PART IV: Issues Relating to the New Greyhound Regulator
THE BREEDING, OVER-SUPPLY, MONITORING AND RETIREMENT OF GREYHOUNDS
Above we describe how very large numbers of greyhounds are bred, particularly in Ireland, for racing in Britain. Although the statistics are inadequate, it is estimated that some 10,000 greyhounds enter and leave the licensed sport each year, with a further 3-4,000 believed to race on unlicensed tracks (though some of these dogs also run, contrary to the Rules of Racing, on licensed tracks, often under different names).
Serious welfare problems can arise because so many of these greyhounds retire from racing at a relatively early age and henceforward many need either to be re-homed or are disposed of in other ways, not always humanely. Of the estimated 10,000 greyhounds leaving the licensed sport each year, only some 4,000 are re-homed through the Retired Greyhounds Trust (RGT) and about a further 1,500 are re-homed through other welfare charities. The RGT is a nation-wide organization, primarily funded by the BGRB, with over 60 branches which re-homed 3,900 greyhounds in 2006 (having increased from 2,030 five years earlier). Some of those that remain are cared for by their private owners and trainers, but the fate of the rest is unknown and therefore of welfare concern. In addition, there is the issue of the greyhounds which do not ever make the grade to competitive racing and these too have to be homed or otherwise disposed of.
The Current Situation
One fundamental difficulty when approaching this issue is the paucity of satisfactory information about the numbers and the life careers of greyhounds. We do not know the precise numbers of dogs or what actually happens to them during their lives. The public, through Parliament, has made clear its expectation that the industry establishes a situation, which must of course include the independent sector, where the whereabouts and status of all greyhounds, preferably 'from cradle to grave', or certainly from birth to retirement, is known. This is why in another section of this Review (see Chapter 14), we stress that greyhound racing's governing and regulatory bodies must urgently develop improved and integrated data bases.
Currently, greyhound bitches have litters intended for racing, but with no comprehensive monitoring nor licensed regulation of their breeding (and incidentally therefore with little enforcement of the existing 1999 Breeding and Sale of Dogs [Welfare] Act). All greyhounds are earmarked at around 12-15 weeks, but they are not registered with the Regulator unless or until they are ready to race, usually at about 15 months. Along the way, those which display insufficient ability or inclination to race have to be cared for or are disposed of in some way or another. On retirement from racing, the tracking of greyhounds has been erratic but is improving. Rule 18 offers some protection and the Rule is now being more firmly, though still insufficiently prosecuted.
The increased volume of racing in recent years and the flow of greyhounds leaving the sport means that demands for re-homing outstrip the current supply of retirement provision. It should be an urgent priority of the new governing and regulatory authority to make a firm commitment to tighten up this situation where there is an over-supply of greyhounds, particularly poorly-bred ones, a lack of information on and monitoring of their careers, and inadequate provision for their retirement.
It should be noted that this question of over-supply does not derive primarily from over-breeding in Britain. Again, the statistical information on this issue is thin, but the British Greyhound Stud Book indicates that the number of British bred dogs is only around 3,000 per annum, has actually declined in the past year and is close to a low point for recent decades. It has been suggested to us that a significant proportion of these British greyhounds are bred in the north of England but that the owners/trainers breed in small numbers and race on provincial, sometimes unlicensed, tracks and who are believed to care passionately for their dogs and happily look after them in retirement. On this basis, if accepted, it is hard not to conclude that the numerical welfare problem of over-breeding and demand for re-homing derives mainly from supply from Ireland - itself, of course, responding to increased demand from Britain, including the growing needs of British BAGS racing (around one third of licensed racing planned for 2008).
These welfare issues have received greater publicity in recent years and British greyhound racing, to the credit of all involved, has given higher priority to, and spent much more money on, welfare and greyhound retirement. Apart from the RGT, the BGRB's Retired Greyhound Fund also provides grants for capital projects to private individuals and organisations undertaking greyhound re-homing. Taken together, the BGRB initiatives and the welfare charities re-home about a half of the dogs which retire from racing. Some others are personally re-homed by their owners and trainers. We do not know what happens to the rest. But there undoubtedly remains a widespread feeling in political, government, welfare and media circles that more should be done, as was strongly expressed in the recent APGAW report. Certainly there needs to be greater promotion of these lovely pets for retirement outside the limited greyhound community.
Our Review has taken much evidence relevant to these welfare questions and particularly in relation to the over-breeding and over-supply of greyhounds. Theoretically, three broad policy approaches have been suggested to us which might ease the situation of over-breeding and over-supply. One would be to reduce demand for greyhounds by intervening to limit the amount of racing on offer (the RSPCA suggested that the number of races be limited by a quota system). A second would be to try to limit the supply by controls over breeding. A third approach is to improve the micro-monitoring of greyhounds' careers 'from cradle to grave'.
The difficulty with the first approach of controlling the supply of racing and thereby limiting the demand for greyhounds is that such measures are probably, as the BGRB stated in its legally-based evidence, impractical on grounds of competition law. The difficulty with the second approach of controlling the supply of greyhounds through their breeding is that in fact the main source is in Ireland which is beyond our jurisdiction, although we have suggested that the industries and Governments in Great Britain and Ireland should have closer liaison. However, we believe that measures can be taken to improve the breeding situation and set them out below. The third option is clearly fruitful and we suggest below ways of improving the registration, tracing, monitoring, health, nutrition and retirement of greyhounds during their careers.
Licensing of Breeding Establishments
Currently, there is no regulatory inspection of breeding kennels (unless they happen also to be licensed racing kennels) and the Regulator has no jurisdiction over breeding.
This Review agrees with those witnesses, including the BGRB and Greyhound Voice, who argued that this deficiency should be corrected. All greyhound racing breeders should, as we state in our chapter on Regulation and the Animal Welfare Act 2006, be licensed by the Regulator and subject to fully qualified veterinarian supervision. Such licensing would give authority to the stewards to enter all greyhound breeding premises. Proper licensing supervision should, together with more research into breeding and nutrition, reduce the number of poorly-bred greyhounds deriving from British jurisdiction and therefore limit the number of greyhounds that prove insufficiently sturdy or are injury-prone and so ultimately do not qualify for racing. It should also then be easier to enforce the Breeding and Sale of Dogs (Welfare) Act which states that a bitch should not be mated if less than one year old and should not give birth to more than 6 litters in her lifetime. The Regulator might add as a condition of licensing that no births should be delivered when the bitch is more than 8 years old. Together with proposals for stimulating more research into better breeding of sturdy dogs, including better nutrition, this might help to reduce the supply of unfit or unsuitable dogs. However, this would be effective only in Britain. The supply issues which derive from Irish breeding should be the subject for negotiation between the British and Irish governments and racing authorities.
There was considerable support among some witnesses for increased ownership registration fees as a means of deterring excessive and irresponsible greyhound ownership. A fee range of £200-£500 was aired - though the owners and trainers baulked at the higher figure. However, such a higher figure might be acceptable to most if it were to be imposed, with a part of the fee being viewed and retained as an advance deposit towards the later costs of suitable retirement and re-homing for the greyhound. We have considered this proposition amongst others and discuss our proposals for the ownership registration of greyhounds in greater detail in Chapter 10.
We support the proposal that all greyhounds should be registered at birth, or at least at the time of ear-marking (12-15 weeks). The case for specifically requiring this under secondary legislation is set out in our chapter on Regulation and the Animal Welfare Act 2006 (Chapter 11).
Identification and Tracking
It has been suggested to us in evidence that the identification and tracking of greyhounds would be improved and facilitated by:
- Stricter prosecution of Rule 18. This has lately improved, but with employment of more stewards it could be even more rigorously pursued.
- Better identification techniques, probably through the addition of micro-chipping.
- Establishment of improved IT links between breeders, welfare charities, trainers and the official databases maintained by the new GBGB to enhance the tracking of greyhounds, both during their racing careers and on retirement.
This last measure would be enforced by having a Rule of Racing requiring that trainers as well as owners must report when a dog arrives at and when it leaves a licensed kennel and when it retires from racing (perhaps on an analogy with the DVLA methodology for registering ownership, transfer and "retirement" of automobiles). This Rule would thus incorporate the current operations of the Retired Greyhound Coordinator. We explore this issue further under our section suggesting the improved IT and data base arrangements which will be needed by the governing and regulatory authority (see Chapter 14). Closer and more constructive relations between the Regulator and the presently unlicensed sector (as suggested in Chapter 12 on Independent Tracks) would make it possible to input more comprehensive information about the life careers of greyhounds into the central data bases.
Minimum Values on Sales
This seems a good idea in principle and has been introduced at Irish auctions (at €300). But it is not easy to enforce in practice and does not apply to Irish private sales. The Regulator should explore whether and how a minimum values system could be introduced in Britain.
Extending Greyhounds' Racing Careers
The active racing careers of greyhounds might be extended - and hence their time in retirement reduced - by having more graded races for veteran dogs (currently more often provided by unlicensed tracks). It has been suggested to us that a racing career starting at 15 months may be too early for the health of the dogs. We have seen no evidence to support this view but it seems likely that this is because no formal, targeted research into the issue has been undertaken. If this is considered to be an issue, then the governing body should commission such research to establish verifiable evidence for a desirable age for starting racing (though there will presumably always be variation from dog to dog).
This issue is referred to in our sections on Regulation (Chapter 11) and on Independent Tracks (Chapter 12) but is also relevant here because of its link to early retirement of greyhounds from racing and the consequential need for prolonged retirement and re-homing. It is important that validated track injury statistics are maintained and made available to the Regulator. More research into track surfaces is required (the BGRB has already commissioned some) and more research should be promoted to establish if it is possible to breed greyhounds less prone to injury. Our suggestions for improved veterinary provision throughout the sport (Chapter 15) should also assist in ensuring better treatment for and recording of injuries to greyhounds.
We have received interesting veterinary arguments that poor nutrition is a major factor in producing greyhounds which have poor teeth and bone structure and are prone to injury, particularly where consequential poor cartilage formation leads to prevalent hock injuries. It is alleged that many commercial dog foods are composed excessively of cheap corn which is not natural to them nor best suited to what are basically carnivorous animals. We are not qualified to assess the scientific validity of these arguments but have viewed some of the evidence on which they are based and believe they merit further professional scrutiny. The greyhound authorities should urgently promote appropriate research into the relevant areas of greyhound nutrition.
Retirement of Greyhounds
Some greyhounds are temperamentally unsuited to re-homing, as some are to mass kennelling, but for the majority the demand for retirement places far outstrips the supply. The options for tackling this imbalance include:
- A condition of granting a track licence should be that the track operates an efficient re-homing scheme. Although some licensed tracks already operate efficient homing schemes, this is not universal.
- The racing and betting industries should increase the allocation of financial support for retirement provision. Indeed, the racing and betting industries have indicated a willingness to do so under a general welfare heading providing the arrangements for handling the finances were satisfactory.
Since some of the issues relating to the over-supply, over-breeding and lack of tracing of greyhounds, especially poor quality ones, derive from Irish breeders (though the original demand derives from Britain), the relationship between the British and Irish greyhound authorities is of great importance. These relations have improved significantly in recent years and this Review found the Irish greyhound authorities impressive and welcoming. This liaison should be systematically developed and maintained at a close and cooperative level both by the greyhound racing authorities and by the relevant government departments. At governmental level, Defra might fruitfully establish a senior committee with this objective in mind and initiate talks at ministerial level. The relevant British and Irish data bases should be shared as much as possible to the mutual benefit of the sport in both countries and we are encouraged by the progress already made in this respect.
The important areas discussed above, concerning breeding, licensing, registration, tracing, research, nutrition and retirement, are crucial to the good regulation and better welfare of British greyhound racing. Currently, they are not always monitored or regulated with sufficient efficiency, authority or comprehensiveness. Our analysis and proposals, based on the evidence of witnesses from the industry, should assist in producing an improved regulatory situation in the sport. They should constitute part of the agenda of greyhound racing's governing and regulatory authorities. They should also, as we propose below, be at the heart of the Government's Animal Welfare Act Regulations.