What does this mean in practice?
Your training and competency must be supported by appropriate supervision. It is your responsibility to ensure that you remain supervised until you have been assessed as competent by either the Project Licence Holder or another competent Personal Licence Holder.
Being competent means having the necessary knowledge, skills, and ability to perform a procedure successfully, safely, and consistently, while maintaining animal welfare and complying with ASPA requirements.
When competency is assessed, consideration should be given not only to whether you can perform the technique correctly, but also whether you feel confident carrying it out independently in the absence of another competent person.
If you do not yet feel confident or capable of performing the procedure without support, you should continue working under an appropriate level of supervision. This allows you to develop your skills further while ensuring the correct support and safeguards remain in place for both animal welfare and legal compliance.
To learn more about your establishment’s local training and competency framework, you should speak with the Named Training and Competency Officer (NTCO).
How do I comply with PIL Standard Condition 17?
Each Project Licence should include a training plan that identifies all regulated and unregulated skills an individual may need to perform while working under the authority of the licence. This will usually align with the establishment’s DOPS (Direct Observation of Procedural Skills) framework.
The training plan should clearly identify the procedures and activities each individual is expected to carry out and the competencies they must achieve before working independently.
A typical training plan may include:
- Required DOPS competencies
- Relevant Personal Licence (PIL) authorities
- Skills not already covered during induction or PIL modular training
- Additional local training requirements
The Project Licence Holder (PPLh) is responsible for identifying which competencies are required for each individual, regardless of whether they already hold the competency or authority elsewhere.
Where Home Office modular training or additional PIL authority is required, this should be arranged before practical training begins. Training in regulated procedures should only start once the individual has the necessary underpinning knowledge, legal authority, and supervision arrangements in place.
What is supervision?
Every establishment will have its own local policy describing supervision levels and how competency is managed. A typical supervision framework may include:
- Direct supervision – The trainee observes the procedure and then performs it while the supervisor remains in the room, providing immediate guidance and intervention where required.
- Close supervision – The trainee performs the task independently, but the supervisor remains nearby and is available for rapid intervention. The task is checked regularly.
- Local supervision – The trainee performs the task independently while the supervisor is elsewhere within the building or local area and available to attend if needed.
- Remote supervision – The individual has been assessed as competent and performs the task independently. A supervisor remains available for advice or discussion, for example by telephone.
Good trainers will naturally adjust supervision levels as confidence and competency develop. Ideally, individuals should not be assessed as competent until they are ready to take responsibility for the procedure independently as the responsible PIL holder.
Following assessment, you should receive feedback on the outcome promptly. If competency is not achieved, the assessor should provide constructive feedback to help you identify areas for improvement and continue developing your skills with support from your trainer or supervisor.
It is also important to remember that competency assessment involves more than technical skill alone. A strong understanding of ASPA requirements, licence conditions, animal welfare responsibilities, and regulatory compliance will often form part of the assessment process.
What resources are available to support me?
Every establishment will have its own local training framework and competency assessment process. However, many UK establishments use DOPS (Directly Observed Procedural Skills assessments), which are commonly used within medical and veterinary training environments.
DOPS assessments define the criteria required to achieve competency and are usually linked to local Standard Operating Procedures (SOPs) for the relevant technique or skill.
These assessments commonly evaluate performance in areas such as:
- Legal and regulatory compliance
- Animal welfare
- Technical and procedural skill
- Professionalism
- Application of the 3Rs
Most establishments also use scoring systems to support the assessment process and determine the appropriate level of supervision following assessment.
The local supervision framework used at Newcastle University is provided below as a reference.
| Competent: No Supervision required, able to complete the task independently |
|---|
| Requirement to be assessed as COMPETENT: Borderline scores matching (or under) the percentage limit for the task |
| Candidates scoring “Below expectations” or “Borderline” Scores for the specific task are recommended to “Continue Supervision” using one of the following levels |
| Direct Supervision | Close Supervision (Supervisor in the vicinity/room) | Local Supervision (Supervisor in the building/area) | Remote Supervision (Supervisor available via telephone) |
|---|---|---|---|
| Observing the task undertaken by a competent person and then conducting with the supervisor in the same room as the candidate, advice/guidance given for a number of occasions until at a level to progress to Competency | Conducting the task with indirect supervision by a competent person; the task will be checked periodically, and the supervisor is available for rapid intervention | Conducting the task with indirect supervision by a competent person; the task will be checked periodically, and the supervisor is available to attend | Conducting the task with indirect supervision and is assessed as competent. However, the supervisor is aware and is available for discussion to provide advice if necessary |
| If the individual scored any borderlines in the Legal and Compliance / Procedural Category | If the individual scored Meets Expectations in Legal and Compliance, and Procedural, and any borderlines are present in the Animal Welfare Category | If the individual scored Meets Expectations in Legal and Compliance, Procedural and Animal Welfare and any borderlines are present in the Professionalism Category | If the individual scored Meets Expectations in Legal and Compliance, Procedural, Animal Welfare and Professionalism, and any borderlines in the 3Rs Category ONLY |
The Named Training and Competency Officer (NTCO) is responsible for ensuring that staff are appropriately trained, supervised, assessed, and supported until competency has been demonstrated.
The NTCO role may include:
- Setting and maintaining local training standards
- Applying competency frameworks
- Supporting the development of trainers and assessors
- Managing training and competency records
- Overseeing supervision and competency assessment processes
- Supporting Continuing Professional Development (CPD)
If you have questions about maintaining compliance with PIL Standard Condition 17, the NTCO should be your primary point of contact for advice, guidance, and support.
What happens if I don’t comply with PIL Standard Condition 17?
If you carry out procedures independently without the appropriate level of supervision or before being assessed as competent, you are in breach of your Personal Licence conditions and may also place the Project Licence Holder in breach of their licence conditions.
This includes Project Licence Standard Condition 6:
“The licence holder shall ensure that the appropriate level of supervision is provided for all personal licensees carrying out regulated procedures under the authority of this licence.”
Such incidents are likely to be reported by the establishment as potential non-compliance notifications to ASRU. The report may include:
- Details of the procedure performed
- Why the procedure was carried out by an individual who was not yet assessed as competent
- The animals affected
- Any associated welfare concerns
- The outcome of the procedure
- Copies of relevant training and competency records
- Actions the establishment will take to prevent recurrence
Potential consequences may include:
- Retraining
- Increased supervision
- Reassessment of competency
- Suspension or revocation of a Personal Licence in serious cases
It is also important to ensure that competencies remain current. Carrying out procedures after local competency approvals or refresher requirements have expired may also be viewed as non-compliance and could demonstrate a lack of engagement with local policies, training expectations, and competency management processes.
How does ASRU assess compliance with PIL Standard Condition 17?
ASRU assesses compliance with PIL Standard Condition 17 by reviewing how Personal Licence holders are trained, supervised, and assessed as competent before carrying out regulated procedures independently.
During an inspection, ASRU may review Standard Operating Procedures, training frameworks, competency assessment systems, and study-specific training materials relating to regulated procedures. Inspectors may also examine records demonstrating supervision arrangements, competency assessments, and progression through local training frameworks.
Compliance may additionally be assessed through discussions with the Named Veterinary Surgeon (NVS), Named Animal Care and Welfare Officer (NACWO), and Personal Licence holders to confirm that appropriate supervision and competency processes are in place and being followed.
ASRU may also directly observe regulated procedures to assess whether procedures are being performed competently, whether supervision levels are appropriate, and whether individuals are working within the limits of their training and competency.
How do I know if I am complying with PIL Standard Condition 17?
You should be aware of your training record, current competencies, and your stage of training for any procedures you are learning to perform.
You should actively engage with local training and competency systems, particularly when notified that:
- Competencies are approaching expiry
- Refresher training is required
- A break in practice means reassessment may be necessary
Where you no longer require competency in a particular technique, you should inform the Named Training and Competency Officer (NTCO), or update the relevant training management system, so that your records remain accurate and up to date. Clear and organised training records are important, particularly if they are reviewed during an ASRU inspection or audit.
You should also feel confident speaking to your trainer, supervisor, or Project Licence Holder if you do not yet feel comfortable performing a technique independently and believe you require additional supervision or support. This is especially important for new licence holders.