PART IV: Issues Relating to the New Greyhound Regulator
It is in the nature of greyhound racing that large numbers of dogs either start or end their racing careers every year; many, indeed most, of these are importations from Ireland. As we have discovered, no-one actually knows what the numbers are, although there are plenty of people ready to make estimates which vary widely according to the point the particular parties are seeking to make at the time and to whom.
It is, we believe, essential that the governing body and those on the independent track circuit should address the effective monitoring of greyhounds and puppies, including those entering from Ireland, so that their registration, licensing and tracking can be a matter of record. Parliament and the public have made it clear enough that they require the sport's authorities to know the status of all greyhounds and to be able to account for them. The task is significant covering, as it must, not only tracking and tracing but also the maintenance of injury statistics. Significant investment in technology and innovative thinking will be required to deliver an adequate and joined-up system.
This Review cannot undertake that exercise itself but it can, we believe, highlight what it believes to be the key areas which need addressing and to which priority of expenditure should be allocated.
Tracking of Greyhounds Database and Process
The name of every greyhound that is licensed for racing is currently entered on the NGRC database by name and identification when it is first registered for racing.
An effective tracking system should enable the authorities to identify the location of a particular greyhound at any particular time. When a stipendiary steward carries out a routine inspection at a training kennel, that steward should be able to call upon a list of greyhounds resident at that kennel and the current status of each one: for example, racing, resting, injured, recovering from injury, retired, etc. At the moment, that is not possible because greyhounds are linked to owners on the database and not to trainers. Since, unless owned by the trainer concerned, racing greyhounds do not live with their owners, this system falls at the first hurdle when it comes to traceability.
It is, in our view, necessary either to modify the existing system or to design and maintain a replacement which adheres to the following principles for a tracking system which is both simple and consistent with the stock management requirements of any business  :
- Every greyhound that is licensed for greyhound racing comes under the control of the sport when it is first registered, which is generally at about 15 months. As we have recommended elsewhere, this should take place coincident with earmarking at approximately 12 weeks.
- The name and identification (to include distinguishing marks) of the greyhound is entered into the database at that point and the animal then becomes an accountable entity. If earmarking takes place at a breeding kennel which is not also a training kennel, then the breeder is accountable for the greyhound until such time as it is sold or otherwise moved on. Either way, the breeder would be required to inform the database manager that the dog had left their establishment and to where it had gone.
- Every licensed racing greyhound has a trainer; therefore all greyhounds on the database would be linked to a trainer (primary) as well as to an owner (secondary).
- All trainers have kennels; therefore the greyhound is linked not only to a trainer but also to an address where the trainer keeps the greyhound at any given time.
- If a greyhound is moved, on more than a temporary basis, from one trainer to another, the database manager must be informed by both the trainer losing the greyhound from his strength and the trainer receiving the greyhound onto his strength (as with notifying the DVLA when buying, selling or "retiring" a car).
- At any given time, a stipendiary steward, when inspecting trainers kennels would know how many and which greyhounds should be at a trainer's kennels. Any discrepancies would be immediately identified and appropriate action taken.
- When a greyhound retires from racing, the trainer would inform the database manager immediately, stating how it has been retired. This would trigger an enquiry with the registered owner (who may also be the trainer) to implement the process of compliance with Rule 18.
The NGRC maintains a dedicated database of retired greyhounds which has been built up over recent years as a result of hard work and innovative thinking. In essence, it tracks and records all retired greyhound information; its information is part of the overall database of registrations maintained by the NGRC and is shared with all the tracks and the National Form Database.
Regulating the Process
Once a tracking system is ready for operation, it would provide the Stipendiary Stewards with the information needed to check that a trainer has at his kennels all the greyhounds he is supposed to have. Thus, prior to a visit, a Stipendiary Steward would have access to the information needed to carry out the necessary checks.
It would be for the GBGB to decide how to make this proposition work in practice and the Rules may need to be amended or modified to provide any disciplinary vehicle thought to be necessary, although this should just be a matter of record-keeping and notification. The system would, however, depend on the following requirements, some of which are, or should be, already in place:
- For a trainer to report when a greyhound moved on for more than a temporary basis  from the kennels at which that greyhound was registered.
- For a trainer to report when a greyhound was received by its kennels from another trainer's kennels on more than a temporary basis.
- For a trainer to report when a greyhound registered in that trainer's kennels retired from racing.
The maintenance of injury statistics in a central database is inevitably a sensitive issue. There is a danger of inconsistency in reporting standards and also the risk of misuse; it is an old saw that statistics can be used to demonstrate any point which the protagonists in a particular debate may be seeking to prove - but it is nonetheless true. There are, however, obvious advantages to be gained from a properly collated, maintained and interpreted database. It would provide a powerful tool capable of extending the racing life of greyhounds and reducing injury. As prevalent trends emerged, so corrective action could be taken. Furthermore, such a database would provide a valuable epidemiological research facility.
It seems highly likely that the keeping of injury statistics by all tracks, be they licensed or independent, will be a mandatory requirement of the 2009 Regulations and it makes eminent sense for all that information to be maintained on the same database. That alone will require a constructive interaction between the independent sector and the GBGB.
The RCPA already maintains an injury database but it has been put to us in evidence, although not by the RCPA, that its injury recording system is in some respects incomplete. We are told that it includes only such injuries as are estimated by the track vet to require a lay-off of over six weeks; and that it excludes injuries resulting in immediate euthanasia, as well as all of those requiring less than a six week lay-off. In effect, this means that only serious injuries are recorded and so the incidence of injuries in general is likely to be much higher, including those that do not manifest themselves until the following day or even later. Such methodology is clearly inadequate for collating the complete and reliable information on which to base injury prevention measures.
There appears to be agreement between the current regulator and the Society of Greyhound Veterinarians that a database similar to that used by the British Horseracing Authority would provide a useful model. The BHA database is generally perceived to have been effective, not only for recording but also facilitating research into injury causes in horses.
We understand that there have already been discussions between the main parties and with the BHA in an effort to take this issue forward although progress is reported to be slow. The GBGB needs to maintain this initiative and to regenerate momentum. It is for the governing body to agree, within its Committee structure and with expert veterinary advice, common standards for injury classification and reporting. As a point of principle, it should be a requirement that all reports are certified as accurate by the vet concerned when forwarding to the governing body, irrespective of whether the track is a licensed track or not.
We note that the NGRC has already developed the ability to gather and collate information through its network of track vets, underpinned by UKAS accreditation so that any sample of figures is verifiable. But the system is not yet in place. It is a matter of considerable regret that, after many decades of greyhound racing, there is still no comprehensive, verifiable injury data available.
It is, we believe, of crucial importance for the welfare of the racing greyhound and the confidence of the general public and greyhound welfare interests that a properly managed and comprehensive injury database be constructed as soon as possible. We see no reason why the injury statistics for individual tracks should be publicly available; the value would lie in an aggregated, anonymised dataset, although the data held centrally on each track should of course be available to that track. If possible, there is obvious value in involving the Irish Greyhound Board and we are informed that they have signalled their willingness to be engaged. We see this as another welcome opportunity for cross-border co-operation which should be taken forward as a matter of priority.
Greyhound Stud Book.
The Stud Book records all puppies whelped in Great Britain. These births are notified to the NGRC which allocates a unique earmarking which is then carried out by earmarking stewards. At the moment, we are informed, this information exchange takes place by post. It would seem an obvious candidate for automation.
A system such as we have described above, which would allow greyhounds absent from kennel strength to be identified, would also provide an opportunity to highlight a situation in which a greyhound has not run for a specified period of time. This is a mechanism currently used for helping to identify retired greyhounds but would also be beneficial to the tracking across the wider spectrum of registered greyhounds.
It should be possible for PA Sport to "flag up" to the database manager a greyhound that has not run for, say, 28 days - or whatever time span experience showed to be optimal for the purpose. This would facilitate the tracking of registered greyhounds thus, hopefully, deterring persons from disposing of them illegally and helping to catch those that do.
Greyhound racing involves some thousands of dogs which are owned, bred and trained by a large and diverse community covering the whole of the United Kingdom and the Republic of Ireland. By its nature, the sport needs fit and healthy greyhounds to race across some 30 licensed tracks and perhaps 14 or 15 unlicensed tracks in Great Britain. Although the life span of a greyhound may be up to 12 years, it unlikely to race much beyond 5 years of age and the majority finish racing well before that.
Thus the turnover of greyhounds coming into and leaving the sport every year is inevitably very high and it is small wonder that tracking and tracing the whereabouts of each one has proved so challenging in the past, to the extent that the degree of accountability has been unacceptably low. The IT systems and software packages needed to monitor and manage the task of registering and then subsequently tracking and tracing individuals are not excessively complex. Nor, indeed, are the mechanisms for reporting and recording injuries. However, it is the quality of the information that goes into the database and the communications infrastructure which enables such inputs to be made which are the keys to a successful system. These are management issues.
Whilst good progress has been made in certain areas, developments have, it appears to us, been difficult to achieve and there has been little consensus between the different interests within the industry as to the priority to be afforded to the various initiatives, some of which have, as a consequence, failed to make progress, to the detriment of greyhound welfare.
It is to be hoped and expected that the establishment of a single governing body, with a staff structure which is responsive to Board and executive direction, should be well positioned to define its IT requirements clearly and to allocate both management and financial priority to putting an efficient and effective system in place as soon as possible.
Any new system will of course take time to bed down and it could well take several years to build up the full picture. But until a comprehensive programme is put in place and implemented with the appropriate protocols to make it work on the ground, the current inability to track and trace each greyhound will not be resolved.
 This is not to say that greyhounds are to be regarded as "stock"; merely that a stock management system would be a suitable vehicle for the tracking of greyhounds.
 Temporary Basis: excludes the need to report when, for example, a bitch in season is placed in resting kennels or when a greyhound is in transit. In such circumstances it would be for the trainer to explain the dog's absence and for the stipendiary steward to make such checks, if any, as might be deemed appropriate.