Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Memorandum submitted by Greyhounds UK

Supporters: Alexandra Bastedo, Jean Boht, Rory Bremner, Simon Callow, Jilly Cooper, Charlotte Cornwell, Annette Crosbie, Rolf Harris, Sir John Harvey-Jones, Joanna Lumley, Dame Diana Rigg, Richard Wilson.


    —  There has been widespread and sustained concern about the welfare of racing greyhounds in Parliament and among welfare groups for more than a decade.

    —  In the self-regulating greyhound racing industry, cruelty is institutionalised and welfare for the dogs competes unsuccessfully with business priorities.

    —  The draft Bill fails the greyhounds. While it includes provision for licensing, registration and a Code of Practice which would protect greyhounds, these animals are last in the line for attention (in 2010). The greyhound industry is left in the meantime, maybe permanently, to its own devices.

    —  It is not clear what evidence Defra would collect in 2010 to decide what then needs to be done for greyhounds.

    —  The National Greyhound Racing Club exists to protect the bookmakers not the dogs. Their Rules are not a welfare Code of Practice.

    —  Greyhound racing is a medium for betting and generates £millions in profits for the bookmakers and track owners and revenue for the Treasury.

    —  Veterinary surgeons at all greyhound tracks should be independent and not directly employed by track management.

    —  Independent scrutiny of the greyhound racing industry is vital to ensure greyhound welfare is not compromised by profit. Action under the Bill's provisions is needed urgently.

  1.  Paragraph 13 of the Regulatory Impact Assessment reports widespread support in those responding to the Consultation for better regulation of greyhound tracks. The concerns we expressed in our response to the consultation went wider and covered the greyhounds' welfare before, during and after racing. Nearly 300 Members of Parliament signified their concerns about greyhound welfare by putting their names to an Early Day Motion earlier this year, 13 years after the Home Affairs Committee recommended that profits of track owners and bookmakers should be directed to establish sanctuaries for greyhounds when their racing life is over. Those recommendations were never actioned.

  2.  In the 75 years since greyhound racing was introduced as a medium for betting in this country, a culture of institutionalised animal cruelty has developed within the greyhound industry, sanctioned by Government. This self-regulating industry is a closed world, defensive and without independent inspection from outside. Welfare for the dogs competes with business priorities of restaurants, lounges for human customers. Lack of organised arrangements for looking after the dogs when they are past racing and surplus to the industry's requirements results in premature death and abandonment.

  3.  Hopes were high that a 21st century Animal Welfare Bill would deliver protection for greyhounds. Our conclusion on examination of the proposals in the draft Bill is that the Government has failed the greyhounds not by accident but by design.

  4.  Our comments on clauses in the draft Bill are linked to statements in the Explanatory Notes and Regulatory Impact Assessment (in particular Annex H).

  5.  Following are the passages in those three documents which are relevant in considering the welfare of greyhounds:

    (a)  The power to make regulations for promoting welfare among animals being used in sport is in Clause 6(2)(a)(v) of the draft Bill.

    (b)  The power to license and register activities involving animals (Clause 6(2)(h) and (i)) which then invokes the powers of entry and inspection contained in Clause 37 of the Bill.

    (c)  Clause 6(2)(q) provides for bodies with advisory functions on animal welfare.

    (d)  Clauses 7 and 8 provide the power to issue Codes of Practice for particular categories of animal care. As paragraph 49 of the Explanatory Notes indicates, Codes of Practice issued under the Bill will be capable of being evidence of either an offence under the Bill or compliance with its requirements.

    (e)  Paragraph 29 of the regulatory Impact Assessment describes Option 3—the draft Bill which is now before the Committee—and anticipates that within five years of the Act coming into force, regulations and Codes of Practice would be introduced and enforced by local authorities in relation to, among others, "The welfare of greyhounds at race tracks".

  6.  However, Annex H to the Regulatory Impact Assessment considers a proposal to licence/register kennels at "Dog Race Tracks" and includes the following statements:

    (a)  "The National Greyhound Racing Club (NGRC) works to a Code of practice."

    (b)  "[NGRC] tracks attract off-course betting from large betting companies and it is suggested, though not proved, that this could be to the detriment of the welfare of the dogs."

    (c)  "Over the last few years there has been a growing impetus within the racing industry to raise welfare standards."

    (d)  "The British Greyhound Racing Board (BGRB) is in the process of drawing up proposals for further reform and in these circumstances it is premature for government to assess the extent to which government regulation would be necessary to raise standards."

    (e)  "Consideration is being given to self-regulation by the NGRC, who would also regulate non-NGRC tracks—such regulation would not affect local authority costs."

    (f)  In Annex L—Regulations Timetable—Regulation of Greyhounds is targeted in year 2010.

  7.  Taken together, the provisions described above show that while the Government has acknowledged widespread support for action to licence, register, introduce Codes of Practice to protect greyhounds, it has chosen not to do anything for five years and even then would rather leave it to self-regulation. Without any Code of Practice in the meantime, there will be no yardstick against which to judge whether the general offences of cruelty and suffering have been committed against greyhounds for which some prosecuting authorities already expect a lower standard of care.

  8.  The NGRC is a self-appointed undemocratic body whose purpose is to reassure the bookmakers that dogs are not doped, that the dog running is the one described in the programme and that the bookmakers can lay odds on the basis of previous form. NGRC Rules are not directed toward to the greyhounds' welfare and in some instances run counter to it: Their view about frequency of racing is that a dog should race not more than twice a day whereas veterinary surgeons consider that a race once a week is desirable. When dogs are found abused, abandoned or dead, the NGRC refuses to supply details of the last owner to the police or other lawful authorities, claiming that the Data Protection Act prevents disclosure; their Registration document with the Information Commissioner gives the lie to this. Trainers and owners are penalised if they withdraw their dogs from races because of concerns over track safety and a challenge to an NGRC ruling of this kind is due to be heard in the High Court in October. A book of Rules from a discredited organisation should not constitute a Code of Practice under Animal Welfare legislation. Self-regulation protects the bookmakers, not the dogs.

  9.  It is inaccurate to say that "there has been a growing impetus within the racing industry to raise welfare standards". In truth, the greyhound industry has reacted—slowly, reluctantly—to pressure from welfare campaigners. Even now, though the word "welfare" is frequently uttered by Ministers, industry spokesmen and the bookmakers, action is lacking because it suits the vested interests of Government and the racing industry not to divert resources from profit-making enterprises.

  10.  The following facts and figures show the level of activity by the animals and profits earned for others by the greyhounds:

    (a)  More than 30,000 greyhounds are on the racing strength of British greyhound tracks which operate under the rules of the National Greyhound Racing Club (NGRC) and which provide an off-course betting market. (In addition, an unknown number of greyhounds race on independent tracks.)

    (b)  Racing life is short: two to three years.

    (c)  Around 10,000 greyhounds are surplus to NGRC racing every year through age or injury. There are no records of their destination afterwards although cases of abuse, abandonment and violent death are known to occur. One veterinary surgeon alone said in 1998 that he euthanased nine greyhounds every week. A survey by Greyhounds UK in 1999 showed that of those which survived, more than 130 greyhounds a month ended up in the care of local authorities, animal welfare charities and voluntary greyhound rescues.

    (d)  £2 billion a year is bet on greyhound races with off course bookmakers. 97% of the total is bet on the Bookmakers Afternoon Greyhound Service (BAGS) shown in betting shops between horse races. 16 tracks take part in BAGS; of these six are owned by bookmakers. In 2002 16,000 races were run for BAGS, an increase of nearly 300% on the preceding year. The trend is accelerating sharply and duration of meetings lengthening in the summer. The dual role of bookmakers has the effect of depressing the market price for BAGS contracts, impacting on the returns to owners and trainers.

    (e)  Bookmakers pay £13.5 million to tracks for BAGS meetings—in some instances, paying themselves—and derive £92 million in net profits through betting plus of course the contract payments back to their own tracks.

    (f)  The Treasury receives £351 million a year from bookmakers in general betting duty (15%). Greyhound racing constitutes 21% of betting office business.

    (g)  The greyhound industry argues that greyhound ownership is a "hobby" and greyhound owners have sole responsibility for the dogs' future once racing is over and the BGRB Chairman has said that the first principle remains that the owner should take the dog home in retirement. However, the five also-rans in BAGS races are likely to receive no more than £20. Owners have little chance of recouping the purchase price for the dog, much less cover kennel and veterinary bills or provision for retirement. The number of private owners is understandably declining and some bookmaker-owned tracks even prefer dogs to be owned by trainers. As trainers may have more than 70 dogs in their kennels there is no chance of them taking that number home.

    (h)  Most bookmakers pay 0.4% of their gross profits to the greyhound industry as a voluntary levy and have promised, not guaranteed, this will rise to 0.6% in the next two years. 10 years ago this was £1.6 million—this year it is estimated at £7 million. This funding is used mainly for infrastructure improvements at tracks (including those owned by bookmakers). The racing industry decides how much can be allocated to care for greyhounds after their racing life through financial support of voluntary rescues.

    (i)  Under sustained pressure from welfare campaigners the amount of the bookmakers' money devoted to the industry controlled charity—the NGRC Retired Greyhound Trust which uses volunteer labour—has risen from £138,500 10 years ago to £850,000 this year. This is supplemented by public donations

  11.  Independent veterinary care at every track (that is, not employed by track management who could exert inappropriate influence) should be introduced everywhere. The focus on reform at independent (flapping) tracks contained in Appendix H while endorsing and supporting extension of the rules of the National Greyhound Racing Club is flawed but not unexpected.

  12.  Recently, the British Greyhound Racing Board, the governing body for the greyhound industry, has extended financial inducements to independent tracks to race under the NGRC rules. This follows the line taken by Defra in Appendix H to the Explanatory Notes to the Bill. The argument that this is suggested on welfare grounds is suspect when it is obvious that existing centres for betting are prime targets for exploitation under the Government's plans to liberalise gambling. Businesses overseas have expressed an interest in investment. The self-regulating industry now wishes to embrace the independent tracks—supposedly on welfare grounds—which are themselves convenient local centres for gambling.

  13.  Many NGRC tracks are poised to incorporate casinos as soon as they can and will constitute the "entertainment centres" envisaged by the Labour peer and Chairman of the BGRB, Lord Lipsey. Casinos will of course yield tax revenue for the Treasury. But until the public and Parliament can be assured that no dog suffers injury or premature death, it is not entertainment.

  14.  The Government's endorsement of the closed self-regulating world of greyhound racing, as indicated the Regulatory Impact Assessment could be interpreted as a reluctance to "rock the (very profitable) boat" because so much actual and potential tax is involved. Ready utterances of a commitment to greyhound welfare which emanate from the industry and Government Ministers do not hide the fact that in future, as now, they want to leave it to the industry to decide what is necessary for the greyhounds' welfare without outside interference.

  15.  Self-regulation by the industry has failed the greyhounds for 75 years. We have already commented on the lack of priority given to the animals by the Government. It is not clear on what objective evidence Defra will be able to judge whether and what action is needed for greyhounds when the target date of 2010 arrives. If they are intending to rely on industry assurances without any independent scrutiny in the intervening period to inform decisions, then the proposals are both immoral and incompetent.

  16.  Independent scrutiny of this industry is critical and urgent to ensure that greyhound welfare does not continue to be compromised by profit. An independent adviser on greyhound welfare should be appointed, drawn from the charitable sector, who would examine issues of concern and publish annual reports. As soon as the Bill is passed, we want to see regulations to provide licensing by Local Authorities with accompanying inspection together with a Code of Practice drawn up by experienced animal welfare charities.

  17.  Delay invites the criticism that Defra, the Department of Culture, Media and Sport and the Treasury are in collusion to maximise new gambling opportunities in preference to legislating to safeguard welfare standards for greyhounds.

24 August 2004

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