimulate tissue regeneration.

DHA is the “Resolution Molecule”. Its long, kinked 22‑carbon chain integrates into the phospholipid bilayers of neuron membranes and photoreceptors, where it increases membrane fluidity and improves receptor communication. It modulates gene expression for antioxidant enzymes and cytokine suppression, generating neuroprotectin D1, which blocks NF‑κB inflammatory pathways, preserves neuronal structure after oxidative stress, and is crucial for retinal cell survival.

Essentially, EPA quiets inflammation; DHA prevents it from reigniting.

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Why it matters for dogs and cats

EPA and DHA obviously perform important roles in healthy individuals, but even more so when fed processed diets to counter the chronic, low‑grade inflammation the inappropriate ingredients cause that results in oxidative stress which is probably most commonly recognised when arthritis starts.

In feline retinal and canine cognitive tissues, DHA is irreplaceable - there is no possible substitute. Its anti‑inflammatory metabolites are neuro‑inflammatory modulators, so deficiency manifests first as cognitive or retinal degeneration rather than joint pain.

There is an optimal functional ratio (based on mammalian studies and carnivore profiles), which is EPA:DHA ≈ 1 – 2:1.

Too much EPA without DHA suppresses prostaglandin synthesis excessively, impairing membrane-mediated signalling, whereas too much DHA without EPA slows acute inflammation resolution. Together they form a bi-phasic control system.

So, where did omega-3 come from, from an evolutionary perspective?

Many raw feeders will add an omega-3 oil supplement to their dog’s or cat’s diet, but as you might imagine, not oils are equal. How the omega-3 is structured and its oxidation state determines whether it is healing or harmful.

DHA’s value depends not on quantity alone. Its bioavailability is determined by where it sits on the triglyceride backbone and how well it resists oxidation. EPA is less affected by the triglyceride position because there’s usually enough in the plasma to be absorbed and available.

For both humans and our carnivorous pets, these biochemical subtleties determine whether DHA acts as medicine or as molecular junk.

The fish with the most DHA in absolute levels aren’t necessarily the best source because availability depends on where it is placed as part of the triglyceride. Consequently, anchovy, sardine, and mackerel offer the densest DHA per gram of oil, but krill and roe oils provide the most efficiently absorbed DHA per gram consumed.

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Why “sn‑2” placement matters

Few nutritionists I’ve encountered seem to understand that where DHA sits within the triglyceride is important. Every triglyceride is built on a glycerol “spine” with three attachment sites identified as sn‑1, sn‑2, and sn‑3. This means that sn-1 and sn-3 are on the outside with sn-2 between them and effectively shielded.

During digestion, pancreatic lipase removes the outer fatty acids (sn‑1, sn‑3) first, leaving the sn‑2 fatty acid intact which is then efficiently absorbed as a 2‑monoacylglycerol and then transported around the body.

That means only DHA occupying the sn‑2 position is transported seamlessly into neural and retinal membranes. In practice, it is therefore not only the amount of DHA per gram that is important, but also the proportion which is sn-2 DHA.

The fish that have the DHA we source from position the DHA’s according to stability and how it functions within them, so fish often park it on the ends (sn‑1, sn‑3). There is no consideration of the benefit to what is going to eat them!

Dogs and cats absorb and utilize sn‑2 DHA far more effectively than free DHA. The other high yield source structure is phospholipid DHA from krill or roe which delivers higher blood, retinal, and sperm DHA enrichment than generic fish oils.

Oxidation

DHA’s six double bonds make it fragile. Once oxidized, it generates peroxides and aldehydes that cause inflammation rather than heal. Oils are rated according to their Peroxide Value (PV) which indicates liability to form peroxide, and Anisidine Value (AV) which is a measure of the ability for secondary oxidation that creates aldehydes and ketones. The TOTOX figure is the total oxidation ranking that combines PV with AV.

Most commercial “fish oils for pets” never publish these values, and many fall below the efficacy threshold before sale. It is therefore better to feed fresh fish as part of the diet than to supplement unless using a high stability oil as indicated by the table below.

There are natural stabilisers to varying degrees which impact the stability and oxidation oils.

• Astaxanthin found in krill and salmon oils: strongest known carotenoid protector.

• Mixed tocopherols (vitamin E) which provide a good baseline antioxidant effect.

• Avoid synthetic phenolics, especially in cats whose metabolism limitations make natural antioxidants safer.

Cats have limited hepatic glutathione reserves, so oxidised fats accumulate faster. Chronic exposure causes:

• Retinal photoreceptor damage.

• Suppressed appetite (they smell rancidity before you do).

• Hepatic lipidosis and low‑grade inflammation.

Putting all these factors together results in the following hierarchy of DHA sources…

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If you are looking to supplement for whatever reason, then follow the top recommendations above as closely as possible. If you have a choice within a source then you can rank them according to their stability rating based on their PV, AV and/or TOTOX figures.

Store omega-3 oils in the refrigerator. The container should ideally be dark glass, or clear glass in a box and the lid should be airtight to minimise oxidation which will increase as the bottle level gets lower, so don’t buy a bigger bottle just because it looks like it’s better value. There’s no value in giving rancid oil with no omega-3 activity. Avoid oxygenated pump bottles.

Smell the bottle immediately after opening it to detect rancidity. Fresh oils should smell mild, oceanic and slightly sweet. Oxidised, rancid oil will smell sharp, metallic and like paint.

Remember – just because it says “Omega‑3” on a label, it means nothing without structural integrity and oxidation control.

Feeding fresh fish is best, and better than giving a supplement oil. The following two tables will help you calculate the amount of fish to give your dog/cat to ensure they get the right amount of omega-3.

Use the first table and your pet’s body weight to calculate the daily amount of EPA and DHA required. Using this information, check the second table to calculate how much of the fish you’re feeding to give. If you’re using a different fish, then you’ll have to Google the second column figure!

Example: a 10 kg dog ideally gets 500–1000 mg EPA + DHA daily.
A 5 kg cat: 300–400 mg EPA + DHA daily.

These figures provide a therapeutic “whole‑body equilibrium” level - enough to influence membrane composition and resolvin pathways, not just coat health.

As a rule of thumb:

• Dogs on raw diets need 1 g fish oil (≈ 300 mg EPA + DHA) per 10 kg BW ≈ equivalent to ~50–60 g of fatty fish.

• Cats need 20–30 g fish twice weekly or small daily amounts (~5 g/day).

Feeding fish daily in small amounts or larger amounts twice weekly (eg as a fish meal) are nutritionally equivalent for long‑term membrane enrichment, because DHA/EPA integrate and remain in tissues for weeks.

It is more important your pet gets a consistent supply over an extended time for life than a daily bolus.

The sharp-eyed readers may be wondering why we might need to feed these levels when our pets’ ancestors didn’t necessarily get these amounts in their ancestral diet. I think these levels above have been researched and calculated using studies where the study participants were fed a species-inappropriate diet, which we know is fundamentally inflammatory. It is therefore no surprise that recommended omega-3 levels are much higher than our pets’ ancestors would have eaten in many cases, and it doesn’t mean they were deficient either! It is yet further proof that the veterinary profession and nutritionists wilfully ignore the evidence before their eyes that commercial diets are harmful, and yet still they try to put the onus on raw feeders to prove that the RMB diet is safe!

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If a domestic dog or cat is fed a properly constructed raw, species‑appropriate diet (i.e. meat, bone, organ, and absolutely no seed oils or plant matter) then their need for supplemental omega‑3 is dramatically lower than if they were fed on kibble or a “raw” processed diet containing inappropriate ingredients.

It comes down to the omega‑6:omega‑3 ratio, where omega 6 oils are pro-inflammatory.

Although the figures I’ve therefore provided are likely higher than required for many raw feeders, there are legitimate reasons why these higher EPA/DHA levels remain advantageous, even in pure RMB diets:

1. Modern meat sourcing – grain-fed meat is higher in omega‑6 than wild prey; some poultry or pork can exceed 10:1ratios. It should be no surprise that how we rear animals for food impacts their nutritious value for consumers.

2. Lack of whole prey – Most raw feeders omit brain and eyes, removing the natural DHA reservoirs that ancestral individuals would have eaten.

3. Stress/pollution – poor air quality inside and outside in more built-up areas, nnEMFs, and medications all elevate the oxidative load, raising DHA turnover and dietary requirements for both EPA and DHA.

4. Medical conditions – Arthritis, dermatitis, renal disease, cognitive aging all benefit from higher EPA/DHA regardless of baseline diet.

Summary

Omega-3 is often overlooked and taken for granted because we’re told it’s been added or is present. In reality, there’s a good chance that it’s not there at the levels quoted because of oxidation and oil structure.

Sourcing the right omega-3 will help your pet dogs and cats lead a longer and more comfortable life, and maybe you too! What I’ve written here is equally applicable to humans.

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We then go on to talk about how our pets live in the moment and that their transition from physical life to death is not the end, but an opportunity to learn more about our own spirituality, and how to maintain our connection with them in spirit thereafter.

I hope that these discussions will help bring peace to those who find the trauma of losing a dearly loved one overwhelming. It may be a different perspective on this difficult topic than you’ve heard before, but it is only through discussion that we can help people come to terms with what has happened. People often have their own way of coping but even then there may be times when we are hit even harder by the passing of that extra special individual.

Isla’s contact details should you wish to follow and/or contact her are

Website: www.kachinacanine.com

YouTube: https://www.youtube.com/@drislafishburn-kachinacani1312

Instagram: @kachina_canine-wellness

Facebook: https://www.facebook.com/profile.php?id=100002647440378

and https://www.facebook.com/kachinacanine/

The Veterinary Surgeons Act 1966 (VSA) reforms are being framed by the Royal College of Veterinary Surgeons as modernization, and it seems that some proponents of complementary and alternative medicine (CAM) are welcoming the proposals in good faith. I would agree that there does need to be some regulation of CAM in that people can seemingly do a weekend course, get a certificate, and set themselves up as a practitioner all too easily. I regularly see bad advice being posted on social media with no consequences should somebody follow it. It doesn’t help the animals, the owners or those of us who are CAM veterinarians.

The problem is that this trust in the what the RCVS are saying is totally misplaced. There is plenty of evidence already that indicate which direction the RCVS has been and is travelling in respect to CAM, not least the revised statement on CAM they issued in November 2017. For the same people who protested against that to think the RCVS is now intending to embrace CAM with open arms is incredibly naïve in my opinion and flies in the face of all the evidence as I shall set out below.

The subtext to the VSA revision is a regulatory consolidation that could severely restrict CAM within veterinary practice under the guise of “evidence-based reform.”

An analysis of what is proposed, taking into account the RCVS’s consistent stance that CAM lacks evidence-based validity and the effect that the proposed shift from a criminal to a civil standard in disciplinary proceedings, has potentially serious implications for the professional freedom of MsRCVS and paraprofessionals.

Intended changes to the Veterinary Surgeons Act 1966

The VSA reform is set to redefine the structure of veterinary regulation in four broad areas:

1. Creation of a unified veterinary team

The reform seeks to legally recognize the “wider veterinary team” encompassing veterinary nurses, paraprofessionals, and certain non-veterinary specialists. On the face of it, this sounds like the recognition for CAM that CAM practitioners have sought for a long time. Jumping into bed with the RCVS is fraught with danger and once done, it will be far more difficult, if not impossible, to separate away than to get a divorce!

Paraprofessionals will likely be legally required to register with the RCVS under the new framework in order to work with animals in the UK, granting the RCVS control over their scope of practice. The concept of “reserved activities” would replace the original Act’s blanket ban on non-vets treating animals without veterinary permission with defined permissions for specific procedures.

2. Formalization of regulatory powers

The reforms would significantly expand the RCVS’s statutory powers, giving it explicit authority to define what constitutes “veterinary work”, decide which activities may be delegated and by whom, and regulate “fitness to practise” and impose sanctions without needing criminal-level proof. It begs the question as to who decides on the definition of “fitness to practise”, and if the RCVS, how can they determine that in modalities they have no experience in or knowledge of?

3. Reclassification of veterinary misconduct

In terms of taking disciplinary action, the RCVS would move from a criminal (“beyond reasonable doubt”) to a civil standard (“balance of probabilities”) in disciplinary matters which is a much lower threshold of proof which from their perspective would be much easier to prove.

“Failure to adhere to evidence-based principles” could be interpreted as professional misconduct, particularly for those practicing CAM.

4. CAM clarification and restriction

The RCVS continues to maintain that most CAM lacks sufficient evidence of efficacy and has repeatedly issued position statements asserting that only therapies supported by “robust scientific evidence” are acceptable under professional conduct. Given their refusal to accept any scientific evidence in support of homeopathy, probably the most accepted of CAM modalities, it doesn’t bode well for the rest.

The revised Act is likely to codify this stance, empowering the RCVS to restrict or prohibit CAM modalities, demand justification rooted in institutional science rather than clinical outcome or owner consent, and potentially exclude unqualified CAM paraprofessionals from legal practice altogether.

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For MsRCVS who practise CAM

There are a number of implications for vets who practice CAM, with the highest implications for those who use CAM treatment exclusively, although we use both conventional and CAM approaches to assess a patient.

1. Erosion of clinical autonomy

The proposed shift in the disciplinary standard from “beyond reasonable doubt” to “balance of probabilities” means that even minor deviations from orthodox practice could result in disciplinary action.

A vet offering acupuncture, homeopathy, herbs or whatever, even with client consent, could be accused of acting “outside the evidence base” and sanctioned more easily than before.

In effect, clinical judgement may be side-lined by compliance with orthodoxy and guideline/protocol medicine which is largely how medical doctors now work. We only have to see how some excellent doctors such as Dr Sarah Myhill are constantly under threat and attack from the GMC (46 times to date) to see the direction the RCVS would seek to follow. They’re looking to bring the RCVS in line with the GMC regarding on the “balance of probability”, so why wouldn’t they follow the GMC in terms of how they implement it?!

2. De facto suppression of CAM

The ongoing position that CAM is “not evidence-based” essentially predetermines that its practice is non-compliant with professional standards.

The RCVS could use the Act’s expanded authority to redefine “acceptable practice” such that CAM treatments become legally or disciplinarily untenable, thereby functionally banning them without explicitly outlawing them.

Practitioners could face sanctions and/or reputational damage simply for offering integrative options.

3. Administrative overreach

The centralization of authority under the RCVS means that MsRCVS are answerable to a self-policing institution with no external oversight, operating on subjective determinations of what qualifies as “evidence.” The fact that the RCVS knowingly and wilfully puts itself above the law by refusing to recognise the obligation of veterinarians to prescribe CAM in preference to allopathic treatments on organic farms is an indication that the RCVS already engages in administrative overreach.

The proposed VSA reforms place all CAM veterinarians under chronic threat of regulatory intimidation which discourages innovation or individualised medicine. I can envisage a situation where a vet recommends euthanasia over CAM to protect themselves rather than what is best for the patient. That is not acceptable.

4. Insurance

The Veterinary Defence Society (VDS), as the dominant professional indemnity insurer for the UK veterinary profession, already plays a quasi‑regulatory role by shaping what forms of practice it considers “defensible.” Its position closely shadows the RCVS stance on what is deemed “evidence‑based.” So even before the proposed reforms to the VSA, there has already been a kind of soft suppression of CAM through insurance policy and risk‑management mechanisms for a number of years.

The VDS makes it explicitly clear that cover is contingent upon the practitioner acting “in accordance with accepted professional standards” - a phrase it interprets largely by reference to the RCVS Code of Professional Conduct.

When the RCVS states that CAM “lacks sufficient evidence of efficacy,” the VDS follows suit. This means a vet who undertakes CAM therapies does so at their own professional risk unless insured separately to cover their CAM work, although there is nothing to stop other insurers follows the VDS lead which would make it impossible to be insured for CAM. With vet fees so high, insurers will look to whatever means possible to reduce their risk.

Although the VDS is technically a mutual insurer, not a statutory body, its discretionary power over pay-outs has the same regulatory effect as a legal prohibition thereby making it de facto regulation by underwriting. The consequences of disciplinary action for using a CAM therapy, may be that you find yourself uninsured and potentially uninsurable. If you’re uninsured, you can’t lawfully practise. Insurance limitations could effectively establish an economic ban on non‑orthodox approaches.

The VDS has historically raised red flags about:

• Homeopathy, herbalism, and certain forms of acupuncture.

• Chiropractic or osteopathic manipulation performed by untrained individuals.

• Ozone therapy, MMS/ClO₂, and unlicensed nutraceutical regimens without documented justification.

Even therapies such as herbal, phototherapy, nutritional detoxification, etc.) may fall into this “no cover” category if defended purely on clinical experience rather than peer‑reviewed trials, or practitioners may be limited to only using CAM alongside pharmaceuticals which rather negates the reason why most people choose CAM. It also compromises pharma medications that have never been trialled in combination with CAM and potentially creates an adverse reaction as a direct result of the actions of the RCVS. In those situations, the adverse reaction would be blamed entirely on the CAM regardless of what part it actually played.

Under the proposed civil standard the RCVS would be able to discipline a practitioner for CAM practice merely on the likelihood that, in their view, it wasn’t evidence-based. Once sanctioned, the VDS could refuse defence or pay-out because the disciplinary finding itself becomes “proof” of misconduct by civil standard.

The VSA reform and insurance policy to follow suit synergizes to constrict the legal and financial defensibility of CAM practice entirely.

Essentially, after reform, a single adverse finding, even on shaky grounds, could trigger automatic insurance denial, creating career-ending consequences for any MsRCVS who steps outside the orthodoxy.

The implications of this create a feedback loop of conformity and a self-reinforcing system. It’s a form of institutional hegemony by economic leverage, not open scientific dialogue.

Final analysis for MsRCVS

The current situation is that CAM vets already face economic coercion via insurance constraints unless insured by a company that does not adopt the restrictions that the VDS have.

After the reform: the legal and financial levers would become fully synchronised ensuring that only RCVS-approved, pharmaceutical-aligned, “evidence-based” practices remain viable unless there are insurers who are prepared to provide adequate insurance to practice, but no doubt at a premium, and unlikely to cover disciplinary procedures.

What’s presented as raising standards is in reality a bureaucratic filter that privileges institutional consensus over individual clinical experience. It rewards conformity and punishes curiosity - the antithesis of both science and animal welfare.

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For paraprofessionals and lay CAM practitioners

1. Likely exclusion under regulatory capture

Currently tolerated non-vet practitioners such as equine massage therapists, chiropractors, and herbalists could lose their informal right to practise if the RCVS extends its statutory reach unless they embrace the regulatory requirements foisted upon them.

if the RCVS reforms proceed along their current trajectory, RAMP (Register of Animal Musculoskeletal Practitioners) and similar entities (such as AHPR and IRVAP) stand directly in the crosshairs, because they would either be absorbed, subordinated, or co-opted into the RCVS regulatory ecosystem. Bodyworkers who may already have joined and subsequently rejected joining RAMP could be forced to join and pay for the privilege. Those who do bodywork but are not recognised by RAMP and may not be allowed to join would be left out in the cold and unable to practice legally unless their training body go through whatever process would be required to gain acceptance and recognition.

All paraprofessionals would be required to hold registration, pay fees, and conform to RCVS-approved training frameworks - systems designed to ensure compliance with conventional methodology.

2. Economic and structural displacement

Many independent CAM providers, who are often self-employed, could be priced or licensed out of the market altogether.

Corporate and institutionally aligned veterinary groups would gain a monopoly on all therapeutic activity, and potentially even non-invasive ones like hydrotherapy.

3. Legal vulnerability

Once the RCVS controls the definitions of both “evidence-based” and “fit to practise,” paraprofessionals who operate outside that scope — even competently and harmlessly — become liable to prosecution or sanction.

Even anecdotal complaints or differences in clinical approach could be enough to justify sanction if the RCVS believes that CAM lacks objective evidence. This transforms the disciplinary system from protective to punitive, particularly toward those who do not conform to establishment modalities.

Broader implications of the undeclared CAM agenda

The RCVS presents its stance as purely methodological (“protecting the public through evidence-based medicine”), but in practice this would function as an ideological filter whereby only interventions developed or validated within the mainstream scientific-industrial establishment would qualify as authorised.

This aligns closely with the interests of pharmaceutical sponsors, corporate clinics, and academic partners, who have a financial and reputational interest in maintaining mainstream control of veterinary practice.

CAM therapies, being low-margin, often owner-driven, and outside IP protection, pose little commercial benefit to these institutions.

The reform thereby risks codifying institutional bias into law, effectively prohibiting non-industrial, non-pharmaceutical approaches to animal care.

Conclusion

The reforms to the Veterinary Surgeons Act 1966, while publicly justified as modernisation and safety enhancement, carry a powerful undercurrent: the consolidation of regulatory authority in the RCVS and the suppression of medical plurality.

Through embedding “evidence-based” criteria that systematically exclude CAM from legitimacy, introducing the civil burden of proof to discipline practitioners by mere probability, and extending institutional control over paraprofessionals who were previously unregulated, or self-regulated, the reform risks creating a closed veterinary system where innovation, holistic care, and independent thought are subordinated to bureaucratic orthodoxy without clinical freedom.

Veterinarians would cease to be professionals and become mere technicians with diagnostics replaced by AI and vets used solely for animal handling and administering medications.

There is a DEFRA public consultation that I encourage all UK animal owners in favour of CAM to submit their views on the proposed VSA reform to.

https://consult.defra.gov.uk/reform-of-the-veterinary-surgeons-act/consultation/

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Motley and I wish all my Subscribers a very merry Christmas and happy New Year!!

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