A draft code for the welfare of greyhounds in NSW has been released and a call is being made for feedback. The feedback deadline has been extended until 14 April 2020. Participants, industry stakeholders and the general public are able to provide feedback.
We need as many people as possible to make it clear to the NSW State Government that there are serious shortcomings in the greyhound protection offered by this Code of Practice.
You can find out more about the draft NSW Greyhound Welfare Code of Practice and feedback process here: https://www.gwic.nsw.gov.au/about/industry-consultation/public-consultation/draft-nsw-greyhound-welfare-code-of-practice?
The CPG submission is available as a .pdf here: https://coalitionprotectgreyhounds.files.wordpress.com/2020/03/cpg-response-to-the-draft-nsw-greyhound-welfare-code-of-practice.pdf
Please provide your feedback via the online response form here https://www.surveymonkey.com/r/FJ2QXGB. The form also allows you to upload a submission if you are providing a more comprehensive response.
We have provided suggested responses to the form questions in the grey shaded areas below. This includes a response to Question 10 which highlights the main areas of the Code of Practice that CPG believes must be amended if greyhounds are to be protected.
If you would prefer to upload a document which contains the response to Question 10, please click here to download the word document. You will need to reference the document in the Question 10 field on the form. Please note any fields on the form with an asterisk will need to be completed whether you upload a document or not.
These responses are for guidance only and please replace or amend with your own words or experiences. You may also choose to wait and view the complete CPG response.
Completing the feedback form
Questions 1-7 are for personal and general details.
Question 8. Do you believe the Code of Practice, as drafted, will be easy to comply with?
Select the Yes tick box
Reasons: It is too easy to comply with as many of the standards are broad and allow too much room for individual interpretation. I also believe that welfare standards should be nationally consistent and refer you to the Victorian Code of Practice for the Keeping of Racing Greyhounds which takes a far more prescriptive approach.
Question 9. Do you think the standards in the draft Code of Practice have been set at an appropriate level?
Select the Not at all appropriate tick box
Reasons: Please see response to Question 8.
Question 10. What standards of the Code would you like to see change and why? (Note: you can copy the text below into the Question 10 field or edit and upload this document and reference it in the Question 10 field.
Part 1: Introduction, amendment required to following clause on page 4: “This Code applies to all participants and greyhounds kept by them, regardless of whether or not the greyhound is being kept for the purpose of racing. This includes greyhounds that are retained by participants as a breeding dog or pet.”
Why: This paragraph condemns greyhounds that are not required for racing to a life of confinement which would not be considered appropriate for other companion dogs. This is not acceptable or in line with public opinion. Greyhounds not required for racing could live more than 15 years and must not be kept in conditions that apply to racing greyhounds, the majority of whom have a racing career of about 12 months. Separate standards are required for greyhounds not required for racing.
Part 1: Introduction, amendment required to following clause on page 5: “Participants may delay compliance with Standard 5.8 of this Code, as far as it relates to construction: for up to ten years from the date that this Code comes into effect…”
Why: This paragraph condemns greyhounds to live in sub-standard conditions for up to 10 years. This is not acceptable. The maximum period to upgrade facilities must be 12 months. The shift in community expectations of the greyhound industry is not a new occurrence; 10 years is an excessive period to bring facilities into line with what is deemed to be the welfare minimum.
Part 5: Housing and Enrichment: this entire section is far too general in nature and allows for interpretation by individuals that may not be in accordance with the intent of the Code. The entire section should be brought into line with the Victorian Code. Specific inclusions are:
kennel roof height (must allow a greyhound to stand upright on its hind legs)
toileting yards (minimum 5m2 per dog, no more than four greyhounds to be toileted together at one time)
exercise yards (at least 20m2 with a minimum width of 4m2, supervision required at all times when in use)
day yards (for extended unsupervised exercise, contain weatherproof area and raised bed)
outdoor sleeping areas (at least 3m2 weatherproof area including kennel with raised sleeping area)
appropriate housing of dogs in pairs or groups
Why: A review into best practice for the socialisation of greyhounds in a racing context conducted by the Australian Working Dog Alliance found that: “It is common practice for greyhounds in Australia to spend a significant period of their adult life under conditions of individual housing. This is unacceptable from an animal welfare standpoint. Dogs are highly social animals and single-housing eliminates their ability to demonstrate one of the Five Freedoms (as defined by the RSPCA) – Freedom to express normal behaviour: by providing sufficient space, proper facilities and company of the animal’s own kind. Co-housing of compatible dogs should be adopted as standard practice for greyhounds at all stages of their lifecycle.”.
Part 8: Training, trialling and racing, amendment required to clause 8.18: “Greyhounds must not participate in a race or trial if the ambient temperature at the race or trial track exceeds 38°C.”
Why: While the scientific evidence base shows a heightened risk of heat stress in racing greyhounds at temperatures of greater than 38°C due to the loss of the ability to appropriately thermoregulate, risks and ill effects can occur at lower temperatures, with some risk from 31°C, and the threshold of being able to maintain thermal equilibrium at 36°C. (McNicholl J, Howarth GS, Hazel SJ. Influence of the Environment on Body Temperature of Racing Greyhounds. Front Vet Sci 2016; 3:53.)
On these grounds, while racing should be prohibited at 38°C and higher, allowances should also be included in the draft NSW Code to accommodate for the risk at lower environmental temperatures.
Steps should also be taken to reduce the congestion on track, which is correlated with incidence of injury. The University of Technology Sydney investigation into optimal greyhound track design for safety and welfare strongly recommended reduction of greyhounds from eight to six starts per race. (University of Technology Sydney. 2017. Identifying optimal greyhound track design for greyhound safety and welfare. Phase I Report Jan 2016 to 31 Dec 2016.)
This important welfare step should be reflected in the draft NSW Code.
Part 9: Retirement and Preparation for Rehoming, amendment required to clause 9.13: “Where a greyhound is not suffering from an intractable condition or injury … before the greyhound is euthanased.”
Why: Euthanasia must be restricted to those cases where a veterinarian certifies that the greyhound is suffering from an intractable condition or injury that causes significant pain or discomfort, or a marked reduction in quality of life, such that it is inhumane or would otherwise compromise the welfare of the greyhound to delay euthanasia.
Question 11. Is there anything that should be removed from the draft Code?
Please see response to Question 10.
Question 12. Is there anything else you would like to see in the draft Code?
A marked omission in the draft NSW Code is that there is no acknowledgement of the critical socialisation period of puppies; the period from three weeks to three months of age in which early behavioural experiences shape how the animal will be able to cope with novel experiences as an adult. The importance of this period and how it will impact long term rehoming outcomes must be acknowledged in the draft NSW Code. While the ‘wind down’ period is also important, plans for gradual exposure to novel stimuli during the critical socialisation period must also be included to result in more positive retirement outcomes.
Steps should also be taken to reduce the congestion on track, which is correlated with incidence of injury. The University of Technology Sydney investigation into optimal greyhound track design for safety and welfare strongly recommended reduction of greyhounds from eight to six starts per race and this should be reflected in the Code. (University of Technology Sydney. 2017. Identifying optimal greyhound track design for greyhound safety and welfare. Phase I Report Jan 2016 to 31 Dec 2016.)
Question 13. Do you think the transition period of 10 years for complying with kennel sizes is sufficient?
Select the Yes tick box
Reasons: This paragraph condemns greyhounds to live in substandard conditions for up to 10 years. This is not acceptable. The maximum period to upgrade facilities must be 12 months. The shift in community expectations of the greyhound industry is not a new occurrence; 10 years is an excessive period to bring facilities into line with those deemed to be the welfare minimum.
Question 14. Do you think a transition period should apply to other areas of the Code?
Select the No tick box
Question 15. Is there anything else you would like to add to your submission?
Please complete with your feedback.
Thank you so much for letting the NSW Government know how strongly people feel about the suffering inflicted on greyhounds. Please comment on the CPG facebook site facebook.com/CoalitionForTheProtectionOfGreyhounds/ or email firstname.lastname@example.org if you have any questions or suggestions.