Submission responding to the draft NSW Greyhound … Submission...BARF being Biologically Appropriate Raw Food. The BARF diet consists of raw boneless meat, raw bone, raw viscera and

March 2020 NSW GBOTA Submission to draft NSW Greyhound Welfare Code of Practice 1

Submission responding to the draft

NSW Greyhound Welfare Code of Practice

Overview

This submission provides feedback to the Greyhound Welfare and Integrity Commission on

the draft NSW Greyhound Welfare Code of Practice, made under Sections 35 and 36 of the

Greyhound Racing Act 2017.

The proposed Code of Practice replaces the current Code of Practice for the Keeping of

Greyhounds in Training, and the Code of Practice for Breeding, Rearing and Education of

Greyhounds implemented in July 2018.

About the NSW GBOTA The NSW Greyhound Breeders, Owners and Trainers (NSW GBOTA) is a member

organisation that provides services to its membership relating to participation in the

greyhound racing industry. These services include provision of commercial racing operations

and advocacy in the interests of its membership.

NSW GBOTA is governed by a Board of Directors and professional management based at

Wentworth Park, Glebe. Further information is available at the NSW GBOTA website:

http://www.gbota.com.au/

NSW GBOTA operates greyhound race meetings throughout NSW, including at the State's

premier greyhound track Wentworth Park, the sole metropolitan venue in NSW. TAB

operations include Bulli, Bathurst, Gosford, Lismore and Maitland, as well as TAB/non-TAB

operations at Gunnedah and Temora. Appin Way is also utilised as a training facility.

NSW GBOTA also operates a network of branches throughout NSW (25 in total) which

provide greyhound racing participants with the opportunity to meet on a monthly basis and

progress issues of significance to the industry and discuss their ongoing participation.

Consultation with Stakeholders

http://www.gbota.com.au/


Over the course of the past two months, the NSW GBOTA has consulted with a range of

stakeholders to prepare the response to the Code as contained below. This included our

Directorate, members across 25 Branches of the Association, the hosting of several phone

conferences with owners, trainers and breeders, and discussions with major breeders and

trainers within the industry.

Further Consultation

Feedback provided through submissions and gained by the Commission during their

workshops should be applied, and a rewritten version of the Code produced for further

consultation with stakeholders.

It is absolutely imperative that participants get a further opportunity to consult on any

changes made, before any draft Code is provided to the Minister.

It is also essential that the Commission, and the Minister fully consult with Greyhound

Racing NSW, and other stakeholders on the commercial realities of the application of the

Code prior to any final document being submitted to the Minister for approval.

Part 1: Introduction

Name of the Code

The name of the Code should remain similar to previous, Code of Practice for the Keeping of

Racing Greyhounds. The name should specifically refer to racing greyhounds.

Objectives of the Code

The Association is of the view that the Code should only apply to racing greyhounds and is

not applicable to retired racing greyhounds that are kept by participants. Therefore, the

objectives of the Code should refer to racing greyhounds, not just greyhounds.

Recommended wording:

The objectives of this Code are to protect the welfare and promote the wellbeing

of racing greyhounds kept by greyhound industry participants in NSW.

Purpose of the Code

35 Commission to prepare code of practice

(1) The Commission is to prepare, for submission to the Minister, a code of practice

relating to the welfare of greyhounds.

(2) The code of practice must (without limitation) deal with the following:

(a) Standards for the keeping, treatment, handling and care of greyhounds,

(b) Standards for the facilities, equipment and conditions at premises where


greyhounds are kept, trialled, trained or raced,

(c) Standards for the procedures and practices to be adopted in relation to the

keeping, trialling, training and racing of greyhounds.

36 Making of code of practice

(1) The Minister may, by order published on the NSW legislation website, make the

code of practice that has been submitted by the Commission. The order is to set

out the code of practice.

(2) The code of practice takes effect on the day on which the order is published or, if a

later date is specified in the order for commencement, on the later date so

specified.

(3) The Minister may, by order published on the NSW legislation website, amend or

repeal the code of practice. An amendment to the code may only be made if it has

been submitted by the Commission.

An order by the Minister under this section may only be made with the concurrence of the

Minister for Primary Industries.

Application of the Code

The Association is of the view that the Code should not apply to retired racing greyhounds

that are kept by a participant as a pet.

Once a greyhound is retired from racing, it becomes subject to the requirements of the

Companion Animals Act 1998.

To include retired greyhounds in the Code is unnecessarily over regulating. Large sections of

the Code, such as housing, would more than likely not apply to retired racing greyhounds.

To include retired greyhounds is to say that greyhounds retired at home with their owners

or trainers are requiring of higher care and regulation than those that are rehomed to non-

participants.

Commencement of the Code

Current participants have worked with the varying authorities over many years to comply to

the standards they have now. If there are no welfare concerns with existing infrastructure,

current participants should be grandfathered, and the proposed changes should only apply

to new participants, or existing participants who are moving to new properties, upgrading

their facilities, or in circumstances where there are serious welfare concerns related to

housing.

Breaches of the Code


In the event of a breach of the Code, it is understood that Section 24N of the Prevention of

Cruelty to Animals Act 1979 (POCTA) provides for inspectors to issue a notice in writing

requiring an individual to take such action so as to remedy the breach to avoid further

contravention.

The Association is concerned with how this power relates to the rules of racing. The rules of

racing also have their own penalty guidelines. This is confusing to participants and may put

participants in a double jeopardy style situation. The Commission needs to provide further

clarification on this matter.

Offence Provisions

The Association does not support the link to Section 39 of the Greyhound Racing Act 2017

(NSW), which provides for Part 9 to be an offence provision, and therefore the maximum

penalty to be two years jail time.

It is the Association’s position that having a jail term attached to these matters is too harsh

a penalty for the offence. In particular Clause 9.11 contains no time length, therefore strictly

speaking, any participant transferring a greyhound who knows that it may be euthanised

due to old age or ill health would thus be committing an offence under that provision.

The Association believes that breaches of these provisions can be dealt with sufficiently

utilising other penalties such as fines and disqualification.

Definitions

Further detail has been provided on a clause by clause basis in the table below where the

Association feels that further definitions are required.

Advisory Information

The advisory information is best practice recommendation information only and should not

form part of the Code.

If GWIC intends the advisory information to be enforceable, then it should have it moved

under a formal clause, and further consultation take place on it.

Advisory or recommended information is best contained within recommended guidelines or

other published material produced designed to assist participants.


NSW GBOTA Submission to draft NSW Greyhound Welfare Code of Practice

NUMBER CLAUSE NSW GBOTA RESPONSE

Part 2: Nutrition and Hydration

Standards: Food

2.1 Food provided to puppies and greyhounds must be

nutritionally balanced and complete, and of sufficient quantity

and quality to meet the daily requirements of the greyhound,

taking into account its physical and dental health, condition,

age, size and level of activity.

Supported.

2.2 Food must not be allowed to become rancid, decayed or insect

infection. Uneaten food must be disposed of before a fresh

meal is provided.

Supported.

2.3 Food fed to greyhounds must not contain raw offal. It is noted that this provision does not appear in the

current code, nor the Victorian Code. The Victorian Code

suggests that feeding raw offal is not recommended, but

if done so, should be fed in conjunction with a worming

program.

There are an innumerable number of educated sources

that, whilst recognising the infection risk involved,

provide for the nutritional benefits for canines of raw



offal.

Australian recognised veterinarian Dr. Ian Billinghurst

developed the BARF diet for canines. BARF being

Biologically Appropriate Raw Food.

The BARF diet consists of raw boneless meat, raw bone,

raw viscera and fruits and vegetables. This mostly

consists of 70% boneless meat, 10% bone, 10% fruit and

vegies, 5% liver, and 5% of another secreting organ. Raw

viscera in this case is usually chicken, lamb, turkey

hearts, chicken gizzards, poultry, cattle, veal liver and

kidneys. ** Billinghurst, Dr Ian, Give your dog a bone,

and The BARF diet

Questions should be raised about withholding this

nutritional dense product from greyhounds, without

regard for the long-term effect on the health of the dog.

Whilst the preference is to have this clause removed

completely, giving regard to the risks associated with the

feeding of raw offal, suggest that wording is changed to

reflect the Victorian Code of Practice:

Feeding raw offal is not recommended, unless doing so in

conjunction with a regular worming program.

It may also be useful to include a definition of raw offal.



Standards: Cleaning and Storage

2.4 Food containers and food preparation areas must be kept

clean and be disinfected regularly.

Supported.

2.5 Food must be stored in such a way as to prevent spoilage or

contamination.

Supported.

Standards: Water

2.6 Fresh, clean drinking water must be available to greyhounds at

all times, at a temperature that greyhounds will drink.

No other code refers to the temperature of the water,

and this should be removed as it is impractical for

participants to be able to monitor the temperature of

water at all times.

Further, the Code needs to have flexibility in

circumstances where a veterinarian has provided advice

that access to drinking water needs to be limited.

The Association suggests replacement of this with the

Victorian Code of Practice wording:

Greyhounds must have access to a sufficient supply of

fresh clean water at all times at the establishment, unless

advised otherwise by a veterinary practitioner.



2.7 Puppies must be provided with access to clean drinking water

of an appropriate temperature from three weeks of age.

It is impractical for a participant to be expected to

monitor and maintain the temperature of water at all

times.

Suggest replacing the wording with the Victorian Code of

Practice:

Young puppies, from three weeks of age, must be

provided with access to water.

2.8 Water containers must be cleaned regularly. Supported.

2.9 If water becomes contaminated with food, urine, faeces or

vomit, the container must be removed, cleaned and replaced

immediately.

The Association suggests this clause is unnecessary and

recommends that it should be removed, given the

application of Clause 2.8 above: Water containers must

be cleaned regularly.

If continuing to remain within the Code, the word

“drinking” should be inserted before water. It is not

uncommon for greyhounds to have access to other

bodies of water for playing in, such as dams or small

pools.

Advisory Information: Nutrition and Hydration



• From the time they are fully weaned to the age of 16 weeks, puppies

should be fed at least three times a day to sustain growth and

optimal physical health.

• Greyhounds aged between 16 weeks and six months should be fed

at least twice a day to sustain growth and optimal physical health.

• Greyhounds over the age of six months should be fed at least once a

day.

• Pregnant and lactating greyhounds require more food than normal

and should be fed at least twice a day to maintain condition.

The advisory information is best practice information

only and should not form part of the Code. This should

not appear within the final written document of the

Code.

If GWIC intends the advisory information to be

enforceable, then it should have it moved under a formal

clause, and further consultation take place on it.



Part 3: Health and Wellbeing

Standards: Monitoring Greyhound Health

3.1 Participants must check greyhounds in their care at least twice

a day.

The word “check” should be replaced with another

descriptive word, such as “observe”.

The word “check” to a greyhound participant is

associated with the process of having their greyhound

“checked” pre and post-race for signs of injury, soreness

or stress, or the processing of having a greyhound

“checked” by a veterinarian.

Standards: Veterinary Care

3.2 Participants must have a relationship with a veterinarian (or

veterinarians) capable of providing 24-hour veterinary advice

in regard to all greyhounds in the participant’s care.

Supported.

3.3 Veterinary treatment must be obtained without delay if a

greyhound or puppy is showing signs of pain, injury, ill health

or distress.

The words “without delay” should be removed.

The Association is concerned that a greyhound may

suffer minor injuries, ailments or ill health that can be

easily diagnosed by the participant, and managed

through rest, isolation or home care without veterinary

intervention. The wording of this clause appears to

suggest that a participant is required to seek after hours



care for what may be minor injuries or illnesses.

GRNSW has provided opportunity for most participants

to access first aid training for their greyhounds, and with

experience, most participants are capable of diagnosing

and treating minor injuries or illnesses.

When these escalate to more serious matters,

participants should absolutely seek veterinary treatment.


A greyhound should be regularly checked for signs of

pain, injury, ill health and distress, and veterinary

treatment sought when necessary.

3.4 Any directions of a veterinarian in relation to treatment of

pain, injury, ill health, distress or post-surgical care must be

followed.

Supported in principle.

However, what if the vet advice provided is to give the

greyhound medications that would breach greyhound

racing rules?

What should a participant do in circumstances where

there is conflicting advice from different vets?

Standards: Sclerosing Agents



3.5 Sclerosing agents must not be administered to greyhounds. More information or clarification is needed for

participants to understand the requirements of this

clause.

What is a sclerosing agent?

What are the names of sclerosing agents that

participants should be avoiding?

Standards: Heritable Disease or Defect

3.6 Where a greyhound is found to have a heritable disease or

defect, the owner must:

• have the greyhound’s parents and any other existing

offspring of the parents tested for the heritable disease

or defect or, if an accepted test is not available,

assessed for the disease or defect by a veterinarian;

• in consultation with a veterinarian, prepare a

treatment plan for any greyhound found to have a

heritable disease or defect where the greyhound is to

be retained by the owner, or

• prepare the greyhound for rehoming, if the intention is

to rehome the greyhound.

The definition clause of heritable disease or defect does

not adequately reflect what is a heritable disease or

defect for which this clause seeks to address, unlike the

Victorian Code which expressly refers to definitions

within the Prevention of Cruelty to Animals Act.

The definition within the draft Code is far too vague.

Certainty needs to be provided around what constitutes

a heritable disease or defect.

If the Commission’s intention is to water down and

remove particular diseases or defects that are a problem

within the breed, then the Code would be best served

clarifying and outlining them, rather than leaving

participants uncertain.

Further, the need to have the greyhounds parents and



any other offspring tested is completely impractical, if

not impossible. For example, consider the use of an older

sire, and the vast number of offspring he may have

already created.

Standards: Storage, administration and treatment records

3.7 • Participants must keep a complete health care and

veterinary history for all greyhounds and puppies in

their care that includes:

• vaccination records and matching vaccination

certificates

• internal and external parasite control (e.g. fleas, ticks

or heartworm)

• any injuries sustained or health issues identified

• administration of any oral supplements, injected

substances or medications (by date, time, dose, route

of administration, drug name and name of person

giving the medication) Draft NSW Greyhound Welfare

Code of Practice

• any other treatment administered, including the

person prescribing the treatment and the name and

signature of the person administering the treatment

Supported in part.

Each greyhound already has its own health card, which

should record veterinary, medical and health history.

However, requiring participants to now add any injuries

sustained, or health issues identified will burden

participants unnecessarily.

The listing of major injuries or illness requiring significant

veterinary care should be kept, however, it is

unnecessary and too prescriptive to require participants

to record all injuries and illnesses, however minor.



3.8 Any medications prescribed by a veterinarian for a greyhound

must be administered in accordance with veterinary

directions.

Supported.

3.9 Medications, treatments, or supplements must be labelled

clearly and kept in their original container or packaging.

Supported.

3.10 Medications which have expired or which are no longer in use

must be disposed of.

Supported.

Participants should be advised of where best to dispose

of expired or not needed medications.

It is suggested the words “in accordance with

manufacturer instructions or the advice of the

prescribing veterinarian” be added after “disposed of”.

Standards: Vaccinations

3.11 Puppies must not be vaccinated before four weeks of age. Supported.

3.12 Participants must ensure that all greyhounds in their care are

vaccinated from the age of 6-8 weeks, and that vaccinations

are kept up to date.

Supported.



3.13 Unless a veterinarian has provided contrary advice in writing,

greyhounds must be vaccinated against: • Distemper virus •

Parvovirus

• Canine Adenovirus

• Parainfluenza virus

• Bordetella bronchiseptica.

Supported.

Standards: Worming and Parasite Management

3.14 Participants must administer an effective internal and external

parasite control program (e.g. gastrointestinal worm,

heartworm, ear mites, fleas and ticks) which is age

appropriate, to all greyhounds in their care.

Supported.

3.15 Worming and parasite treatments must be used and stored in

accordance with the manufacturer’s instructions.

Supported.

Standards: Dental Health

3.16 Participants must monitor the dental health of all greyhounds

in their care and seek veterinary advice if the greyhound

shows signs of dental disease.

This clause is not included in any Code in any other

jurisdiction.

Undoubtedly, dental health and dental hygiene is an

extremely important aspect of maintaining the overall



health of a greyhound.

Concern is raised regarding the broad wording of this

cause “shows signs of dental disease”, and the ability for

it to be open to varying interpretation by the

Commission’s inspectors.

Should this clause remain within the Code, the

Association suggests that a strong policy which details

the specifics of what constitutes dental disease is

important to minimise the wide interpretation of it.

Standards: Grooming

3.17 Participants must ensure that the greyhounds in their care are

maintained in a good and clean condition.

Supported.

3.18 Participants must ensure that their greyhound’s toenails are

trimmed regularly.

Suggest using the Victorian wording which is much

clearer regarding the responsibilities associated with

toenails:

All greyhounds must have their toenails checked and

trimmed at a frequency that prevents overgrowth.

Standards: Stress and Anxiety



3.19 Participants must provide greyhounds in their care with

opportunities for expression of normal canine behaviours, to

prevent stress and anxiety.

There is no definition of normal canine behaviour

contained within the Code.

Whilst supportive of the overarching intention of this

clause, which seeks to address welfare concerns, the

interpretation of what is normal canine behaviour differs

remarkably between dogs, between breeds, across age

and other related factors. What may seem an unusual

behaviour in one dog, may be perfectly normal within

another.

The Association prefers the model used within the

Victorian Code of Practice, which uses a Table to outline

common behavioural types and stress, and how to

address them if they become a problem.

3.20 If a greyhound shows signs of stress, anxiety or stereotypies

which do not resolve quickly, participants remove the trigger

or cause, or seek veterinary advice.

Supported.

Advisory Information: Health and Well Being

Failure to provide veterinary treatment to an animal when necessary is an

offence under the Prevention of Cruelty to Animals Act 1979.

• Participants should monitor their greyhounds to check if they are

eating and drinking normally, able to defecate and urinate normally,




Code.



able to move about freely and without pain, and their skin and coat

are in a normal condition.

• The following symptoms indicate that a greyhound may be ill:

sneezing or abnormal coughing - abnormal, rapid or laboured

breathing - vomiting, diarrhoea or difficulties with urination -

lameness or inability to stand or walk - bleeding or swelling of body

parts - weight loss or lack of appetite - dehydration - apparent pain,

fits or staggering - wounds, irritations or inflammations - signs of

poor dental health - significant or unusual hair loss - repeated

scratching or shaking of the head.

• Participants should be aware of the current requirements of the

Australian Pesticides and Veterinary Medicines Authority for

administration and storage of veterinary treatments.

• The following behaviours, where excessive or repeated, may

indicate that a greyhound is stressed or anxious:

cowering/shaking/shivering/trembling - tucked tail - ears back -

avoidance/withdrawal/inhibition - disengaging/loss of focus -

freezing in response to stimulus - aggression - hypervigilance -

muscle tension - excessive panting - yawning - teeth chattering - lip

smacking - lip licking - cheek puffing - unresponsive dilated pupil,

pacing - salivation.

• Stress and anxiety are key causes of stereotypic behaviours in




Advisory or recommended information is best contained

within recommended guidelines or other published

material to assist participants.



greyhounds and early intervention is necessary to prevent their

development. Examples of stereotypic behaviour include:

repetitive behaviour such as excessive licking (of environment, self,

other greyhounds) - pacing/circling/spinning (worn pads) -

destructive behaviour such as chewing wire, beds or bowls -

persistent barking or howling.

• Participants should maintain good dental hygiene in their

greyhounds. This can be achieved by routine teeth brushing, feeding

of bones or dental treats, and use of chew toys.


Part 4: Greyhound Breeding

Standards: Suitability for Breeding

4.1 Participants must obtain from a veterinarian a written

certification that a greyhound is suitable to breed before the

greyhound may be registered for breeding.

What is the definition of “suitable to breed”?

What information would a veterinarian utilise to certify

that a greyhound is suitable to breed?

This clause is concerning and may lead to the reduction

of breeding to commercially unsustainable levels.



4.2 A greyhound must not be bred from if it has been diagnosed

by a veterinarian as having a heritable disease or defect, or

there is a reason to believe that the greyhound has a heritable

disease or defect.

There needs to be certainty on what constitutes a

heritable disease or defect, as there is in the Victorian

Code of Practice.

4.3 Participants must not arrange matings of greyhounds that will

result in first-degree crosses such as father-daughter, mother-

son, or brother-sister, or second degree crosses such as

grandfather-granddaughter.

The Association needs further clarification, and evidence,

as to why second-degree crosses are to be completely

restricted.

Recommend using the less restrictive wording applied in

the Victorian Code of Practice:

Second degree matings) for example, grandfather and

granddaughter) are not recommended without

appropriate prior expert advice.

4.4 Neither male nor female greyhounds are to be registered for

breeding before they are at least 18 months of age.

Supported.

4.5 A female greyhound must have no more than two litters in any

two year period, unless with written veterinary advice, and

approval has been obtained from the Commission.

Not supported.

This has recently been changed from 18 months to two

years and is now out of step with all other jurisdictions,

who remain at 18 months.



The Association is keen to understand the reason for the

change. Has there been any welfare study done on why

it is needed to alter it from 18 months to 2 years?

From the Association’s perspective, there is no material

welfare issues at stake, and this decision will have a

deleterious effect on the commercial aspects of breeding

and the provision of dogs for greyhound racing in NSW.

In particular, the Association is concerned that

participants who have female greyhounds who are on a

twelve month cycle may miss out on being able to have

their third litter, due to the restriction, and that by the

time the greyhound comes around to her next cycle, she

may be too old to breed with.

The Association recommends the use of the Victorian

Code of Practice wording:

A female must not have a third litter until the first litter

are at least 18 months of age.

Standards: Natural Mating

4.6 Natural mating pairs must be physically separated from other

greyhounds.

Supported.



4.7 If the female greyhound is being unduly harassed by the male

greyhound, they must be separated immediately.

Supported.

4.8 A male greyhound must not be put with more than one female

at any one time for the purpose of natural mating.

Recommend changing the word “put” to housed.

4.9 After mating, both greyhounds must be physically separated,

assessed for signs of injury, and treatment provided if

necessary.

Supported.

4.10 Dog breeding stands must not be used in mating. Supported.

Standards: Artificial Insemination

4.11 Artificial insemination must only be conducted by a

veterinarian or an artificial insemination technician.

Supported.

4.12 Surgical artificial insemination can only be performed by a

veterinarian using general anaesthetic, with appropriate pain

relief during and post-surgery.

Supported.

Standards: Whelping



4.13 A pregnant greyhound must be moved to a whelping box at

least three days prior to her estimated whelping date. The

whelping box must be clean, safe, quiet, and separated from

other greyhounds.

There needs to be flexibility to take into account

individual trainer and greyhound circumstances.

It is not uncommon for hobby trainers to keep pregnant

greyhounds within their home, and they should not be

forced to move the greyhound to a whelping box where

it may be less comfortable, and potentially cause the

greyhound distress.

4.4 After whelping is complete, the dam and her puppies must be

closely monitored to ensure the puppies are feeding normally

and maternal acceptance has been firmly established.

Supported.

4.15 The whelping area must be cleaned and disinfected within 24

hours of the completion of whelping.

Supported.

Standards: Lactating

4.16 Dams must be examined twice a day for mastitis during the

first two weeks postwhelp, and veterinary advice sought

where mastitis is present.

Supported.

4.17 Participants must seek veterinary advice in relation to any

puppies which are not feeding properly, or do not gain weight.

Supported.



Standards: Puppies

4.18 Gentle daily handling of puppies must be provided within

seven days of whelping.

Supported.

4.19 Puppies must not be re-homed before eight weeks of age,

unless directed by a veterinarian.

Supported.

Advisory Information: Greyhound Breeding

Where practicable, the dam and puppies should be checked by a

veterinarian within three days after whelping.




Code.









Part 5: Housing and Environment

NSW GBOTA Response:

The Association considers the overall housing areas of the Code to be far too prescriptive. Understandably, in the course of

development of the code, broad principles have been considered and applied. However, there are a number of practical issues around

prescribing areas and widths of where greyhounds are held. The practical considerations around existing facilities must be given weight

in the drafting of the Code.

Further, this entire section appears to make the assumption that all greyhounds are housed in kennels. It does not allow for

greyhounds, racing, retired, pregnant, that are kept within the main house. Given that this Code also applies to retired greyhounds that

are kept by participants, it is likely that a large number of greyhounds would be housed inside a participants home.

The Association supports the need for good size kennelling and runs for greyhounds. Whilst in principle, the 10-year transition for

existing kennels to meet standards appears to be flexible and provide participants with sufficient time to meet standards, there is still

enormous capital infrastructure costs for replacement of existing kennels.

Current participants have worked with the varying authorities over many years to comply to the standards they have now. If there are

no welfare concerns with existing infrastructure, current participants should be grandfathered, and the proposed changes only applying

to new participants, or existing participants who are moving to new properties, upgrading their facilities, or in circumstances where

there are serious welfare concerns related to housing.

The implementation of the proposed section regarding housing and environment will require a very clear implementation policy

developed by the Commission, in consultation with stakeholders and participants, which outlines the Commission’s interpretation of

this section so that participants are well aware and understand what will and will not be acceptable during inspections by the

Commission. This will also ensure that the Commission is consistent with its application across the board.



The Association believes there needs to be a far more flexible approach taken to these clauses, giving regards to individual participant

circumstances. As an example, some breeders may only have one bitch, and may choose to whelp that bitch within a room in a home.

Therefore, whilst hygiene and welfare standards would need to apply, the recommendations in respect of boxes would not need apply.

Flexibility in reasonable interpretation from the Commission is necessary, and clear guidelines and policy for the Commission’s

inspectors is an absolute essential requirement.

Standards: Construction of housing pens, kennels and yards

5.1 Greyhound enclosures and perimeter fencing must be

designed, constructed and maintained in a way to prevent

injury or distress to greyhounds, and to prevent their escape.

Supported.

5.2 All perimeter fences must be a minimum of 1.2m high, and

must have a secure gate.

Supported.

5.3 Any security measures installed in or around greyhound

enclosures must not prevent easy access to greyhounds, or

efficient removal of greyhounds in the event of an emergency.

The very nature of something being a security measure

usually means that it prevents easy access, so this clause

is quite contradictory.

To assist participants, it is recommended the

Commission issues examples of what a security measure

that would be suitable in an emergency looks like.

5.4 Vehicles, caravans, portable crates and the crawl space under

any dwelling must not be used as long-term housing for

Supported.



greyhounds.

Standards: Indoor Housing

5.5 All indoor greyhound housing areas must have adequate

ventilation.

Supported.

5.6 Where greyhounds are housed indoors and forced ventilation

is the only form of air movement:

• temperature must be maintained at between 16OC and

26 OC;

• effective air cleaning and filtration must be in place;

and

• a power back-up and effective alarm system must be

installed and available for use in the event of power

failures or breakdown.

What is the definition of forced ventilation?

The Association is interested to understand why this is

necessary, and what unnecessary cost burden it will add

to participants.

Has there been a welfare study which specifies this

requirement for dogs, which a lot of humans do not even

have access to?

The Association cannot support the requirement for this

within the Code, it is far too prescriptive and

unaffordable for participants.

5.7 Where greyhounds are housed indoors, light cycles must be as

close as possible to natural conditions

Supported.

Standards: Greyhound housing area space requirements



5.8 Greyhounds must be housed in greyhound housing areas that

meet the minimum size requirements outlined in Table 1.

The requirement to have adequate sized kennels and

exercise areas for greyhounds is supported in principle,

however the Association is concerned that Table 1 is far

too prescriptive.

• Minimum Height – Concerns are raised where the

minimum height restrictions should be reduced in

circumstances where it is necessary to restrict a

greyhounds ability to jump to prevent injury to

itself.

• Pen (includes kennel) for greyhound registered for

breeding:

“greyhound registered for breeding” should be

replaced with “greyhound in pup or greyhound

undertaking breeding activities.” It is not

uncommon for a female greyhound registered for

breeding to still be racing, and further greyhound

registered for breeding would include stud dogs.

• Whelping greyhounds housing pen – This is far

too prescriptive, and concerns are raised that the

space is too large to be safe for the greyhound

and her puppies.

Further, this clause exacerbates the issue of the fact that

the Code applies to both racing greyhounds, and retired



greyhounds that remain within the participants care.

Retired greyhounds are most likely not living in kennels,

and therefore the requirements for them would be

vastly different to those of racing greyhounds.

Standards: Housing and Environment

5.9 Greyhounds must at all times be kept in greyhound housing

areas that provide adequate protection against extreme

temperatures, direct sunlight, humidity, dampness, persistent

loud noises, light pollution, noxious odours and draughts.

Recommend changing “must at all times” to “should”.

Standards: Sleeping areas

5.10 Areas where greyhounds sleep must:

• be divided by a solid partition;

• include a raised bed or wooden pallet, which is large

enough for the greyhound to lay down completely

stretched out on;

• be provided with bedding that is warm, soft and dry;

and made of materials that are safe for greyhounds and

puppies.

Supported in principle, where it applies to greyhounds

housed in kennel blocks only.

The application of this Code to retired racers who are

kept by participants makes this requirement challenging,

as in a large majority of circumstances these greyhounds

would be kept in the house, or potentially housed

together in yards with indoor kennels.

Standards: Tethering



5.11 Participants must regularly monitor any greyhounds that are

tethered.

Supported, but to be read in conjunction with response

from 5.12.

5.12 Greyhounds must not be tethered for more than two hours

per day.

While this is supported in principle, it may be necessary

to tether a greyhound for the purposes of cleaning their

kennel or other necessary hygiene or welfare practice.

Further, the Association questions how this operates in

conjunction with Clause 6.3.

The Association supports the Victorian Code of Practice

wording in this regard:

Greyhounds may only be tethered for temporary, short-

term restraint under supervision.

Greyhounds must not be permanently tethered or

tethered as a form of long-term containment or housing

at any time.

Standards: Housing Greyhounds for breeding and whelping

5.13 No female greyhound which is near or in season is to be

housed with a male greyhound six months of age or older that

Supported.



has not been desexed.

5.14 Whelping boxes must be large enough for the dam to lie

comfortably while whelping and to accommodate the dam and

her puppies for the first four weeks after whelping.

Supported.

5.15 Whelping boxes must have sides that are high enough to allow

the dam to exit readily but also prevent puppies under four

weeks from falling out.

Supported.

5.16 Whelping greyhound pens must contain a fully screened

bedding area to allow the dam physical separation from other

greyhounds and provide the dam with access to an area where

her puppies cannot reach her.

Supported.

5.17 Puppies from a litter must not be housed together unless they

are all compatible.

The word compatible is far too obscure a description and

lends itself to various interpretations of what may

defined as compatible.

Normal canine behaviour in puppies usually includes play

fighting, as puppies brawl with their litter mates, mother

and other dogs to develop their skills, bodily

coordination, strength and control. Further, play fighting

amongst cohabitating puppies is a natural and essential



mechanism for establishing pack structure and

socialisation.

Preference is for the using a variation of the wording

contained in the Victorian Code of Practice:

Puppies must be actively monitored when housed

together and if serious fighting, bullying or other adverse

welfare outcomes are identified, they must be separated

Standards: Cleanliness and Hygiene

5.18 Greyhound housing areas and bedding must be maintained in

a clean, hygienic and safe condition at all times.

Supported.

5.19 Pens and kennels must be disinfected using an effective

disinfectant no less than four times per year, as well as:

• after an outbreak of an infectious disease

• prior to introduction of a new greyhound

• prior to whelping

• upon the removal of puppies.

Supported.



5.20 Greyhounds must be removed prior to hosing of greyhound

housing areas, and must not be returned until cleaning is

complete and the area is dry.

Supported.

Standards: Preventing transmission of disease

5.21 All premises where more than one greyhound is kept must

include an isolation housing area for greyhounds suspected of

having an infectious disease. Isolation housing may be

provided off-site at a veterinary practice under a written

agreement with that practice.


Understandable that a greyhound should be isolated if

there is an infectious disease, however the Association

raises concerns about the practicalities of application of

the rule, particularly in circumstances of hobby trainers

who may only have a few kennels. Requiring that trainer

to house their greyhound at an offsite veterinary practice

would be extremely costly and impractical.

5.22 Isolation housing must be physically separated by an

impervious barrier from other greyhound housing areas.

Definition of impervious barrier is required.

5.23 Biosecurity procedures must be put into place to prevent the

spread of disease from isolation areas to other parts of the

premises.

Supported.



5.24 Visitors to all greyhound housing areas must be provided with

access to hot and cold water hand washing facilities with soap

or hand sanitising stations.

Supported.

5.25 If a greyhound is diagnosed or suspected of having an

infectious disease, it must be moved immediately to isolation

housing.

Supported.

Standards: Pest control

5.26 Pests (including fleas, ticks, flies, mosquitoes, spiders and

rodents) must be controlled effectively in all greyhound

housing areas to prevent health of greyhounds being affected.

This is far too prescriptive. The Association questions

how a participant is able to “control effectively” pests

such as mosquitoes, spiders, or flies within indoor/

outdoor kennels.

Recommend:

Pests (including fleas, ticks, flies, mosquitoes, spiders and

rodents) as far as reasonably practicable must be

controlled effectively in all greyhound housing areas to

prevent health of greyhounds being affected.



5.27 Pest control chemicals must be kept in their original container

and used and stored in accordance with the manufacturer’s

instructions.

Preference for the Victorian Code of Practice wording

with regards to pest control:

Chemicals used for pest control must be commercially

available, registered by the Australian Pesticides and

Veterinary Medicines Authority and used and stored in

accordance with the manufacturer’s instructions.

5.28 Greyhounds must be removed from any areas where and while

pest control chemicals are being used.

This is too broad and generic and may capture pest

controls that are designed to be utilised on the dog, such

as flea or tick control, or pest control which is safe to be

used around animals.

Insert the words:

Greyhounds must be removed from any areas where and

while “toxic” pest control chemicals are being used.

Standards: Emergency evacuation procedures

5.29 Participants must have an effective evacuation plan to ensure

that greyhounds can be removed safely in the event of an

emergency.

Supported.



5.30 Emergency evacuation procedures must be prominently

displayed in or near all greyhound housing areas.

Supported.

The Commission should assist participants in this regard

by providing a template which can used.

5.31 All greyhound housing areas must have functioning and visible

fire extinguishers or other adequate fire protection.

It may not be practical for greyhound housing areas to

have fire extinguishers, depending on individual

participant facilities and environment.

Preference for less prescriptive wording, such as

contained in the Victorian Code of Practice:

Facilities must have appropriate fire extinguishers or

other fire protection.

Advisory Information: Housing and Environment

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; or

• where any welfare or safety issues relating to non-compliance

facilities are identified at the premises, until a date specified by the

Commission.

This means that participants who are required to construct new kennels in

order to comply with standard 5.8 of this Code have up to ten years to do

so, unless welfare issues attributable to non-compliance with Standard 5.8

The time frame of providing up to ten years for

participants to comply with housing sizing is supported in

principle.

However, the Association believes there needs to be a

clear policy created by the Commission, in consultation

with participants and other stakeholders, which provide

guidelines for inspectors undertaking inspections, so that

participants are fully aware or, and understand what will

and will not be acceptable.



are identified at their premises. The construction of any new kennelling

facilities, following commencement of this Code, must comply with

Standard 5.8.

The wording of “welfare issues attributable to non-

compliance with Standard 5.8” is too broad, and open to

variable interpretations, therefore the Association

believes having a clear policy outlining that

interpretation is necessary.


Part 6: Transporting Greyhounds

Standards

6.1 Participants must not transport any greyhound in a manner

likely to cause injury or undue stress to the greyhound.

Suggest replacing the word “must”.


Participants should ensure greyhounds are transported in

a manner that is not likely to cause injury or undue stress.

6.2 Compartments and cages, when used for transporting

greyhounds must be weatherproof, have adequate ventilation

and be maintained at a comfortable temperature and level of

humidity for greyhounds.

Supported.



6.3 When using compartments or cages for transporting

greyhounds, participants must:

• provide enough space for the greyhound to sit, lie

down and stand in a natural position;

• where two or more greyhounds are transported in the

same compartment or cage, individually restrain

greyhounds during transport;

• fix compartments/cages securely to the transport

vehicle;

• keep compartments/cages clean; and

• disinfect compartments/cages at least four times each

year, or as otherwise necessary to maintain good

hygiene.

Suggest include wording:

• where two or more greyhounds are transported

in the same compartment or cage, individually

restrain and muzzle greyhounds during transport

except for puppies under 16 weeks of age.

6.4 When being transported, greyhounds must be removed from

transport compartments/cages at least every two hours and

offered an opportunity to drink, exercise and toilet.

This is impractical, too prescriptive, and may place

onerous burden on participants that may even be

dangerous to both the participant and the greyhound.

Greyhounds may be being transported following racing,

or overnight, when they would normally be sleeping and

not getting up to drink, exercise and toilet.

Depending on the time of night, or the area which

participants are travelling through, it may be unsafe for

both participant and the greyhound to stop and get out



of the vehicle.

The Association supports the need for participants to

check on travelling greyhounds, however does not

support the need for them to have to get out the

greyhound every time. A participant should be able to

make an assessment of their individual greyhounds and

the circumstances of their travel in this regard.

The Association prefers this clause be replaced with the

wording in the Victorian Code of Practice:

During transportation, greyhounds must be inspected at

least every three hours unless it is unsafe to stop the

vehicle. Inspections must occur more frequently if advised

by a veterinary practitioner.

6.5 Transport compartments may only be used for short-term

housing whilst at race meetings or trials.

This clause does not capture the many reasons a

greyhound may be housed in a transport compartment.

For example, in emergencies, or if there are issues with

their kennel and they need to be moved temporarily

whilst cleaning or maintenance takes place.

Further, there is no definition of what would be

considered short term.

Advisory Information: Transporting Greyhounds



The temperature in transport compartments or cages should be no higher

than 26oC. If the temperature is lower than 16oC, greyhounds should be

provided with adequate protection against the cold.

The advisory information and recommendations do not

form part of the Code and should not be written into it.

This information is best contained in guideline material

issued to participants to reflect best practice.


Part 7: Exercise, Socialisation and Enrichment

NSW GBOTA Response:

It is well understood that three to six months of age is a critical socialisation period for puppies, and in principle supported that puppies

and greyhounds should be provided with adequate exercise, socialisation and enrichment.

While the general intent of Part 7 is supported, the Association remains concerned regarding the administration and paperwork aspects

in terms of what is expected in respect of record keeping. A significant proportion of participants would have trouble keeping this level

or records, or it may be impractical depending on the number of dogs under the participants care. The Association believes there would

need to be a significant transitional period provided by the Commission to allow participants to be adequately informed, trained and

get up to speed with new requirements such as this.

Further, in kennels where there are multiple greyhounds or litters or puppies, it is essential that an allowance for a generic plan for the

kennels be acceptable, rather than plans for each individual greyhound as implied in Clause 7.10.

It will be absolutely essential that the requirements for document plans needs to be assisted by templates provided by the Commission

that participants can follow, and strong education on how to use them. The Association believes this needs to form a critical part of

GRNSW and the Commission’s education of participants going forward.



Further concerns need to be raised regarding the practicalities of some of the clauses, particularly in larger kennels or rearing facilities

with multiple litters of puppies. This is particularly true of clauses where the time periods are specifically prescribed. The Association

feels that the time prescriptions need to be removed, as they create an impractical and impossible task for participants.

Standards

7.1 All puppies and greyhounds must be provided with daily

contact with humans through gentle handling.

What is the definition of gentle handling?

Suggested word replacement:

“exposure to humans through daily handling as

appropriate”

7.2 All puppies and greyhounds older than 8 weeks of age must be

provided with regular contact with, and exposure to, other

vaccinated dogs that are compatible.

Remove “regular contact with”. Exposure to is sufficient.

Standards: Puppies aged 0-8 weeks

7.3 Each day, puppies aged 0–8 weeks must be:

provided with access to normal puppy activity and play with its

mother and littermates; b) exposed to a variety of surfaces;

and, c) provided with a variety of toys.

Supported.

Standards: Puppies aged 8-16 weeks



7.4 Puppies aged 8–16 weeks must be provided with: a) a

minimum of one hour per day to run or play within a secure

area outside of the greyhound housing area, and b) access to

toys for interactive play.

This is impractical, particularly in circumstances where

puppies are already housed or kept in large yards or runs

and have constant access to run around and play.

7.5 During each week, puppies aged 8–16 weeks must be

provided with three or more of the following:

(a) lessons in how to walk on a lead whilst wearing a collar;

(b) chasing games for play;

(c) training to respond to basic verbal commands;

(d) exposure to a variety of surfaces;

(e) exposure to novel experiences (see advisory

information);

(f) a variety of toys;

(g) travel in cars or trailers;

(h) exposure to different levels (such as walking up and

down stairs);

(i) access to training facilities such as slipping or galloping

runs.

This is very prescriptive, and may not be practical for all

participants, particularly in rearing facilities with large

numbers of puppies.

7.5(e) – needs to be removed, as the advisory

information does not form part of the Code, so it is

inappropriate for the Clause to refer to it.

7.6 Puppies aged 8–16 weeks must be housed in groups or pairs,

unless directed otherwise by a veterinarian.

Supported.

Standards: Greyhounds older than 16 weeks which have not yet commenced training



7.7 Greyhounds older than 16 weeks which have not yet

commenced training for racing must be given:

(a) access to a secure area outside of the greyhound

housing area for play, for a minimum of five hours each

day;

(b) interactive play or obedience training each day; and,

(c) each week, two or more of the following:

• reward-based training;

• walking on a lead;

• travel in cars or trailers;

• racing-related activities (such as access to starting

boxes, circular training facilities, straight tracks, lures or

race-day cages).

(a) Supported.

(b) Supported.

(c) This is far too prescriptive and impractical, in

particular for kennels or rearing facilities who

may have a large number of puppies.

Standards: Pregnant or lactating greyhounds

7.8 Pregnant or lactating greyhounds must be:

(a) provided with access to an exercise yard or walked on a

lead for at least 30 minutes each day,

(b) access to toys at all times.

Supported.

Standards: Spelling, breeding and retired greyhounds



7.9 All greyhounds which are being spelled, bred or which are

retired must be provided with the following activities for a

minimum of 60 minutes each day:

• gentle exercise in an area containing natural daylight,

either through walking on a lead or access to an

exercise yard;

• access to toys.

This clause is too prescriptive, and also may be

impractical or dangerous in certain circumstances.

A greyhound may be being spelled due to an injury which

requires the greyhound to rest, and not engage in

exercise, therefore the 60 minutes gentle exercise may

be more harmful than good to a greyhound. Similarly, to

pregnant bitches nearing the end of their pregnancy

term.

Retired racers by nature, do not need, nor enjoy a lot of

exercise, rather an aging racer is likely to be quite lazy

and prefer sleep over exercise.

The industry’s own Greyhounds as Pets program

advertises greyhounds as only required 15-20 minutes of

exercise on their information pages:

See: https://www.gapnsw.com.au/faqs/

A participant would also be knowledgeable in regards to

their individual retired racer, with some of them enjoying

a lot of activity, and others not so. There may be a

danger in enforcing 60 minutes of activity in a retired

racer who is no longer fit enough to handle that level of

activity.

https://www.gapnsw.com.au/faqs/



Standards: Exercise, socialisation and enrichment plan

7.10 Participants must have a written plan detailing how the

Exercise, Socialisation and Enrichment standards in this Code

will be met for each greyhound in their care.

The Association is concerned with the requirement of a

detailed plan for each greyhound, it appears to apply an

extremely onerous and impractical burden on

participants.

A participant should be able to have one plan that is to

be applied to all greyhounds within their care.

It is accepted that the exercise and training of

greyhounds will vary from time to time.

It is imperative that the Commission develops templates

to assist participants to implement this clause, and a

suitable transition period is implemented to assist

participants to become trained and start using these

plans.

Standards: Muzzling



7.11 Any muzzle used on a greyhound must be the correct size and

properly fitted, and must not cause pain, injury or distress to

the greyhound.

Supported.

7.12 Barking muzzles must not be used. Any muzzle used on a

greyhound must not restrict normal behaviour such as panting

or drinking.

Supported.

7.13 Greyhounds must not be muzzled for more than 30 minutes at

a time unless:

(a) being walked in a public place;

(b) travelling;

(c) in race day kennels;

(d) the greyhound is subject to a dangerous dog order

made under the Companion Animals Act 1998; or

(e) under written direction by a veterinarian; or the

Commission

Supported in principle, however concerns that a 30-

minute requirement is unnecessarily prescriptive.

The practicalities of this need to be considered. For

example, there may be times where greyhounds are left

unsupervised together in the yard or in the main house

and it is safer to leave muzzles on them. Most

greyhounds prefer the company of others, rather than

being isolated, and therefore it should be acceptable to

put them together, with muzzles on for safety.

Recommend replacing the word “must” with “should”.

Recommend including:

(f) unless it is in the best welfare and safety interests

of the greyhound;

(g) unless there is a likelihood of stress or injury.



7.14 Greyhounds under the age of nine months must not be

muzzled at any time, except:

a) as part of the education process and then only whilst in the

presence of the participant, or

b) at the written direction of a veterinarian.


Participants should be free to muzzle puppies where it is

necessary for their safety.

7.15 Greyhounds must not be muzzled for more than two hours a

day, unless at the written direction of a veterinarian.

Consideration needs to be given to circumstances that

arise which may require an extended period of muzzling.

For example, whilst travelling, or required for the safety

of the greyhound in circumstances where the greyhound

may injure themselves. For example, greyhounds that

that eat bedding, the cage or metal hazards such as

water bowls.

There needs to be flexibility with this where it is required

for the safety of the greyhound, or in circumstances of

travel, or emergencies.

7.16 Any veterinary direction about muzzling that extends for

longer than 12 months must be reviewed by the veterinarian

at least annually.

Supported.

Advisory Information: Housing and Environment



• Toys can include: rope toys, squawkers, rubber toys,

chew/food toys, or bones; and should be safe and appropriate

for greyhounds.

• Novel experiences could include: introduction to new people,

and people of different ages, sounds which they may

encounter in a normal home, food bowl exercises, places and

experiences outside of the home environment.

• Participants who keep more than one greyhound may have a

single plan for all of the greyhounds in their care, provided

that it meets the needs of all greyhounds.

• An Exercise, Socialisation and Enrichment plan may be varied

or suspended under the written advice of a veterinarian,

having regard to an individual greyhound’s circumstances.

• Participants are encouraged to check the Commission’s

website for templates and materials around exercise,

socialisation and enrichment plans. Contact details for the

Commission are also available on the website.




Code.







Part 8: Training, trialling and racing

Standards: Training and trialling facilities



8.1 All training facilities, trial tracks and equipment used in the

training, trialling and racing of greyhounds must be

appropriately constructed, maintained, and fit for purpose,

and supervised at all times when being used.

Supported.

Standards: Training methods

8.2 Training of greyhounds must be based on positive

reinforcement and the use of reward-based methods.

Supported.

8.3 Food rewards must not be attached to, or make up any part of,

a lure used to entice greyhounds to chase.

Not supported.

The Association supports a review of this clause and the

current policy which precludes food rewards for training

purposes.

Traditionally, canines have been trained utilising positive

cues including treats, food and toys. Once a greyhound

becomes a retired racer, they are regularly trained with

food-based rewards just like any other canine.

The use of food-based rewards or treats, which can be

clearly defined to ensure compliance and community

confidence, should be permitted for the overall benefit



of the industry.

8.4 Teaching, training, and all other interactions with greyhounds,

must be kind, humane and gentle.

This clause is too open to individual interpretation, and

therefore impractical in application and must be

removed.

8.5 Aversive devices or substances must not be used in the

training of greyhounds, except where prescribed by a

veterinarian.

There needs to be a more prescriptive definition of what

constitutes an aversive device or substance.

Standards: Walking machines

8.6 A walking machine must only be used where: a) it is used in

conjunction with other forms of exercise. b) it is being

supervised during use; c) the greyhound has been

behaviourally conditioned to willingly use a walking machine;

and d) the greyhound shows no signs of reluctance, fear or

distress while using a walking machine.

This clause is contradictory in nature.

A greyhound may show signs of reluctance and fear

whilst being trained to utilise a walking machine to

become behaviourally conditioned to it.

Suggest inserting words:

d) the greyhound shows no ongoing signs of reluctance,

fear or distress while using a walking machine.



Standards: Greyhound trialling and racing

8.7 Greyhounds shall only participate in trials or races that are

conducted at a registered trial track or licensed racecourse.

This clause appears to relate to the rules of racing, and is

best served within those riles, rather than appearing in

this Code.

There may be circumstances where trainers with

significant numbers of greyhounds in training opt to trial

at their own private facility that is not available for public

use, and therefore not registered.

This form of trialling should be allowable, and this clause

may operate to prevent it.

8.8 No greyhound under the age of 16 months shall be nominated

for a race or trial.

This clause appears to relate to the rules of racing, and is

best served within those rules, rather than appearing in

this Code.

The use of the word “trial” needs to be clarified. To

enable a greyhound to be ready to be nominated to race

at 16 months of age, it will need to be trialled

beforehand to ensure it is fit and ready to race.

It appears the intention of the clause is to prevent formal

performance trials or racing to take place before the age



of 16 months, rather than trialling for the purposes of

training or fitness.

These trials are no longer utilised in NSW and are not run

in other jurisdictions.

8.9 A greyhound that is presented for a trial or race must be fit

and in proper condition to trial or race.

Trials are utilised by participants for the purpose of

conditioning and building fitness of a greyhound to get it

ready to race, or in building fitness when returning from

injury. Participants should be encouraged to trial to

gauge fitness of greyhounds before nominating them to

race.

The word “trial” needs to be removed from this clause

completely.

8.10 Greyhounds must be presented for examination by an On

Track Veterinarian prior to starting in a race.

Supported.

However, this is already part of the race day process, and

seems unnecessary to be include in the Code.

8.11 A greyhound must not participate in a race or trial on

consecutive days.

Supported.



8.12 A female greyhound must not participate in or attend a race or

trial if she is or is suspected of being pregnant or in season.

Supported.

8.13 A greyhound which has whelped a litter must not participate in

a race or trial until at least ten weeks after the date of

whelping.

Supported.

8.14 A greyhound which has mated or had semen drawn must not

participate in a trial or race until at least two days after the

mating or drawing of semen.

Supported.

8.15 Any injury suffered by a greyhound during a trial must be

reported by the participant to the attending steward, if the

trial is conducted at a licensed race track. If the trial is

conducted at a registered trial track, the injury must be

reported to the trial track proprietor.

The definition of what constitutes a reportable injury

should be considered. An injury may be extremely minor

in nature, such as a scratch.

Does this include following the trial or race meeting, for

example if the injury is discovered the next day? Will

participants need to notify the attending steward, or will

notifying the Commission be acceptable?

8.16 Any injury suffered by a greyhound during a race must be

reported by the participant to the attending steward and On

Track Veterinarian.

Supported.



8.17 Participants must follow any directions given by an On Track

Veterinarian in relation to any greyhound in their care or

custody.

Supported.

Standards: Racing and trialling in hot weather

8.18 Greyhounds must not participate in a race or trial if the

ambient temperature at the race or trial track exceeds 38OC.

Supported.

However, the Association would be keen to view the

studies or documentation that supports this number.

8.19 The temperature in kennels at race tracks and trial tracks must

not exceed 26c.

Supported.

However, the Association would be keen to view the

studies or documentation that supports this number.


Part 9: Retirement and Preparation for Rehoming

NSW GBOTA Response:

The need for participants to rehome their greyhounds and prepare their greyhounds for rehoming is supported in principle. The

Association agrees that the industry needs to have a whole of life cycle approach to the greyhound with tracking and monitoring



through all stages of life, and can see that this section of the Code is designed to do that.

However, the Association believes that Part 9 of the Code in its current form is far too prescriptive. The Association believes that this

section of the Code could be met with the requirement for owners to have a rehoming plan for each dog they own, rather than the

heavily prescribed clauses seen below. In its current format, the Code is incredibly prescriptive, which creates an unnecessary burden

on owners to rehome their dogs. For example, lots of greyhounds have already been placed into GAP and rehomed, none of these dogs

were walked every day in shopping centres. Requiring them to be is over the top for both the greyhound and the human.

The Association believes that an owner being able to demonstrate they have a plan of action, and that plan of action is implemented

should be sufficient.

The Association also believes there should be scope within the Code of Practice to outsource the rehoming program to a person or

organisation skilled at doing so. The Association believes that there should be a wind down facility available to owners who are unable

to undertake the rehoming and wind down activities themselves, which should be funded by the industry.

Further, the Association does not support the link to Section 39 of the Greyhound Racing Act 2017 (NSW), which provides for Part 9 to

be an offence provision. It is the Association’s position that having a jail term attached to these matters is too heavy a penalty for the

offence. In particular Clause 9.11 contains no time length, therefore strictly speaking, any participant transferring a greyhound who

knows that it may be euthanised due to old age or ill health would thus be committing an offence under that provision.

Standards: Retirement and preparation of greyhounds for rehoming

9.1

Where a greyhound owner does not wish to retain a

greyhound, the owner must ensure that the greyhound is

adequately prepared for rehoming as a companion animal.

The wording “adequately prepared” should be removed,

as it is a fact that there are greyhounds who will never

able to be prepared for rehoming.

The Association prefers the wording contained within



the Greyhound Racing Victoria Code of Practice:

The registered owner is responsible for ensuring their

greyhound(s) undergoes retirement and rehoming

preparations.

Standards: Preparing greyhounds for rehoming

9.2 A greyhound that has ceased racing or training for racing must

be provided with a ‘wind down’ period of at least 30 days

before being rehomed. During this wind down period, the

owner must ensure that:

the greyhound’s diet is adjusted to suit new levels of exercise;

• the greyhound’s exercise is adjusted to levels

appropriate for a companion animal;

• the greyhound is moved to different housing,

either in an outdoor pen or to within a family

residence;

• the greyhound is walked for at least 20 minutes

daily in public, while muzzled and on a lead;

• the greyhound is exposed to new environments

such as dog parks/shopping areas and interaction

with other dogs (not greyhounds);

• the greyhound is exposed to different surfaces

The Association is concerned with the strict need for a 30

day wind down period, as this would be unnecessary in a

number of greyhounds.

Further, the wind down provision is far too prescriptive

and onerous on owners. The Association believes that

this should be replaced with a requirement for an owner

to have a rehoming plan, which includes activities to

adjust the greyhound to the home environment within

the capacities of the owner and the greyhound. This

should not be so prescriptive so as to create an

unnecessary burden on an already challenging process.

There are greyhounds that are trained in an environment

where they have already been exposed to all of these

things and have already had a period of slow down as

they neared the end of their racing career, leaving them

ready to immediately commence pet life.



and a variety of people in a nontraining or racing

setting;

• the greyhound is exposed to daily periods of

isolation from other dogs and humans, starting

with 30 minutes and gradually increasing to three

to four hours in duration.

The Association understands that even the industry’s

Greyhounds as Pets body has a system of identifying

those dogs that are immediately ready to be rehomed,

those that require more wind down and work, and those

that are not yet ready to be rehomed, which is

implemented during their GAP phase.

Providing a requirement for an owner to have an action

plan to rehome their greyhound, and ensuring that

action plan is implemented would be sufficient to meet

the intentions of this clause.

9.3 Participants must monitor greyhounds whilst being introduced

to new environments, people or animals. If the greyhound

shows signs of fear or predatory or aggressive behaviour the

interaction must be terminated.

Supported.

9.4 Participants must seek advice from a veterinarian or animal

behaviourist if the greyhound being prepared for rehoming

shows excessive fear, aggressive or predatory behaviours

towards people, small dogs and/or other animals.

Standards: Requirements for rehoming of greyhounds



9.5 Greyhounds must be desexed prior to rehoming as a

companion animal.

Supported.

9.6 A greyhound owner must make genuine attempts to rehome

any greyhound that they do not wish to retain. If an owner is

unable to rehome the greyhound privately, they must first

seek the greyhound’s admission to the Greyhounds As Draft

NSW Greyhound Welfare Code of Practice 25 Pets (GAP)

program. If the greyhound is not admitted to the GAP

program, the owner must then:

• seek to rehome the greyhound through at least

one other pet rescue or rehoming organisation;

or

• seek the greyhound’s admission to the GAP

program a second time.

Whilst the intention of the clause, which is to ensure

owners make multiple attempts to rehome their

greyhounds is supported, the Association does not

support the clause being an offence provision.

The clause should not be an offence provision under

Section 39 of the Greyhound Racing Act 2017 (NSW) (‘the

Act’), given the practicalities and difficulties that are

often faced by owners attempting to rehome

greyhounds.

At the present time, the Greyhounds as Pets (GAP)

program in NSW has limited capacity to take on dogs and

wait lists which are often months long. The program is

currently limited in its ability to offer pre-assessment in

all areas, currently only offering assessments at

Richmond, Newcastle, Dapto, Bathurst and Tamworth.

Similarly, at the current time, many rehoming and

adoption organisations also have wait lists, and are

located in specific regions which make it difficult for

participants.

There is no timeframe associated with how long a



participant needs to attempt to rehome the greyhound.

9.7 Participants rehoming a greyhound as a companion animal

must provide the new owner with all relevant information on

the greyhound’s:

• housing;

• feeding;

• exercise regime;

• health;

• behaviour; and,

• preparation for rehoming.

Supported.

9.8 Participants rehoming a greyhound as a companion animal

must provide the new owner with a written statement

detailing the following:

• any known abnormality (including current or past

injury) affecting the greyhound;

• any available information about how that

abnormality may affect the short and long term

health and well-being of the greyhound;

• any veterinary treatment the greyhound is

receiving or requires; and,

• current vaccination certificates relating to the

The Association questions the practicality of this clause.

The Commission should ensure that templates are

created and provided to participants to assist in meeting

the obligations of this clause.



greyhound.

9.9 The owner of a greyhound being rehomed must advise the

greyhound’s new owner of their obligation to register the

greyhound in accordance with the requirements of the

Companion Animals Act 1998 and direct the new owner to the

NSW Pet Registry for that purpose.

Registration in accordance with the requirements of the

Companion Animals Act 1998 is the responsibility of the

new owner of the rehomed greyhound and should not

form part of the obligations of the former owner or

participant.

9.10 Participants must not transfer a greyhound to a person who is

under the age of 18 years.

Supported.

9.11 A greyhound owner must not transfer a greyhound in

circumstances where the owner knows or has reason to

believe that the greyhound may be euthanased.

This should not form part of Section 39 offence

provisions of the Act. As it does not contain any time

lengths, it is too open to interpretation, for example, an

owner rehoming an older dog would be well aware that

in time, the greyhound may be euthanised by the new

owner for reasons of old age or ill health.

Asking participants to make a judgement on what a new

owner may or may not do is not acceptable.

Standards: Euthanasia



9.12 A greyhound may be euthanased 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.

Supported.

However, there is no reason for this to be contained

within the offence provisions of the Act, as a breach of

this clause is contained within Clause 9.13.

In respect of Clause 9.4, a veterinarian who has assessed

a greyhound showing aggressive or predatory behaviour

should also be able to provide certificate to this effect to

enable humane euthanasia in cases where a greyhound

is deemed unsuitable for rehoming due to such

behaviour, for the safety of the public.

9.13 Where a greyhound is not suffering from an intractable

condition or injury that causes significant pain or discomfort or

a marked reduction in quality of life, the owner must meet

minimum rehoming standards as detailed in 9.6 before

considering euthanasia. If the owner has complied with the

minimum rehoming Draft NSW Greyhound Welfare Code of

Practice 26 standards, has been unable to rehome the

greyhound and intends to have it euthanased, they must notify

the Commission of this intention at least 10 business days

before the greyhound is euthanased.


The Association believes that Owners must make strong

attempts to rehome the greyhound before considering

euthanasia.

However, where a greyhound is deemed professionally

unsuitable for rehoming due to temperament or

aggressive behaviour, then humane euthanasia must be

available.



9.14 Euthanasia of a greyhound must only be performed using

humane methods. Euthanasia of a greyhound may be

performed by a person who is not a veterinarian only where

the euthanasia is:

• necessary to relieve the animal’s immediate suffering, and

• a veterinarian is unable to attend in a timely manner, or

transporting the animal to a veterinarian would unreasonably

prolong the animal’s suffering; and,

• a veterinarian has been consulted.

Advisory Information: Retirement and Preparation for Rehoming

Fear or predatory or aggressive behaviour can include: barking, lunging,

growling, snapping, stalking, shaking, cowering and freezing.




Code.







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