Greyhound welfare Contents

1Effectiveness of the regulatory framework

6.This section addresses the effectiveness of the regulatory framework relating to greyhound welfare, and in particular the Welfare of Racing Greyhounds Regulations 2010 (the 2010 Regulations). It sets out the current structure of the regulatory system, reviews the impact of the 2010 Regulations and assesses how effectively they have met their objectives.

The regulatory framework

7.Different aspects of greyhound welfare are covered by different pieces of legislation. The primary piece of legislation relating to all animals under human control is the Animal Welfare Act 2006.6 This Act covers conditions away from the track, including trainers’ kennels, and means it is an offence to be cruel to a greyhound or not provide for its needs. The 2010 Regulations were made under the Animal Welfare Act and specifically cover conditions at the racing track. The enforcement of the Animal Welfare Act is beyond the scope of this inquiry but we would draw the reader’s attention to a recently launched inquiry that will cover some of these issues.7

8.Other relevant legislation includes the Breeding of Dogs Act 1973 (as amended), Council Regulation (EC) No. 1/2005 and The Microchipping of Dogs (England) Regulations 2015 (relating to breeding, transportation and traceability respectively). 8

Current structure

9.Greyhound racing tracks operate within a hybrid or two-tier system. The majority of racing tracks, 24, are licensed by the Greyhound Board of Great Britain (GBGB). This means they operate under GBGB’s ‘Rules of Racing’ and are subject to inspections by the organisation.9 The standards that the GBGB sets at tracks are also independently accredited by the United Kingdom Accreditation Service (UKAS) and supported by the work of track veterinarians. Any track that meets the required standards may apply to be licensed by the GBGB.

10.In England, there are also around five independent or ‘flapper’ tracks that are not licensed by GBGB, but regulated and inspected by Local Authorities. Independent tracks have seen a notable decline in recent years—there were nine when the 2010 Regulations were introduced. These tracks mostly cater for local hobbyist racing as opposed to GBGB tracks which are large-scale, commercially focused and often televised. Although different licensing arrangements exist, tracks under both systems must comply with the 2010 Regulations.

Scope of the 2010 Regulations

11.The aim of the 2010 Regulations was to ensure that:

“all greyhound tracks in England are covered by the same minimum welfare standards and there will be improved traceability of greyhounds.”10

Impact of the Regulations

12.The 2010 Regulations introduced five minimum standards for all greyhound tracks in England:11

13.The introduction of statutory guidelines has brought minimum welfare standards at independent tracks into line with those at GBGB tracks. Experienced greyhound veterinarians have told us that this made significant improvements to greyhound welfare.12 The 2010 Regulations put into law many pre-existing welfare standards at GBGB tracks: for instance, veterinarians had been present at GBGB tracks since the 1990s, as had 100% provision of kennels at tracks. Prominent animal welfare organisations also agree that the 2010 Regulations have been a positive step for conditions at tracks.13 Nevertheless, they are critical that the provisions do not go beyond racing tracks.14

14.There is general acceptance that the formalisation of welfare standards at GBGB tracks and the extension of minimum welfare standards to independent tracks contained in the 2010 Regulations has improved the welfare of greyhounds at racetracks.

15.It is, however, difficult to make more than a subjective judgment about the level of the improvement since the 2010 Regulations introduction. The 2010 Regulations’ requirement to collect data on, for example, injuries at tracks, has not been accompanied by a willingness to make that data available for public scrutiny or analysis. We shall cover this issue in further detail in the next Chapter, but must emphasise that the lack of transparency and paucity of publicly available data leaves no clear baseline against which to judge the effectiveness or impact of the 2010 Regulations. Similar conclusions were reported in Defra’s review of the Regulations:

“The impact of the regulation on welfare is difficult to assess—there is no transparency in relation to data and statistics which allows comparisons of pre and post regulation.”13

16.The absence of baseline data regarding issues such as injuries, euthanasia or rehoming makes it difficult to accurately assess the impact of the 2010 Regulations on key welfare issues.

17.Whilst the 2010 Regulations require that the same minimum standards apply at GBGB-regulated and independent tracks, there are still differences between the two systems.

18.A clear example is the approach to anti-doping testing: GBGB tracks take 9,000 independently tested samples a year, whereas independent tracks do not undertake any formal anti-doping activities. Another difference is apparent in the greater frequency of inspections of GBGB-licensed facilities and their accreditation by an independent body, UKAS. GBGB tracks are subject to annual inspections, by contrast, independent tracks need receive only one mandatory inspection by the relevant Local Authority every three years. This suggests that GBGB tracks may be held to higher standards.

19.The extension of minimum statutory guidelines to all greyhound tracks is welcome. However, significant differences remain between the levels of regulatory oversight of the two systems.

20.We recommend that the frequency of Local Authority inspections of independent tracks be increased and include random inspections.

21.Recognising the limitations of the available data, we have identified two key questions relating to the effectiveness of the 2010 Regulations:

a)Whether adequate standards of greyhound welfare are upheld under the current regulatory framework?

b)Does a self-regulated industry see statutory guidelines as a minimum standard to be proactively built on, or, is meeting the minimum requirement the full extent of their ambition?

Strengths of the 2010 Regulations

22.Despite the difficulties in judging their impact, the 2010 Regulations were praised in the evidence we received for introducing a number of positive requirements. The mandatory presence of a veterinarian for all racing or trialling events is an important step forward, especially at independent tracks, which typically tended not to have them previously. Beyond the 2010 Regulations, the introduction of mandatory microchipping of all dogs from April 2016 should eventually go a long way to ensuring greyhounds can be traced from birth to death. We hope this development will put to rest some of the concerns about the fates of retired greyhounds.

Weaknesses of the 2010 Regulations

23.Even where they believe the Regulations have worked “as far as they go”, many animal welfare charities have criticised them for being limited in scope. Clarissa Baldwin of the Greyhound Forum, for example, told us the regulations were misnamed:

“They are not the Welfare of Racing Greyhounds Regulations. They are for racing greyhounds at tracks”.14

24.Particular areas highlighted by critics as requiring attention include: breeding; importation; transportation; training; kennelling; rearing; trialling; racing; rehoming; euthanasia; and retirement.15 Although as previously stated, many of these areas are covered, specifically or in general, by other legislation (whose enforcement lies outside the scope of this inquiry) a number are covered individually in further detail later in the report.

Areas of concern

25.We have concerns about a number of welfare issues that do not appear to have been fully addressed by the 2010 Regulations. These issues are presented here and expanded upon in more detail in following chapters:

i)Trainers’ kennels, where racing greyhounds spend approximately 95% of their time, are not covered by the 2010 Regulations. Despite their being covered by the Animal Welfare Act, there was a broad consensus across stakeholders, including GBGB senior management and trainers, that extension of the Regulations to include these kennels and incorporate them in the UKAS inspection regime was necessary;

ii)Secondly, the fate of retired dogs unable to be rehomed at the end of their careers is unclear. The Greyhound Forum believes that somewhere between 1,000 to 3,700 dogs are unaccounted for each year.16 The introduction of microchipping should help illuminate this matter. Improved traceability will also depend to some extent on compatibility between GBGB and public pet databases. We believe that greyhounds bred for racing should be traced from birth to death to remove uncertainty over their fate;

iii)A final concern is anecdotal evidence regarding inconsistency in the standards of welfare, and their enforcement, experienced by greyhounds across the country. Dr Hazel Bentall, for example, told us:

“I have seen no evidence that the regulatory framework is consistent and moderated at its levels across the country”.17

7 The Environment, Food and Rural Affairs Committee will inquire into Animal Welfare in 2016.

9 Greyhound Board of Great Britain’s ‘Rules of Racing’

11 Department for Food, Agriculture and Rural Affairs (GHW 61) para 2.3

12 Q 54 [Dr. Bentall], Q 56 [Dr. Adams]

13 Exploring the Effectiveness of Racing Greyhound Regulations 2010 - Final Report (6 November 2015) p.4

14 Q 2 [Mrs Baldwin]

15 See written evidence: RSPCA (GHW 30), League Against Cruel Sports (GHW 09) and Blue Cross (GHW 32)

16 Greyhound Forum (GHW 24) para 4.i All evidence attributed to the Greyhound Forum in this report is in the name of the following welfare members only: Battersea Dogs Home, Blue Cross, Dogs Trust, Greyhound Rescue West of England, Greyhound Rescue Wales, Greyhounds in Need, Kennel Club Charitable Trust, and Wood Green Animal Charities.

17 Q 54 [Dr. Bentall]

© Parliamentary copyright 2015

Prepared 22 February 2016