Veterinary Surgeons Act Review - Have Your Say (closes 7th Sep)

Many painful procedures, including mulesing, castration, tail docking, and dehorning, are still legally performed on farm animals in Queensland, often without pain relief.

These practices continue despite modern alternatives - because the law allows it.

The Queensland Government is reviewing the Veterinary Surgeons Act 1936, and your voice is needed!

Submissions close 7 September. Let's demand laws that protect animals from unnecessary suffering.

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SUBMISSION EXAMPLE:

Date:

To the Veterinary Surgeons Act Review Team,

RE: Submission opposing the retention of section 2A exemptions permitting non-veterinary performance of invasive animal husbandry procedures

I am writing to make a submission in response to the review of the Veterinary Surgeons Act 1936, specifically regarding section 2A(3)(a) and the associated regulation listing 'particular acts not veterinary science.' I ask that the review reconsider the scope of these exemptions and move toward requiring these procedures to be performed, or directly supervised, by a qualified veterinary surgeon.

1. Summary of concern

Section 2A currently permits a wide range of invasive, painful, and potentially high-risk procedures to be carried out by unqualified persons because they are classified as 'animal husbandry' or 'animal dentistry' rather than veterinary science. These include castration, dehorning, spaying (via the Willis dropped-ovary technique), tailing, mulesing, dental filing/rasping, artificial insemination, and pregnancy testing by rectal palpation or ultrasound. In effect, the current law allows major surgical and invasive interventions on animals — including abdominal entry in the case of the Willis technique — to be conducted without veterinary training, veterinary registration, or the professional accountability that comes with both.

2. Why these exemptions should be narrowed or removed

Animal welfare and pain management. Procedures such as castration, dehorning, tailing, and mulesing cause acute pain and physiological stress, and the degree of harm is highly dependent on technique, hygiene, and the animal's condition. The age thresholds in the current exemptions (for example, castrating cattle or sheep under six months without a vet) are a blunt proxy for reduced pain and risk; they do not guarantee it. Where sedation, local anaesthesia, or analgesia is warranted, only a trained veterinary professional is equipped to assess and administer it appropriately — the current lidocaine exemptions in paragraphs (j) and (k) attempt to address this but only within narrow product formats, and do not require any assessment of whether that pain relief is sufficient for the individual animal.

Surgical risk of the Willis dropped-ovary technique. The Willis technique for spaying cattle, as described in the exemption, involves piercing the vaginal wall to enter the abdominal cavity and blindly severing the ovaries by rectal manipulation. This is an invasive internal surgical procedure with genuine risk of haemorrhage, peritonitis, infection, and injury to adjacent organs if performed incorrectly. Classifying this as 'not veterinary science' understates the level of anatomical knowledge and skill required to perform it safely, and leaves animals exposed to serious complications where the operator is not a trained and registered veterinarian.

Complication management and accountability. Non-veterinary rogue operators performing these procedures are not bound by the professional standards, continuing education requirements, disciplinary oversight, or clinical judgement expected of a registered veterinary surgeon under this Act. If a procedure goes wrong — for example excessive bleeding after dehorning, infection after castration, or a botched Willis spay — there is limited  or no regulatory recourse for the animal owner and no professional body accountable for the outcome. Bringing these acts within the scope of veterinary science, or at minimum requiring veterinary oversight, would close this accountability gap.

Inconsistency with the Act's stated purpose. The consultation materials state that the Act exists to protect animal welfare and public confidence in veterinary services. Retaining broad carve-outs for invasive procedures performed by unqualified persons sits at odds with that objective, and is increasingly out of step with community expectations regarding animal welfare standards.

3. What I am asking the review to consider

● Require that castration, dehorning, spaying (including the Willis dropped-ovary technique), tailing, and mulesing be performed only by, or under the direct on-site supervision of, a registered veterinary surgeon, regardless of the animal's age.

● If full veterinary-only performance is not adopted, require mandatory pain relief (analgesia and/or local anaesthesia appropriate to the procedure and animal) for all procedures currently exempted under section 2A, with the adequacy of pain relief assessed against animal welfare science rather than a fixed age cut-off alone.

● Remove the Willis dropped-ovary technique exemption specifically, given it involves entry into the abdominal cavity and carries a materially higher risk profile than the other listed husbandry procedures.

● Introduce a mandatory training, competency, and accreditation scheme (similar to the existing approved cattle procedures accreditation scheme for pregnancy testing) for any person other than a veterinary surgeon who is permitted to perform an exempted procedure, with clear reporting obligations for complications.

● Establish a mechanism for animal owners to report adverse outcomes from these procedures when performed by non-veterinarians, feeding into the Veterinary Surgeons Board's compliance and enforcement function.

I would also like to call on the department for a complete ban of mulesing and follow in New Zealand’s conscious footsteps. Tail docking is also a practice that needs to be reconsidered to be banned. It is possible to keep sheep healthy without using these cruel practices. It would require reducing numbers kept together and paying close attention to the conditions of fly breeding, and it may mean more crutching as well. It really is the only humane way forward, for again, we would not do this to our pets. It is an outdated and inhumane practice that needs to stop.

I thank the Department for the opportunity to comment on this review. I would hope that this review is done with empathy and compassion for our fellow animal friends. These barbaric procedures are outdated and cruel.

I look forward to viewing the review.

Yours sincerely,

[Your name]

[Your suburb/3region, Queensland]