Mark Latham's Submission Draft Code Of Practice
IT is incredible to think of the sequence of events that has led to the publication of this Greyhound Welfare Integrity Commission (GWIC) document.
4 April 2020
It is incredible to think of the sequence of events that has led to the publication of this Greyhound Welfare Integrity Commission (GWIC) document.
A notorious Fake News program, the ABC’s 4 Corners, broke the law in airing footage deliberately designed to damage the NSW greyhound industry; after which Premier Mike Baird promised his (supposedly distressed) teenage daughters he would close down greyhound racing; after which the ancient former-judge and keen thoroughbred racing man, Michael McHugh, produced a shambolic, inconsistent and hopelessly incomplete report; which gave Baird the justification he needed to keep his promise to his teenage daughters; a decision so ill-conceived and destructive, it had to be reversed; with the compromise of establishing a bloated, officious bureaucracy in GWIC, drawn mainly from the human-sports doping industry (not racing industry) to police greyhound participants in a manner no other racing industry in NSW has had to endure.
This was one of the all-time appalling public policy processes in NSW history, giving rise to the all-time appalling GWIC Code of Practice now on public display.
The inconsistencies are massive:
* The wastage issues in NSW thoroughbred and harness racing have been swept under the carpet, with a singular official obsession about greyhound racing.
* Thoroughbred and harness racing administer their own animal welfare and stewards’ processes, while greyhounds have been given GWIC, even though, over many decades, in terms of integrity, greyhound racing has been the cleanest of the three racing codes.
* Pet owners in NSW can do to their dogs (including retired and rehomed greyhounds) whatever they like under the Companion Animals Act with very little chance of official scrutiny, whereas GWIC is there to scrutinise greyhound dog-owners and trainers as if they are Ronald Biggs. The double standard is completely disproportionate.
* Zany rule making has inevitably followed, such as the no dead-meat/skins-on-the-lure rule. You can feed any dog in NSW as much dead-meat as you like; you can purchase hundreds of dead chickens at supermarkets if you wish (pre-panic buying); there are tens of thousands of fur coats for sale in NSW; greyhounds are carnivores in nature; they chase better with meat or skins on the lure, giving a return to their owners and avoiding wastage; yet dead-meat and skins are banned, replaced by plastic mops on the lure. Go figure.
* On acreage properties there are scores of rabbits out at night, which hunting-type dogs can chase, kill and eat. That’s all fine under NSW law, indeed it is praised as part of our wonderful farming way of life (as it should be). But if a greyhound touches a dead rabbit skin, that’s a serious offence.
It is time to call off this farce, and return sanity to the administration of greyhound racing in NSW. GWIC should be abolished under its 2020 statutory review and its Code of Practice should be binned. The full administration of the sport should be returned to GRNSW. Working people should be allowed to get on with racing their animals – for hope, pride, fun and prizemoney, without feeling like they are part of a police state.
The NSW economy is tanking under the weight of the current health emergency. Unemployment is expected to reach double-digit levels. The last thing we need is a contracting greyhound industry as participants leave and jobs are lost due to over-policing.
Working people are going through enough without GWIC breathing down their neck with this Draft Code of Practice. Some humanity is needed, please. Put people first and allow them to get on with the time-honoured pleasure of racing their dogs in NSW, freely and successfully.
DRAFT CODE OF PRACTICE IN DETAIL
Any normal, intelligent person would read this document as a long-winded advertisement for the abolition of GWIC. Many of its rules are confusing, unmeasureable and unenforceable, such as:
Feeding greyhounds ‘raw offal’ content (2.3), with no definition of what this means. It might be 1-2 percent of the feed, so that an owner or trainer can never really know.
The meaning of “appropriate drinking water temperature” (2.7). No practical guidelines or measurement and enforcement methods have been outlined.
At the page 7 Advisory, contrary to the requirement, pups won’t eat three times a day.
The regular trimming of toenails, with no definition or expectation for what this means in practice (3.18).
“The expression of normal canine behaviours, to prevent stress and anxiety” (3.19). Bizarrely, by this test, GWIC itself is guilty, as running and hunting dogs such as greyhounds love to chase prey, fur and meat.
Removing the cause of dog stress and anxiety (3.20), which sounds like an endless flow of vet bills.
The page 10 Advisory, warning of dogs with their ears back or licking their lips, is impractical. That’s every dog, every day (not just greyhounds).
The micro-management of “suitability for breeding” standards (4.1) to (4.5) and whelping/pup care (4.13) to (4.19).
Specifying detailed kennel measurements, “adequate air ventilation”, alarm systems and “temperature must be maintained at between 16C and 26C degrees” (5.1) to (5.8). There are many school classrooms in NSW that do not meet these standards.
Rule (5.6), in effect, requires kennel air conditioning, which is ridiculous.
The micro-managed, undefined requirements of (5.9) for kennel amenity cannot be enforced in any fair, measureable way.
Why can’t trainers be allowed to look after the general wellbeing of their dogs, without minutiae requirements for dogs needing to “lay down completely stretched out” (5.10)?
Specifying “warm, soft and dry” bedding at (5.10), without any definition of what this means and how it can be measured.
Tethering dogs when travelling can be for longer than two hours (a safety measure) but it’s ruled out by (5.12).
Not housing puppies together at (5.17) contradicts the provision at (7.6) for housing them in groups or pairs.
The provision at (5.26) for pest control raises the classic Bart Cummings question: how many flies are the kennels allowed to have? It was nonsensical then, and remains nonsensical now.
The Part 7 provisions for ‘Exercise, Socialisation and Enrichment’ are not practical, especially at (7.5). How can GWIC police these things without 24/7 surveillance? Again, why can’t trainers be encouraged to care for the general wellbeing of their dogs, without unenforceable micro-management?
Trainers have not been given any guidance as to what the written plan at (7.10) involves, why it is needed or how its contents can be enforced. Another unnecessary GWIC over-reach.
Provision (8.2) stresses the importance of reward-based training methods, but then (8.3) rules out the most effective reward for a dog: food rewards.
Provision (8.8) prohibits trialing dogs under 16 months old, even though this is an important part of a young greyhound’s education.
Dogs can suffer enormous pain in (9.14) if a vet needs to be consulted but cannot be found in a timely manner.
Other rules and proposed penalties in the Draft Code are disproportionate to the standards of the NSW criminal justice system. This includes 2-year jail terms for individuals “not making genuine attempts to rehome greyhounds” (9.6); and (9.11) to (9.14) on the correct euthanasing of dogs.
Who would want to enter a sporting industry where you can end up in prison for such matters, especially when the financial rewards in greyhound racing are so limited? Criminalising a recreational activity is a surefire way of destroying the activity altogether.
In most cases, GWIC has developed rules and regulations just for the sake of having rules and regulations. This is typical of a government body trying to justify its own existence, instead of acting purely in the best interests of the industry. If GWIC were truly concerned about animal welfare it would have vets inspecting the kennels, rather than quasi-police.
For most owners and trainers, greyhound care is straightforward. GWIC has turned it into a complicated, bureaucratic nightmare, underscored by the possibility of jail time.
In effect, the Draft Code of Practice is a 30-page advertisement for the abolition of GWIC. This would deliver a much-needed cost saving for greyhound racing in NSW, redirecting funds into track upgrades and improved prizemoney. With the greyhound industry knocked around by the CoronaVirus restrictions (and still recovering from the Baird ban), this would be the best policy for the NSW Government to adopt.