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ACADEMIC VETERINARY MEDICINE EDUCATION IN EUROPE

Focus on Laboratory Animal Veterinary Medicine

Aquatic Animal Veterinary Medicine Honeybee Veterinary Medicine One Health interdisciplinary education

Despoina Iatridou

Mapping the implementation of European Union policies in the

European veterinary curricula to uncover elements for

consideration within a policy reform aiming at facilitating One Health

Interdisciplinary

collaboration.

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Academic Veterinary Medicine Education in Europe

Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration

within a policy reform aiming at facilitating One Health Interdisciplinary collaboration

Despoina Iatridou

Supervisors: Prof. Dr. Jimmy Saunders, Prof. Dr. Ana María Bravo Moral

A dissertation submitted to Ghent University in partial fulfilment of the requirements for the degree of Doctor of Veterinary Medicine.

Academic year 2020-2021

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Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

Despoina IATRIDOU

Department of Medical Imaging of Domestic Animal and Small Animal Orthopaedics Faculty of Veterinary Medicine

Ghent University Belgium

No part of this work may be reproduced in any form without permission of the author.

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«Δόξα τῷ Θεῷ μου·

διατελῶ γηράσκουσα δ’ ἀεὶ πολλά διδασκόμενη»

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4

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5 To my husband Vassilis

& my son Athanasios

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6

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TABLE OF CONTENTS

List of abbreviations ... 12

CHAPTER I ... 15

GENERAL INTRODUCTION ... 15

1. Introduction ... 16

2. Regulation of education in the European Union ... 16

3. Regulation of veterinary education and recognition of professional qualifications of veterinarians in the European Union ... 19

4. Quality assurance of education in the European Union ... 25

5. Quality assurance of veterinary education in the Europe ... 26

5.1. European System of Veterinary Training ... 26

5.2. Systems of evaluation of post-graduate veterinary training in Europe ... 28

6. Current challenges for the veterinary profession ... 29

7. References ... 30

CHAPTER II ... 35

SCIENTIFIC AIMS ... 35

References ... 37

CHAPTER III ... 40

TEACHING OF LABORATORY ANIMAL VETERINARY MEDICINE ... 40

1. Abstract ... 41

2. Introduction ... 41

3. Materials and methods ... 41

4. Results ... Error! Bookmark not defined. 5. Discussion ... 50

6. References ... 53

CHAPTER IV ... 57

TEACHING OF AQUATIC ANIMAL VETERINARY MEDICINE ... 57

1. Abstract ... 58

2. Introduction ... 58

3. Materials and methods ... 59

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4. Results ... 59

5. Discussion ... 65

6. References ... 69

CHAPTER V ... 73

TEACHING OF HONEYBEE VETERINARY MEDICINE ... 73

1. Abstract ... 74

2. Introduction ... 74

3. Materials and methods ... 75

4. Results ... 76

5. Discussion ... 80

6. References ... 84

CHAPTER VI ... 89

ONE HEALTH INTERDISCIPLINARY ACADEMIC VETERINARY EDUCATION ... 89

1. Abstract ... 90

2. Introduction ... 90

3. Materials and methods ... 91

4. Results ... 93

5. Discussion ... 101

6. References ... 105

CHAPTER VII ... 109

GENERAL DISCUSSION ... 109

1. Introduction ... 110

2. Major findings ... 111

3. Limitations of the study and future perspectives ... 117

4. General Conclusion ... 117

5. References ... 118

Summary ... 123

Samenvatting ... 127

Curriculum Vitae ... 131

Bibliography ... 133

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Acknowledgements ... 137

Appendices ... 139

Appendix1 ... 140

Appendix 2 ... 140

Appendix 3 ... 140

Appendix 4 ... 141

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List of abbreviations

AVBC: Australasian Veterinary Boards Council 3Rs: Replacement, Reduction, Refinement

CertAVP: Certificate in Advanced Veterinary Practice

COE -AVMA: Council on Education® of the American Veterinary Medical Association CPD: Continuous Professional Development

EAEVE: European Association of Establishments of Veterinary Education EACCME: European Accreditation Council for Continuing Medical Education EBVS: European Board of Veterinary Specialisation

EC: European Community

ECAAH: European College of Aquatic Animal Health ECCVT: European Coordinating Committee

ECEVT: European Credit System for Vocational Education and Training ECLAM: Diplomate of the European College of Laboratory Animal Medicine ECOVE: European Committee on Veterinary Education

ECTS: European Credit Transfer and Accumulation System EFTA: European Free Trade Area

EHEA: European Higher Education Area

ENQA: European Association for Quality Assurance in Higher Education EQAR: European Quality Assurance Register for Higher Education EQF: European Qualifications Framework

ESEVT: European System of Evaluation of Veterinary Training

ESG: Standards and Guidelines for Quality Assurance in the European Higher Education Area ESLAV: European Society of Laboratory Animal Veterinarians

ET: Education and Training EU: European Union

EURATOM: European Atomic Energy Community EUROSTAT: European Statistical Office

Eurydice: Education Information Network in Europe

EVERI: European Veterinarians in Education, Research and Industry FELASA: Federation of European Laboratory Animal Science Associations FVE: Federation of Veterinarians of Europe

HACCP: Hazard Analysis and Critical Control Points

ISVPS: International School of Veterinary Postgraduate Studies LAS: Laboratory Animal Science

LASM: Laboratory Animal Science and Medicine LAVA: Laboratory Animal Veterinary Association MUMS: Minor Uses and Minor Species of animals OIE: World Organization for Animal Health PQD: Professional Qualifications Directive QA: Quality Assurance

SAVC: South African Veterinary Council SOP: Standard Operational Process

UEVP: Union of European Veterinary Practitioners

UNESCO: United Nations Educational, Scientific and Cultural Organization UK: United Kingdom

VEE(s): Veterinary Education Establishment(s) VET: Vocational Education and Training

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 13

VetCEE: Veterinary Continuous Education in Europe WAVMA: World Aquatic Veterinary Medical Association WHO: World Health Organization

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CHAPTER I

1

GENERAL INTRODUCTION

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

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CHAPTER I: General Introduction

16 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

1. Introduction

21

This dissertation investigates whether there is a need for a policy reform of the legislative 22

requirements used for the automatic recognition of veterinary diplomas and competences in the 23

European Union (EU). The research starts by screening the EU legislation relevant to undergraduate 24

and postgraduate veterinary education. Each veterinary education establishment (VEE) in EU and the 25

European Free Trade Area (EFTA) must implement and follow the requirements laid down in these 26

pieces of legislation to develop a curriculum that leads to a diploma in veterinary medicine, which is 27

automatically recognised in all Member States of the European Union.

28

This chapter presents an overview of the governance of the undergraduate and postgraduate 29

education and veterinary education in the European Union and the European Free Trade Area. It also 30

indicates some trends and challenges that the veterinary profession faces today and for which 31

veterinary students must be prepared during their studies. Figure 1 depicts in short what are the 32

issues that veterinary education establishments should minimum consider, and which are analysed 33

further below.

34

35

Figure 1: Factors to be considered by each veterinary education establishment in preparation of the 36

curricula and overall veterinary training.

37 38

2. Regulation of education in the European Union

39

EU treaties set out the EU objectives, the rules for the EU institutions, how decisions are made and 40

the relationship between the EU and its member countries. Under the Treaty of Lisbon (last EU 41

Treaty signed 13 December 2007)1, education is a policy area where the Union supports, 42

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 17

complements or supplements the actions of the Member States (Article 6, Treaty on the Functioning 43

of the European Union (TFEU)), but does not foresee harmonisation of national laws and regulations 44

(Articles 165 and 166, TFEU). Each Member State assumes full responsibility for the organisation of 45

its education and vocational training systems and the content of its teaching. Education falls under 46

the subsidiarity principle2,3. No binding legal act, such as an EU Regulation*, an EU Directive or an EU 47

Decision applies for educational matters.

48

Eurydice database of the EU presents a detailed overview of national education systems at all 49

levels4. Eurydice includes information as provided by 42 national units based in the 38 countries 50

participating in the Erasmus+ programme, namely the 27 EU Member States plus Albania, Bosnia 51

and Herzegovina, the Republic of North Macedonia, Iceland, Liechtenstein, Montenegro, Norway, 52

Serbia, Switzerland, Turkey and the United Kingdom. Information includes descriptions of the 53

organisation of the national educational systems on 14 chapters, as following:

54

1. Political, Social and Economic Background and Trends 55

2. Organisation and Governance 56

3. Funding in Education 57

4. Early Childhood Education and Care 58

5. Primary Education 59

6. Secondary and post-Secondary non-Tertiary Education 60

7. Higher Education 61

8. Adult Education and Training 62

9. Teachers and Education Staff 63

10. Management and Other Education Staff 64

11. Quality Assurance 65

12. Educational Support and Guidance 66

13. Mobility and Internationalisation 67

14. Ongoing Reforms and Policy Developments 68

Nevertheless, recognition of competences achieved over completion of education is not automatic 69

among the EU countries. Mutual recognition processes of upper secondary qualifications and 70

learning outcomes, especially for study periods abroad, are underdeveloped. Holders of such 71

qualifications giving access to higher education in one Member State often lack certainty about 72

access to higher education in another Member State. Only the European Baccalaureate gives the 73

same rights and benefits to its holders and access to all higher edication institution in all EU 74

countries5. 75

Tools for recognition of qualifications are more developed in higher education, but even then 76

recognition procedures are in many cases much complicated, expensive and time-consuming 4,6. 77

Only few groups of Member States, e.g. BENELUX, Nordic countries, Baltic countries, as well as 78

mutual agreement between Italy and Austria, have stated since 2018 to implement automatic 79

recognition for all higher education diplomas4. 80

While the responsibility for education and training systems lies within the individual Member States, 81

EU has set a number of tools to support Member States to develop their national education systems 82

* A "Regulation" is a binding legislative act. It must be applied in its entirety across the EU.

A "Directive" is a legislative act that sets out a goal that all EU countries must achieve. However, it is up to the individual countries to devise their own laws on how to reach these goals.

A "Decision" is binding on those to whom it is addressed (e.g. an EU country or an individual company) and is directly applicable.

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CHAPTER I: General Introduction

18 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

in line with the vision for a European Education Area, where qualifications are recognised across the 83

EU, where learning, studying and doing research would not be hampered by borders7,8 anchored to 84

transparency and integrity in and through education and research9,10,11,12. These tools provide 85

support through policy guidance [European Policy Cooperation (ET 2020 framework)]13. 86

Harmonisation of education of future professionals is fundamental and should encompass both an 87

updated list of day one competences as well as 14, funding [Erasmus+ programme15; European 88

Structural and Investment Funds]16 and yearly evaluation of education and training systems across 89

Europe [The Education and Training monitor]17. 90

Regarding higher education, EU works towards a European Higher Education Area (EHEA)18, which 91

encompass the political will of over 50 countries. Countries of EHEA agree on the adoption of a more 92

harmonised approach through the application of structural reforms on higher education and the 93

implementation of quality assurance with a view to facilitate recognition of competences and free 94

movement of university educated students, professionals, researchers or academics in EU and 95

beyond. The first step towards a EHEA was made by signing the Convention on the Recognition of 96

Qualifications concerning Higher Education in the European Region developed by the Council of 97

Europe and the United Nations Educational, Scientific and Cultural Organization (UNESCO) [Lisbon 98

Recognition Convention]19 in 1997 followed by the agreement on the establishment of an 99

intergovernmental higher education reform process in 199820, the so-called Bologna declaration21. 100

Bologna process aims at facilitating recognition of degrees, periods of study and professional 101

qualifications by proposing a 3-cycle system of study (bachelor/master/doctorate) and strengthening 102

quality assurance 21. 103

The Lisbon Recognition Convention19 and its subsidiary texts22,23,24 had been the only legal 104

framework for the recognition of higher education until the adoption of the Council 105

Recommendation (2018/C 444/01) on 26 November 201825, when EU Member States made a 106

political commitment to introduce automatic recognition of diplomas and qualifications by 2025 in 107

the European Education Area. Council recommendations25 investigate fostering transparency and 108

building trust within the EHEA by linking national qualification systems with the European 109

Qualifications Framework (EQF)26; by organising higher education systems in line with the Bologna 110

process21; and by implementing external QA in compliance with the Standards and Guidelines for 111

Quality Assurance in the European Higher Education Area (ESG)27. This commitment was reiterated 112

during the Rome Ministerial Conference in November 2020 aiming at building an inclusive, 113

innovative, and interconnected EHEA by 2030 based on transparency and integrity in education and 114

research9,10,11,12. 115

Additionally, EU promotes life-long learning in the European Education Area and works towards the 116

establishment of a European Credit System for Vocational Education and Training (ECEVT)28 to 117

facilitate the transfer, recognition, and accumulation of assessed learning outcomes of individuals 118

who are aiming to achieve a qualification. The recommendation of the European Parliament and the 119

European Council of 18 June 200929 promotes ECVET to facilitate transnational mobility and the 120

recognition of learning outcomes in vocational education and training (VET) as well as borderless 121

lifelong learning.

122

Currently, EU provides several tools to help Member States with the recognition of qualifications and 123

learning outcomes achieved abroad, such as the Europass30, the European Qualifications 124

Framework26, the European Credit Transfer and Accumulation System (ECTS§)31, the Diploma 125

§ One ECTS is overall considered the teaching time equivalent to 25 to 30 hours.

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 19

Supplement32 and the European Credit System for Vocational Education and Training (ECEVT)28, 126

among others.

127

However, despite the political calls19,33,34 for promoting cooperation of Member States on mutual 128

recognition of higher education and upper secondary education diplomas, and the support by the 129

European Commission, so far progress on automatic recognition of diplomas and qualifications 130

continues to be slow or non-existent5. 131

132

3. Regulation of veterinary education and recognition of professional qualifications of

133

veterinarians in the European Union

134

While Council Recommendation 2018/C 444/0125 promotes automatic mutual recognition of higher 135

education to facilitate recognition of competences and qualifications in the European Education 136

Area, it clearly states that this is without prejudice to the system for mutual recognition of 137

professional qualifications and harmonised minimum training requirements for several professions 138

pursuant to Directive 2005/36/EC of the European Parliament and the Council35 as amended by 139

Directive 2013/55/EU of the European Parliament and of the Council36, the so called “Professional 140

Qualifications Directive or PQD”.

141

Directive 2005/36/EC has been established in line with Article 47 of the Treaty laying down that 142

directives shall be issued for the mutual recognition of diplomas, certificates, and other evidence of 143

formal qualifications. It provides a general system for the recognition of training and automatic 144

recognition of professional experience for a limited number of professions (sectoral professions), 145

based on harmonised minimum training requirements. Sectoral professions that benefit from an 146

automatic recognition of their diplomas and qualifications through the EU are architects, dental 147

practitioners, doctors, midwifes, nurses responsible for general care, pharmacists, and veterinary 148

surgeons. These are the so-called regulated professions in EU, for which the legislators clearly 149

envisage specific provisions as public health or safety of the EU citizens directly rely on their 150

professional competences.

151

With regard to the veterinary profession, automatic recognition of diplomas, and consequently of 152

competence to practice as veterinary surgeon, relies on the recognition of any of the veterinary 153

qualifications listed in Annex V, point 5.4.2 of the Directive 2005/36/EC[Table1].

154

Directive 2005/36/EC Annex V, 5.4.2

Evidence of formal qualifications of veterinary surgeons

Country Evidence of formal

qualifications Body awarding the evidence of

qualifications Certificate

accompanying the evidence of qualifications

Reference date

België/Belgique/Belgien Diploma van dierenarts/Diplôme de docteur en médecine vétérinaire

— De universiteiten/Les universités

— De bevoegde Examen- commissie van de Vlaamse Gemeenschap/Le Jury compétent d'enseignement de la Communauté française

21 December 1980

Česká republika — Diplom o ukončení studia ve studijním programu veterinární lékařství (doktor veterinární medicíny, MVDr.)

Veterinární fakulta univerzity v

České republice 1 May 2004

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CHAPTER I: General Introduction

20 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

— Diplom o ukončení studia ve studijním programu veterinární hygiena a ekologie (doktor veterinární medicíny, MVDr.)

Danmark Bevis for bestået

kandidateksamen i veterinærvidenskab

Kongelige Veterinær- og

Landbohøjskole 21 December 1980

Deutschland Zeugnis über das Ergebnis des Dritten Abscnitts der Tierärztlichen Prüfung und das Gesamtergebnis der Tierärztlichen Prüfung

Der Vorsitzende des Prüfungsausschusses für die Tierärztliche Prüfung einer Universität oder Hochschule

21 December 1980

Eesti Diplom: täitnud

veterinaarmeditsiini õppekava

Eesti Põllumajandusülikool 1 May 2004

Ελλάς Πτυχίo Κτηvιατρικής Πανεπιστήμιο Θεσσαλονίκης και

Θεσσαλίας 1 January 1981

España Título de Licenciado en

Veterinaria — Ministerio de Educación y Cultura

— El rector de una universidad

1 January 1986

France Diplôme d'Etat de docteur

vétérinaire 21 December 1980

Ireland — Diploma of Bachelor in/of Veterinary Medicine (MVB)

— Diploma of Membership of the Royal College of Veterinary Surgeons (MRCVS)

21 December 1980

Italia Diploma di laurea in medicina

veterinaria Università Diploma di abilitazione

all'esercizio della medicina veterinaria

1 January 1985

Κύπρος Πιστοποιητικό Εγγραφής

Kτηνιάτρου Κτηνιατρικό Συμβούλιο 1 May 2004

Latvija Veterinārārsta diploms Latvijas Lauksaimniecības

Universitāte 1 May 2004

Lietuva Aukštojo mokslo diplomas (veterinarijos gydytojo (DVM))

Lietuvos Veterinarijos Akademija 1 May 2004

Luxembourg Diplôme d'Etat de docteur en

médecine vétérinaire Jury d'examen d'Etat 21 December 1980

Magyarország Állatorvos doktor oklevél —

dr. med. vet. Szent István Egyetem Állatorvos-

tudományi Kar 1 May 2004

Malta Liċenzja ta' Kirurgu

Veterinarju Kunsill tal-Kirurġi Veterinarji 1 May 2004

Nederland Getuigschrift van met goed gevolg afgelegd

diergeneeskundig/veeartse- nijkundig examen

21 December 1980

Österreich — Diplom-Tierarzt

— Magister medicinae veterinariae

Universität — Doktor der

Veterinärmedizin

— Doctor medicinae veterinariae

— Fachtierarzt

1 January 1994

Polska Dyplom lekarza weterynarii 1. Szkoła Główna Gospodarstwa Wiejskiego w Warszawie 2. Akademia Rolnicza we

Wrocławiu

3. Akademia Rolnicza w Lublinie 4. Uniwersytet Warmińsko-

Mazurski w Olsztynie

1 May 2004

Portugal Carta de curso de licenciatura

em medicina veterinária Universidade 1 January 1986

Slovenija Diploma, s katero se podeljuje strokovni naslov ‘doktor veterinarske

Univerza Spričevalo o

opravljenem državnem 1 May 2004

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 21

medicine/doktorica

veterinarske medicine’ izpitu s področja

veterinarstva Slovensko Vysokoškolský diplom o

udelení akademického titulu

‘doktor veterinárskej medicíny’ (‘MVDr.’)

Univerzita veterinárskeho

lekárstva 1 May 2004

Suomi/ Finland Eläinlääketieteen lisensiaatin tutkinto/Veterinärmedicine licentiatexamen

Helsingin yliopisto/Helsingfors

universitet 1 January 1994

Sverige Veterinärexamen Sveriges Lantbruksuniversitet 1 January 1994

United Kingdom 1. Bachelor of Veterinary

Science (BVSc) 1. University of Bristol 21 December 1980

2. Bachelor of Veterinary

Science (BVSc) 2. University of Liverpool 3. Bachelor of Veterinary

Medicine (BvetMB) 3. University of Cambridge 4. Bachelor of Veterinary

Medicine and Surgery (BVM&S)

4. University of Edinburgh

5. Bachelor of Veterinary Medicine and Surgery (BVM&S)

5. University of Glasgow

6. Bachelor of Veterinary

Medicine (BvetMed) 6. University of London

TABLE 1. Annex V, point 5.4.2 of the Directive 2005/36/EC 155

All these qualifications meet the basic criteria for automatic recognition, namely an at least 5- years 156

full-time theoretical and practical training (article 38.1 of the Directive 2013/55/EU) including the 157

coverage of the subjects listed in Annex V, point 5.4.1 [Table 2] of the Directive 2005/36/EC as well 158

of the competences and skills laid down in Article 38.3 of the Directive 2013/55/EU, namely:

159

(a) adequate knowledge of the sciences on which the activities of a veterinary surgeon are based and 160

of the Union law relating to those activities;

161

(b) adequate knowledge of the structure, functions, behaviour and physiological needs of animals, as 162

well as the skills and competences needed for their husbandry, feeding, welfare, reproduction and 163

hygiene in general;

164

(c) the clinical, epidemiological and analytical skills and competences required for the prevention, 165

diagnosis and treatment of the diseases of animals, including anaesthesia, aseptic surgery and 166

painless death, whether considered individually or in groups, including specific knowledge of the 167

diseases which may be transmitted to humans;

168

(d) adequate knowledge, skills and competences for preventive medicine, including competences 169

relating to inquiries and certification;

170

(e) adequate knowledge of the hygiene and technology involved in the production, manufacture and 171

putting into circulation of animal feedstuffs or foodstuffs of animal origin intended for human 172

consumption, including the skills and competences required to understand and explain good practice 173

in this regard;

174

(f) the knowledge, skills and competences required for the responsible and sensible use of veterinary 175

medicinal products, in order to treat the animals and to ensure the safety of the food chain and the 176

protection of the environment.’

177 178 179

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CHAPTER I: General Introduction

22 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

Directive 2005/36/EC Annex V, 5.4.1

Study programme for veterinary surgeons

The programme of studies leading to the evidence of formal qualifications in veterinary medicine shall include at least the subjects listed below.

Instruction in one or more of these subjects may be given as part of, or in association with, other courses.

A. Basic subjects Physics Chemistry Animal biology Plant biology Biomathematics B. Specific subjects

a. Basic sciences:

Anatomy (including histology and embryology) Physiology

Biochemistry Genetics Pharmacology Pharmacy Toxicology Microbiology Immunology Epidemiology Professional ethics b. Clinical sciences:

Obstetrics

Pathology (including pathological anatomy) Parasitology

Clinical medicine and surgery (including anaesthetics)

Clinical lectures on the various domestic animals, poultry and other animal species Preventive medicine

Radiology

Reproduction and reproductive disorders Veterinary state medicine and public health Veterinary legislation and forensic medicine Therapeutics

Propaedeutics c. Animal production

Animal production Animal nutrition Agronomy Rural economics Animal husbandry Veterinary hygiene

Animal ethology and protection d. Food hygiene

Inspection and control of animal foodstuffs or foodstuffs of animal origin Food hygiene and technology

Practical work (including practical work in places where slaughtering and processing of foodstuffs takes place) Practical training may be in the form of a training period, provided that such training is full-time and under the direct control of the competent authority, and does not exceed six months within the aggregate training period of five years study.

The distribution of the theoretical and practical training among the various groups of subjects shall be balanced and coordinated in such a way that the knowledge and experience may be acquired in a manner which will enable veterinary surgeons to perform all their duties.

TABLE 2. Annex V, point 5.4.1 of the Directive 2005/36/EC 180

Veterinarians holding any degree of the ones included in Annex 5.4.2 (Table 1) are automatically 181

qualified for their registration to the competent authority or veterinary statutory body in any 182

country of EU and EFTA, and may ask for a license to practice in the country.

183

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 23

184

Figure2: Factor influencing vision and mission of veterinary education establishments in EU.

185

The veterinary statutory body in each Member State or, in the case of absence of a veterinary 186

statutory body, the respective competent authority, e.g. a Ministry, supervises the quality of the 187

competence of the veterinarians practicing in the country, and is responsible for their license and 188

registration.

189

Directive 2005/36/EC of the European Parliament and the Council35 as amended by Directive 190

2013/55/EU36 calls also on Member States to encourage, in particular, continuous professional 191

development for doctors of medicine, medical specialists, general practitioners, nurses responsible 192

for general care, dental practitioners, specialised dental practitioners, veterinary surgeons, 193

midwives, pharmacists and architects. It considers particularly important that those professionals 194

can update their knowledge, skills and competences in order to maintain a safe and effective 195

practice and keep abreast of professional developments, although no harmonisation is foreseen in 196

this area.

197

Over the years, more references to the specific competences of the veterinarians and their 198

responsibilities have been included in different pieces of EU legislation, such as the Animal Health 199

Law37, the regulation on veterinary medicinal products38 and on medicated feed39, the official 200

controls40, the directive on protection of animals used for scientific purposes41 and the Directive on 201

radioprotection42. 202

Regulation (EU) 2016/429 of the European Parliament and of the Council of 9 March 2016 on 203

transmissible animal diseases and amending and repealing certain acts in the area of animal health 204

(‘Animal Health Law’)37 recognises that veterinarians play a crucial role in all aspects of animal health 205

management by having the necessary knowledge, skills and competencies to diagnose diseases, to 206

treat animals, to inform about prevention and to raise overall awareness about animal health, 207

animal welfare and public health. Additionally, article 12.3 highlights the need for continuous 208

professional development, by calling on veterinarians to maintain and develop their professional 209

capabilities related to their areas of activities which fall within the scope of this Regulation.

210

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CHAPTER I: General Introduction

24 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

Regulation (EU) 2019/6 of the European Parliament and of the Council of 11 December 2018 on 211

veterinary medicinal products38 as well as Regulation 2019/4 on the manufacture, placing on the 212

market and use of medicated feed39, consider the veterinarian as the gatekeeper of health and 213

welfare of all animal species without any exemption. Both pieces of law highlight veterinarian’s role 214

and obligations about prescription of veterinary medicines; responsible use of medicines – especially 215

of antimicrobials; retail and use of veterinary medicinal products within EU; prescription and use of 216

medicines off-label; reporting of adverse events in animals and people; and determination of 217

withdrawal periods.

218

Regulation (EU) 2017/625 of the European Parliament and of the Council of 15 March 2017 on 219

official controls40, together with Regulation (EC) No852/2004of the European Parliament and of the 220

Council of 29 April 2004 on the hygiene of foodstuffs43 and Regulation (EC) No 853/2004 of the 221

European Parliament and of the Council of 29 April 2004 laying down specific hygiene rules for food 222

of animal origin44, also highlight competences and responsibilities for the EU veterinarians working 223

as hygienists or official veterinarians, that is to say veterinarians appointed by a competent 224

authority, either as staff or otherwise. Official veterinarians should be appropriately qualified to 225

perform official controls in relation to products of animal origin intended for human consumption in 226

slaughterhouses, game-handling establishments and border control posts. These controls include a 227

long list of important activities, such as: ante-mortem inspection and post-mortem inspection in 228

slaughterhouses; verification of the compliance of meat and meat products with hygiene 229

requirements, determination of the maximum residue limits or presence of contaminants in 230

products of animal origin; audit of the implementation of good hygiene practices and procedures 231

based on HACCP principles (Hazard Analysis and Critical Control Points) while processing animals for 232

human consumption as well as of the handling and disposal of animal by-products and of specified 233

risk materials; verification of the compliance with the requirements for laboratory testing as well as 234

health and welfare of the animals. Additionally, official veterinarians are responsible for the 235

supervision of official auxiliaries and remain responsible for the decisions taken during the official 236

controls.

237

Overview of the pieces of legislation of the European Union relevant to the veterinary profession

• Directive 2005/36/ EC (PQD), 5 years of education / Annex 5.4.1

• Regulation (EU) 2017/625 (on Official Controls)

• Regulation (EC) No852/2004 (on the hygiene of foodstuffs)

• Regulation (EC) No 853/2004 (specific hygiene rules for food of animal origin)

• Directive (EU) 2010/63 (on protection of animals used for scientific purposes)

• Regulation (EU) 2016/429 (on transmissible animal diseases and amending and repealing certain acts in the area of animal health);

• Regulation (EU) 2019/6 (on veterinary medicinal products); and

• Regulation (EU) 2019/4 (on the manufacture, placing on the market and use of medicated feed)

• Council Directive 2013/59/Euratom (basic safety standards for protection against the dangers arising from exposure to ionising radiation

TABLE 3: Veterinary legislation 238

Directive 2010/63/EU41 of the European Parliament and of the Council of 22 September 2010 239

establishes measures for the protection of animals used for scientific or educational purposes. It 240

recognises the need to ensure the ongoing monitoring of the welfare of those animals by providing 241

appropriate veterinary care available at any times. It also puts particular emphasis on the 3Rs 242

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 25

principle, namely the Replacement and Reduction of the use of animals in procedures and the 243

Refinement of the breeding, accommodation, care and use of these animals. The legislator foresees, 244

particularly, that each breeder, supplier, and user shall have a “designated veterinarian” charged 245

with advisory duties in relation to the well-being and treatment of the animals.

246

Whereas the EU legislative framework described above lays down the requirements, competences, 247

and responsibilities of qualified veterinarians in EU, there are some other policies and 248

recommendations which are relevant to the veterinary and other professions. The Council Directive 249

2013/59/Euratom of 5 December 2013, which lays down basic safety standards for protection 250

against the dangers arising from exposure to ionising radiation, is such an example as it applies 251

equally on both medical and veterinary practices. Besides this, current challenges, such as 252

antimicrobial resistance, climate change, natural or mankind disasters, digitalisation, telemedicine, 253

and implementation of new technologies are important elements that would similarly impact 254

veterinary and medical practice. Many EU and global policy recommendations already address these 255

novel needs and call for action, such as the EU One Health Action Plan against Antimicrobial 256

Resistance45, Recommendations of the World Animal Organisation (OIE) at the 4th OIE Congress on 257

Veterinary Education46, tripartite policy recommendations and many others47. These are elements 258

that must be considered when building upon future veterinary curricula, concept of teaching, and 259

learning outcomes.

260

Further to the undergraduate education, the EU Law36 calls for continuous professional development 261

of the professionals who benefit from the automatic recognition of their professional qualifications, 262

such as veterinarians. Legislators acknowledge the importance of lifelong learning to ensure safe and 263

effective practice and requests Member States to make such opportunities available for 264

veterinarians as well as to share them with the Commission and other Member States. This 265

recommendation is also in line with the Code of Conduct and Veterinary Act48 for the European 266

veterinarians, which lays down that veterinarians should update their knowledge, skills and 267

competences in order to maintain a safe and effective practice and keep abreast of professional 268

developments.

269 270

4. Quality assurance of education in the European Union

271

Quality assurance (QA) is one of the cornerstones of improving transparency and building trust in 272

the European Higher Education Area (EHEA). In most European countries, higher education 273

institutions or study programmes are submitted to regular external review by a QA agency. QA 274

ensures that students have achieved the same minimum learning outcomes and competences, when 275

graduating from different establishments adhered to the same set of policies and processes. It 276

promotes a harmonised approach in education and training, thus being of great importance for 277

mutual recognition of each other’s educational systems. That is why QA is highlighted as a 278

fundamental element within the Bologna process21, ET 202013,14, Council Recommendation (2018/C 279

444/01) on 26 November 201825 for recognition of qualifications and facilitating mobility of students, 280

professionals, academics, and researchers in EHEA as well as in the last EHEA Rome Ministerial 281

Communication9. 282

QA in higher education is promoted by the European Association for Quality Assurance in Higher 283

Education (ENQA)49 across all the Bologna Process signatory countries. ENQA together with other 284

stakeholders in European academia have proposed the “Standards and Guidelines for Quality 285

Assurance in the European Higher Education Area (ESG)”, which have been adopted by the Ministers 286

responsible for higher education and updated in 201527. The ESG 2015 provides guidance, covering 287

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CHAPTER I: General Introduction

26 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

the areas which are vital for the successful quality provision and learning environments in higher 288

education.

289

ESG together with EQF26, ECTS31 and Diploma Supplement32 are tools assisting higher education 290

establishments to increase transparency and to build mutual trust in EHEA. The ESG 2015 is also the 291

basis for the external assessment of national or international QA agencies in the EHEA, which aim to 292

become accredited by ENQA and placed or maintained on the list of ENQA members50 and on the 293

European Quality Assurance Register for Higher Education (EQAR)51. In addition, a Database of 294

External Quality Assurance Results (DEQAR) is being developed looking to enhance access to reports 295

and decisions on higher education institutions/programmes externally reviewed against the ESG, by 296

an EQAR-registered agency52. 297

298

5. Quality assurance of veterinary education in the Europe

299

5.1. European System of Veterinary Training

300

Although quality assurance is nationally implemented in different European countries, a study on the 301

transposition of the Professional Qualifications Directive conducted on behalf of the Commission in 302

2009 clearly indicated that “the Member States lack trust in each other’s educational systems and it 303

is important to establish this trust if the Directive (2005/36/EC) is to work properly”53. The veterinary 304

profession has shown unique responsibility and has established the European System of Evaluation 305

of Veterinary Training (ESEVT)54, which has been running successfully since 1985. The veterinary 306

academia in Europe represented by the European Association of Establishments for Veterinary 307

Education (EAEVE)**, 55, together with the whole veterinary profession in Europe represented by the 308

Federation of Veterinarians of Europe (FVE)††,56, have created this professional peer evaluation 309

system for veterinary education establishments. Veterinary education establishments participating 310

in this system are evaluated against a set of standards by a team of experts that visit each 311

establishment and prepare a report to be reviewed by the European Committee of Veterinary 312

Education (ECOVE)57, which is the decision body of ESEVT. The establishments that meet the 313

requirements of the Standard Operating Procedure of ESEVT get to the status of ‘‘approval’’ or 314

‘‘accreditation.’’‡‡

315

ESEVT was initially focused on the professional requirements for veterinary surgeons laid down in 316

Professional Qualifications Directive and aimed to ensure that veterinary education establishments 317

help all their students to effectively acquire the minimum learning outcomes and competences 318

required by the EU legislation. Currently, this system the appropriate tool for providing the minimum 319

standard regarding veterinary training. ESEVT Standard Operating Procedure58 is set up based among 320

others on the minimum requirements set in both the European Directives35,36 and the list of 321

**Members of EAEVE are veterinary education establishments that commit to its mission and vision for veterinary education in Europe and are evaluated by the European System of Evaluation of Veterinary Training.

††Members of FVE are national veterinary associations and/or national veterinary chambers in European countries. FVE also embraces four Sections each one of which represents a vital part of the profession, namely the Union of European Veterinary Practitioners (UEVP); the European Association of Veterinary State Officers (EASVO); the Union of European Veterinary Hygienists (UEVH); and the European Veterinarians in Education Research and Industry (EVERI).

‡‡“Approved” or “Non-approved” are the veterinary education establishments that have been assessed under the Stage 1 of the “Budapest Standard Operating Procedure 2012” of the European System of Evaluation of Veterinary Training (ESEVT). “Accredited” or “Non-accredited” are those veterinary education establishments that have been assessed against Stage I&II of the “Budapest Standard Operating Procedure of 2012” or any following update of the SOP, i.e. the “Standard Operating Procedure 2016” or the current “Standard Operating Procedure 2019”, of the ESEVT.

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 27

subjects35 and Day One Competences59. It therefore encompasses several other than only Annex V 322

requirements to ensure up-to-date training of veterinary students and competence of all graduate 323

veterinarians to take up entry roles in different areas of the veterinary profession. That way the 324

academia and the veterinary profession work together towards providing assurance to the public 325

and strengthening their trust in the quality of graduate veterinary surgeons and the services they 326

deliver.

327

Over the years, more references to veterinary competences and responsibilities have come on the 328

different pieces of the EU legislation. At the same time, veterinary education establishments have 329

been also part of the European Higher Education Area and had to follow the Bologna Process and 330

general provisions for all higher-education institutions in this area. This raised the need for 331

incorporating the implementation of quality assurance within the ESEVT processes as well.

332

EAEVE together with FVE have been following closely all those developments and presented a more 333

holistic list of Day One Competences for veterinarians59. Prevention and biosecurity; examination;

334

early detection of diseases by carrying out proper diagnosis and differential diagnosis to rule out or 335

confirm a disease; prescription and implementation of the right treatment; raising awareness of 336

resistance to treatments, including antimicrobial resistance, and its implications; food inspection;

337

One Health approach; and 3Rs principle are now considered as core competences59 that all graduate 338

veterinarians should have acquired by the time of their graduation and must be able to apply in the 339

different domestic species, including minor uses and minor species of animals (MUMS). Further to 340

this, quality assurance has been fully incorporated in the ESEVT Standard Operating Procedures and 341

EAEVE sought external accreditation by ENQA.

342

In 2018, EAEVE passes successfully the ENQA assessment and became the first European-wide 343

profession-specific accreditation body accredited by ENQA, gaining more international recognition.

344

Even though the ESEVT is not legally binding, the number of veterinary education establishments 345

that strive to meet the requirements and ask for the EAEVE-FVE evaluation increases year by year.

346

This is representative of the wide acceptance of ESEVT by the European community of the veterinary 347

education establishments. Similarly, the number of approved and accredited veterinary education 348

establishments in and beyond the EU is steadily increasing. EAEVE has now 83 full-members, 18 349

candidate members and 4 associate-members60,61. 350

EAEVE and FVE have been pioneers in the implementation of profession-specific Europe-wide quality 351

assurance within the European Higher Education Area by running the European System of Evaluation 352

of Veterinary Training from 1985 to date. Hence, ESEVT contributes to the transparency and trust to 353

the veterinary education systems across EU and beyond62. Currently, EAEVE and the Council on 354

Education® (COE) of the American Veterinary Medical Association (AVMA)63 are the bigger 355

accreditation institutions for veterinary training in the world. Many veterinary education 356

establishments, both in Europe and globally ask for accreditation by both bodies in order to enlarge 357

potentials in the global market for their graduates. In the European Union, seven veterinary 358

education establishments are currently accredited by both EAEVE and COE-AVMA and three of them 359

are also accredited by the Australasian Veterinary Boards Council (AVBC)64 as well. Table 4 presents 360

an overview of the existing systems of accreditation of veterinary training globally along with the 361

requirements for recognition of veterinary diplomas and licensing of veterinarians in the different 362

parts of the world.

363 364 365

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CHAPTER I: General Introduction

28 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

EU and EFTA US & Canada Oceania South Africa Duration of studies 5-7 years 7-9 years 5-7 years 7 years Veterinary-specific

Accreditation

Voluntary Obligatory

for licensing

Obligatory for licensing

No

Accrediting body EAEVE, Royal College of Veterinary

Surgeons (RCVS)65

COE - AVMA AVBC -

Recognition of diplomas

Automatic recognition of diplomas as set down in EU legislation Annex 5.4.2 of Dir 2005/36

COE - AVMA AVBC According to Veterinary and Para- Veterinary Professions Act, Act 19 of 1982 License exams for the

veterinarians

Only for the graduates with a third-country qualification

according to national requirements for each Members State

Obligatory for all graduates, run by COE - AVMA

Only for the graduates with a non- recognised qualification by AVBC

Only for graduates with a qualification not

recognised by the Act 19 of 1982 Registration of

veterinarians

Obligatory registration by a competent authority/Veterinary Statutory Body in a EU Member State

Obligatory, run by COE - AVMA

Obligatory by AVBC

Obligatory by the South African Veterinary Council (SAVC)66 TABLE 4: Overview of accreditation bodies of veterinary education worldwide 366

367

5.2. Systems of evaluation of post-graduate veterinary training in Europe

368

Continuous Professional Development (CPD) is an obligation for each veterinarian48, 67 and other 369

health professionals68. Nevertheless, as it generally occurs with lifelong learning in EU, no common 370

framework exists so far. Even though the importance of the CPD, especially for all professionals 371

contributing to public health and safety who has been recognised within legislation36, there is a great 372

variation between the different countries in the way that CPD is implemented and regulated. A study 373

conducted in 2013 under the EU Health Programme, mapping and reviewing continuous professional 374

development and lifelong learning for doctors, nurses, dentists, midwives and pharmacists in the 31 375

member countries of the EU, and EFTA countries, has highlighted the great diversity in the ways that 376

different European countries regulate CPD68. CPD for these five health professions in EU and EFTA 377

can be mandatory, voluntary, or a combination of these two approaches. European Commission has 378

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CHAPTER I General Introduction

Despoina IATRIDOU et al. 29

not conducted a similar structured survey for veterinary profession which is also a regulated 379

profession. Anecdotal and small-scale case-studies show, however, that landscape for veterinary 380

CPD is similar and a great variation of systems apply per country.

381

CPD of veterinarians can be achieved via many ways, such as through participation in scientific 382

events, in seminars, in online training or through the enrolment in a complete academic programme 383

leading to a formal qualification. Kinds of CPD falling in the last category which lead to qualifications 384

at EQF level 7, are a certificate or a Master programme, or at EQF level 8, a PhD programme or a 385

specialisation programme. Enrolment in structured CPD at EQF level 7 in some countries can lead to 386

the acknowledgement of the level of competences via a particular title, such as ‘vakdierenarts’ in 387

Belgium, ‘Fachtierarzt’ and ‘Zusatzbezeichnung’ in Germany, ‘CertAVP’ in the United Kingdom or 388

other national specialisation titles.56 Enrolment in programmes at higher level (EQF 8) lead to a 389

“Doctor” qualification or a formal qualification as “Diplomate” or “Specialist”. Society, especially 390

nowadays, needs high-level veterinary services and veterinarians with advanced skills and 391

knowledge to cover these needs.

392

The implementation of a system for the accreditation of CPD varies also per country. Although there 393

are not complete data on accreditation systems for veterinary CPD, available case studies about CPD 394

for companion animals indicate that the situation is similar. Only few countries have established 395

national CPD committees to take care of the registration and accreditation of available CPD for 396

veterinarians, e.g. Belgium, Germany, Ireland, Poland, The Netherlands, Spain, UK69. 397

In order to bridge inconsistencies between the different national CPD systems, academia, veterinary 398

specialists and the veterinary profession set up jointly VetCEE in 201470. VetCEE is a joint initiative of 399

EAEVE48, FVE49, EBVS71 and UEVP72 established with a view to propose a scheme for QA and mutual 400

recognition of lifelong learning for veterinarians throughout Europe, thus facilitating recognition of 401

their competences achieved through structured CPD (EQF 7).

402

Except VetCEE, private initiatives try to take a role as international accreditors for veterinary CPD in 403

Europe, such as the International School of Veterinary Postgraduate Studies (ISVPS).

404

One level higher, the European Board of Veterinary Specialisation (EBVS)71 provides the framework 405

of competences and assures the quality of training for veterinary specialists at level EQF 8 by 406

recognising and monitoring the 27 veterinary speciality Colleges73 in Europe. Specialists have a very 407

important role in animal health and welfare, public health, sustainable production, development of 408

research for all the diverse disciplines of veterinary medicine, and make a valuable contribution to 409

the society. However, EU legislation has not yet introduced a system for the recognition of 410

veterinary specialists in each territory. EBVS comes to fill that gap by regulating veterinary specialists 411

qualified by its colleges in thirty-eight distinct areas of veterinary medicine, which can be species 412

specific or discipline specific73. College programmes account for an equivalent of 180 ECTS acquired 413

through a 3-year full-time residency programme, or an equivalent part-time dedication as defined by 414

the EBVS Policies and Procedures74. EBVS assures the quality of the training provided by each 415

College, ensures transparency of qualification, which is awarded with the title of European 416

Veterinary Specialist™ in the particular field of veterinary medicine.

417 418

6. Current challenges for the veterinary education establishments

419

Veterinary profession contributes to society in many different roles. With their competences, 420

knowledge and skills, ensure the health and welfare of different species of animals used for different 421

purposes; contribute to productivity, profitability and sustainability in farming; ensure food safety 422

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CHAPTER I: General Introduction

30 Academic Veterinary Medicine Education in Europe: Mapping the implementation of European Union policies in the European veterinary curricula to uncover elements for consideration within a policy reform aiming at facilitating One Health Interdisciplinary collaboration.

and security of products delivered from animals; contribute to public health; contribute to research 423

and innovation; as well as to ecosystem conservation. Legislators in the European Union 424

acknowledge the need for the veterinary contribution in many different pieces of legislation as 425

presented above under Subchapter 3.

426

Veterinary curriculum must prepare efficiently veterinary students to meet current global challenges 427

in any career path they select to follow graduation. Such challenges include, for example, the control 428

of zoonotic diseases, antimicrobial resistance, sustainable production, climate change, disaster 429

management or ethical research. All of them require the combination of multi-disciplinary 430

knowledge as well as the close collaboration of professionals coming from different backgrounds, 431

what it is now called One Health interdisciplinary practice.

432

This thesis focuses on four areas of veterinary medicine - namely laboratory animal veterinary 433

medicine, aquatic animal veterinary medicine, honeybee veterinary medicine and One Health - for 434

which European Union legislators foresee the involvement of veterinarians and other professionals.

435

Now, these sectors are somehow less popular career paths, with about 15% of veterinarians being 436

occupied in academic or industrial research, 4% in aquatic animal health, 9% in One Health and 13%

437

in practice with exotic species75. Nevertheless, these are all very dynamic sectors, and overall 438

outlooks for them are very positive. It is therefore of utmost importance to ensure that veterinarians 439

will be active participants of their future development. By mapping the veterinary curricula in the EU 440

and EFTA, this investigation tries to find out how the European veterinary education establishments 441

incorporate teaching in those fields in their curricula. By analysing the results, this study investigates 442

in identifying the elements that need to be considered within a policy reform of the Professional 443

Qualifications Directive, in a way that will enable future veterinarians to meet efficiently current and 444

future challenges.

445 446

7. References

447

1 Treaty of Lisbon [Internet]. Brussels: European Union; 2007 Dec 17. Available from: https://eur- lex.europa.eu/legal-content/EN/TXT/?uri=celex:12007L/TXT.

2 EUR-Lex Access to the European Union law. Glossary of summaries: Subsidiarity. http://eur- lex.europa.eu/summary/glossary/subsidiarity.html.

3 European Committee of Regions. Subsidiarity monitoring in the area of education, vocational training and youth. https://portal.cor.europa.eu/subsidiarity/policyareas/Pages/Education.aspx.

4 Eurydice: National Education Systems - http://eacea.ec.europa.eu/national-policies/eurydice/national- description_en

5 European Commission proposal for a Council recommendation on promoting automatic mutual recognition of higher education and upper secondary education diplomas and the outcomes of learning period abroad.

6 Making Integration Work, Organisation for Economic Co-operation and Development (2017):

http://www.oecd.org/migration/making-integration-work-humanitarian-migrants-9789264251236-en.htm

7 Education in the EU. European Education Area - https://ec.europa.eu/education/education-in-the- eu/european-education-area_en

8 Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee Of The Regions: Strengthening European Identity through Education and Culture; The European Commission's contribution to the Leaders' meeting in Gothenburg, 17 November 2017 - https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2017%3A673%3AFIN

9 Rome Ministerial Communiqué. 19 November 2020 –

http://www.ehea.info/Upload/Rome_Ministerial_Communique.pdf

10 Rome Ministerial Communiqué - Annex I - Statement on Academic Freedom - http://www.ehea.info/Upload/Rome_Ministerial_Communique_Annex_I.pdf

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