Submission by the Coalition for the Protection of Greyhounds, Inc. (CPG) for the Draft Victorian Code of Practice for the Keeping of Greyhounds.

Below is our submission regarding the Draft Victorian Code of Practice for the Keeping of Greyhounds.  Please use it as a guide for your own submission.

Please note. If you want to cut and paste, the best thing to do is to save the blog as a pdf file and cut and paste from the pdf file.

Submission details can be found at:

http://agriculture.vic.gov.au/pets/dogs/greyhounds/code-of-practice

 

About the CPG

 The CPG was started by several members of the Animal Justice Party in 2015, following the Four Corners live baiting expose. Today the Coalition is a mix of independent greyhound welfare campaigners, representatives of various animal welfare activist groups and representatives of greyhound rescue groups from across Australia.

The group is dedicated to exposing the truth behind the greyhound racing industry. Greyhounds are sensitive and intelligent dogs who have the same desires and instincts as all dog breeds. The lives lived by the vast majority of greyhounds in the industry are short and filled with misery. The vast majority of racing greyhounds are treated like objects for money making. Once their racing career is over at the young age of four or five years, these sentient beings are discarded like broken objects (often referred to as “product” by industry participants). During their racing days, they endure lives of solitary confinement in cages which is a life completely at odds with the social nature of the species.

 

CPG Submission

We support the objectives of the regulatory proposal (stated on page 9 of the Regulatory Impact Statement – RIS):

“To increase (improve) the quality of life and welfare of greyhounds, throughout their lifecycle and provide consistent management which will alleviate stress and therefore enable an easy, smooth and rapid, transition to a pet at any time point in its lifecycle”

We also are in agreement with the definition given on page 8 of the RIS regarding social license: “A social license to operate has been defined as the ‘ongoing acceptance or approval from the local community and other stakeholders’.

The Draft Victorian Code of Practice brings the treatment of greyhounds into significantly closer alignment with the societal expectations of the way dogs should be treated, as noted in the executive summary of the Regulatory Impact Statement notes (RIS).

The significant problems that have historically plagued and continue to plague the greyhound racing industry have been highlighted in the RIS on page 37 (section 1.4) as:

“a lack of transparency or identification of operators, lack of education or information of operators, perceived poor breeding, rearing and training programs, poor welfare of dogs, wastage (oversupply) of animals, governance of racing and betting, and the live baiting issue.”
These issues have been classified into six main categories as shown in Box 1 below.  Box 1

In particular, the industry “wastage” has been highlighted as a significant, if not the most significant, issue in the public’s digestibility of the industry. The treatment of the dogs by racing participants contributes to the extremely high number of dogs considered to have poor rehoming potential each year (see Box 2 below). The proposed code of practice will address this issue to a significant degree if it is endorsed – extending somewhat of a temporary lifeline to the industry (see the section titled “Sustainability of the Industry” below for elaboration on our argument that the lifeline is temporary).

Box 2 

“Of the 5,353 reported greyhounds being retired per annum on average, between 2013-14 and 2015-16, it is estimated that around 4,189 dogs are affected by poor rehoming potential each year.” (RIS, page 10)

 

Noted Positives of the Draft Code

  • The standardization and consolidation of existing legislation and local rules that give wider coverage and that cover greyhound welfare at all stages in their lifecycle.
  • The proposal to give greater powers to authorized officers to enforce and audit along with significantly higher penalties.
  • A focus to enable an easy, smooth and rapid transition of racing dogs to companion animal status thereby reducing the need for euthanasia as a result of lack of suitability to companion status.
  • The fact that the proposed code has been systematically researched, detailed and costed is impressive and to be applauded.

Shocking details are exposed in the RIS including Table 13 on page 11 showing the estimated numbers of greyhounds are at welfare risk from a number of factors including low staff to greyhound ratios in large facilities, lack of independent veterinary advice, inadequate health checks, insufficient housing (outdoor and indoor), insufficient perimeter fencing, and lack of clean or appropriate food receptacles.

It is therefore essential that the draft incorporates detailed requirements (as shown on pages 9 and 10 of the RIS) for the following:

  • Staff ratios
  • Independent veterinary advice
  • Health management plans
  • Storage of establishment records
  • Record of supplements, drugs, transfers, rehoming activities and disposals and provision of statement of health and management for dog transfers
  • Access to food receptacles which are regularly cleaned (all breeders) and adequate storage of food (large breeders only
  • Health checks and treatment plans for breeding females
  • Additional health check for all dogs
  • Bedding materials, exercise, enrichment and socialisation
  • Owners taking responsibility for the initial rehabilitation and rehoming
  • Perimeter fencing requirements
  • Adequate weather proofing of outdoor housing and raised sleeping beds
  • Indoor kennel facilities improvements, including sleeping areas with solid partitions and
  • GRV notifications of transfer between properties

 

Culture of Cruelty – resistant to change

The complaints regarding the proposed code both by Greyhounds Australasia and in News Corporation media only serve to reinforce the denial of neglect and cruelty that is rampant in the industry as well as the ignorance of appropriate care requirements. They also reinforce the very hardened attitudes that participants have pointing to an almost certain failure that the industry will ever be sufficiently reformed to meet community expectations of animal welfare.

For example:

  • On 25th June, 2017, an article published by Australian Racing Greyhound titled “Vic Cod of Practice: Let’s State the Bleedin’ Obvious” [1] fails to acknowledge that a significant proportion of greyhound racing participants do not provide adequate basic care requirements including shelter and water as detailed in the RIS.
  • During the week beginning 19th June, an article was published almost daily criticizing the code and running a scare campaign against the Andrews government [e.g., 2, 3]. The articles essentially argue that the very basic care and welfare requirements spelled out in the draft code are impractical.

The push back already being seen by industry participants to the draft welfare reforms strongly indicates that their non-compliance rates and poor treatment of dogs is acceptable practice for them, further strengthening the need for the code and its strong enforcement with significant penalties for breaches, as opposed to the current situation wherein “the penalty is often so small it offers no deterrent to the industry.” (RIS; p. 36)

These poor standards that are not in line with community expectations but considered acceptable by racing participants are highlighted by the following information extracted from the RIS (see Box 3 and Table 11 below).

Box 3 Table 11 As shown in Table 11 above, as many as 32% of participants do not comply with regulations because of the racing industry culture, attitude or their age, 32% lack the means or capability and 32% are ill-informed or lack the education.

The clear failure of the industry to treat dogs as the community expects, as evidenced by the low rehoming suitability rates already cited above (Box 1) and further data provided in the RIS (Box 2 and Table 11) further support the need for the detailed and strongly enforced reforms.

On page 43 of the RIS, it is highlighted that all dogs and all life cycles are at risk of poor welfare but dogs most at risk are those on properties that are small and hidden or not registered because they are avoiding being monitored and audited. According to the data, a total of 86.05% of breeders and trainers are classified as small (fewer than 9 dogs who make a start). Thus, the majority of racing dogs in Victoria are at risk of poor welfare, further reinforcing the importance of this code.

 

Participants’ Expressed Concerns about the Affordability of the Reforms 

Based on analysis, the impact of the proposed code on small business and competition – that is, on 97.5% of participants will be small. The RIS analysis shows that such participants are unlikely to face significantly different or disproportionate costs from complying with the code.

The rise in cost faced by small owners will be $1,550.00 per dog over its entire lifetime – which even includes costs of rehabilitation. Given that the average cost of a greyhound at auction is $5,800.00, the increased cost of just over 1.5 thousand dollars cannot be considered unaffordable. 

Areas of the Draft Code that need Attention and Change

  • Section 2.5 Muzzling – Barking muzzles should be banned at all times without exception. See case studies in the RIS document for evidence of misuse and resulting abuse with barking muzzles (see example in Box 5 below).
  • Section 3.1 Staff Ratio: The code states that “A minimum of one full-time staff member must be present onsite at the establishment during business hours for every 25 greyhounds (or equivalent) housed in the establishment. The staffing ratio must be maintained seven days per week.”  Given that, as highlighted on page 25 of the RIS, a total of 86.05% of breeders and trainers are deemed to have fewer than 9 dogs (see Table 2) and that the majority of racing dogs in Victoria at risk of poor welfare are those from small establishments, the draft code staffing stipulations do not apply to the majority of racing dogs in Victoria . The code needs to include specific requirements that will improve the welfare of the dogs belonging to the 86.05% of small establishments.
    As noted in more detail in a comment that follows this post, “together [the small trainers] are responsible for 10,819 registered greyhounds — more than half the total in the state. As staffing rules in the draft Code do not apply to them, the vast majority of Victoria’s racing dogs may be left without human oversight for hours at a time.”
    It is noteworthy that the Draft code for the care of greyhounds has a great deal of overlap with Victorian government’s code for Breeding and Rearing Businesses (i.e., puppy farms). This code is currently being reviewed by the government as there is evidence that it is not protecting dogs from cruelty. Having the draft code for greyhounds based upon a code shown to have serious failings means that it will not adequately protect greyhounds from neglect and suffering. This code needs to go further in its proposals. Staffing to dog ratio is one area that needs particular attention.
    Also, more needs to be done to protect greyhounds in small facilities. More detail about staff attendance requirements and socialisation needs to be provided.
  • Section 3.12 – The muzzling requirement during the 20 minutes walk per day for retired greyhounds should be removed as per recommendation by the Breed Specific Legislation review.
  • Section 4 relating to Exercise, training and enrichment: Treadmills should be banned and walking the dog should be encouraged instead. This is also more in line with the socialisation requirements for optimising rehoming.
  • Socialisation of dogs is a key factor to rehoming ability: In this regard, the draft code’s proposed 1 full-time staff member to 25 greyhounds falls far short of satisfactory socialisation requirements. According the McHugh report (see Volume 2, page 156), a minimum of 15 minutes of care per day just for feeding and cleaning is required to adequately care for dogs in the industry. Four full-time staff would be required just for feeding and cleaning 100 pups. To devote one hour for socialisation per pup each day, would require an estimated 13 full-time staff.
  • Section 3.9 Rearing – Given the staff to dog ratio specified in section 3.1 of one full-time staff member per 25 dogs, it is difficult to see how one person in charge of 25 dogs could spend 30 minutes each day per individual pup aged between 4-8 weeks. The same applies to greyhounds 16 weeks +. The ratio of staff member to dog needs to be reviewed.
  • Section 4.2 of the code refers to emergency situations where euthanasia is required. This gives an escape clause to the requirement for veterinary performed killing.
  • Section 4.3 of the code – Greyhound transport vehicle: These are necessary and common sense requirements except that maintaining a temperature between 10 and 32 degrees Celsius needs revising since 10 is too cold and 32 is too hot.

Box 5 – Misuse and Abuse relating to Barking Muzzles (Case Study 1 – RIS page
53)
 

box 5

  • Section 6.3.13 of the code – Retirement and rehoming of greyhounds: As discussed in a later section, the flood of greyhounds moved on from the racing industry is undoubtedly displacing other breeds of dogs in desperate need of a home. The specification in the code that authorizes the surrendering of greyhounds to a registered pound or shelter, or a community foster care network, will only intensify this problem. If this is to remain in the code, then dedicated funding should be allocated by the industry to support such surrenders.
  • Greyhounds surrendered for experimentation: No mention is made of greyhounds surrendered to research institutions for experimentation. This should be prohibited under any circumstances. Racing greyhounds have already been used in the life endangering race industry. They should not suffer a second round of exploitation for experimentation and subsequent death, for research where results more often than not cannot be generalised to humans.

 

Sustainability of the Industry – Wastage

The issue of “wastage” is not specifically addressed in the proposed code, however, it is argued that the reduction of wastage will results as a positive consequence of good management practices during a greyhound’s lifecycle (RIS; page 8). This reduction is proposed to be achieved through an easier, smoother and more rapid transition of dogs from racing status to companion animal status.

At the same time that it is argued that the objective of the code is not to deal with wastage, it is made clear that greyhound racing operates under social license and that such license is at risk if it continues to involve the deaths of young and healthy dogs purely for the purpose of gambling.

Although reducing industry ‘wastage’ is crucial for the industry’s social license, given that a minimum number of dogs is required to be bred every year to keep the industry going – 4,500 each year in Victoria alone – according to a recently published article in The Australian [2], how realistic is this goal?

Rehoming most of the dogs bred by the industry is simply not a realistic proposal. There are simply not enough homes in Australia for greyhounds bred for the industry since a greyhound’s lifespan is roughly 12 years and the industry will churn out thousands of dogs every single year.

Moreover, rehomed greyhounds are inevitably displacing other dogs from being adopted and so the kill rate of other dog breeds will increase.

Another major problem is that the vast majority of greyhounds are rescued and rehomed by volunteer rescue individuals and groups, at their own expense. This situation is not only unsustainable, it is exploitative and unethical [4].

 

Conclusion

The cruelty to dogs and other animals used in live baiting, and the exploitation of compassionate people for an industry that merely serves to increase gambling and to compound the size of already problematic gambling in Australia is highly exploitative and unethical [5].

Allowing greyhound racing to continue particularly when, as reported in the RIS, the vast majority of participants are hobbyists is highly irresponsible. Considering that claims of the economic contribution the greyhound racing industry makes to the state of Victoria have been significantly exaggerated and that it’s contribution is projected to further decline at a compound annual rate of 2.3% [7], the most responsible government action is to phase the industry out to an imminent shutdown.

 

References

  1. Australian Racing Greyhound (25.6.17). Vic Code of Practice: Let’s State the Bleedin’ Obvious. https://australianracinggreyhound.com/australian-greyhound-racing/victorian-greyhound-racing/vic-code-of-practice-lets-state-the-bleedin-obvious/88410/
  2. The Australian (19.6.17). Labor follows lead, and goes for the dogs. http://www.theaustralian.com.au/national-affairs/state-politics/labor-follows-lead-and-goes-for-the-dogs/news-story/dd0a236e4b47e6dc7eb0510f8fcceda3
  3. The Australian (22.6.17). Draft Victorian code has taken the fun out. http://www.theaustralian.com.au/national-affairs/state-politics/draft-greyhound-code-has-taken-the-fun-out/news-story/55585f964dbd54e3df8d89ee070b1505
  4. https://coalitionprotectgreyhounds.wordpress.com/2017/06/20/greyhound-racing-being-a-rescuer-in-an-industry-based-on-exploitation/
  5. https://coalitionprotectgreyhounds.wordpress.com/2017/06/22/the-greyhound-racing-industry-makes-a-questionable-economic-contribution-to-victoria-but-is-unquestionably-harmful/
  6. IBISWord (2015) IBISWorld Industry Report R9120 Horse and Dog Racing in Australia.
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3 thoughts on “Submission by the Coalition for the Protection of Greyhounds, Inc. (CPG) for the Draft Victorian Code of Practice for the Keeping of Greyhounds.

  1. For those who prefer to send a briefer submission, see below, a contribution shared by an Animal Justice Party member. Feel free to use it as a guide:

    http://agriculture.vic.gov.au/pets/dogs/greyhounds/code-of-practice

    The News Corp press is, once again, greatly overplaying imagined outcomes of the proposed code of practice for racing greyhounds.

    For far too long, the greyhound racing industry has been allowed to fly under the radar when it comes to the kind of regulatory and welfare standards reasonably expected by the majority of the population.

    The letter of adequacy from the Commissioner for Better Regulation states that the aims of the Proposed Code of Practice for the Keeping of Racing Greyhounds is to ‘increase the quality of and welfare of greyhounds…alleviate stress and therefore enable an easy, smooth and rapid transition to a pet at any time point in its lifecycle.’ This is a thoroughly reasonable and dispassionate objective, and one presently being denied to thousands of Victorian greyhounds each year. The proposed code simply seeks to ensure that greyhounds bred for racing are afforded the same care and legitimacy as those kept as companion animals, and indeed as other breeds. Greyhounds need to be recognised and cared for as dogs, not investments.

    In response to the draft code, News Corp has been trumpeting its usual alarmist agenda. In likening the proposed code to the NSW government’s announcement of a shut down last year, The Australian puts across a clear message of its disinterest in giving the reforms the slightest due consideration.

    As most people open to reason can see, the proposed code simply sets out to put in place — for the benefit of greyhounds as well as the industry — the most basic requirements of care and management, such as the provision of food, water, shelter and exercise. The increased cost per dog will not have anything like the impact on owners and trainers that the doomsayers claim. In fact, the expense has been costed at $1,550.00 per greyhound to be paid over several years. If trainers can afford to pay the average of $5,800.00 to buy a young racing greyhound at auction, they can afford to pay $1,550.00 for its care. If they can’t afford to care for the dog, they should not buy one in the first place.

    Comments by industry people reported in the recent News Corp articles merely serve to expose industry people for who they really are. These are clearly people who are in the racing industry for the express purpose of personal monetary gain. Claims in The Australian this week forecast costs to trainers that they claim would see them go out of business and cause the industry, as a whole to suffer. This is a gross generalisation, though, as costs would be apportioned per dog and would not unfairly disadvantage owners. Those able to afford to have multiple dogs should be able to afford to pay the requisite registrations and provide the appropriate levels of care, in just the same way that they stand to be able to win more prize money from entering more races. Those trainers with fewer dogs under their management would be proportionately less affected.

    The very fact that a code needs to be drawn up at all demonstrates that there is a significant segment of the industry that cannot be relied upon to adequately care for the dogs under their guardianship, and reinforces the culture of cruelty on which the industry is based.

    The vast majority of Victorians, however, do support the proposed reforms and are willing to speak out in support. While certain sections of the media — those who see themselves as the flag-bearers for the racing industry and who have vested economic interests in the industry — continue their scare campaign about which way those in the industry may or may not vote, the overwhelming majority of Victorians (who also vote) are tired of the excuses and second chances of this tired industry and welcome the proposed reforms.

    The Proposed Code of Practice for the Keeping of Racing Greyhounds is a well-planned document, which the racing industry sorely needs if it expects to have any future at all. Indeed, its self-predicted downfall will no doubt come about much sooner than expected if its stakeholders and participants do not begin moving in step with these reforms.

    Yours Faithfully,

    Like

  2. Congratulations on a well-researched submission, and thank you.

    I have three main concerns and several small concerns with the draft Code of Practice:

    1. Staff ratios

    Under the draft Code, an establishment having 24 greyhounds has no requirement for any full-time staff (Sec. 3.1). This seems arbitrary, and insufficient to ensure that the needs of the dogs are being met.

    We know that the vast majority of greyhound trainers are hobbyists, which the Code arbitrarily defines (Sec. 8) as having fewer than three racing greyhounds, but in fact there are hobbyists with several more dogs than that. Any owner or trainer who has a regular job outside of the industry is a hobbyist.

    Table 4 in the Regulatory Impact Statement contains figures that show that 85% of Victorian trainers and breeders have fewer than 11 greyhounds under their care. And Table 6 shows that 85% of trainers are “small trainers” (defined as those with fewer than 3 dogs in their care) but together they are responsible for 10,819 registered greyhounds — more than half the total in the state. As staffing rules in the draft Code do not apply to them, the vast majority of Victoria’s racing dogs may be left without human oversight for hours at a time.

    2. Greyhounds for medical research.

    There is no mention in the draft Code of the practice of industry members giving or selling unwanted greyhounds to medical research facilities. This is a terrible fate for the dogs, and it ought to be prohibited outright. I was glad to see that the Coalitiion’s submission mentions this as well.

    3. Impact on the veterinary profession.

    The terms of the draft Code give a great deal of authority and discretion to veterinary practitioners, who are not subject to the regulatory oversight of the greyhound regulator, GRV.

    Throughout the draft Code, there are references to GRV participants performing functions “as directed by” or “under the direction of” or “on the advice of” a veterinary practitioner. The Code also prescribes certain duties and functions of veterinary practitioners that are to be included in the “written agreement” (Sec. 3.2) between the vet and the kennel and in the “health management plan” (Sec. 4.1), which must include an “emergency euthanasia plan” (Sec. 3.2). All of this gives a significant amount of authority to the vet and, in some circumstances, the power to authorize a departure from the requirements of the Code. Whether this creates problems for the veterinary profession from a regulatory or ethical point of view, I cannot say. But I am concerned that enforcement of the draft Code may be problematic for the regulator GRV, not only in relation to the conduct of veterinary practitioners (see for example the euthanasia provisions in section 4.2), but also in relation to ensuring compliance with the Code by industry participants, who may seek to excuse a departure from the rules by referring to their veterinarian’s advice.

    It’s especially concerning because the draft Code does not require the veterinary practitioner to have an arm’s length relationship with the kennel operator. In fact, the draft Code contemplates (in Sec. 3.6) that the veterinarian and the proprietor of the establishment may be one and the same person. In that special case, and only in that special case, an annual inspection and review must be carried out by an “independent veterinary practitioner” (as defined in Sec. 2). But the rest of the draft Code does not require the services of such an “independent veterinary practitioner” for any other purpose. Needless to say, a lack of independence could quite conceivably create a conflict of interest, or allow for undue pressure and influence on the veterinarian’s exercise of judgment, to the detriment of the dogs’ welfare.

    4. Other concerns:

    Sec. 3.5 sets out requirements for vehicle drivers and Sec. 4.3 for greyhound transport vehicles. But vehicle drivers are not among the list of registered persons mentioned in the definition of “GRV participant” in section 2. If people who specialize in operating dog transport vehicles are not required to be registered with GRV, how can these rules be enforced?

    Sec. 6.1.2 requires the provision of access to “fresh clean water”, but does not mention water temperature. The dogs’ water should be cool.

    Sec. 6.3.13 still allows euthanasia for unwanted greyhounds “when dictated by health or behaviour problems or when an acceptable home is unable to be found.” This wording is far too broad to stem the massive wastage problem in the Victorian industry.

    Like

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