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thewilberforcesociety.co.uk
R  R   G R I TWS Policy Paper
November 2011
Regulation and Reform of the Greyhound Racing Industry .
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Regulation and Reform of the Greyhound Racing Industry P O is proposal sets out to evaluate the state of the greyhound racing industry in the United Kingdom.
is paper does not endorse any form of root and branch reform of the industry's regulatory structures.
With the amalgamation of the British Greyhound Racing Board (BGRB) and the National GreyhoundRacing Club (NGRC) to form the current regulatory framework of the Greyhound Broad of Great Britain(GBGB) in January 2009, the new regulatory framework seems to be showing signs of improvement.
However, this paper does endorse the strengthening of the current rules and regulations, increasingfunding for animal welfare and dealing with the principal underlying cause of many healthy greyhoundsbeing unnecessarily destroyed every year, the overbreeding of racing dogs. To counter this, the paperrecommends the following set of proposals; • e immediate priority for policy makers must be to ensure that the remaining 13 flapping tracks in the United Kingdom are brought under British Greyhound Racing Board (GBGB) regulation, ifnecessary through mechanisms or passing an amendment to the Animal Welfare Act 2006. Whilstflapping tracks are now regulated by the Act, and required to have a vet in aendance at races,the regulation of flapping tracks still remains woefully inadequate, with limited or non-existentregulation over drug testing.
• One of the most noticeable problems in the greyhound racing industry is the lack of information available on racing dogs. e industry needs to produce an open and credible, 'cradle to the grave'database, recording injuries, dogs put down and dogs homed aer retirement from racing. iswould allow policy makers and regulators alike to see exactly what is happening within the in-dustry itself, measure the success of new policies and increase public awareness of racing as anissue.
• As well as the current registration fee, the Greyhound Board of Great Britain should consider implementing a minimum £100 deposit with the registration of any new dog for racing, to ensurethat the owner has an interest in securing the safe retirement of a racing dog at the end of itscareer. e deposit would be returned no sooner than 6 months aer the retirement of a dog, andonly upon the presentation of proof that the dog had been successfully rehomed, or placed in aretirement kennels.
• Greater research needs to be done on the prevalence of congenital diseases amongst greyhounds, and whether this is in any part the product of the intensity of inbreeding amongst racing dogs. eGreyhound Board of Great Britain should commission the Royal College of Veterinary Surgeons(RCVS) to conduct more detailed research on this subject.
• As a maer of immediate priority bookmakers must offer more transparency over the proportion of their profits drawn from unclaimed winnings and handling fees on dormant accounts. From thisthe government should look at developing a framework to divert unclaimed winnings towardsanimal welfare, regulation and infrastructure for the long term benefit of the industry.
• e British Greyhound Racing Fund (BGRF) should look at equalising the amount spent on prize money with its annual grant to the Retired Greyhounds Trust (RGT). In the past year this wouldimply an almost 20% increase in RGT funding, a contribution that would make a significant dif-ference to the safe retirement of greyhounds every year, and the day to day operations and man- Regulation and Reform of the Greyhound Racing Industry • Everything possible must be done to ensure the continued impartiality of the BGRF, and that funds are seen to be allocated to where they are needed most. ere should be no overlap between boardmembership of recipient firms, contributing firms, and the board of the BGRF itself.
• Over the coming years the international dynamic to racing will become increasingly important.
Serious consideration should be given to the idea of cross border models of regulation. EuropeanUnion-wide regulation deserves serious consideration in the long run. is could form part of theEU Strategy for the Protection and Welfare of Animals, due for renewal in 2015.
• e United Kingdom and Irish governments and regulatory authorities should consider an im- mediate moratorium on the export of greyhounds to the People's Republic of China until greaterreassurances can be given over animal welfare.
2.1 Greyhound racing in the UK
Greyhound Racing is one of the most popular spectator sports in the United Kingdom, aracting over 3million spectators who wager some£2.5 billion on 70,000 races every year. e majority of the industryoperates under a system of self-regulation through the Greyhound Board of Great Britain (GBGB), thebody that sets and enforces the rules and regulations of racing for some 28 registered stadiums acrossthe country. In addition to this are around are a number of unregulated racing tracks, commonly knownas 'flapping' tracks, which are subject only to regulation under the statute, in particular the AnimalWelfare Act 2006.
Greyhound Racing in its modern form was brought to the United Kingdom by Owen Patrick Smith,commonly described as the 'father' of the modern sport for devising the first mechanical lure (hare) andcircular track in the United States in 1925. Alongside the businessmen Charles Munn, Smith founded theGreyhound Racing Association (GRA), building the first purpose built greyhound racing stadium in theUK at Belle Vue, Manchester in 1926 Over the coming years aendances at races would boom, as would the number of tracks across thecountry and the money wagered on races each year. Recent decades have seen the sport move furthertowards professionalism, to secure the integrity of the sport and to recognise increasing public concernfor animal welfare.
2.2 Retirement and rehoming
e Retired Greyhound Trust (RGT), founded by the National Greyhound Racing Club in 1974, is theprimary re-homing organisation for retired racing greyhounds in the United Kingdom. ere remainsa tremendous amount of good will towards greyhound welfare and their supporters, with the RGTdepending in part on voluntary contributions from the public to do its work. Major tracks, including ¹ British Greyhound Racing Board, History of Greyhound Racing, ² ibid.
Regulation and Reform of the Greyhound Racing Industry Harlow and Romford host charity nights, with all proceeds supporting the safe retirement of dogs.
Tracks are increasingly taking responsibility for re-homing a high proportion of the dogs that race withthem.
2.3 Issues
e industry has traditionally operated under a model of self-regulation. is has, to a broad extent,secured a good standard of animal welfare within the industry when compared with other countries.
Equally though, there are issues with welfare that still need to be addressed, and more can be done.
One of the key issues is the re-homing of retired racing dogs. According to 2009 figures it costs theRetired Greyhound Trust an average of over £800 to re-home each racing dog on its boIn order toensure the safe re-homing of the 10,000 greyhounds presently running on tracks, a budget of some £8million would be needed if the industry were to seriously address the issue of re-homing the numberof dogs it produces, a figure far in excess of the current RGT grant from the British Greyhound RacingFund (BGRF).
is is then an industry that operates with profit as its primary concern. Dogs are bred intensely forgood racing nature, and sold and traded as commodities across borders, in particular between the UnitedKingdom and Ireland. A racing greyhound is both a living thing and a financial investment that playsan important role in a number of British communities.
Clearly there are at least regulations to secure this already. Indeed, NGRC Rule 18 states 'that the owneris responsible for the welfare of the greyhound at the end of its racing career'. What is clear then is thatthere are already the necessary statutes and rules to hold trainers and owners accountable for animalwelfare. e issue here is one of enforcement, and funding for enforcement.
A watershed moment for the industry came in 2006, following a Sunday Times investigation into DavidSmith, a builders' merchant from Seaham, Co. Durham. For over 15 years Mr. Smith, had been destroyinghealthy greyhounds no longer considered by their trainers to be fast enough to race, with the remains ofan estimated 10,000 dogs found on his one acre property. Following an RSPCA and police investigation itwas decided there wasn't enough evidence to prosecute the Seaham case on animal welfare legislation.
Following a six-month investigation, the Environment Agency eventually pursued a private prosecutionunder waste disposal regulations, and Mr. Smith was ordered to pay £2000 in costs. It is generally ac-cepted within the industry that the scale of Mr. Smith's actions went unpunished. e case though led torenewed scrutiny of the racing industry, and its regulatory structures, culminating with the amalgama-tion of the British Greyhound Racing Board (BGRB) and the National Greyhound Racing Club (NGRC)to form the current regulatory framework of the Greyhound Broad of Great Britain (GBGB) in January2009 ³ Retired Greyhound Trust, Trustees Report and Accounts, 2010, p2.
⁴ BBC News, Man fined over greyhound deaths, 16th March 2007, Regulation and Reform of the Greyhound Racing Industry 3.1 Unregulated tras
e immediate priority for policy makers must be to ensure that the remaining 13 flapping tracks in theUnited Kingdom are brought under British Greyhound Racing Board (GBGB) regulation. Whilst trackssuch as Armadale Stadium, and Highgate Stadium are now required to have a vet in aendance, theregulation of flapping tracks still remains woefully inadequate, with limited or non-existent regulationover animal welfare or drug testing.
ese tracks are far from a statistical insignificance within the industry. Whilst the GBGB, to its greatcredit, does not allow any dog racing on these independent, 'flapping' tracks to race on its own regulatedtracks, there are a number of cases of dogs in the past 12 months being raced in both the regulated andunregulated sector, contravening GBGB rules. is has the potential to risk the long term integrity ofthe regulated sector, especially over the use of performance enhancing drugs, and illegal substances onracing Flapping tracks not only compromise the integrity of the regulated sector, they also risk the health andwelfare of racing dogs. A unified approach to greyhound racing in the UK will ensure an industry withgreater standards of integrity, animal welfare and public confidence. Perhaps even more importantlythis would help rehoming organisations like the Retired Greyhound Trust beer coordinate their work,and place a greater responsibility on currently unregulated tracks to retire racing dogs in an appropriatemanner.
3.2 A 'cradle to the grave' database.
One of the most noticeable problems in the greyhound racing industry is the lack of information avail-able on racing dogs. e industry needs to produce an open and credible, 'cradle to the grave' databaserecording injuries, dogs put down and dogs homed aer retirement from racing.
is would allow policy makers and regulators alike to see exactly what is happening within the in-dustry itself, measure the success of new policies and increase public awareness of racing as an issue.
e industry already tracks breeding records through the website , whichdemonstrates regulating and recording the industry is far from an impossible task. e not for profitwebsite has successfully constructed a database of more than 1.5 million greyhounds worldwide in lessthan a decade.
A cradle to the grave database, tracking injuries, ownership and the status of registered racing dogs isa fully feasible and affordable idea. e transfer from earmarking registration to micro chipping wouldmake the implementation of this database far easier than it would have been in the past.
⁵ British Eurosport, Greyhound trainer 'gave his dogs Viagra', 13th July 2011 Regulation and Reform of the Greyhound Racing Industry 3.3 Racing injuries
e Greyhound Board of Great Britain must also do more to collect and make available for public con-sumption a full record of injury data within the industry. A more transparent approach to racing injurieswould allow for comparisons to be made of the number of injuries at different tracks, and different sur-faces, allowing the industry to over time identify forms of best practice in dog racing.
3.4 Registration deposit
As well as the current registration fee, the Greyhound Board of Great Britain should consider imple-menting a minimum £100 deposit with the registration of any new dog for racing, to ensure that theowner has a long term interest in securing the safe retirement of a racing dog at the end of its career.
e deposit would be returned no sooner than 6 months aer the retirement of a dog, and only upon thepresentation of proof that the dog had been successfully rehomed, or placed in a retirement kennels. iskind of proposal has been criticised in the past for punishing independent trainers, potentially pushingthem out of the regulated industry altogether. Seing a deposit at a relatively low level of £100 shouldthough be affordable for most dog owners and trainers, whilst still providing a financial incentive tosecure the safe retirement and rehoming of a racing dog.
In 2000, the then regulatory body the NGRC introduced a deregistering scheme for retired dogs in theindustry, requiring owners to inform them when a greyhound has officially retired from racing, givingnotification of the new owners address and its permanent home. A deposit would provide the necessaryfinancial incentive to encourage owners to take a more proactive approach to the safe retirement ofracing dogs.
3.5 Dealing with overbreeding and inbreeding
One of the key concerns discussed in the 2007 APGAW report was that of overbreeding in the industre report estimated that some 1500 to 3000 British born dogs never end up racing on a regulated track.
Given that 75% of racing dogs in the United Kingdom originate from Ireland, the report speculatesthen that 'ere will be a much higher number of puppies who never make it to the track in Ireland'.
Reducing the number of puppies bred each year then should be a continued priority to secure the longterm sustainability of the industry, as well as animal welfare.
Whilst EU regulations may prevent restrictions on breeding, this by no means suggests that the industryshould abandon all responsibility for the number of dogs breed each year. An increased registration feeand registration deposit may help with this, encouraging trainers to pay greater aention to the quality,not just the quantity of the dogs they breed. Certain breeding lines have greater propensity for injuries,or longevity in racing, so with a more considered approach to breeding we may be able to incentiviselonger racing careers for the dogs themselves. Furthermore, the government should use its influence inEurope to argue for a substantial reduction in European Union grants, used to subsidise the breeding ofracing dogs in the Republic of Ireland, to help curtail the surplus of dogs bred each year.
⁶ e Associate Parliamentary Group for Animal Welfare, e Welfare of Greyhounds, May 2007, p2.
⁷ ibid.
Regulation and Reform of the Greyhound Racing Industry Greater research needs to be done on the prevalence of congenital diseases amongst greyhounds, andwhether this is in any part the product of the intensity of inbreeding in the industry. e British Grey-hound Racing Board should commission the Royal College of Veterinary Surgeons (RCVS) to conductmore detailed research on this subject. In the long term the RCVS should consider introducing a grey-hound specialism for the veterinary profession, in recognition of the risk of incorrect diagnosis andtreatment given the unique anatomy and physiology of greyhounds as a breed.
3.6 Releasing funds from unclaimed winnings and dormant betting accounts
One of the principal difficulties of enforcing the already existing regulations and guaranteeing highstandards of animal welfare remains funding. One of the core funding mechanisms for funding animalwelfare has been the British Greyhound Funding Board (BGFB) allocation of voluntary contributionsfrom bookmakers in the United Kingdom. Whilst this average 0.6% contribution of turnover amounts toseveral million pounds every year, it is apparent that greater funding would be useful to secure moreeffective regulation and long term animal welfare.
As a maer of principle though, the taxpayer should not have to take on the burden of increased fundingfor welfare. With spending at the Department for Culture, Media and Sport being cut by 25% over thecourse of the next 4 years under the 2010 Comprehensive Spending Review, it is unreasonable to expectthis burden to be placed on the public purse.
One alternative would be to make the currently voluntary contribution a compulsory one, compellingcontributions from the few major firms who do not contribute towards the British Greyhound FundingBoard. However, the 2007 APGAW report concluded that whilst it would be desirable to introduce acompulsory levy on bookmakers, it would be 'contrary to European Law' on compAssumingthis to be the case, there are some alternative methods of increasing funding drawn from bookmakers.
For example the Coalition Agreement in May 2010 pledged to investigate how dormant being accountsand unclaimed winnings could be used to fund grassroots sport in the United Kingdom. Don Foster, theLiberal Democrat MP for Bath was commissioned to research this and produced his report on this inDecember 2010, later published in September 2011. Unfortunately the report was largely unable to finddetailed figures on unclaimed winnings within the industry, with firms refusing to provide data 'eitheron the grounds of commercial confidence or because they claim to be unable to produce the figur In lieu of these figures, Foster instead uses estimates drawn from the National Loery, where unclaimedwinnings amounting to 1.5% of sales in 2008-2009, a figure exceeding £78.2 million. is implies thenthat the amount of unclaimed winnings within the being industry on dog racing may amount to £37.5million per annum, drawn from a source that should not form part of a responsible business's operatingprofits.
Even at a more conservative estimate, this figure would adequately secure the welfare of greyhoundswithin the industry several times over, with millions of pounds available to redevelop racing infrastruc-ture to secure the long term future of the racing industry, as well as those who work within it. iswould also adequately cover the regulation of the remaining flapping tracks in the United Kingdom,drawing them under GBGB regulation.
⁸ ibid., p.9⁹ Don Foster MP, e use of dormant being accounts and unclaimed winnings, December 2010, p.4 Regulation and Reform of the Greyhound Racing Industry As a maer of immediate priority then, bookmakers must offer more transparency over the proportionof their profits drawn from unclaimed winnings and handling fees on dormant accounts. From there thegovernment should look at developing a framework divert unclaimed winnings towards animal welfare,regulation and infrastructure for the long term benefit of the industry.
e United Kingdom would not be unique in pursuing this model. In Hong Kong, horse race winningsunclaimed aer 60 days are donated to the country's Jockey Charity Trust, which according to Mr.
Foster raised HK$51million in 2009-2010, a figure amounting to £4.1 million. With the cooperation ofthe industry then this is a clearly feasible policy that deserves greater investigation over the comingmonths.
3.7 e British Greyhound Funding Board
e British Greyhound Racing Fund (BGRF) are the industry body responsible for collecting the annuallevy paid by bookmakers, as well as allocating these funds to every aspect of greyhound racing in theUnited Kingdom. In the year ending March 2011, the BGRF received some £7.8 million in grants frombookmaker. Of this, some £1.5 million was granted to the principal rehoming charity the RetiredGreyhounds Trust, with a further £1.3 million granted to support what the report describes as 'welfare-related issues' including veterinary care and track safety, amounting to 36% of BGRF expenditure overthe past 12 months.
However the same report also boasts of £2 million of expenditure on prize money over the same period.
Whilst the sport's popularity and long term success in part depends on there being an incentive fora competitive industry, it questionable why this should be the largest single expenditure head for theBGRF. Similarly, the £1 million spent on marketing the industry also appears excessive when the industryseems to be thriving even in a difficult economic climate.
ere is clearly more than adequate financial and sporting incentive to keep the industry competitive inthe UK, a fact demonstrated by the thousands of dogs being bred surplus to industry requirements everyyear. At the very least, the BGRF should look at equalising the amount spent on prize money with itsannual grant to the Retired Greyhounds Trust, and not at the expense of other 'welfare-related issues'.
In the past year this would imply an almost 20% increase in RGT funding, a contribution that wouldmake a significant difference to the retirement of greyhounds every year, and the day to day operationsand management of the RGT and its kennels. Again, it is important to acknowledge the steady increaseof the percentage of BGRF funds spend on welfare over the past decade, but equally, more clearly canand should be done.
Concerns also need to be raised with regard to the allocation of BGRF spending on track improvementseach year. For example William Hill, one of the contributing firms, were awarded £209,209 in the form ofa grant to improve two of their stadia last year, with Ladbrokes awarded a further £181,300 to improvetwo of theirs.
ere are further complications when we consider that a number of directors of the BGRF, both pastand present, also sit on the boards of recipient firms, including Ladbrokes and William Hill. Needlessto say there needs to be an appropriate level of expertise on the board to allocate funding within theindustry, and this report does not in any way question the integrity of any of those on the board, or for ¹⁰ British Greyhound Racing Fund, BGRF Report 2010-2011, p.3 Regulation and Reform of the Greyhound Racing Industry that maer the board itself. Indeed we fully acknowledge the statement in last year's report that 'It is thecompany's policy that the directors concerned take no part in the awarding of racecourse improvement.
However it is absurd that a grant given to the funding board, by bookmakers as an act of goodwill, isthen partially spent to improve stadia owned by the contributing companies in the first place. Regardlessof the motivations of these board members, everything possible must be done to ensure the impartialityof the BGRF, and that funds are seen to be allocated to where they are needed most. ere should beno overlap between board membership of recipient firms, contributing firms, or the board of the BGRFitself to help ensure this is the case.
3.8 Reform of races and race practice
e industry should continue to follow up on the 2007 APGAW proposals by improving racing surfacesto reduce injuries to dogs racing in the industry each year. is approach, integrated with a databaserecording greyhound injuries would make a real difference in supporting the longevity of dogs. Similarlythe number of veteran races should continue to increase aer their successful trial in recent years.
e BGRF should target prize money to support veterans racing at tracks, and other events that increasethe racing life of the greyhound and the long term sustainability of the industry. Prize funds, where theyare allocated by the BGRF should also offer some reward to all runners, not just race winners, to reducevariance in prize money for owners and trainers.
3.9 Developing a framework for international regulation
Greyhound racing is already an industry that works across borders, something clearly demonstrated inthe long established relationship between greyhound racing in the Republic of Ireland and the UnitedKingdom. Over the coming years this international dynamic to racing will become more important andserious consideration should be given to the idea of cross border models of regulation, to secure a highstandard of racing integrity and animal welfare in the mainstream industry across borders.
e most obvious level for this to operate at is the European Union. e European Commission hasalready taken some responsibility for regulation of animal welfare e.g. the banning of cosmetics testingon animals. In the long run this could form part of the EU Strategy for the Protection and Welfare ofAnimals, due for renewal in 2015. By then we should have a stronger idea of the success of the newlyinvigorated British model of self-regulation under the GBGB since 2009, and if appropriate discussionscan be opened for a new level of European regulation. Given the concerns expressed about the welfareof racing dogs in a number of European countries, in particular Spain and Italy, Europe-wide regulationwould seem a particularly appropriate model to work with.
3.10 Export of greyhounds to China and India
e United Kingdom and Irish governments' should consider an immediate moratorium on the exportof Greyhounds to the People's Republic of China until greater reassurances can be given over animal Regulation and Reform of the Greyhound Racing Industry welfare, including the establishment of a regulatory framework for the racing industry in China. isfollows apparent interest from the Bord Na gCon (Irish Greyhound Board) in sending Irish dogs to theChina to develop the industry there earlier this yearAn idea that has apparently been rejected sincethen, following criticisms from welfare groups and the Irish government. is report warmly welcomesthe fact that this idea has now been rejected as part of the development strategy for the industry inIreland Whilst these new markets represent a major opportunity for the industry to expand into developingworld with a growing middle class with disposable income, clearly there needs to be a credible frame-work to ensure we're not just exporting responsibility for racing dogs at the expense of their welfare.
A similar policy approach should also be considered with regard to India and other emerging marketsfor the industry in the coming years.
Whilst there is a tremendous amount of good will and progress within the industry on the issue ofanimal welfare, more needs to be done to ensure that regulation is enforced and appropriately funded.
is paper has outlined ways in which to increase and beer distribute industry funding, and proposalsto access new sources of funding for welfare and regulation that could be implemented without anysignificant burden on the taxpayer. e most immediate priority for policy makers though should bethe regulation of flapping tracks. By doing this we can secure the long term integrity of the regulatedsector, and take further steps towards a unified and successful racing industry in the United Kingdom.
¹² e Dogs Trust, Greyhound Racing In China, March 2011,

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