The California Veterinary Medical Board on Oct. 22 approved proposed modified text for the alternate veterinary premises regulations and authorized a 15-day public comment period, with delegation to the executive officer to adopt the changes if no adverse comments are received.

Why it matters: the package updates standards for mobile and alternate veterinary premises (including mobile veterinary premises formerly described as "small animal mobile clinics") and clarifies which equipment and space requirements apply depending on whether services are provided from within a vehicle or out of it. The Office of Administrative Law (OAL) had flagged clarity and formatting issues that the board and stakeholders worked to resolve.

What the board did

Board counsel and staff summarized OAL's review. OAL asked the board to remove language such as "if applicable" where it caused ambiguity and to ensure new text was properly identified for notice. After meetings with regulation counsel, members of the Mobile/Alternate Premises drafting group, and representatives from the California Veterinary Medical Association (CVMA), staff proposed modified language and formatting changes. The board then voted to post the modified text for a 15-day public comment period and to delegate adoption authority to the executive officer if no adverse comments are received.

Discussion points

- Diagnostic imaging language: OAL questioned a provision that used "if applicable" in a sentence about diagnostic imaging during surgery. Stakeholders debated whether modern regulatory language should require "equipment for viewing radiographs" or broader "diagnostic imaging" equipment. One commenter said the draft language was "way too specific" and urged restoring the broader term "diagnostic imaging," noting that CT and MRI images may be reviewed on laptops during operations and that modalities beyond radiographs are sometimes used in nonorthopedic surgeries. After stakeholder discussion, staff revised the language to clarify when radiograph viewing must be available (for orthopedic surgery) and to remove the ambiguous "if applicable" phrase where it would create scope confusion.

- Mobile premises scope: The draft previously limited regulations to "small animal mobile clinics." Staff said the intent of the package is to broaden the scope to "mobile veterinary premises" that cover both small and large animal practices and to distinguish requirements that apply when services are delivered within a vehicle from requirements that apply when services are delivered from the vehicle but not within it.

Public comment and vote

The board took limited public comment from CVMA representatives and from veterinarians and then opened the motion for a roll-call vote. The motion to approve the proposed modified text for a 15-day comment period, with delegation to the executive officer to adopt if no adverse comments are received and to make technical, non-substantive changes as needed, passed on a roll call with the members present voting in the affirmative.

Ending: staff will post the 15-day notice and continue to coordinate with OAL; if no adverse comments are submitted the executive officer may proceed to adopt the changes and complete the rulemaking file.