Under the RCVS Code of Professional Conduct veterinary surgeons are expected to demonstrate that they are keeping their skills and knowledge up-to-date by engaging in at least 105 hours of CPD over a rolling three-year period.
As part of the auditing process the 1,071 vets will be asked to share their CPD records for 2014 to 2016, either by allowing the College to access their online Professional Development Record or by sending the College a copy of their CPD record card.
The audit will focus on six groups:
The College says that if any of the veterinary surgeons who have been audited are found to be non-compliant they will be asked to explain why and send a plan stating how they will make up the hours in order to become compliant.
The deadline for sharing records is Tuesday 31 October 2017.
As part of the auditing process the College is reminding veterinary surgeons that CPD encompasses a wide range of recorded activities, which can be clinical or non-clinical, including private reading/study, webinars, mentoring, clinical audit and discussion groups as well as attending seminars and workshops.
Don't forget that reading content and participating in forum discussions on VetSurgeon.org can count towards your annual requirement, using the 'Claim CPD' feature at the top of each page.
Those with any questions about the auditing process or what constitutes CPD can contact Jenny Soreskog-Turp, RCVS Education Officer, on cpd@rcvs.org.uk.
Of particular note is the guidance that prescriptions should no longer be written in mg/kg, as it may lead to errors when the dose is calculated.
The Standards and Advice update also answers questions about:
https://www.rcvs.org.uk/news-and-views/features/prescribing-pom-vs-joint-guidance-from-the-rcvs-and-vmd/
The RCVS has published a list of 369 veterinary surgeons who missed the 31st May deadline for retention fee payments, were removed from the Register and not restored by 24 June, on its website.
The College says it publishes the list to alert those vets who have not replied to its communications to check their Register status, and to remind veterinary employers to check the registration status of their employees. The registration status of any vet or VN can be checked online at www.rcvs.org.uk/check-the-register.
Information about restoration, and an application form, can be found at www.rcvs.org.uk/registration, or by contacting the RCVS Registration Department: membership@rcvs.org.uk.
For a veterinary surgeon to be restored, a restoration fee needs to be paid, as well as the annual retention fee. The restoration fee is at least £299, and multiplies each successive year a removed member remains off the Register.
A veterinary surgeon's registration acts as a licence to practise and those removed from the Register may not practise unless and until they have been restored.
Emotional Resilience Skills for the Veterinary Profession, which the BSAVA presents in association with the RCVS Mind Matters initiative and Two Roads Charity, are half day events will be now held virtually by the BSAVA Regions.
Mary Harrison, Programme Director at Two Roads Charity, said: “Twice as many members of the Veterinary Profession suffer mental health issues as the general population; due to many reasons including overwork, trauma, imposter syndrome, unsupportive colleagues and overly demanding clients. Emotional Resilience is a major defence against many mental health issues including depression and anxiety and the good news is that it’s primarily learned behaviours."
The programme is designed to equip participants with an understanding of the role emotional resilience plays in protecting our mental health. Emotional resilience is mainly a learned behaviour, and there are recognised steps that can be taken to increase resilience and reduce the risk of developing mental health issues including depression.
Jennie Bartholomew, Education Coordinator at the BSAVA said: “We’re thrilled to be able to offer these courses to the veterinary profession again, especially given the exceptionally tough year we have all experienced which has placed additional strain on mental health and wellbeing for many. We know that this programme will be well received and will be helpful to all members of the profession, wherever they are based”.
Lisa Quigley, Mind Matters Initiative Manager, said: “We know how tough the last 18 months have been for the veterinary profession, and we’re pleased to be working in partnership with two organisations who are as passionate about supporting the mental health of the profession as we are. We are really looking forward to the launch of the programme and we are sure that anyone who attends will come away with a better understanding of their mental wellbeing and how to respond to emotional challenges.”
Designed for the whole practice team, the programme is suitable for anyone who wishes to increase their own resilience and develop the ability to help others at work or at home. Participants will work in groups, and no personal disclosures are necessary, although participants are welcome to discuss private issues after the programme.
The programme is free to BSAVA members; £40 to non-members. Spaces are limited and the sessions will not be recorded. You can book your place online now at: https://www.bsava.com/emotionalresilience.
The nomination period runs until 5pm on Tuesday 31 January 2018. In order to stand, candidates will need to submit a nomination form along with contact details, a short biography and a statement, and supply a high-resolution digital photograph.
Each candidate also needs two nominators, who should be veterinary surgeons who are on the College’s Register but are not current RCVS Council members.
Professor Stephen May, RCVS President, said: "I myself have been an elected Council member since 2012, and it has given me tremendous opportunity to get involved with a whole range of subjects, including my particular interests, undergraduate education and lifelong learning. It’s incredibly rewarding to see how the decisions you make during your time on Council can really benefit the profession, and I would encourage anyone who shares an interest in the future of our profession, whether that be about graduate outcomes, practice standards, the wider veterinary team or the effects of Brexit, for example, to stand for election."
Although the RCVS is planning the elections as usual, it is concurrently preparing for a change to its governance arrangements, including a reduction in the size of the Council, as agreed in March 2016.
Commenting on the Legislative Reform Order (LRO) that will be required to amend the Veterinary Surgeons Act 1966, RCVS Registrar Eleanor Ferguson said: "This is a complex matter and, unfortunately, due to unavoidable delays associated with the 2017 General Election and the impact of preparing for the UK’s departure from the European Union, the LRO has not yet completed the legislative process.
"This means that whilst we will be running the elections on the basis that there will be six elected places available, as per the old size and structure, it should be expected that under the new size and structure, only three places will ultimately be available."
Meanwhile, due to comparable changes to the governance of the Veterinary Nurses Council, including a reduction in its number, there will be no 2018 VN Council elections as the outgoing members will not need to be replaced.
The RCVS Council election period will start around mid-March and voting will close at 5pm on Friday 27 April 2018.
Nomination forms, guidance notes and frequently asked questions are available for prospective RCVS Council candidates at www.rcvs.org.uk/rcvscouncil18.
The Royal College of Veterinary Surgeons is warning practices and would be veterinary nurse students to check that VN training courses are approved by the College, or they will not lead to qualification as a veterinary nurse.
The RCVS has reported one such course, run by Direct Veterinary Services of Oxford (http://www.direct-vets.com/), to Trading Standards: it advertises 'accredited training for veterinary nurses' leading to 'an honours degree in veterinary nursing' without being an RCVS-approved training provider or awarding organisation.
RCVS Head of Veterinary Nursing, Libby Earle said: "Would-be veterinary nurse students should always check that the course they are embarking upon will lead to a qualification that is recognised by the RCVS for the purposes of registration, or they may be in for a disappointment.
"Only those courses approved by the RCVS will lead to registration, and without registration (or listing), individuals should not call themselves veterinary nurses and cannot legally carry out medical procedures and minor surgery under Schedule 3 to the Veterinary Surgeons Act."
The College says candidates should also be wary of training providers who demand money upfront online.
All new veterinary nursing courses and qualifications must be approved by the RCVS and this process can take some time. The list of approved centres providing VN training courses, together with details of approved qualifications, are available at: http://awardingbody.rcvs.org.uk/,
RCVS Day - the Royal College of Veterinary Surgeons Annual General Meeting and Presentation of Awards - will be held on Friday 1 July 2011 at One Great George Street, London.
All members and listed/registered veterinary nurses are invited to attend the day, which will start at 10am with AGM business, followed by the celebration of veterinary and veterinary nursing achievements. Professor Soraya Shirazi-Beechey will be receiving her Honorary Associateship and Dr James Kirkwood and Des Thompson will be accepting their Honorary Fellowships.
A new award to mark the 50th anniversary of veterinary nursing will also be presented, as well as a Lifetime Contribution Award from the RCVS Charitable Trust.
In his last official engagement as President, Peter Jinman will give a review of his year before formally welcoming new Council and VN Council Members, and Dr Jerry Davies to the role of President for 2011-2012.
To celebrate Vet2011, the RCVS is honoured to announce that there will be two guest speakers this year - Dr Christophe Buhot DVM and Professor Gary England FRCVS, who will deliver a talk about the history and future direction of veterinary education.
For tickets, which are free and allocated on a first-come, first-served basis, please contact Fiona Harcourt at the RCVS on f.harcourt@rcvs.org.uk or 020 7202 0773.
The Disciplinary Committee heard three charges against Dr Dhami, relating to events which took place while he was in practice at Vets4Pets in Market Harborough, Leicestershire.
The first charge against him was that, in November 2017, he used excessive force in kicking and stamping on a Staffordshire Bull Terrier he was treating.
The second charge was that, between in October and November 2017, he failed to pay adequate regard to the welfare of a Jack Russell in his care by leaving it in a sink without adequate reason and for an excessive period of time.
The third charge was that, between April and March 2018, he failed to have adequate regard to the welfare of a six-to-eight week old kitten, including providing bedding and warmth.
At the outset of the hearing Dr Dhami admitted to lightly kicking the dog, but denied forcefully kicking it and also denied that he had stamped on the dog, as well as denying the other two charges against him.
In considering the circumstances of the first charge, the Committee heard evidence from two of Dr Dhami’s colleagues stating that the dog had bitten him whilst he was cleaning its ears and, following this, he took the dog out of the consulting room, closed the door and whilst holding the dog’s lead then proceeded to kick her twice, knocking her along the floor both times, and then finally stamp on her when she was prone.
Dr Dhami disputed his colleagues' version of events and stated that he had only delivered two light kicks to the dog’s rump, that neither of these had made her fall to the floor and also denied in categorical terms that he stamped on the animal. Furthermore, he also denied the second and third charges against him.
In considering the evidence as to whether Dr Dhami kicked and stamped on the dog, the Disciplinary Committee found the evidence of his two colleagues to be credible and reliable, and so found all aspects of the charge proven.
Ian Green, chairing the Committee and speaking on its behalf, said: "For the avoidance of doubt, the Committee finds that the admitted kicks administered to [the animal] by the respondent were of significant force. The Committee rejects the respondent’s assertion that the admitted kicks amounted to mere taps on the backside. The Committee finds that the ‘stamping’ was also of significant force."
In regards to the second and third charges, the Committee was not satisfied that the charges had been proven by the evidence it heard and therefore dismissed them both.
Having found all parts of the first charge proven, the Committee then went on to consider whether or not Dr Dhami’s conduct amounted to serious professional misconduct, something that Dr Dhami, following the Committee’s decision on the facts, through his counsel, had admitted.
The Committee identified a number of aggravating factors, including the real risk of physical harm to the animal and the deliberate nature Dr Dhami’s conduct against the animal, committed in anger.
In mitigation, the Committee accepted that this was an isolated incident and that Dr Dhami had been bitten and was in pain. The Committee therefore found that Dr Dhami’s admission of serious professional misconduct was ‘properly and prudently made’.
The Committee then considered what sanction to impose on Dr Dhami. In doing so it took into account some of the written testimonials and character witnesses called on behalf of Dr Dhami. The Committee was also satisfied that Dr Dhami had had a hitherto long and unblemished career, that he had apologised to colleagues immediately after the incident and that, since the events, he had continued to work as a veterinary surgeon without any problems.
In relation to insight about the event, the Committee accepted Dr Dhami had provided some evidence of reflection, in that he admitted kicking the dog and accepted that this conduct, once found proven, amounted to serious professional misconduct.
The Committee decided that suspending Dr Dhami from the Register for four months would be the most proportionate sanction.
Ian Green concluded: "Having regard to all the matters urged by way of mitigation, and having taken into account all the evidence that it has heard, the Committee is satisfied that a period of suspension is sufficient in this case to protect the welfare of animals, maintain public confidence and to declare and uphold proper standards of conduct."
Dr Dhami has 28 days from being informed of the outcome of the hearing in which to make an appeal to the Privy Council.
The 2009 RCVS Continuing Professional Development Record Cards have been sent to all practising vets and Registered Veterinary Nurses.
Undertaking and recording Continuous Professional Development (CPD) is a mandatory professional requirement for these vets and RVNs. Vets must average at least 35 hours of CPD per year and RVNs 15 hours, although many will do far more.
The RCVS can ask to see CPD records - and they may be checked during practice inspections as part of the Practice Standards Scheme. For newly-qualified veterinary surgeons, completing the Professional Development Phase also fulfils the CPD requirements in their first year of practice.
Jill Nute, President of the RCVS, said: "CPD is about maintaining professional competence. Vets and RVNs are expected to make continuous improvements in their knowledge and skills, which will have benefits for their patients and clients, their own development and the profession at large. Undertaking CPD allows vets and RVNs to demonstrate their commitment to maintaining the highest professional standards."
As professionals, vets and RVNs are expected to evaluate what knowledge and skills they need to develop, and how they will do this. This may include activities such as going to particular case-conferences or asking for some in-house training. Getting together with other practices to organise training sessions or secondments or finding a mentor can also be useful.
Personal study - documented in a learning diary detailing the aims of the study, what was studied and the outcomes, for example, a change made to a practice protocol - can also be used. There is no limit on properly documented study, but vets cannot count more than 10 hours, and veterinary nurses five hours, each year of undocumented study.
All CPD activity should be systematically planned to meet identified professional needs, and clear records must be kept of what has been done.
Further information about CPD requirements for veterinary surgeons and Registered Veterinary Nurses can be found on the back of the CPD Record Card, and at RCVSonline (www.rcvs.org.uk).
Dr Power faced a number of charges relating to alleged clinical and communications failings surrounding surgery carried out on two separate dogs on two separate occasions.
The first concerned laryngeal tieback surgery carried out on Harvey, a Tibetan Terrier in March 2018, and the second concerned oesophageal surgery carried out on a boxer dog, Boss, in October 2018.
The College withdrew a number of the charges at the start of the hearing, and more later after hearing from witnesses.
Of the remainder, Dr Power admitted that she had not undertaken pre-operative radiographs before proceeding with the laryngeal surgery, had failed to perform the surgery appropriately (she dissected excessive tissue and had inappropriately placed sutures), and had undertaken the surgery when it was outside her area of competence.
In relation to the oesophageal surgery, Dr Power admitted failing to provide a referral report and/or clinical records to the veterinary practice he was referred from, despite requests from the practice.
The Committee found that the majority of the charges which had not been withdrawn or admitted by Dr Power, not proven.
However, the Committee found that in addition to the admitted charges, Dr Power had subjected the dog undergoing oesophageal surgery to an excessive 9.5 hours of anaesthesia.
The Committee then went on to consider whether the proven charges amounted to serious professional conduct.
Counsel for the College submitted that Dr Power’s conduct breached the part of the Code of Professional Conduct relating to veterinary surgeons keeping within their area of competence and referring responsibly; and providing veterinary care that is appropriate and adequate.
In terms of aggravating factors, the College submitted that there was both actual injury to the animal, as well as actions that posed a risk of injury, that Dr Power financially benefitted from the alleged misconduct as she was paid to perform a procedure outside her competence, and that she occupied a position of increased trust and responsibility as she advertised herself as a practitioner who accepted referrals and was competent to perform soft tissue surgery.
Dr Power’s counsel submitted that the charges that had been found proven amounted to clinical and administrative failings and that this was not a case of a veterinary surgeon deliberately or recklessly acting outside of their capabilities, but rather a case where a diligent and responsible veterinary surgeon had fallen short in discrete areas of her clinical practice and had reasonably believed at the time that she was competent to perform the surgery.
The Committee found that although the conduct within the proven charges fell short of what would be reasonably expected of a veterinary surgeon, it did not fall so far short that her conduct constituted serious professional misconduct.
Paul Morris, chairing the Disciplinary Committee and speaking on its behalf, said: “The Committee understood that it had a responsibility to consider the wider public interest, taking into account the view of a reasonable member of the public in possession of all the relevant facts and information.
“The Committee considered that such a member of the public would understand that veterinary surgery is a challenging profession. It was of the view that such a member of the public would not expect perfection, but understand that any professional practitioner may make mistakes in the course of their practice.
“It is the judgement of this Committee that the respondent’s conduct does not constitute disgraceful conduct in a professional respect.”
The full findings of the Disciplinary Committee can be found at www.rcvs.org.uk/disciplinary
The meeting follows growing concerns expressed both within the profession and in the national media about the shortage of veterinary surgeons in the UK.
Lizzie Lockett, RCVS CEO (pictured right), said: “Workforce shortages within the veterinary sector has been a concern for some time, however, in the past few months there has been a ‘perfect storm’ of circumstances, which have come together to exacerbate the problem. The issues include the ongoing impact of the pandemic, burnout and fatigue within the profession; the UK’s exit from the European Union, which has seen a significant reduction in the number of EU vets joining the Register as well as an associated increase in the need for veterinary certification; and an increase in pet ownership, and therefore demand for veterinary services, over the course of the pandemic."
In advance of the meeting, which is due to be help in November, the College will be conducting research to better gauge the extent of the problem both nationally and regionally.
The meeting will then consider how recruitment, retention and return to work might address the problem.
Lizzie added: “While there has already been a lot of focus and discussions around recruitment and retention, something less spoken about is return, and the summit will consider the reasons why members of the profession may move away from clinical practice, and if there’s more scope for different ways of working that could bring people back into clinical practice.
“Ahead of the summit we will be reviewing all the latest data that we and other organisations have shared to better understand the gap between capacity and demand, the push and pull factors on decisions to either join or leave clinical practice and build a more evidence-based picture of veterinary workforce trends.”
The summit itself, the date of which is yet to be confirmed, will involve key veterinary stakeholders including the veterinary schools, veterinary employers and representative bodies, coming together to ensure that there will be a joined-up approach in finding solutions to the issues confronting the profession.
Lizzie said: “It may not necessarily be easy to identify all the solutions in one day, and they won’t all come from the RCVS, but opening up the conversation and getting the professions focused on taking appropriate action is an important first step.”
Meanwhile, RCVS President Kate Richards this week wrote to all vets and nurses to reassure them them that the RCVS was aware of the problem and the additional pressures they are under as a result.
In the letter she wrote: “In the face of current shortages, I would like to stress that we support practice teams in prioritising cases strictly according to the health and welfare needs of their patients, and in informing their clients of the need to do so.
“We would also urge veterinary surgeons to share their caseload as much as possible, delegating permitted procedures to their veterinary nurse colleagues wherever appropriate to do so.
"And, we would like to remind veterinary surgeons that their current 24/7 emergency cover obligations, as set out in the RCVS Code of Professional Conduct, are limited only to taking steps to provide 24-hour emergency first-aid and pain relief to animals according to their skills and the specific situation."
She also added that, while members of the profession may be anxious about a potential increase in the number of concerns being raised by clients because they are not able to offer the level of service they would ideally like to, the RCVS would always take into account the entire circumstances surrounding a complaint as part of its investigation process.
She also said that the College would also continue to raise awareness amongst animal owners of the acute challenges currently facing veterinary teams around the country, and to request their ongoing patience and understanding.
To assist the profession, a series of FAQs have been produced to help with different situations that vets may encounter at the moment, particularly around the provision of 24/7 emergency cover, and to provide further guidance on delegating procedures to veterinary nurses. These can be found at: www.rcvs.org.uk/news-and-views/news/
Mr Beveridge had been removed from the Register following a disciplinary hearing in May 2013 in which he was found guilty of disgraceful conduct in a professional respect with the Committee finding that he had treated clients badly, kept inadequate clinical records, was dishonest in his dealings with the College and that animals in his care were placed at risk. He subsequently appealed to the Privy Council but this was later withdrawn, resulting in him being formally removed from the Register in March 2014.
He first applied to be restored to the Register in 2015 but his application was refused by the Disciplinary Committee at a hearing in November 2015. At the time the Committee found him unfit for restoration to the Register because, following his removal, his veterinary medicines account had been used on an unauthorised basis to order prescription-only veterinary medicines, which reflected a "cavalier attitude to practice". Furthermore, the Committee found that he had not fully accepted the Committee’s original findings, had made inadequate effort in regards to engaging in continuing professional development (CPD) and also considered the seriousness of the original findings.
At the opening of his second hearing Mr Beveridge, who represented himself, sought to address the concerns that the Disciplinary Committee had outlined upon refusing his first application for restoration. Regarding his acceptance of the original findings, the Committee heard that he now apologised "unreservedly for his failings that led to erasure of his name from the Register" and the Committee considered that he had demonstrated a significant change in attitude from the previous restoration hearing where he had not fully accepted the reasons for being removed.
In considering issues of public protection the Committee also accepted that Mr Beveridge, until his original Disciplinary Committee hearing, had an unblemished professional record and had run a successful small animal practice for over 30 years. It considered numerous client testimonials as well as a petition signed by 600 clients from 2013.
The Committee also considered that there was no risk to the future welfare of animals in the event of Mr Beveridge being restored to the Register, noting the testimonials and references to satisfactory care and treatment given by Mr Beveridge to his patients.
Regarding CPD, Mr Beveridge produced evidence before the Committee that he had attended courses run by the North American Veterinary Community (NAVC) and the British Small Animal Veterinary Association (BSAVA). The Committee accepted that he had made "considerable progress" in terms of CPD.
In concluding the hearing Judith Way, chairing the Committee and speaking on its behalf, said: "It is the judgement of the Committee that the conduct which resulted in the applicant’s name being removed from the Register is unlikely to be repeated. The applicant has satisfied the Committee that he is fit to be restored to the Register."
Voting for this year’s election will take place from 15th March until 5pm on Friday 23 April 2021 and the 14 candidates are:
This year, four candidates will be elected to serve a four-year term.
For the first time, the RCVS Council election will be carried out completely online.
Eleanor Ferguson, RCVS Registrar and Returning Officer for the election, said: “Due to the coronavirus pandemic and the issues that it has caused regarding disruption to the postal service, the RCVS has gained permission from the Privy Council to temporarily amend our Election Scheme, a document that governs how we run our elections, to allow voting to take place entirely online this year. This means that physical ballot papers will not be distributed to veterinary surgeons eligible to vote this year.
“The small number of veterinary surgeons for whom we do not hold an email address will receive a letter with instructions on how to vote online, in addition to their security code to allow them access to their unique voting website. If they need further help there will also be the opportunity for them to call Civica Election Services, which runs the election on our behalf, who will assist them with casting their vote.”
Ahead of the start of the election, the RCVS is also inviting members of the profession to submit one question each for the candidates. The candidates will then be asked to record a short video of themselves answering two of the questions of their choice which will be published when the election starts.
Questions can be submitted by emailing vetvote21@rcvs.org.uk or via the RCVS Twitter account (@theRCVS) using the hashtag #vetvote21.
The full candidate biographies and manifestoes have already been published on the RCVS website and are available to view at: www.rcvs.org.uk/vetvote21
Members of the profession have until Wednesday 24 February 2021 to submit their question.
The RCVS has extended the deadline for nominations for the RCVS Queen's Medal to 31 January, to allow time for the nominations paperwork to be completed on return from the Christmas and New Year break.
RCVS CEO Nick Stace said: "We received more enquiries about the Queen's Medal over the Christmas period but appreciated that people might welcome a little extra time in the new year to complete and submit their nominations. We're certainly keen to allow anyone who wishes to make a nomination for this very special award the chance to do so."
The Queen's Medal, launched at the House of Lords last November, is a new Honour that will be awarded to a veterinary surgeon for a lifetime of outstanding contributions to the profession and who has dedicated their career to working above and beyond the call of duty in the fields of veterinary medicine or science, or related areas.
It is the most prestigious Honour that the RCVS can bestow, and will be awarded at RCVS Day in London in July.
Full details about the nominations process are available on the RCVS website (www.rcvs.org.uk/Queensmedal). Nominations should be received by the RCVS no later than 5pm on Friday, 31 January 2014.
According to the RCVS, 86% of veterinary surgeons, and 92% of veterinary nurses have so far failed to vote in this year's council elections.
There's still time: voting for the RCVS Council and VN Council doesn't close till 2nd May and 28th April respectively.
Voting can be done online: http://www.rcvs.org.uk/Templates/Internal.asp?NodeID=205006, where you can also read each candidate's manifesto.
The Committee had found Dr Elefterescu guilty of serious professional misconduct in relation to a number of charges which covered issues such as dishonesty, poor record-keeping, and failure to carry out adequate clinical examinations.
The full charges and findings of the RCVS Disciplinary Committee can be found at: www.rcvs.org.uk/disciplinary.
The Judicial Committee of the Privy Council held the appeal hearing in October last year with three Justices of the Supreme Court - Lord Kerr, Lord Carnwath and Lord Kitchin – comprising the Board.
The basis of the appeal to the Privy Council was that the Committee’s findings on the facts of the case were flawed, with his counsel saying that Dr Elefterescu 'strenuously disputes the findings by the Committee of his dishonesty and lack of professional competence and submits that there is no adequate basis for them in the evidence’.
His counsel also told the Board that the Disciplinary Committee’s sanction failed to take into account mitigating factors and that the decision to remove Dr Elefterescu from the Register was disproportionate.
In relation to the appeal against the Disciplinary Committee’s findings on the facts, the Board was not persuaded by any of the arguments put forward on behalf of Dr Elefterescu. These arguments included that the RCVS had failed to call relevant witnesses and had failed to make Dr Elefterescu aware of the significance of some evidential matters, disclosed to him.
In respect of the sanction, the Board was also unpersuaded by the arguments put forward by Dr Elefterescu’s counsel, namely that it was too harsh in its assessment of aggravating factors, did not give adequate weight to mitigating factors, and that it failed to distinguish lack of competence from misconduct.
In its judgment on the arguments put forward by Dr Elefterescu’s counsel, the Board said: "It is the opinion of the Board that these criticisms are not well founded. The Committee considered with care Dr Elefterescu’s proven and admitted conduct in relation to each of the charges and whether it fell below or far below the standard to be expected. It is to be noted in this regard that a number of the charges which were either admitted or upheld were not the subject of any challenge on this appeal.
"Overall, the Committee found that Dr Elefterescu’s clinical failures were very serious, involved failures in the basics of animal care, resulted in animal suffering and involved widespread breaches of the respondent’s [RCVS] code of professional conduct. It also expressed particular concern about its findings of dishonesty, and rightly so. That conduct was, in its view, ‘at the top end’ of disgraceful conduct in a professional respect. What is more, Dr Elefterescu had a lack of insight into his failings and a wholly unjustified confidence in his abilities which constituted an ongoing risk to animal welfare."
"These were findings which the Committee was clearly entitled to make and, in the light of them, the Board is firmly of the view that the decision of the Committee to direct the removal of Dr Elefterescu’s name from the Register cannot be impeached. The Board rejects the criticisms made of the Committee’s reasoning and the conclusions to which it came. The direction that Dr Elefterescu’s name must be removed from the Register was appropriate and proportionate."
The Judicial Committee’s full findings can be found at www.jcpc.uk/cases/docs/jcpc-2018-0060-judgment.pdf.
Prior to the start of the hearing, the RCVS received correspondence from Mr Kombert confirming that he did not intend to attend the hearing, either in person or via a video-link, nor did he intend to send legal representation in his stead.
The Committee, chaired by Dr Martin Whiting, decided to proceed with the hearing in the absence of Mr Kombert and any legal representation, on the basis that it was in the public interest and the interests of justice to proceed and that Mr Kombert had been given the opportunity to attend or be represented.
The Committee heard that staff at the practice where Mr Kombert was working as a locum had undertaken a check of the medicines kept in the practice’s controlled drugs cabinet and discovered that 5.5ml of ketamine and 1.5ml of methadone was missing. After the code to the controlled drugs cabinet was changed, Mr Kombert was observed taking an additional 3ml of methadone, which he then administered to himself while on duty at the practice.
After Mr Kombert was confronted with the evidence, he was given the details of the Vetlife charity for support and asked not to return to the practice.
The police were contacted and, on 4 January 2019, Mr Kombert was arrested and interviewed. He received a police caution for theft, with conditions that he should attend and complete a drug-use awareness course, and engage in a restorative justice process, which involved attending the practice to discuss his offences. At this meeting, Mr Kombert admitted stealing the drugs and administering them to himself while on duty, which meant he was not in a fit state to see patients. He apologised for his actions and the matter was then also reported to the RCVS.
In relation to the fact that Mr Kombert had accepted the police caution, made the admissions at the restorative justice meeting and had emailed the RCVS apologising for his actions, the facts of the case were found proven.
The Committee then went on to consider if Mr Kombert’s actions amounted to disgraceful conduct in a professional respect (henceforth called ‘serious professional misconduct’), something which Mr Kombert had admitted to in correspondence with the RCVS.
The Committee found that Mr Kombert’s actions did amount to serious professional misconduct. Dr Martin Whiting, chairing the Committee and speaking on its behalf, said: "The respondent’s conduct was dishonest; it constituted both a breach of trust and an abuse of his position with regards to access to veterinary medicines; it risked animal welfare and jeopardised the reputation of colleagues. It fell far short of the conduct expected of a member of the profession and amounts to disgraceful conduct in a professional respect."
The Committee then considered what the appropriate sanction against Mr Kombert should be, taking into account both aggravating and mitigating factors.
In terms of aggravating factors, the Committee took into account the risk of harm to animals, his dishonesty, the premeditated nature of the misconduct, the breach of trust and the fact it was repeated.
It also took into account three previous matters recorded against Mr Kombert in the United States of America.
These were: a letter of admonition from the Colorado State Board of Veterinary Medicine for practising when his licence had expired; a stipulation order from the same body in which he agreed to relinquish his licence in that state following an allegation that he took controlled substances from a veterinary practice and self-administered them; and a criminal conviction in New York State for obtaining an opioid controlled drug by deception, for which he was sentenced to three years’ probation. The Committee was made aware of the New York State criminal conviction after Dianne Norris, a Probation Officer based in that state, had contacted the RCVS after hearing about the inquiry and informed the College that Mr Kombert was in breach of his probation conditions.
Dr Whiting said: “The Committee has considered the witness statement of Ms Dianne Norris, a probation officer employed by Putnam County Probation in New York, who was responsible for supervising the respondent as part of his probation. Ms Norris explained that the respondent breached his probation on numerous occasions, which took place from November 2017 to 2018…. As a result of the breaches, Ms Norris required the respondent to increase his attendance at support groups to an inpatient treatment program for 28 days from 13 July 2018. He failed to attend.
"Ms Norris explained that warrants were issued for the respondent’s arrest…. The Committee noted that the conduct of the respondent in relation to obtaining controlled drugs from his employers for his own use while in the United States of America was similar to his conduct … [described in] the charges."
In mitigation the Committee considered that Mr Kombert had consistently admitted the charges against him as well as accepting and agreeing with the evidence against him.
However, the Committee decided that in light of the seriousness of his misconduct, including dishonesty and risk of serious harm to animals, removal from the Register was the most appropriate and proportionate sanction.
Summing up, Dr Whiting said: "The respondent has failed to uphold the requisite standards to be expected of him on multiple occasions. The Committee considers that the only sanction that is sufficient to protect the welfare of animals, maintain public confidence in the profession and declare and uphold proper standards of conduct is one of erasure."
Mr Kombert has 28 days from being informed of the outcome of the hearing in which to make an appeal to the Privy Council.
The full facts and findings from the case can be found at www.rcvs.org.uk/disciplinary
The College says that 1CPD has been designed to facilitate the new outcomes-focused CPD model which was introduced in 2020 and becomes mandatory from 2022.
An important part of this new model is reflection, so 1CPD encourages vets to reflect on the quality, relevance and impact of their CPD activities.
Dr Linda Prescott-Clements, RCVS Director of Education said: "Although the outcomes-focused element of these changes won’t become mandatory until January 2022, we recommend that you incorporate reflection in your cycle of planning, doing and recording CPD as soon as possible, and our new 1CPD app makes this much easier to do than before.
"Research has found that reflection enhances the quality, impact and relevance of CPD as professionals consider what they have learned, how they will apply their learning and how it will improve their practice. To support this CPD model, which research has shown has a positive impact on both professionalism and patient outcomes, the 1CPD platform facilitates reflection by allowing you to record your reflective notes on your recorded CPD activities, through a variety of means including text, audio or uploading a document."
The old PDR was taken offline last Friday and all of the data saved in the PDR has been transferred to 1CPD.
The 1CPD app is now available for both Apple and Android devices, available on and off line, and through a new dedicated website, all of which is now accessible using the same credentials used to access My Account.
Richard Burley, RCVS Chief Technology Officer, said: "1CPD provides a range of enhancements to RCVS’ previous offerings in this space and represents an important step forward in the College’s digital approach. Built on the latest best-practice technologies, it improves on every aspect of our previous approach to CPD support, delivering the first stage of a new, integrated, career-long CPD support capability for members.”
The launch of 1CPD also coincides with a change to the way that the College assesses CPD compliance, moving to an annual CPD requirement of 35 hours a year for veterinary surgeons and 15 hours a year for veterinary nurses.
More information on the CPD changes, along with accompanying resources, can be found on the RCVS website: http://www.rcvs.org.uk/cpd2020.
So that practices can make sure everyone in their team is aware of the changes, the RCVS has also produced a poster which can be downloaded at: https://www.rcvs.org.uk/news-and-views/publications/cpd-poster/.
For more information, contact the Education team on 0203 795 5595. For technical advice about 1CPD, email the RCVS at onecpd@rcvs.org.uk.
The RCVS Disciplinary Committee has reprimanded and warned as to his future conduct a Hampshire veterinary surgeon found guilty of serious professional misconduct for cumulative failures to provide adequate professional care, and insufficient regard for animal welfare whilst treating a dog that had ingested broken glass.
The sanction was decided following a 12-month postponement of a decision ordered at a hearing on 19 November 2010.
At last week's hearing, the Committee was asked to decide what sanction would be appropriate in the case of Peter Ardle MacMahon for his treatment of a Cocker Spaniel called Wilfred, while working as a locum in Portsmouth. In 2010, the Committee found that Mr MacMahon had not removed the ingested glass from Wilfred's stomach or adequately checked that he had done so; had inadequately prevented abdominal contamination; and, had failed to communicate this contamination problem to Wilfred's usual veterinary surgeon. Considering these charges cumulatively, the Committee found that the treatment Mr MacMahon provided to Wilfred had fallen far short of the standard to be expected in the profession and amounted to serious professional misconduct.
Shortly prior to treating Wilfred, Mr MacMahon had returned to practice after a ten-year absence and, at last year's hearing, agreed to comply with undertakings regarding his professional development. These included performing at least 70 hours of medical and surgical continuing professional development (CPD); providing the Disciplinary Committee Chairman with quarterly CPD reports and two employer reports regarding his competence; observing 24 days of current practice by shadowing another veterinary surgeon; and, providing reports from this veterinary surgeon as to his competence and a case diary.
The Committee considered the factual findings from the November 2010 hearing and the concerns then expressed about Mr MacMahon's conduct and capabilities as a veterinary surgeon, as well as his compliance with the agreed undertakings. As advised by the Legal Assessor, the Committee's considerations of sanction began at the lowest level that would ensure that the welfare of animals was properly protected; that proper standards would be maintained among practitioners in the profession; and, that would be in the interests of the public.
Speaking on behalf of the Disciplinary Committee, Chairman Professor Peter Lees said: "The Committee is satisfied that the respondent had complied fully with the spirit of the requirements of the undertakings he had entered into on 18 November 2010. Indeed, the view is that the respondent has done well to achieve the level of compliance that he has, given that he had suffered a period of significant ill-health during the period since he entered into those undertakings.
"The ultimate decision is that the respondent's conduct [...] warrants the imposition of at least a reprimand," he continued. "However, it is also the Committee's firm view that the respondent must be warned about his future conduct so that he will know the Committee considers he needs to maintain the level of continuous professional development that he has achieved [over the last] 12 months, and to have constantly in mind the paramount obligation of all veterinary surgeons to ensure the welfare of animals under their care.
"Such a warning as to future conduct should, and the Committee believes that it will, serve as a constant reminder to the respondent that he must undertake only those procedures, and only proffer professional advice, in the areas where he has the requisite up-to-date skills, knowledge and experience."
The Committee reprimanded Mr MacMahon and warned him as to his future conduct.
The RCVS is now accepting applications from veterinary surgeons and veterinary nurses who wish to serve as members of the RCVS Ethics Review Panel (ERP).
The ERP has been established by the RCVS in order to facilitate access to ethical review for those wishing to undertake practice-based research outside of a university or industry context. The ERP will begin considering research proposals from veterinary surgeons and veterinary nurses from 1 August 2016 and the trial will run for a period of one year. The process will be limited to considering research projects involving cats and/or dogs during the trial period, with the possibility of expanding to other species if the trial is extended or made permanent.
The trial came about following a joint working party established by the RCVS and British Veterinary Association which reported on ethical review and found that an increasing amount of clinical research was being conducted by vets based in private practice. One of the key recommendations of the report was that the RCVS should consider establishing a committee for ethical review of practice-based research.
Ahead of the launch of the ERP, the RCVS is currently looking to recruit four veterinary surgeon members and a veterinary nurse member to the Panel to join a lay member and ethicist Chair.
More details about the roles, the function of the ERP and how to apply can be found at www.rcvs.org.uk/workforus and www.rcvs.org.uk/ethics. Those who are interested in applying can also email ethics@rcvs.org.uk for an informal discussion. The closing date for applications is 15 April 2016.
Vet Futures, the joint initiative by the RCVS and BVA to stimulate debate about the future of the profession, has opened a new discussion exploring the issue of mental health problems.
The discussion has been opened by this month's Vet Futures guest blogger, Rosie Allister, Chair of the Vet Helpline and a Director of the Veterinary Benevolent Fund.
Rosie, who is also a researcher at the University of Edinburgh specialising in veterinary wellbeing, writes that members of the profession should be more willing to open up about their own mental health problems and intervene by talking and listening to colleagues who may be suffering from mental ill-health. She said: "Looking to the future, we need to better understand who is most at risk, how to reach out to them, and how we can start to change our culture so that it is OK to ask for help."
Her blog also proposes that, due to the caring nature of the occupation and high client expectations, members of the profession routinely put work and animal welfare ahead of their own needs and that, in order for there to be wider cultural change, individuals need to change their own attitudes towards asking for help. This includes the discussion of 'taboo subjects' such as suicide: "Perhaps all of us have to start trying to change our culture to one that is more accepting and supportive and looks out for those in need even when they aren't able to reach out themselves."
As part of the discussion, Vet Futures is running a poll which asks: "Could you recognise the signs of mental ill-health in a colleague?"
To read Rosie's blog and take part in the poll, visit and take part in the poll, visit: http://goo.gl/EmLhhF
At the same time as paying the fee, all veterinary surgeons must annually confirm their Register and correspondence details, declare any convictions, cautions or adverse findings and confirm they are compliant with RCVS continuing professional development (CPD) policy.
The deadline for completing the annual renewal, 1 April 2019, has now passed and all veterinary surgeons who are yet to pay their fees must do so before the end of May 2019. As of 1 June 2019, any non-payers will be removed from the Register.
If paid by 30 April 2019, the annual fee is £340 for UK-practising veterinary surgeons, £170 for veterinary surgeons practising outside the UK, and £56 for non-practising veterinary surgeons. Following this date, the fee goes up by £35 across all these groups and veterinary surgeons will have until 31 May 2019 to pay.
If the renewal fee is not received in full by 31 May 2019, then non-paying veterinary surgeons will be removed from the Register. In order to restore their name to the Register, a restoration fee of £340 will need to be paid, in addition to the appropriate retention fee. During this time they will not be able to use the postnominals MRCVS and UK-practising vets will need to cease practising.
Annual renewals can be completed online on the RCVS website and all the information needed to complete the annual renewal is in the renewal notice that has been sent to veterinary surgeons. Those who need any help or have any questions about completing their renewal and paying fees should contact the RCVS Registration Department on 020 7202 0707 or registration@rcvs.org.uk.
The VetGDP, which replaced the Professional Development Phase (PDP), provides a period of structured support to aid the transition of newly-registered veterinary surgeons from veterinary studies to life in the workplace.
VetGDP is being rolled out during 2021 and this year’s veterinary graduates will need to enrol on it.
One of the main features of VetGDP is the requirement for a trained VetGDP Adviser to be available in the practice to provide their new graduate with one-to-one, meaningful support and guidance, to help develop their confidence and capabilities.
In order for veterinary surgeons to become VetGDP Advisers they must complete an online training package being developed by the RCVS and formally commit to supporting new graduates.
Practices that have trained VetGDP Advisers and make this commitment will receive the status of an RCVS-Approved Graduate Development Practice.
The original plan was that practices who wish to employ this year’s cohort of graduates should have obtained RCVS-Approved Graduate Development Practice status by June 2021.
This has now been amended in recognition of the additional pressures that veterinary practice teams are under as a result of the pandemic.
Practices who employ graduates this year will now have until December 2021 to achieve this status, provided they have started to work towards RCVS-Approved Graduate Development Practice status and commit to supporting their new graduate while they do so.
Dr Linda Prescott-Clements, RCVS Director of Education, said: “The ongoing pandemic restrictions, specifically changes made by the government to veterinary professionals’ key worker status on 13 January, means that there are now significant additional pressures on practice teams, particularly in terms of staffing, as many members of the profession will be balancing their work with caring responsibilities. We recognise this and, as such, we have updated the timeframe for the completion of our training for VetGDP Advisers.
“I would also like to personally thank the 850 vets who have already registered their interest in becoming VetGDP Advisers. It is very reassuring to see so many members of the profession committed to supporting new members of the profession, and wanting to engage with the training and with VetGDP to help nurture and develop our future vets through their first few years in practice.”
The College will be holding three VetGDP workshops in February. Each workshop will feature the same content, so there’s no need to attend more than one.
They take place on:
The workshops are open to anyone in the veterinary team including veterinary surgeons who may be considering becoming a VetGDP Adviser, practice managers and others involved in graduate recruitment and anyone else who would like to find out more about VetGDP.
The sessions will be interactive and there will be a significant portion of time given over to Q&As. The RCVS Chair of Education Committee, Dr Sue Paterson FRCVS, and Dr Linda Prescott-Clements, will be available to answer any questions which can be submitted live during the event. You can also submit questions as you register for the workshop at: www.rcvs.org.uk/vetgdpworkshops.
For more information, visit: www.rcvs.org.uk/vetgdp
In total Mr Hendrie Smith had faced eight charges against him, all of which related to him undertaking the euthanasia of a German Shepherd named Bouncer during a home visit in January 2017.
The charges alleged that when John Hendrie Smith undertook the euthanasia of Bouncer he had:
1. failed to ensure he was sufficiently prepared for the euthanasia in that he failed to attend the visit with a muzzle and failed to attend with any sedative and the means of administering sedative;
2. failed to delay the euthanasia until he was in possession of the above items;
3. undertook the euthanasia by means of an injection without first sedating Bouncer;
4. failed to provide Bouncer’s owner with an adequate explanation of the procedure. Including:
a. failing to explain that the procedure involved an attempt at injection directly into the heart;
b. failing to explain that an injection into the heart without sedation is (except in extreme circumstances) not an accepted means of euthanasia;
c. wrongly stated that Bouncer would not feel the injection;
d. failed to provide an explanation of the risks;
e. failed to explain the risks and signs of narcotic excitement;
f. failed to explain the risks of injection into the heart without sedation;
5. failed to obtain Bouncer’s owner’s informed consent for the procedure;
6. failed to make any clinical records in respect of the procedure;
7. provided inadequate veterinary care to Bouncer and caused him unnecessary suffering; and
8. failed to communicate with Bouncer’s owner.
Having considered evidence about the case from Bouncer’s owner, his owner’s former partner, two expert witnesses and Mr Hendrie Smith, the Committee found all of the charges against Mr Hendrie Smith proven, with the exception of charge 4(e) on the grounds that there was insufficient evidence against him on this particular charge.
In considering whether the charges that were found proven amounted to serious professional misconduct, the Committee heard further evidence from the College’s two expert witnesses, and submissions from both the College and Mr Hendrie Smith. Having considered the evidence and submissions, the Committee concluded that in relation to each of the charges found proven, Mr Hendrie Smith’s conduct had fallen far below that which was to be expected from a veterinary surgeon and was therefore serious professional misconduct.
The Committee went on to consider what sanction was appropriate following its earlier findings against Mr Hendrie Smith. The Committee took into account a number of mitigating and aggravating factors. In mitigation the Committee considered that this was a single, isolated incident and that Mr Hendrie Smith had been a practising veterinary surgeon for 65 years and had an otherwise unblemished career with no adverse professional findings against him. It also took into account testimonials from professional colleagues, clients and his local community.
However, the Committee also considered the aggravating factors which included actual injury and unnecessary suffering to an animal, a blatant disregard of the systems that regulate the veterinary profession including the RCVS Code of Professional Conduct and its supporting guidance relating to euthanasia, informed consent, preventing unnecessary suffering and working within one’s area of competence.
In explaining its decision to direct his removal from the Register of Veterinary Surgeons, the Committee noted Mr Hendrie Smith’s lack of insight into his behaviour, which included denying that he was at fault, challenging several of the Committee’s findings and disputing that an intracardiac injection into the heart of a dog without administering sedation or anaesthesia was wholly unacceptable, despite expert opinion to the contrary.
Chitra Karve, chairing the Committee and speaking on its behalf, said: "The respondent, in his oral evidence, admitted that he was not really a small animal vet, and had not been dealing regularly with small animals for a significant period of time. His specialisation in recent years was with large farm animals. The Committee considered that the respondent had, and still has, no concept of the difficulties now recognised as inherent in the procedure he performed, or the risks of pain and suffering it posed to the animal."
She added: "The Committee has found that the respondent’s conduct in attempting an intracardiac injection without prior sedation or anaesthesia caused appalling pain and suffering to Bouncer, as evidenced by his screaming, and was wholly unnecessary. The respondent accepted that he had a sedative in his car, but chose not to postpone attempted euthanasia so that he could sedate his patient first.
"The respondent explained in his oral evidence that he had, in the past, euthanased over 200 dogs by intracardiac injection without sedation or anaesthesia. The Committee concludes that this was the respondent’s customary method of euthanasia, and he did not understand why it was wholly unacceptable for a reasonably competent veterinary surgeon to carry out euthanasia in this way. Given his lack of insight, the Committee considers that there is a risk that, if the respondent were to be asked to euthanase a dog in the future, he would be likely to use his customary method, and thereby cause injury and suffering to another animal."
In determining the sanction the Committee decided that, because there had been a serious departure from the professional standards set out in the Code, serious harm was caused and there was a serious risk of harm to animals in the future, that removing Mr Hendrie Smith from the Register was the only means of protecting animals and the wider public interest.
Mr Hendrie Smith has 28 days from being informed of the Committee’s decision to make an appeal to the Privy Council.
The Disciplinary Committee heard three charges against Dr Jones.
The first and second charges were that, in March 2018, Dr Jones made signed entries in the passports and made corresponding entries in clinical records of four horses indicating that he had administered an influenza vaccination booster to each horse on 15 March 2018 and in relation to another horse a tetanus booster, when in fact he had administered the vaccination boosters on 21 March 2018, and that his conduct was misleading, dishonest and undermined the integrity of a vaccination process designed to promote animal welfare.
The third charge was that, on or around 21 March 2018, Dr Jones failed to make any entries in the clinical records for a horse in relation to an examination on 21 March 2018.
At the outset of the hearing Dr Jones admitted the facts in the first and second charges, and accepted that his actions were misleading, dishonest and that they undermined the integrity of a vaccination process. However, he disputed certain aspects of the written statements of the College’s witnesses. In particular he wanted his conduct to be taken in the context of the pressures that he was working under on that day, primarily that he was in a stressed state having had to euthanase a valuable stallion at the conclusion of his previous client appointment.
Dr Jones did not admit the third charge, explaining that he did not remember examining the horse on 21 March 2018 as alleged.
Based on Dr Jones' own admissions, the Committee found the first and second charges proven.
Regarding the third charge, the Committee heard evidence from the horse’s owner who said they were present during the examination taking place and the Committee was satisfied that the respondent did examine the horse on 21 March 2018 and that he had a duty to make a brief clinical note on the examination. As Dr Jones admitted that he made no such note, the Committee found the charge to have been proven to the requisite standard.
Having found the charges proven, the Committee then went on to consider whether or not Dr Jones’ proven conduct amounted to serious professional misconduct. The Committee, having considered the aggravating and mitigating factors, found that Dr Jones’ conduct as found proved in relation to both charges one and two, did constitute serious professional misconduct.
However, with regards to charge three, the Committee accepted that the respondent simply forgot that he had examined the horse and, therefore, the Committee was not satisfied that the failure to compile a record entry covering the horse’s examination constituted serious professional misconduct.
The Committee then considered what sanction to impose on Dr Jones in relation to the facts found proven in charges one and two. In doing so it took into account the 78 written testimonials and 4 character witnesses called on behalf of Dr Jones.
Ian Green, who chaired the Committee and spoke on its behalf, said: "The Committee’s decision on sanction has been based on an acceptance that the respondent’s conduct on this occasion was out-of-character, as the evidence of his character witnesses and the contents of the letters submitted in his support by his clients and other veterinary colleagues assert. The Committee also accepts that the respondent self-reported himself to his employer and to the College and has made a full and frank admission of his wrongdoing.
"Consideration was given to whether the sanction of a reprimand and/or warning as to future conduct would adequately reflect the gravity of the misconduct, however, after careful reflection it was concluded that such a sanction could not be justified. The reason is that acts of falsification involve acts of dishonesty by a professional person acting in a professional capacity, and the gravity of the matter arises not simply from the dishonesty but also from the possible consequences of the false certification. It should be clearly understood by members of the veterinary profession that, in appropriate false certification cases, the sanction of removal from the Register is one which may well be imposed."
The Committee therefore decided that suspending Dr Jones from the Register for two months would be the most appropriate sanction.