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Board committee weighs narrowing "owner exemption" for veterinary practice, stakeholders warn of access impacts
Summary
The Medical Director Committee considered draft statutory changes that would limit the "owner exemption" to fewer animals and add narrow caregiver and written‑treatment‑plan exceptions, while also approving tougher citation authority for unlicensed practice.
The Medical Director Committee spent extended time discussing proposed changes to the "owner exemption" and related unlicensed practice enforcement. The committee considered legislative language to narrow the current exemption so that it more clearly excludes most companion animals (including many horses used as pets) and to permit limited caregiver activity when there is a written treatment plan prepared by a licensed veterinarian.
Proposals discussed by the committee included: restricting the owner-exemption to livestock and food animals (with a draft definition of “livestock” that would exclude typical companion animals such as dogs, cats and pet birds and clarify whether certain equines participate as livestock); allowing owners or designated caretakers to administer drugs and medications when performed pursuant to a written treatment plan prepared by a California-licensed veterinarian (routes, dose, frequency to be specified); and an explicit carve-out allowing owners to administer over-the-counter, nonprescription drugs without being deemed to practice veterinary medicine.
Stakeholder response: Several public commenters urged caution. Juliana Tetlow of San Diego Humane Society said narrowing the exemption could reduce access to timely care in rural or underserved areas and increase shelter intakes. Bruce Wagman, an animal-law attorney representing shelters and rescues, said most states preserve an owner exemption; he warned that removal would harm pet owners and shelters and urged the board to pursue enforcement or education alternatives rather than wholesale removal. Karen Atlas of the Animal Physical Therapy Coalition and other commenters said stakeholder suggestions (training, clearer triage and oversight) were not fully reflected in the draft language. Equine practitioners urged care in any definition changes because many horses occupy categories between livestock and companion animals.
Enforcement and citations: Separately the subcommittee proposed statutory changes to unlicensed-practice citation authority: removing the existing $5,000 per‑claim cap and allowing fines more closely tied to the number and severity of violations, and reclassifying citation categories so unlicensed practice can be pursued more readily. The committee voted to recommend a legislative proposal to amend Vehicle/Professional Code (VPC) section 4875.2 and add 4875.7 for unlicensed-practice citations; the motion passed. It also approved conforming changes to CCR Section 2043 to remove redundant regulatory classification language tied to unlicensed practice.
Next steps: The MDC referred owner-exemption language back to the unlicensed-practice subcommittee for further drafting, including outreach to CDFA and other agencies and more stakeholder consultation on livestock/equine definitions and the operational impact on shelters. The committee asked staff to pursue the citation‑authority changes and to prepare legislative transmittal materials.
Ending: Committee members said they want to preserve reasonable caregiver actions (wound care, administration of over‑the‑counter medicines) while improving the board’s ability to discipline unlicensed activity that results in harm; staff will return with revised language after additional stakeholder and agency outreach.
