THE Animal Welfare Act 2006 is perhaps the most significant new piece of animal welfare legislation in the United Kingdom since the passing into law of the Protection of Animals Act 1911.
The framing of secondary legislation under the Act therefore offers an almost unprecedented opportunity for a very extensive review of welfare issues in the greyhound industry and the welfare needs of greyhounds throughout their racing careers and into retirement.
Although the consultation closed to further submissions on 22nd July 2009, the DEFRA Consultation on the Welfare of Racing Greyhounds Regulations 2010 can be accessed on line at http://defra.gov.uk/corporate/greyhound=welfare/index.htm
The Society of Greyhound Veterinarians (SGV) finds it hard to avoid the conclusion that this consultation is an opportunity squandered. Although the Charter for the Racing Greyhound, agreed among industry representatives and welfare groups and launched in May 2002, represents a template for greyhound welfare legislation, the consultation document prefers to confine its attention almost exclusively to discussions of the welfare of greyhounds at racing stadia.
Despite the comment made in November 2007 by Lord Donoughue of Ashton’s “Independent Review of the Greyhound Industry in Great Britain”, that “standards vary widely across the industry and we recommend that minimum standards for kennelling and other built accommodation used for the purpose of keeping or housing greyhounds should be laid down in the Regulations”, scant attention is paid to the welfare of greyhounds on breeders’ and rearers’ premises, in trainers’ kennels, at schooling and trials tracks, at public greyhound sales or in retirement.
This is a very significant omission that needs to be addressed as a matter of some urgency before the proposed Statutory Instrument passes into law.
The SGV sees a very real need for regulations covering minimum standards for the construction, management and maintenance of trainer’s kennels, breeding kennels and rearing kennels, besides regulations covering codes of practice for mandatory kennel inspections and for the training, accreditation and licensing of kennel inspectors. No mention is made of these and related issues in the DEFRA Consultation Document.
As far as the licensing of greyhound racing stadia and the monitoring of welfare standards at tracks goes, the SGV is disappointed that the consultation document offers only one model of greyhound track licensing.
Hybrid’ model
The approach to the licensing of greyhound racing stadia follows the “hybrid” model suggested by Lord Donoughue’s review group. The 28 tracks overseen by the Greyhound Board of Great Britain (GBGB) are to be subject solely to a United Kingdom Accreditation Service (UKAS) accreditation scheme, while the somewhat smaller number of independent tracks are to be subject only to local authority licensing.
At time of writing it is not clear what standards UKAS will apply, if indeed the GBGB application for UKAS accreditation is successful, nor is it clear what standards the Local Authorities Co-ordinators of Regulatory Services will advise should be applied to the independent tracks not regulated by GBGB.
The inescapable impression is given that DEFRA is not only seeking the endorsement on one single plan without offering any alternatives but also that the plan it is recommending is presented only in outline. The SGV would have preferred the consultation document to suggest a number of different possible schemes for the licensing and inspection of greyhound racing tracks, each of which had been presented in some detail.
Lord Donoughue proposed that “the Regulations will, in effect, be the lowest common denominator which spells out the minimum legal standards of welfare which must be maintained in greyhound racing”. The SGV is concerned that a robust, transparent, verifiable code of welfare standards should apply throughout the greyhound industry. It is not clear from reading the consultation document how uniform standards across the two codes, or at very least progress towards uniformity, are to be delivered by this bipartite structure for licensing greyhound racing stadia.
It would be regrettable should the DEFRA consultation result in a substantial reduction in the standards currently imposed by the GBGB “Rules of Racing”, or the standard agreed by the Greyhound Forum as expressed in the “Charter and Code of Practice for the Racing Greyhound”.
At a time of rapidly shrinking financial returns in the greyhound industry, what if there arose a widespread perception that standards were not uniform, and that one track licensing arrangement offered a less expensive and lower standard of greyhound welfare that still complied with the law of the land? Might there not be an exodus of tracks from one code to the other with a concomitant lowering of welfare standards?
Consideration is clearly, and rightly in the opinion of the SGV, being given to keeping the cost of imposing the Regulations within reasonable bounds, presumably so that the majority of the generally less profitable independent tracks will be able to comply.
Inherent in this otherwise laudable approach the SGV sees a real risk that lowest common denominator may be set too low for reasons which have more to do with fiscal considerations than with greyhound welfare.
The SGV feels that, although an acceptable compromise can potentially be reached regarding many of the issues discussed in the consultation document, its position differs markedly from that of DEFRA in some significant areas.
The management of greyhounds differs very substantially from that of pet dogs and the nature of the racing greyhound and of greyhound sport combine to produce a range of health and welfare problems not otherwise found in small animal practice. We feel there is thus a clear need for greyhound track vets to receive some specialist training.
Veterinary surgeons engaged in the certification of animals for export, in tuberculin testing, in meat hygiene work, in the inspection of riding establishments and in the treatment of horses injured at horse race meetings all require to be licensed by the relevant regulatory body. This licensing process inevitably requires some degree of post-graduate training.
By comparison, surely veterinary surgeons should also be licensed to carry out greyhound track work only on completion of suitable training? The DEFRA Consultation Document suggests that it might be necessary for greyhound racing promoters to provide kennels at the track for not more than 20% of the greyhounds due to run at any meeting. We note that the authors of the consultation document do not explain how they decided upon this figure of 20%, although they seek supporting evidence from those attempting to makeacase for a higher figure.
Gold standard
In the opinion of the SGV, the provision of one kennel for every runner is the gold standard in these matters, and it is difficult to see how fewer kennels can be made available without compromising the welfare needs of the greyhounds.
It is proposed in the DEFRA consultation document that the keeping by track management of records of the identity of dogs racing at their track should become obligatory and also that data concerning the nature and incidence of injuries sustained by dogs racing at that track should also be kept by the licensed track veterinarian. The SGV would prefer to see all such data recorded in a standard form and held on a single central database.
Accordingly, in summary, the Society of Greyhound Veterinarians would exhort DEFRA to re-open its consultation on the Welfare of Racing Greyhounds Regulations 2010, this time with a far wider remit.
The SGV submission to the DEFRA consultation can be viewed on line, together with a wealth of other news and information of interest to veterinary surgeons who work with greyhounds, at the society’s website www.greyhoundvets.co.uk.
