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Compassion News

RSPCA submission to DEFRA: welfare of racing greyhounds

The welfare of racing greyhounds – the RSPCA response to the APGAW and Donoughue Reports
 

Executive summary

The RSPCA has major concerns about animal welfare issues relating to the racing greyhound industry, and welcomes this chance to offer a detailed report on the problems as the Society sees them.

This document reflects on both the APGAW and Donoughue reports, and would like to see aspects of these used as a starting point for governmental changes to the industry.  However, neither covers all the aspects that the RSPCA, as an animal welfare charity, is concerned about.  Therefore the Society would implore you to realise that simply using these reports as a blueprint for change would be a major mistake.

Animal welfare issues concerning the RSPCA include the following:
At least 20 greyhounds a day - either puppies which do not make the track, or 'retired' dogs aged three or four - simply 'disappear', presumed killed.
Dogs are generally kennelled for 23 hours a day for their entire racing life – if not longer - usually two dogs per small kennel, sharing one bed.
To avoid fighting in cramped kennels, dogs are muzzled as a long-term solution
Travelling to race meetings can involve long trips in cages so small the dogs cannot properly stand up or lie down.

The recommendations laid out in the following document look at how these, and other, issues can best be improved.  In some cases, our recommendations reflect those of the APGAW and Donoughue reports, while in others, the Society disagrees with or expands on their opinions.  To summarise our findings, the RSPCA recommends the following:

Breeding/Importation:
Tackle overbreeding; better enforcement of current legislation (the Society agrees with APGAW and Donoughue)
Temperament should be a factor in breeding to reduce potential re-homing problems (RSPCA)

Registration:
Microchipping should be considered as a method of identification; registration fee increased with proportion returned for 'satisfactory' retirement provision (APGAW/Donoughue)
Registration of all greyhounds at 12-15 weeks; centralised database to track dogs; only registered greyhounds allowed to race (Donoughue)

Racing and Trialling:
Greyhounds should only race under stud-book names (Donoughue)
Welfare groups should be allowed access to tracks (APGAW)
Further research into when dogs can start to race (Donoughue)
Regulations should define 'racing' and 'trialling' to ensure welfare (RSPCA)
Protocols introduced to safeguard greyhounds at tracks, e.g. warming up before a race (RSPCA)
Track condition should be regulated to ensure best possible standard (APGAW)
New research into track surface and design should be taken into account (RSPCA)
Random drug testing should be compulsory at all tracks (Donoughue)
Information on prohibited/tested drugs should be updated regularly (RSPCA)
Compulsory veterinary attendance at all racing or trialling should be regulated (APGAW/Donoughue)
Removal of dogs from races should be enforced if owners/trainers are unhappy with the track conditions (RSPCA)
Each dog should be examined prior to racing or trialling, with unfit dogs withdrawn (RSPCA)
Vets should be more independent from the industry (more so than recommended by Donoughue)
Vets should be given greyhound-specific training, which should be a condition of licensing (RSPCA)
Injury statistics must be recorded on a central database (APGAW/Donoughue), and should include injuries related to training and trialling (RSPCA)
Remedial action must be taken if a track has a high number of injuries (RSPCA)
Injury data should be made publicly available (APGAW)
Veteran and handicapped races should be increased to extend careers of dogs (APGAW/Donoughue), providing these did not adversely affect older dogs (APGAW)
Dogs should race less, and be given a 'personalised' training schedule (APGAW/RSPCA)

Kennelling and Management:
Kennels and breeding establishments should be regularly inspected by independent inspectors (APGAW/Donoughue)
The number of Stipendary Stewards should be increased urgently (APGAW)
Financial support for the improvement of kennels is a high priority (RSPCA)
Minimum standards for kennels should be regulated (Donoughue), but the standards must be decided upon – potentially those recommended by the English Greyhound Forum (RSPCA)
Small numbers of dogs could be kept in a home environment (APGAW)
Kennelling at breeding establishments should reflect different conditions of dogs (e.g. whelping, pregnant), and introduce dogs to the conditions they may encounter if rehomed (RSPCA)
All greyhounds should be fed a suitable diet (RSPCA) and research should be conducted to establish their nutritional needs (Donoughue)
It is essential that greyhound transport is regulated, given the large number of journeys taken often over large distances (RSPCA)
Greyhounds must be able to stand up/turn around (APGAW) and lie down naturally (RSPCA) when being transported
Standards regarding provision of water, food, ventilation during transport should be introduced (RSPCA)
Long-term muzzling of dogs is of extreme concern, and management techniques which encourage this should be examined as a matter of urgency (RSPCA)
Staff should be trained to a certain standard (APGAW)
Greyhound trainers should be trained to reduce the number of dogs that never make it to the track, with methods based on positive reward systems (RSPCA)
Greyhounds receive no specific fitness training, which the RSPCA believes is essential (RSPCA)

Retirement:
All tracks should include an associated rehoming scheme; racing/betting industries should increase financial support for retirement provision (APGAW/Donoughue)
Euthanasia should only be considered as a last resort, and illegal if performed by anyone other than a vet (APGAW)
Regulations must ensure that it is the owner's responsibility to ensure an animal's needs are met throughout its retirement (RSPCA)

Regulation:
The Government is best placed to implement proposed new policies on greyhound racing, and draft appropriate regulations (RSPCA)
Transparency and accountability are vital if the public is to trust the industry, and the GBGB (Donoughue) would, in the RSPCA's opinion, fail both in this respect, and in respect of the welfare of the greyhounds
Regulations should ensure welfare and integrity; welfare should receive a slice of industry income (RSPCA)
All interest groups should have equal weight of influence (APGAW), while the RSPCA strongly opposes Donoughue's model which appears to be a continuation of the status quo.

For the 20 greyhounds a day that simply 'disappear', and for the thousands involved in racing which endure primitive living conditions, it is vital that the Government takes this rare opportunity to install progressive and effective change. The treatment of these dogs is simply unacceptable, and positive steps must be implemented to ensure this does not continue.

The RSPCA believes that the greyhound racing industry has flaunted its responsibilities and exploited the commodity – the dogs – that brings in billions of pounds a year, and feels it cannot be trusted to make the necessary changes without strong intervention from the Government.

Any action taken should aim to reduce the numbers of dogs discarded from the sport, and drastically improve conditions for those taking part. Dogs must be considered for their entire lives – from cradle to grave – and not simply for the relatively short time they spend on the track. If the public were fully aware of the conditions suffered by racing greyhounds, the Society believes they, like us, would be appalled.

Greyhound racing must be transparent and accountable, and the Society feels it is the Government's responsibility to ensure this happens. So while the RSPCA agrees with much of that proposed by APGAW and Donoughue, it urges you to look at our carefully-weighed recommendations which we believe would constitute an effective and humane new regulatory model for a discredited industry.

Contents

Executive summary          1
Background          5

Welfare           5
Breeding, importation and registration of greyhounds    5
Breeding/importation       5
Registration         6

Racing and trialling of greyhounds       6
General         6
Management at tracks       7
Track design and maintenance      7
The use of drugs        7
Veterinary attendance       7
Injury records         8
Extending racing careers       8

Kennelling and management       9
General kennelling        9
Trainers' kennels        9
Kennelling at breeding establishments     10
Kennelling at race tracks       10
Nutrition         10
Transport         10
Muzzling of greyhounds       11
Training for staff        11
Fitness training for greyhounds      11

Retirement          11

Regulation          12

 

Background
The RSPCA has major concerns about the welfare of greyhounds and welcomes this opportunity to respond to both the Associate Parliamentary Group for Animal Welfare (APGAW) and 'Donoughue' reports.  The RSPCA has been impressed by the thoroughness of the reports and the consideration given to animal welfare. However, the differing remits of these reports must be recognised.  Whilst the independent APGAW inquiry was set up specifically to investigate the welfare issues surrounding racing greyhounds in England, the Donoughue report was financed by the industry to review the entire greyhound industry, with welfare being only one aspect.  Both reports were commissioned in the wake of the 'Seaham incident', after the Sunday Times printed an article exposing the alleged mass destruction of unwanted greyhounds in County Durham.  Therefore, although both reports cover certain aspects of greyhound racing in great detail, they both fail to comprehensively consider all the welfare needs of a greyhound at every stage of its life. The RSPCA believes that Regulations must not only protect, but also promote the welfare of greyhounds from cradle to grave.

It is hoped that the scientific knowledge on the needs of greyhounds will grow in the near future, when the results from two industry commissioned research projects into track design and surface become available. The RSPCA believes it to be essential that further research is commissioned so that it can be better understood how to adequately meet the needs of greyhounds, and that sufficient independent funding is secured for this.  For this reason, the RSPCA believes that the regulations need to be flexible so that developments in knowledge can be applied and they do not date too quickly.  In the interim, the RSPCA believes that the welfare offence provides a suitable starting point for the protection of greyhound welfare and that these dogs must be granted at least the same level of protection as any other dog.

The RSPCA strongly believes that the regulations for the welfare of greyhounds must apply to all tracks and accommodation, whether they are currently independent or licensed. The Society has concerns about how effective a two tiered structure, as proposed by Government, for the two aspects of the sector will be.  To ensure consistency of approach there should be one set of standards that apply to all irrespective of whether they are independent or not and one regulatory body.

The aim of this document is to show areas of agreement between the two reports and further areas of consideration for Government regulations.  The RSPCA's has decided to limit its comments here to  the aspects and considerations that it believes are essential in ensuring effective improvements to animal welfare.

Welfare issues
a) Breeding, importation and registration of greyhounds
i) Breeding/importation
The RSPCA believes that regulations introduced for greyhounds under section 12 of the Animal Welfare Act 2006 must aim to equate the number of greyhounds being bred or imported for racing to the numbers that can be found homes should they retire, become injured or simply prove unsuitable for racing.  This may be achieved not only by introducing measures to reduce the demand and thereby the numbers of greyhounds being bred or imported but also by improving the welfare and suitability of dogs bred.  The RSPCA believes this is a fundamental issue that must be addressed if the welfare of greyhounds used for racing is to be improved and protected.

The RSPCA is therefore in agreement with the recommendations from both the APGAW and Donoughue reports that:
Defra should engage with the Irish authorities over joint initiatives to tackle over-breeding
All breeders and their premises should be licensed by the agreed regulatory body and be regularly inspected so that current legislation may be better enforced.  Standards for breeding establishments are further discussed in section 2) c) iii).

This does highlight a potential difficulty in regulation as both local authorities and a new regulator may have an interest in this area.

Both reports suggest that further consideration should be given to the characteristics for which greyhounds are bred.  However, the RSPCA believes that consideration should not only be given to the potential to breed from greyhounds that are less prone to injury but also for temperament.  This would address the welfare considerations both during their racing careers and afterwards.   The RSPCA considers it essential that injury data are kept on a centralised database (see Section 2) b) vi)).  It is possible that in the future this database could be analysed to identify lines of dogs that are less prone to injury.

ii) Registration
"The objective for the whole industry, therefore, should be to institute a regime whereby, through registration, record keeping and tracking, the identity and location of a greyhound is known from birth until retirement, including what happens to each greyhound at the point of retirement."

The RSPCA believes that regulations must ensure that all greyhounds can be tracked throughout their lives, and missing greyhounds easily identified.  This may be achieved by ensuring that all greyhounds are permanently identified and that a full, accessible and up-to-date central record is kept of information about each greyhound, whether bred or imported.  If numbers of dogs are to be controlled then this is a central aspect by providing an effective and transparent account for each dog.

The RSPCA is in agreement with the recommendations from both the APGAW and Donoughue reports that:
Microchipping should be considered as an alternative or additional method of identification for welfare reasons.
The registration fee should be significantly increased and a proportion could be returned to the owner when evidence (such as proof of change of ownership) is received that their greyhound was treated humanely at the end of its racing career

Whilst the APGAW report makes the general recommendation that the industry must improve its tracking of dogs as a matter of urgency, the RSPCA believes the following further recommendations of the Donoughue report to be essential:
There should be a centralised database to enable the tracking of all dogs from registration to retirement.  Notification should be given to the database when any greyhound is retired from racing or there is a change of ownership
All greyhounds should be registered by the time of earmarking and/or microchipping (12-15 weeks) so that they can be tracked soon after birth.  If a greyhound is purchased that is already earmarked/microchipped, there should be a legal requirement for the buyer to register it on acquisition.
Only greyhounds registered on the national database should be allowed to race, on any track.

b) Racing and trialling of greyhounds
i) General
The RSPCA also supports the recommendation from the Donoughue report that greyhounds on all tracks should only be allowed to race under their Stud-Book names.  The Society welcomes and supports the APGAW recommendation that welfare groups should be allowed access to tracks.  These two factors will help to improve transparency and accountability of the industry - something that is central to effective regulation.

The RSPCA strongly supports the recommendation from the Donoughue report that the age at which greyhounds are allowed to start racing requires further research.  The age is currently 15 months, although there has been no scientific research to establish the effect that racing at this age (or any other age) has on welfare.

The RSPCA believes that any regulations should clearly define what is meant by racing and trialling.
ii) Management at tracks
Neither the APGAW nor the Donoughue reports mentioned the management of greyhounds at tracks. The RSPCA believes that there must be specific protocols in place to regulate how a greyhound is managed, from the time it arrives at a track until the time it leaves.  For example, this may include the need for a greyhound to warm up before and warm down after a race or trial.  This is an important area that needs to be addressed.

iii) Track design and maintenance
The RSPCA believes that that the regulations must ensure that all tracks, including schooling tracks, are maintained to the best possible standards, and that this should be a condition of licensing. 

The RSPCA agrees with the suggestion in the APGAW report that the surface, design, dimension and most importantly maintenance of a track is likely to have an impact on the welfare of the greyhounds racing on it, and that tracks should be maintained to the best possible standard.

However, the RSPCA believes that the two industry commissioned research projects into track surface and design should be taken into account when forming guidelines for track standards.  Such guidelines should be regularly reviewed and updated as new science is discovered.  Thus such detailed information may not be suited for the regulations, but they should reflect the general principles of track design and maintenance required for ensuring greyhound welfare.

iv) The use of drugs
The RSPCA believes that regulations should prohibit the use of any substances in a race or trial that enhance or degrade performance or, more importantly, mask pain and therefore enable a greyhound to run when it is injured. 

A programme of random testing for drug misuse is already in place for National Greyhound Racing Club (NGRC) licensed tracks and as suggested in the Donoughue report, the RSPCA believes that this must be compulsory at all tracks.  Not only is this necessary from an animal welfare perspective, but also to ensure the integrity of the sport. 

The RSPCA believes that it is important that all drugs that are prohibited, the drugs to be tested for, and who should do the testing should be specified and updated regularly.

v) Veterinary attendance
The RSPCA believes that there should be regulations to ensure that a vet is in attendance at all tracks, whenever racing or trialling takes place and welcomes the fact that both reports state this should be a statutory requirement.  Attendance at schooling tracks may be considered in the future.  Their responsibilities should include ensuring that all greyhounds are fit to race, that track conditions are safe for racing, and to provide essential veterinary care (including euthanasia if necessary) for injured greyhounds.

The RSPCA supports the recommendations from both the APGAW and Donoughue reports that:
Veterinary attendance should be compulsory at all tracks whenever racing or trialling takes place
Owners/trainers should be entitled to withdraw their greyhounds from a race if the track vet believes conditions to be unsafe for racing.  Further, the RSPCA believes that removal of the dog from the race should actually be enforced in these circumstances.

The RSPCA also supports the further recommendations from the Donoughue report that:
Track vets should be required to examine each greyhound prior to racing or trialling as part of the statutory requirement.  The RSPCA believes that any greyhound considered to be unfit should not be allowed to race.
Track vets should be required to keep records on injuries to and treatment of greyhounds occurring between the time of kennelling and the time the greyhounds leave the track, and submit these to the industry regulator. This is discussed further in section 2) b) vi) below.

Minimum veterinary facilities should be agreed and the sport's regulator should inspect veterinary provision at tracks.  Where appropriate, improvements should be made before a track operator's licence is approved or renewed.

Reference is made in both reports to the necessity for vets to be more independent from the industry, which the RSPCA considers to be imperative. However, the RSPCA does not believe that the system proposed by the Donoughue report to achieve this would be sufficient.  Vets would still effectively be employed by the tracks and would therefore not be given the autonomy they require.

Whilst the APGAW report recommends that the Royal College of Veterinary Surgeons (RCVS) considers introducing a greyhound specialism for the veterinary profession, the Donoughue report suggests that appropriate training and accreditation should be conditions for vets being licensed. The RSPCA is in favour of the recommendation from both reports that there should be greyhound specific training for vets, and believes that this should be a condition of licensing.

vi) Injury Records
The RSPCA is extremely concerned (as are both the reports) about the poor collection of injury data within the industry, which has had years to rectify the problem and yet still has not addressed this vital issue. 

The Society believes that regulations should ensure that all injury and racing longevity data are kept in a standard format and recorded on a central database.  This data would not only help to highlight tracks that had a high incidence of injury so that remedial action could be taken, but would also be useful as an epidemiological research resource.  Futhermore, it may in the future be used to facilitate the breeding of dogs that are less prone to injury.

The RSPCA supports the recommendation from both reports that all validated (by a vet) track injury statistics must be recorded on a central database and the data to be collected should be detailed in the legislation.  The Society further believes that this should include all injuries that occur in relation to training, trialling or racing (unless clearly caused by factors independent of racing), whether they appear on the track or within a reasonable period after the animal has left the track.

The RSPCA also supports the APGAW recommendation that remedial action must be taken if a greyhound track has an unusually high number of injuries.

However, the RSPCA does not support the suggestion in the Donoughue report that injury data should be anonymised and not made publicly available, and favours the APGAW recommendation that all injury data must be published and made publicly available.  This would add pressure on tracks with high injury incidence to make prompt improvements.  Furthermore, if the public is to regain faith in the greyhound industry, it must be seen to be measurable, open and accountable.

vii) Extending racing careers
The RSPCA believes that the regulations should attempt to prolong the racing careers of greyhounds, so that fewer dogs are required by the industry.

The RSPCA is in agreement with the recommendation from both reports that measures should be taken to increase veteran and handicapped races.  However, as the APGAW report suggests, it is essential to establish exactly how this would affect older dogs, and have procedures in place to ensure that it did not impact negatively on their welfare.

The APGAW report suggests that each individual dog should race less often so that it has an increased likelihood of enjoying an extended racing career.  The RSPCA believes that each greyhound should have an exercise schedule that is specific to its needs so that there is a suitable balance between exercise and rest.

c) Kennelling and Management
i) General kennelling
Greyhounds may be kept in kennels for varying amounts of time in breeding establishments, at tracks and in trainer's kennels.  Each of these will be discussed in more detail in the following sections.  The RSPCA agrees with the recommendation from both reports that all kennels and breeding establishments should be regularly inspected to ensure that they conform to standards which are specific to each type of kennelling.  All inspectors must be independent, have no commercial interest in the premises under inspection and should have received appropriate training.

The RSPCA is firmly in agreement with the suggestion in the APGAW report that the current regulatory body should increase its number of Stipendary Stewards as a matter of urgency.

Further, the RSPCA believes that the industry should increase the financial support for the improvement of kennels as a high priority.

ii) Trainers Kennels
"Typically a racing greyhound will live permanently in a trainers kennels for two to three years.  In the case of a greyhound which is kept by a trainer in its retirement, this may be as much as 12 years."  The RSPCA believes that it is essential that the welfare needs of greyhounds are met whilst they are living in a kennel environment on a long term basis.

The RSPCA strongly supports the Donoughue recommendation that minimum standards for kennelling and other built accommodation for keeping or housing greyhounds should be laid down in the regulations.  Further, the RSPCA supports the APGAW suggestion that when an owner has a small number of dogs, they should be allowed to keep them in a home environment, as long as they are willing for their premises to be inspected.  However, both reports fail to consider what the standards for kennels to be inspected against should be.

Under s9 of the Animal Welfare Act the welfare needs of any kept animal must be met and this applies to greyhounds kept in trainers' kennels.  This is likely to pose a significant challenge to many trainers, as many kennels are far from adequate to meet this requirement.  However, they have a duty to do so.  Failure to meet certain needs at this stage of a greyhound's life is likely to have a significant impact on its behaviour later on in life.  This is of particular significance when greyhounds are to be rehomed.

Long-term kennelling of any dog can have significant welfare impacts on the animal and so care must be taken in designing standards.  Any standards should be regularly reviewed and updated as new science is discovered.

However, s9 of the Animal Welfare Act and possibly the general dog code provide parameters in which such standards should be modelled:
its need for a suitable environment,
its need for a suitable diet,
its need to be able to exhibit normal behaviour patterns,
any need it has to be housed with, or apart from, other animals, and
its need to be protected from pain, suffering, injury and disease

The RSPCA believes that standards could be based on the guidelines for kennel standards from the English Greyhound Forum.  However, these would have to be adapted and regularly reviewed to ensure that they meet both the social and behavioural needs of dogs kennelled on a long term basis.

iii) Kennelling at breeding establishments
The RSPCA believes that in addition to the above, any standards for breeding establishments must ensure that the differing needs of stud animals, pregnant, whelping and lactating bitches and the needs of their puppies before, during and after weaning are met.  Keeping in mind the whole life of a greyhound, it is essential that puppies are introduced to the circumstances and conditions they are likely to encounter as adults, including optimal conditions for socialising, so that they are more suitable for rehoming.

iv) Kennelling at race tracks
Kennel requirements at race-tracks are likely to be very different compared to those of breeding establishments and trainers kennels, due to the fact that greyhounds are kept in track kennels for considerably shorter periods of time. 

However, further consideration must be given as to how best to meet the needs of greyhounds being kennelled before a race.

v) Nutrition
"Athletic performance depends on genetics, training and nutrition.  All three must be optimal for maximal performance.  A deficiency in any one of these factors limits performance."

The RSPCA considers it to be essential that all greyhounds are fed a suitable diet to provide them with appropriate nutrition for optimal health and performance.  It is important that the food type, amount and feeding method are matched to the animal's needs.

The Donoughue report suggests that it is essential that research is conducted to establish the nutritional needs of racing greyhounds at all stages of their life, and the RSPCA would welcome this.  Regulations should require that all greyhounds be fed an appropriate diet to meet these needs.

vi) Transport
Given the large number of journeys for individual dogs involved in greyhound racing, sometimes over large distances, the RSPCA considers it essential that greyhound transport is regulated.  Furthermore, the Society has done its own trials based on the current standards suggested by industry and does not believe the dogs' welfare can be adequately protected if such standards are continued to be used. 

The RSPCA supports the APGAW recommendation that greyhounds must be able to stand up at full height and turn around whenever they are transported.  Further, the RSPCA believes that they should also be able to lie in a natural position.

However, there are other factors to consider during transport.  The RSPCA believes that it is essential that the regulations ensure that greyhounds are afforded at least the same level of detail about their welfare during transport as farmed livestock.  In particular, the RSPCA believes that consideration should be given to:
Fitness to travel
Travelling conditions.  This would include:
Temperature range/humidity (information on the thermoneutral zone for dogs should be available from the Royal Veterinary College).
Ventilation
Space (animals should be able to stand and sit erect, turn around and lie in a comfortable position).
Flooring
Feeding and watering intervals (veterinary advice on feeding and watering intervals for dogs of different ages will be available from the Royal Veterinary College).
Maximum journey times

Any guidelines should take into account the recommendations of the scientific report of the European Food Safety Authority on the Welfare of Animals During Transport (p106-112).
vii) Muzzling of greyhounds
The RSPCA believes that muzzles are sometime necessary as part of responsible dog ownership, however they should not be used as a long-term measure.  If such measures are needed this highlights the fundamental problems with the way greyhounds are kept at present.  The Society is extremely concerned at the management techniques currently used, such as kennelling in pairs but only allowing the dogs the use of one bed thus increasing the chances of fighting.

viii) Training for staff
The RSPCA considers working with racing greyhounds to be a specialist vocation, and as such is in agreement with the APGAW recommendation that it should be a condition of the licensing of tracks and trainers that a certain standard of training for all staff including kennel hands should be introduced.  The RSPCA agrees that all training should have a welfare component and, if appropriate to the post, should include assessment of practical skills in the care of greyhounds.  However, the RSPCA cannot comment on the two NVQs developed by the Industry for track maintenance and kennel hands without first seeing a copy of the course outline.

The RSPCA is highly concerned that there is currently no requirement for greyhound trainers to themselves receive any training on suitable methods for training greyhounds.  Given that it has been estimated that an average of 2,478 earmarked greyhounds never make it to the track (APGAW, p16), it is imperative that greyhounds are skilfully trained to chase by their trainers, to minimise the number of dogs being discarded as 'non-chasers.'  The RSPCA recommends that a certain standard of training on "training methods" must be introduced for trainers and that attending such training should be a condition of their licensing.  Any training methods for greyhounds should be based on positive reward systems. Training should never involve the use of live animals such as rabbits.

ix) Fitness training for greyhounds
"Examples of training-induced changes include increased bone mass, muscle hypertrophy, increased mitochondrial density in muscle and plasma volume expansion.  All of these changes support enhanced performance."

Greyhounds are currently provided with no specific fitness training, and both the APGAW and Donoughue reports failed to mention this fundamental welfare issue. The RSPCA believes that a programme of fitness training is essential for all greyhounds.  Adequate fitness training is likely to have many benefits, in particular, the reduction of injuries.

d) Retirement
The RSPCA believes that rehoming or being retained by the owner as a companion animal should be the ideal fate of greyhounds once they have retired from racing.  Euthanasia should only be used as a last resort and must be carried out humanely by a veterinary surgeon. 

The RSPCA is therefore in agreement with the recommendations from both reports that:
All greyhound tracks as a condition of their licence should include an associated rehoming scheme
Racing and betting industries should increase the allocation of financial support for retirement provision

The RSPCA also agrees with the recommendation from the APGAW report that euthanasia should only be considered as a last resort, and it should be illegal for a greyhound to be put down by anyone other than a suitably qualified person, e.g. a vet.

Regulations must ensure that the responsibility is on the owner to ensure that the needs of the animal will be met throughout its retirement.

Regulation
As indicated at the beginning of this document the RSPCA has decided not to set out a model it believes will effect good regulation.  Instead the previous section outlines the main welfare concerns the Society believes should be addressed by legislation and this section sets out the important principles of regulation that should be followed to ensure the improvement in welfare.  In the Society's view Government is best placed to implement this proposed 'policy' and draft appropriate regulations.

Having considered the issue of regulation for quite some time the RSPCA believes that it is over simplistic to describe the choice of regulatory models for the racing greyhound industry purely in terms of 'self regulation' and 'statutory regulation'.

However, regulation will involve a choice in the degrees of state involvement, transparency and accountability.  It is also essential that the desired regulatory outcomes are clear and agreed and that mechanisms for monitoring and performance measurement are established from the outset.

The Government has acknowledged its commitment to "an efficient, modern and respected regulatory body" but that "the industry needs to introduce significant reform if it is going to meet the welfare standards expected in the twenty first century…".  Thus the RSPCA is pleased to see that animal welfare concerns are high on the Government's agenda and there is acceptance that current practices and systems are not acceptable.

The Better Regulation Task Force (BRTF) was set up in 1997 to advise the Government on improving the quality of regulation.  The BRTF described the principles of better regulation as; transparency, accountability, targeting, consistency and proportionality.  These principles are important and the RSPCA believes that they are central to ensuring positive welfare outcomes for racing greyhounds.   

The RSPCA therefore believes that when assessing the relative merits of the regulatory model produced by Government it is important to be able to identify the following areas:
The desired regulatory outcomes,
The lines of accountability on welfare issues,
Transparency on welfare issues, and
The monitoring and performance measurement.

Although the APGAW report makes welcome recommendations to ensure transparency in relation to injury statistics, it does not deal with the concepts of accountability and transparency in any depth and the RSPCA believes this is important in developing an effective model.

The Donoughue report pays lip service to these concepts but fails to propose a new, more meaningful role for those concerned purely with the welfare of greyhounds.  The RSPCA also believes that Donoughue only deals with those issues in a very narrow context of internal relationships within the industry and fails to address the much wider external relationship issues.  Because of the failures of the past and the lack of meaningful changes proposed for the future the Society does not believe that the welfare of racing greyhounds would be adequately protected or the public regain its confidence in the industry if they were implemented in this way.

The RSPCA believes that the GBGB as described by Lord Donoughue is likely to fail to satisfy the requirement that it be transparent and accountable.  It provides for regulation by six committees which will be self-appointing from amongst themselves.  These would appear to be made up from the current people who control licensed greyhound racing in this country and who have failed so singularly in the past (the latter acknowledged by Government). 

The Society is also concerned at the lack of importance given to inspection under the GBGB.  Both APGAW and Defra have indicated that the current number of seven Stipendiary Stewards is wholly inadequate, even for the current system of inspections which is not sufficiently rigorous, the report indicates there may be more tracks and areas to inspect.  The Donoughue report states that this number might be increased to twelve if funding were available, but this number is unlikely to be sufficient.

Further, there does not appear to be any built-in process of review to assess the effectiveness of the structure, something that is key to monitoring performance.

The body which would be regulating most greyhound racing in England would only have a voluntary source of funding (the voluntary levy from just 37 bookmakers).  Thus no long-term plans or structures could effectively be put in place for the model in case the funding was withdrawn.  Furthermore, the bookmakers at present have significant control over how the funding is spent.  The RSPCA believes that welfare and integrity should be top-sliced from the budget and the needs of these crucial areas should be met ahead of other priorities.  Without some safeguards this will always be subject to commercial pressures.

The RSPCA believes that the GBGB to be a continuation of the status quo in terms of representation from different sectors.  Interestingly APGAW proposed that greyhound racing be regulated by a broadened independent body, having a significant number of representatives from animal welfare organisations as well as the independent sector and veterinary profession.  APGAW called for an equal weight of influence from all interest groups involved.  This latter point is something the RSPCA would support.

Finally, the Donoughue report appears to fail to acknowledge that, due to devolution, there is likely to be different regulation in the different countries.  Thus even the title of the new body is not representative of the situation.

The RSPCA is extremely concerned at the lack of real commitment in the Donoughue report to transparency and accountability.  These two factors are central to effective regulation but also central to improving public confidence in an industry.  However a pre-requisite to this is that the policy objectives (i.e. desired regulatory outcomes) must be clearly defined and effectively communicated to the industry.  Those affected must be clear of their legal obligations and should be given time and support to comply, likewise the consequences of non-compliance should be made abundantly clear.

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