RSK VIC Greyhound Code of Practice Submission

VIC Greyhound Code of Practice Submission


My name is Troy Scott, of Talbot, in central Victoria.

I own and operate a 40-acre greyhound property, along with family members and 2-part time staff members. I have been in the sport for around 16 years, and became fulltime a year ago after losing my sales engineer role in the city.

I predominately only provide education to greyhounds, breaking-in and pre-training, and only a few months ago I started an early education program for young pups to learn in a fun and safe way, this is to ensure more dogs make it to the race track.

I’d like to thank you for the opportunity to have my say on this proposed greyhound code of practice.

Animal welfare is very important to me, so I agree a new code is needed to help improve our already world standards, I believe we can always get better and do things more effectively to the benefit of the dogs and all proper financial stakeholders, but it needs to be realistic… which unfortunately this draft code is not.




3.1 Staff ratio (REJECT)

Assuming these proposed new and unrealistic staffing ratios are animal welfare centric, they would do nothing but make owning a greyhound business unviable and lead to a mass reduction in participation, which will also lead to an avalanche of displaced dogs.


I wouldn’t be much of a parent to choose an animal over my children, and I wouldn’t be a responsible animal owner if I couldn’t afford to feed them, so yes every dog I own would have to be placed in the adoption program.


It is and should be up to the establishment owner to assess staffing requirements, as it’s a business and should not be dictated to by the state government. Like any business, the owner is the expert, and they’re already responsible for the welfare of each dog on their property. Furthermore, the GRV already ensures these welfare standards are being met via constant inspections.


Veterinary clinics and animal shelters don’t require this many staff per dog, so why would the government want to put extra financial pressure on greyhound businesses, it’s totally unfair and not required.


In any case, a staff member should include family members. It’s widely known that greyhound racing is a family sport, more in the sense that it’s a team of family members taking care of the dogs.

1 “staff member” per 50 dogs would be accepted by most people within the greyhound industry, as this seems to be the average number of hands on deck at most establishments I’ve visited over the past 16-17 years.


3.2 Proprietor (PARTIALLY REJECT)

To have a treatment book for each individual pup is an overkill, and would only become a time burden maintaining them. The current form is more than sufficient, 1 book for all dogs.


Regarding a health management plan, this is an insult to anyone with more than 5 years’ experience breeding, rearing and training greyhounds. This would also add unnecessary costs to the business via vet fees, whom would also most likely push their own products onto participants, for example, some clinics only sell Science Diet dry food, which sells for around $100 per bag, but a $45 bag of Box1 Gold (not sold in vet clinics) will also help maintain the health of any greyhound.


Anyone with repeated (more than 1 or 2 severe as deemed by a greyhound specialised vet) cases of malnourished dogs, as reported by GRV welfare inspections, should be forced to adhere to such plans and treatment log books. Further breaches should lead to a lifetime ban.


3.3 Operations manager (PARTIALLY REJECT)

Firstly, these responsibilities can and already get carried out by the establishment owner, and again we shouldn’t be told by the government that we must hire a full time “operations manager,” whom outside of greyhound racing would be on over $100k per year.


This concept is stupid and should be left up to the main operators of the facility to decide on what positions are needed to maintain our already high animal welfare standards.


Besides, what statistics does the state government want this person to collate? This is just dumb and a waste of valuable time, time better spent on our dogs.





3.4 Greyhound attendants (PARTIALLY REJECT)

These duties should be determined by the facility owner, not the state government.


And the comment about the dead greyhounds is insulting! It assumes this is a daily occurrence, of which it’s an extremely rare one at best… or worse! In any case, the GRV has an integrity department that would and do investigate such case, because greyhounds rarely just drop dead. This further proves the author(s) of this draft code has a predetermined notion or an un-favouring opinion about greyhound racing.


3.5 Vehicle driver (PARTIALLY REJECT)

Most of these requirements are pretty standard already, however, what’s with the need to have vet advice on a road trip? Again, this is another added cost that will have zero effect on animal welfare… it’s a road trip, not an around the world voyage on a container ship.


Besides, how would all of these requirements be policed? Would our regulator be required to add extra staff to monitor all road trips? Will the government grant them further powers to pull a vehicle over that’s towing a canine trailer? If that’s the case, then those costs should be passed onto the state government.


3.6 Veterinary practitioner (PARTIALLY REJECT)

The vet and the facility owner should be able to determine if treatment is possible on-site, sometimes it’s better than taking an injured or sick dog on a road trip.


Most clinics, (probably more like all) clinics don’t have an around-the-clock staff to supervise patients, and I highly doubt they’d allow a non-staff person to stay overnight to keep an eye on their sick or injured greyhound.


I’ve already gone over the health management plan idea, and again it’s ill-conceived, unviable and unworkable.

If the facility owner was also an accredited and licensed vet, it would be insulting of this proposed code to say he/she had to seek another vet to meet all of the requirements.


3.7 Mandatory training and education (REJECT)

This should only apply to new participants. I’m all for education, but what would be gained from having those that have been in the industry for 5, 10, 20, 40 years accredited? Nothing is what.


3.8 Staff health (REJECT)

This is another example of overkill, these are hospital standards being applied to a dog kennel, it’s ludicrous and yet another unwarranted added cost to the establishment.


4.1 Health management plan (REJECT)

Already covered earlier. But I’ll reiterate how unfair and over-the-top it is! It’ll be open to manipulation and possible corruption between vets and pet food manufacturers.


4.2 Euthanasia (UNDECIDED)

The proposed code says that euthanasia must be carried by NOT using blunt force trauma, although this is an accepted method used by the RSPCA (bolt gun). However, the code needs to stipulate accepted methods for emergency situations where a vet cannot attend. Nobody likes to see any animal in pain or distress.


4.3 Greyhound transport vehicle (PARTIALLY REJECT)

The temperature range is not required, especially for under 10 degrees. By simply placing a jacket on the greyhound and closing a vent or two (as we do inside our vehicles), this is more than enough to make the dog warm and comfortable. In fact, greyhounds can sustain freezing temperatures, look at countries with greyhound racing that receive snowfall, USA, Ireland, the U.K. etc.


And at the other end of the scale, 32 degrees is not that hot when driving along a freeway as most greyhound trainers do when going to a track. Most participants don’t live in high traffic areas, so there is constant airflow going through the trailer. Constant stops to check on each dog and to wet their feet and face is already widely used, and in my 16-17 years I haven’t seen or heard of a greyhound dying in transit, although I’ve heard of plenty of domestic animal dying in cars. Also, look at countries where greyhound race in hot climates, such as Pakistan and the UAE.


Speaking of other dogs, hunting, farming and show dogs aren’t given the same protection from a government code of practice with such tough rules, and unfortunately I’ve seen a dog come off the back of a tradesman’s ute on a freeway.






4.4 Visitor facilities (REJECT)

This goes to the point of ridiculous. What other animal sports or activities (besides slaughter houses) have to implement bio security measures? None. Why does the government want to protect greyhounds more so than children, I mean we don’t have these measures in kinders or schools.


These proposed measures are used in human food processing plants to ensure the meat we eat is clean and free from contamination, last time I checked we don’t eat greyhounds. This entire section needs to be deleted.


4.5 Security (ACCEPT)

Given the Animals Australia attack on several legal greyhound businesses late last year, and early this year, in particular, the break and enters, it is in everyone’s best interest to increase their security in and around their property. It’s well known one of the AA operatives drugged several dogs, so it’s critical trainers at least lock their kennels up when they leave the property.


5.1 Establishment records (REJECT)

More overregulation. More log books, record keeping, sale records etc. And isn’t giving out medical history for employees illegal? Most of these have nothing to do with improving animal welfare, and more to do with invading citizens privacy.


I’m all for keeping track of a greyhound’s life cycle, but we need to keep it simple and not make it a time burden to follow.


5.2 GRV treatment record book (PARTIALLY REJECT)

We already have GRV treatment books.

But we don’t need to log daily exercise for each dog, that’s because it’s unnecessary. This would add further time restraints on the establishment, time better spent on the dogs. The government doesn’t need to know when the little old lady down the street walks her poodle, so why the sudden interest in our athletes?






5.2.1 Greyhound record files (REJECT)

Firstly, most of this information is already tracked via GRV’s Fast Track system, there’s no need to double up.


This is obviously designed to track the entire life cycle of each greyhound, which is much needed. But the problem I have with this is that it’s “information overload”. The only information that should be logged and included are;

  1. the location of each dog (dates of arrival and departure);
  2. vet records for each dog so a new owner can stay on top of any issues the greyhound may have.


5.2.2 Individual greyhound identification (REJECT)

This is a security and integrity issue that will place the dogs at high risk of those wanting to harm our industry, or those wanting to harm the reputation of an individual trainer.


6.1.1 Food (REJECT)

This should only apply to newcomers to the sport. But only for a 12-month period to ensure they’re competent in maintaining the health and weight of a greyhound. Furthermore, I’d like to see this used as a form of correcting any wayward “experienced” participants that have had several proven cases of malnourished dogs.


6.1.2 Water (ACCEPT)

No comment required.


6.1.3 Supplements and injectable substances (ACCEPT)

Accepted, minus the health management plan already previously rejected.


6.2.1 Vaccination and parasite prevention (under12wks) (ACCEPT)

No need to comment.


6.2.2 Vaccination and parasite prevention (over12wks) (ACCEPT)

No need to comment.


6.2.3 Health checks and treatment plans (PARTIALLY REJECT)

It’s impossible to pinpoint when exactly a dam will come on season, therefore the check 4 weeks prior to being served is impossible and unworkable. This is further reason why this draft code is out of step with reality, and the lack of breed knowledge is prevalent.


Annual checks for breeding greyhounds is a good idea, but this still needs to be rewritten with industry expert input.


6.2.4 Grooming and other requirements (PARTIALLY REJECT)

Greyhounds generally are cat like in their own personal hygiene. Frequent washing is the determent to the greyhounds’ skin health; it washes away the natural oils leaving behind a dry and flaky skin.


I would agree that a greyhound covered in mud or sand would need a clean, but to make it a frequent task is not a good idea in an animal welfare sense. Again, this highlights the lack of knowledge and common sense.


6.2.5 Muzzling (ACCEPT)

Although 1 hour would be more realistic. Sometimes I like to allow many kennel dogs to bath in the sunshine whilst I bleach floors, wash blankets, clean bedding etc. The American (basket) muzzle ensures safety and allows normal panting and drinking. The only thing it prevents is self-cleaning (licking) which is why I say one hour should be the maximum.


6.3.1 Heritable defects (REJECT)

With all due respect, the Government hasn’t demonstrated enough breed knowledge in this draft code to warrant making comment on this subject.


Although this should be discussed when this code is rewritten with industry experts. Because it has some merit.


6.3.2 Breeding males (REJECT)

I’d like to see the scientific reasoning behind this restriction before accepting.




6.3.3 Breeding females (REJECT)

Breeding figures are down by over 50%, this will only increase that number. Besides, I’d like to see the scientific reasoning behind this restriction before accepting.


It’s impossible to pinpoint when exactly a dam will come on season, therefore the check 4 weeks prior to being served is impossible and unworkable.


6.3.4 Natural Mating (ACCEPT)

No comment required.


6.3.5 Artificial Insemination (ACCEPT)

Although the breeder should already be competent enough to know what exercise is appropriate or not.


6.3.6 Whelping (PARTIALLY REJECT)

Oxytocin, when needed, is a time a sensitive tool of the trade. I’d recommend a vet ensures a breeder/whelper is competent and should issue a basic statement to prove they have explained how to use the substance, and that the person is capable.


6.3.7 Caesarean section (ACCEPT)

No comment required.


6.3.8 Lactating Greyhounds (ACCEPT)

No comment required. Although, once again the whelper knows best how to exercise the bitch. Every brood bitch is different, every whelping is different, this needs to be accepted by the VIC Gov.







6.3.9 Rearing (REJECT)

Before I start on the reasons why I reject these changes, it’s worth noting that most professional and certified canine trainers of all breeds will declare that training a dog for 30 mins a day is a waste if time, and it would be detrimental to the dogs’ mental health. Greyhounds have a short attention span, so short sharp 30-60 seconds’ daily sessions is ample for working dogs, even the well-known Steve Austin has stated this.


In order for a rearing business to remain compliant, they would need to hire 2 staff members per 25 greyhounds. This is because 1 person would need to provide 30 minutes to each dog as per this draft code, whilst the other carried out the cleaning of yards, kennels, bowls etc., plus fill out all of the record keeping, treatment books, exercise log books, health management plan etc., also they would have to do the morning and night feed. On top of all of those duties, there’s property maintenance such as fence mending, basic animal welfare duties (general soreness or minor injury repairs), racing or trials, traveling for supplies, facility upkeep, and upgrades… we would have to give up everything else in our lives, including time with family or friends in order to live up to this new code. Granted animal welfare matters and is very important, but is that of their caretakers, humans!


In my case, I’d be running at a daily loss due to wages absorbing all client fees, but still leaving me with a massive food bill, as well as trial fees, vet fees, petrol and car maintenance, electricity, water bills, on top of feeding myself and my family and covering their basic human needs. And that’s just based on Monday to Friday costs! Throw in weekend and weekend rates, and I’ll be homeless along with all of my dogs.


If I was to increase my fees to cover these costs, we’d lose every owner due to greyhound racing becoming an unviable investment for them.


Regarding kennel sizes, 1.2m wide is plenty, this is how wide domestic boarding kennels have to be, and they house larger canines than greyhounds. So, 1.5m is an overkill that would make no difference to the welfare of the greyhounds. But it would in my case leave me with a large bill to have my current new and compliant kennels widened, thus losing 5-6 kennels in the process, meaning the costs would be ongoing through weekly loss of income of around $660 per week!


Also, I currently have several 100m x 4m runs, according to the draft code these need to be 5m wide, again adding no welfare value what’s so ever, but leaving me with yet another massive cost! It’s moments like this I think of all of those pet dogs in their 10m x 10m back yards, yet greyhounds are being treated differently. Lastly, on the yard width, the author of this code only need visit my property and look at the runs, they would see where the dogs run up and down the same 1m lane on either side of the fence. Leaving a 2m wide strip of grass… in other words, you could make the yards 5m, but they would still only use 1m off the fence line. Pointless and expensive. Totally unworkable.


One of the positives to the draft code in this rearing section is something that I already provide, essentially the author is pushing all facilities to provide early education. 100% agree with this. The rest is rubbish and designed to have the lifeblood of the sport sent broke and forced to leave the sport they love and make a living from.


6.3.10 Education and pre-training (REJECT)

Leaving a pack animal in isolation is cruel and goes against all canine’s instincts. This needs to be deleted from the entire code.

An American (basket) muzzle should be allowed in cases where a greyhound is destroying their bedding. This should only be used in extreme cases.


The remainder of this section seems fine.


6.3.11 Training and Racing (REJECT)

Reasons for rejection as per points above in rearing section.


6.3.12 Preparing a greyhound for retirement or rehoming (UNDECIDED)

This entire section has nothing to do with breeders, rearers and trainers, unless they’re the owner of the greyhound(s).


I strongly believe the buck stops with the owner, they are the person responsible for the rehoming.


6.3.13 Retirement and rehoming of greyhounds (UNDECIDED)

As above.


6.4 Exercise, training, and enrichment (SEE BELOW)

Page 47 – ACCEPT

Page 48 – REJECT

  • Isolation time already covered, this is cruel.
  • Baths are only needed when a pup is covered in mud, otherwise, it can be detrimental to their health.
  • Bones cause fighting, this is not needed if a quality kibble is being fed, and plenty of toys provided.
  • Training? This needs to be more specific. I provide an early education program, so prey drive training is the main subject. They only need 30-60 seconds every other day. Otherwise, they lose interest. Greyhounds have a very short attention span.



As a breeder of 16 years’ experience, I’d never walk a heavily pregnant bitch for more than 10 mins. 30 mins is way too much and could lead to over exertion.


Chew toys should be removed during whelping, she has more to worry about than wanting to play chase games.

Lactating bitches should be left to exercise themselves in a medium sized yard, not too big that she could sprint around causing damage to her milk glands etc.


Walking a spelling bitch twice a day is fine, but how would you even police this? Seems a bit silly. If a spelling bitch looks well, happy and has moderate muscle tone, then this should be taken as she has been sufficiently exercised. Policing a lot of this draft code would add an enormous extra financial strain on our regulator, those funds would then come from prize money, further reducing the viability of participation.


6.5 Socialisation and handling


Change 30 minutes per litter, to 1 minute per pup per day. Many professional canine trainers agree that 30-60 seconds of stimulation is all dogs require to be well adjusted. Look up Steve Austin here –



As above.


6.6 Facilities page 52 (ACCEPT)

No comment required.


6.6.1 Disinfection and hygiene (ACCEPT)

Although using a dishwasher isn’t the only way to clean bowls.


6.6.2 Isolation housing (PARTIALLY REJECT)

Delete 10m and health management plan, both an overkill.


6.6.3 Tethering (ACCEPT)

No comment required.


6.6.4 Perimeter property fencing (REJECT)

In terms of kennel dogs, they already have 2 barriers, their cage door, and the kennel door, plus they then have the existing perimeter fence which is around 1.2m high on a typical farm. This is ample as in my 16 years I’ve never had a dog escape the existing perimeter fencing.


Regarding the yard dogs, so long as the fence is at least 1.5m high, this is plenty to retain pups. Being forced to build this 1.8m high fence, would be enough to force the closure of my facility. I’m on 40 acres, to upgrade that amount of fencing would send me broke.


6.6.5 Construction of housing pens and yards (REJECT)

This section shows that 1.5m is enough to create an escape proof area for dogs, hence the reason why a 1.8m perimeter fence is not required.


Separate bedding for pups is ridiculous. These are pack animals that like to curl up together. 3sqm is also not required in pup yards, a kennel big enough to sleep and some shade are all they need to remain happy and healthy.


6.6.6 Construction of indoor kennel facilities (PARTIALLY REJECT)

Similar to my comment regarding vehicle and trailer temperatures, kennels need only be kept clean and well ventilated, jackets can be used in winter, and fans and feet cooling buckets in summer, these should be the minimum standards, because not everyone can afford a $10k air-conditioner, or the power bill to run it.


I’ve never had a problem with any dog in my 16 years regarding cold or warm kennels, you just need to know how to monitor a dog’s health, and manage any that are struggling with conditions.




6.6.7 Minimum housing requirements (REJECT)

Every dog is different; every litter is different. The rearer knows the individuals better than anyone else, and it’s his/her duty to ensure the safety of each dog, as well as their social enrichment. 4 dogs should be the maximum for 9 months and older, and 6 for 4-9 months and the entire litter should remain together up until 4 months.


Bullying and fighting should be closely watched by the rearer, and then and only then should they separate the dogs. I’m seeing too many timid dogs due to current restrictions of 2 dogs per yard, I highlight once again these are pack animals, let them be dogs for the first 12 months of their lives and more will handle race fields and be less timid with the correct mix of personalities in a yard.


Current kennel sizes have proven to be enough, in fact, they are probably too big for over excitable dogs. 3sqm x 1.2m wide should remain. If they don’t, many people will be forced to leave the industry based not being able to afford the upgrades of what are already compliant kennels. I’ve already stated what I’d lose shall these new guidelines go through, 1.5m wide will be enough to shut my educational business down, which will have a flow on effect for my clients and suppliers.


Disturbing kennel dogs 5 times per day would only stress them, 3 checks are plenty.


Regarding yard minimum width, 5m is an overkill and would force many rearers out of the industry due to the high cost of the required upgrade, which not improve the welfare of the dogs as they only ever use a width of 1m along the fence line as they run up and down. 3m is enough for 2 dogs, 4m for 3, 5m for 4+ dogs.


6.6.8 Toileting yards (PARTIALLY REJECT)

How big is the average toilet area in a house? Think about that for a second. 3-5sqm is ample for a dog to empty out. But the maximum height of the fencing should be 1.5m to prevent any dogs from escaping. 2 muzzled greyhounds in one yard to empty is safe and efficient.

This would be another unnecessary cost to most facilities, including mine.


6.6.9 Exercise yards (REJECT)

As already covered twice above, 5m is not necessary as the dogs only use 1m along the fence line, 3m should be the minimum. Mine are 4m x 100m, I’ve never had any dogs get injured or collide.

To upgrade this would force me out of the industry, and again the new 5m minimum would add no welfare value to the dogs. How many domestic dogs have an area like I provide to my dogs? Yet my new facility will be non-compliant should this draft code go unchanged. It’s unfair and will send me broke beyond repair.

6.6.10 Day yards (REJECT)

Again, 5m is not needed. 3m width for any yard should be the minimum except for empty out yards.


6.6.11 Mating areas (ACCEPT)

No comment required.


6.6.12 Whelping/lactating areas (ACCEPT)

No comment required.


6.6.13 Circular training facilities (ACCEPT)

No comment required.


6.6.14 Slipping tracks and galloping runs (ACCEPT)

No comment required.


6.6.15 Trial tracks (N/A)

No comment required.


7 (.1 .2) Sale and Transfer of Greyhounds (REJECT)

This should remain a civil matter unless there is any undesirable activity of which should be reported to the GRV, and they should investigate and become the mediator between the parties involved.

Further to this, I’d like to see this code add in a clause where an owner remains the sole person responsible for his/her greyhound at all times. Too many times (3 in a year) I have had greyhounds dumped on me because the owner didn’t want to pay their final bill for a “slow” dog. The GRV don’t get involved in these matters, but they MUST, it’s an animal welfare issue because if the rearer/trainer/educator isn’t being paid to feed the dog, how can they be expected to properly look after the dumped dog? GRV must be forced to assist in these matters, at very least in a mediator role and publish repeat offenders via Fast Track.


  1. Hobby Establishments (REJECT)

Hobbyists are the backbone of this industry; they should be able to have up to 10 greyhounds before being classed as anything but pure hobbyists.


I urge the government to rewrite this code, and this time with proper industry input. Thousands of rural families, directly and indirectly, rely on this industry as a source of income, most of those living in areas where employment is lacking.


It speaks volumes when so many animal activists are supporting the draft code, that shows how it’s unviable and will end the industry if it’s not amended in almost its entirety.


I’m all for improvements to animal welfare, but we need to make them worthwhile (a real benefit to the dogs) affordable, viable, and cost effective to police from a regulative perspective. There’s no point in implementing an unrealistic code that can’t be policed without sending the industry broke, make it affordable and reasonable and everyone will follow it without any adverse effects to canines or humans.


Do the right thing, and redo this code!



Troy Scott


Owner operator of Rising Star Kennels in central Victoria.