Licensing of activities involving animals: consultation

Part 6 Greyhound Racing

Background

In Scotland there are currently only two greyhound tracks— the official Greyhound Board of Great Britain (GBGB) track at Shawfield in Rutherglen, Glasgow and Thornton, an independent 'flapper' track near Glenrothes in Fife. The Scottish Government understands that the Shawfield track been closed since March 2020. Whether this track reopens remains to be seen. The Thornton track is still open and hosting greyhound racing.

Greyhound racing in Scotland is essentially an unregulated activity. The Welfare of Racing Greyhounds Regulations 2010 ("the 2010 Regulations") apply in England. They require greyhound tracks to be licensed and impose various licence conditions on the operators of greyhound tacks. Licence conditions cover the standard of kennel facilities at a track, record keeping and traceability. They also require a veterinary surgeon to be present at the track before and during racing and to inspect all dogs that are intended to run.

Under the 2010 Regulations greyhound tracks can be licensed by the local authorities or by a UKAS accredited body. As a UKAS accredited body, the GBGB has assumed responsibility for the licensing of greyhound tracks in England that operate to the standards required under the 2010 Regulations and that meet the higher standards set under the GBGB's Rules of Racing: Rules of Racing | Greyhound Board of Great Britain (gbgb.org.uk). Independent tracks that do not meet the standards set by the GBGB are licensed by the local authority.

While the Shawfield venue did operate to the Rules of Racing standards required by the GBGB, the track at Thornton does not. This means that apart from the general cruelty and welfare protections offered by the Animal Health and Welfare (Scotland) Act 2006 there is little in the way of oversight of active greyhound racing in Scotland. The Scottish Government considers this to be unacceptable and that greyhound tracks in Scotland should be made subject to statutory licensing to ensure that premises can be inspected and the welfare of racing and retired greyhounds protected. The rationale for introducing licensing, and what a future licensing scheme may require, is discussed in the section below.

In 2016 a review of the 2010 Regulations by the UK Government found that the introduction of statutory licensing in England had been effective in addressing many of the concerns associated with greyhound welfare at the track that existed prior to licensing. That review did conclude, however, that the industry needed to do more to improve conditions at trainers' kennels as well as being more transparent. In response the GBGB agreed to publish annual independently verified injury, euthanasia, and retirement statistics from GBGB tracks. GBGB also agreed to extend their UKAS accreditation to allow for enforcement of the standards in the 2010 Regulations at GBGB trainers' kennels.

The introduction of the 2010 Regulations in England did, in some part, deliver significant improvements in respect to greyhound welfare and transparency, particularly for GBGB regulated tracks. However, concerns clearly remain and the introduction of a robust and modern licensing scheme in Scotland for greyhound racing will seek to deliver the safeguards and accountability required, particularly for greyhound tracks operating outwith GBGB's regulatory control.

The case for licensing

As has already been stated, there is currently only one greyhound track in Scotland where racing still takes place. As this track is not regulated by the GBGB, it is not subject to any regulatory control and therefore the number of injuries and deaths at this track is not published. There is also no requirement for veterinary presence during racing to assess the fitness of a dog to run and to check its welfare post-race. Furthermore, there are concerns that checks are not being undertaken in Scotland to ensure that performance enhancing substances are not administered prior to racing.

Any racing of animals where prize money and gambling is involved has the potential for risks of exploitation, injury, and compromised animal welfare. These risks increase when there is no regulatory oversight or enforcement.

Animal Welfare organisations and campaign groups have also raised concerns about the racing of greyhounds in extreme weather, over-racing of individual dogs and the number of puppies that are unaccounted for between birth and racing registrations.

Greyhound racing can pose significant risk to the dogs involved. Running at speed around oval tracks can result in serious injury to dogs, and regrettably in some cases the injuries can be severe enough to necessitate euthanasia of the dog. Areas of congestion in particular significantly increase risks of high-speed collisions and subsequent injury. The table below show GBGB recorded numbers of greyhound injuries and fatalities over the period 2018 – 2021 for the whole of GB (does not include death/injury data from non-GBGB regulated tracks).

Note: injury data refers to individual injuries, not the number of dogs injured. Racing was also suspended for some 2 months in Spring 2020 due to Covid restrictions.

While we recognise that the GBGB continues to take steps to improve the welfare of racing greyhounds and reduce the number of fatalities and injuries that arise, these figures are very concerning. The lack of published data from unlicensed tracks makes it impossible to draw comparisons however.

In conclusion, the Scottish Government considers that there is a strong case for the introduction of a statutory licensing scheme for greyhound racing in Scotland. The introduction of such a scheme would improve greyhound welfare require transparency around the recording and reporting of key data, and ensure that there is accountability when greyhound welfare is compromised.

Requirements of a future licensing scheme

While not an exhaustive list, it is proposed that a future licensing scheme covering greyhound racing would—

• Require the operator of a greyhound track to be licensed by the licensing authority (this would likely be the relevant local authority).
• Allow inspectors appointed by the licensing authority to inspect licensed premises or to enter premises suspected of operating without a licence.
• Require any licence holder to comply with the conditions of any licence granted by the licensing authority. As is already the case for animal related activities subject to licensing in Scotland, the conditions that would need to be complied with would be set out in legislation. The licensing authority would have powers to add additional conditions of licence, but only where it considers it necessary to ensure the welfare of animals. Licence conditions could include:
  • Requiring licence holders to ensure the presence of a veterinary surgeon during racing to allow racing greyhounds to be health checked by the vet before and after racing.
  • Requiring the provision of a suitably equipped examination room to be used by veterinarians for the inspection, testing and emergency treatment of racing dogs.
  • Requiring licence holders to ensure the provision of adequate kenneling at the licensed premises that protects racing dogs from temperature extremes and weather.
  • Requiring licence holders to record and publish key data linked to fatalities and injuries attributed to racing.
• Require the licensing authority to be satisfied that the licence conditions are likely to be met and that grant of a licence is otherwise appropriate before issuing a licence. This would involve considering the applicant's conduct, whether the applicant is a fit and proper person and other relevant circumstances. This is already a requirement for licensable activities under the existing licensing framework.
• Require licence holders to refuse entry to greyhound owners/trainers that have failed to transport dogs in a manner that ensures their safety, or, where it is clear that the dogs are not fit to race, refuse to permit any such dog to race.
• Require licence holders to put in place protocols to deter the administration of performance enhancing substances and to undertake random testing of racing dogs for such substances.
• Allow the licensing authority to charge a fee for the consideration of a licence application and grant of licence.
• Allow the licensing authority to vary, suspend or revoke a licence as appropriate due to the actions or conduct of a licence holder.
• Require the licensing authority to publish online a register of licence holders. This is to allow the public to quickly check whether an operator of a track is properly licensed.
• Provide an appeals mechanism for applicants or licence holders aggrieved by a decision by the licensing authority.

Consultation questions

Q1. Do you agree that operators of greyhound racing tracks should be made subject to a statutory licensing scheme?

Yes / No / Not sure

Please explain the reason for your answer.

Q2. If you do not support the introduction of statutory licensing, what controls, if any, would you otherwise recommend?

Q3. Do you support the proposal to require veterinary presence when greyhounds are racing to allow pre and post-race health checks of dogs and ensure prompt veterinary care of any injured dog?

Q4. The current licensing framework to which we propose to add canine greyhound racing allows for licences to be granted for a period of 1 to 3 years duration, depending on assessed risk. Do you agree with the proposal that greyhound tracks are instead required to renew their licence annually, due to the higher animal welfare risks?

Q5. Do you know of any challenges or negative consequences that may arise from the introduction of statutory licensing for greyhound racing? If yes, how best could these be addressed?

Q6. Are you aware of any examples of how any of the proposals above may impact, either positively or negatively, on those with protected characteristics?

These are: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation.

Yes / No / Don't know

If yes, please explain your answer.