Our Review of the Thoroughbred Aftercare Welfare Working Group Report

Our two-year investigation exposing the brutal reality for thousands of racehorses every year once no longer wanted, (available here) led to the formation of the Thoroughbred Aftercare Welfare Working Group (TAWWG).

The TAWWG panel is comprised of:
Dr Denis Napthine – former veterinarian, former Victorian Premier and former Minister for Racing
Dr Ken Jacobs – equine veterinarian and former director of the AVA and the EVA
Dr Bidda Jones – Chief Science and Strategy Officer for RSPCA Australia, Honorary Associate with the Sydney School of Veterinary Science
Jack Lake – Former senior government advisor on agricultural policy. Current advisor to pastoral and poultry industries on policy development and implementation and government relations. Part-owner of racehorses

The panel was supported by an industry steering committee comprising of Tom Reilly, chief executive of Thoroughbred Breeders Australia; leading trainer Chris Waller; managing director of Godolphin Australia, Vin Cox; prominent owner and breeder Neil Werrett; chief executive of the Australian Trainers’ Association, Andrew Nicholl and the chief executive of the Australian Jockeys’ Association, Martin Talty.

CPR made a submission to the TAWWG (available here) and was part of the consultation process.

In their report, released on November 29 2021, the TAWWG made forty-six recommendations, some requiring government legislation, others designed for the industry to adopt.

The recommendations centre around greater industry transparency, government legislated horse welfare standards and the creation of a national welfare body, Thoroughbred Welfare Australia (TWA), funded by the industry itself.

Whilst we recognise these recommendations aim to improve the welfare of racehorses before, during and after racing, it is important the public recognises that:

1. these are just recommendations, with no requirement for them to be implemented

2. they are almost entirely dependent on the industry doing the right thing for the horses they have proven to use and abuse in the most horrific ways, without consequence, for so long.

3. they have only come about due to abhorrent standard practices horse racing has knowingly gotten away with for so long finally coming to light in the public domain. This report was by no means motivated out of concern for racehorses, but rather out of concern for the horse racing industry losing its social licence. This places immediate questions over not only whether the recommendations will be adopted, but can they actually be implemented and enforced?

After thirteen years of researching and investigating the horse racing industry, it is CPR’s position that it is beyond redemption and can never be made kind for the horses it exploits. Horse racing exists to serve the human, not the horse, making it fundamentally flawed and inherently unethical to begin with. Having said this, so long as the industry persists, we must support any measures that can improve these horses’ lives. For this reason, CPR supports the majority of the recommendations made in the report, however, we do not believe that the industry is capable of any kind of legitimate, meaningful and sincere reform, nor that any kind of reform can ever go far enough.

We do not support some of the parameters that guide the recommendations on ‘End of Life’ so have made an overall comment on this section at the very end of our review. 

Like the Martin Inquiry (our summary and comments available here), the TAWWG report once again highlights how badly this industry is failing the very horses it could not exist without, from birth to death.

It is also evident from the report that Australian’s are rightly turning their backs on horse racing due to significant welfare concerns.

Findings & Comments

Below are just some of the findings from the report (many that have long been stated by CPR), that we feel must be highlighted, along with some responses where we feel necessary. Most of them speak for themselves. The full report including its forty-six recommendations can be read here.

P10. The TAWWG has heard from many participants across the country who said that equine welfare – the task of ensuring thoroughbreds are well treated from birth to death – is the most important challenge the industry faces. Ensuring positive welfare outcomes for thoroughbreds is also crucial to the industry receiving the support of the broader Australian community. A significant project researching public attitudes to the thoroughbred industry was commissioned to support the TAWWG’s work, and it demonstrated more people were unsupportive of racing and breeding than supportive. However, this research identified that a key driver to changing those attitudes would be demonstrating that horses are well cared for, not only while in racing and breeding, but also when they retire. This provides a significant challenge as it means the industry is being assessed on the treatment of horses that are no longer in its care. Furthermore, many thoroughbreds will spend the vast majority of their lives outside the industry.
CPR: The above makes two things very clear. 1. The public has come along way in their expectations on animal welfare and they are willing to stop supporting horse racing because of its failings in this regard. 2. The horse racing model brings thousands of lives into the world each year, happily knowing they will be discarding them within a few years by either killing them or expecting someone else to care for and be responsible for them for the majority of their lives.

P11. The TAWWG has identified a number of weaknesses in the current welfare regime for thoroughbreds, such as a lack of national standards for the care of horses, no clear national definition of what constitutes good welfare, no national welfare standards for thoroughbred horses, and a state-based administrative structure that means different welfare funding levels, programs and rules across the seven principal racing authorities.

P12. For a sector as significant as thoroughbred racing and breeding, the TAWWG believes it is a weakness that there is no national strategic plan that considers the future size of the industry and the sustainable production of thoroughbreds to meet that need. A properly developed plan would lay out a vision for the industry, its objectives and goals and the actions, timelines and measurements required to realise that vision. A comprehensive national plan would consider the number of thoroughbreds required to ensure adequate field sizes in races, but also guarantee adequate opportunities for those horses post-racing. The annual Australian thoroughbred foal crop has been about 13,000 in recent years, which is a decrease of around 30% from the late 1990s. Furthermore, a greater proportion of these foals is being registered to race and is competing on the racetrack. Despite this trend, several submissions stated there was overproduction, that more thoroughbreds than needed were being produced. Others, including Racing NSW, argued the opposite. The TAWWG found there was insufficient evidence to say whether there is overproduction. Any plan should also consider the use of race programming to provide more opportunities for the many older, sound racehorses retiring prematurely, and to encourage the breeding of more durable horses.
CPR: If horses are unable to be cared for post-racing and breeding, this should be considered “overproduction”. The report does consider this later.

P12. TAWWG’s analysis of the available data estimated around 8,500 thoroughbreds a year were exiting racing and breeding.
CPR: CPR disputes the 8,500 thoroughbreds exiting the industry each year figure as it does not include the mares taken out of the breeding cycle each year (approximately 3,000). These horses are products of the racing industry and as such must also be considered when estimated the scale of the problem.  CPR estimates approximately 11,500 horses are exiting the industry each year. This figure is also in line with the annual foal crop size (allowing for some deaths after foal registration). The industry does not currently grow in size, so for every horse entering racing, another must be exiting in some way.  

P12. Finding suitable homes for this number of horses annually presents a significant challenge. Therefore this sustainable breeding plan should not only consider how many thoroughbred foals are needed each year to meet the needs of the racing industry, it should also fully and properly consider the industry’s responsibility to provide adequate and appropriate post-racing (including breeding) opportunities for the horses it produces.
CPR: Whilst CPR does not support the breeding of horses into the world for the purpose of racing them, it is with welcome relief that the TAWWG acknowledge appropriate breeding numbers should be not only what the industry needs to sustain itself but also what numbers can be cared for, for their entire lives. The reality is that there are not enough homes for the current numbers of horses the industry is producing. Considering the lifespan of a horse is approximately 25 years, in this time, the industry would add approximately 290,000 horses into the Australian horse population if they were not killing them prematurely as they are now. Considering the large number of horses killed or neglected each year across the country in need of good homes, the racing industry continuing to add to this problem is entirely irresponsible.

P13. The transition of thoroughbreds from racing and breeding to other activities is a key juncture in a horse’s life. Most are rehomed and often this is done through an informal network of people who take horses on to give them another purpose.
CPR: There is no evidence to support the claim made here by the TAWWG that “most are rehomed”.

P13. The importance of these networks is highlighted by Racing Australia’s retirement data, which shows only 2% of retiring racehorses enter a retraining or rehoming scheme overseen by a state racing authority.

P13. The TAWWG believes considerably more resources are needed to create opportunities for horses leaving the industry and to stimulate demand for these animals.

P13. Evidence presented to the panel highlighted the importance of finding horses suitable vocations in which they had a purpose and were therefore valued by their new owner.
CPR: This statement is a poor reflection on ourselves as a society, where we base someone’s value on what they can do for us.

P13. It is evident that if a horse is well handled in early life, and exposed to other equine disciplines in foundation and ongoing training, it is easier to transition to a new career. TAWWG was told that handling practices were shifting from teaching a horse to submit, to a quiet cooperative approach. To encourage and support this transition, there is an opportunity to upskill and improve standards of those providing early handling and foundation training.
CPR: Whilst CPR recognises that horses who undergo training methods that are less abusive is not only better for the horses during their time in racing, but will also increase their chances of rehoming, the language throughout this entire section reinforces the idea that a horse is only valuable if they provide for the human in some way, which is the very reason why horses are in this awful mess to begin with.

P14. The TAWWG found the absence of an agreed end-of-life, decision-making framework, that would help guide owners when making decisions, to be a weakness that needs addressing. The TAWWG’s view, supported by an overwhelming number of submissions, accepts the principle that if circumstances arise where a horse can no longer be appropriately cared for, ensuring a humane death is preferable to its being left alive and suffering from neglect.
CPR: Only 2% of horses used by the racing industry earn enough to cover their own costs. Therefore, it is far from surprising that so many find themselves in a situation where an owner can no longer afford to care for them (or chooses not to spend their own money caring for them). It is entirely unacceptable that this multi-million-dollar industry that turns $21 billion in wagering annually, would not step in and ensure a full and healthy life for these horses. They will happily lure people into the industry on the pretence of dollars, glitz and glamour, yet walk away when the reality of racehorse ownership for most occurs.   

P14. Once a properly considered decision has been made that it is in the best interest of the horse for it to be killed, the most appropriate method is for a rapid painless death in a suitable, preferably familiar, environment.
CPR: Again, so long as this industry is turning a profit, and the horse is not suffering from incurable injury or illness, this is unacceptable.

P14. The TAWWG also considered the use of abattoirs and knackeries. A weakness with both is the lack of species-specific standards for killing horses. The TAWWG found the use of the Meramist abattoir in Queensland (the only abattoir licensed to process horses in Australia) problematic. Many horses are transported long distances to the site in conditions unsuitable for thoroughbreds and the facility is not designed for horses. The TAWWG recommends that while there is a lack of species-specific standards enforced for horses, principal racing authorities should institute rules to prevent participants sending horses to Meramist.
CPR: At the time of writing, it has been over two years since the horrors subjected to thousands of horses each year at the Meramist slaughterhouse were exposed to the world, yet the industry has not done anything to prevent horse being sent there. Whilst the number of horses killed at Meramist has decreased significantly since ‘The Final Race’ exposed their brutal treatment in 2019, CPR has evidence that racehorses are still being sent to the location to endure a most horrific end. 
Whilst Meramist continues to kill horses for human consumption, to be exported to various parts of the world, CPR has been calling on the EU Commission to ban their import due to ongoing animal welfare and food safety breaches of which they continue to deny, as does the Department of Agriculture and Fisheries and Biosecurity Queensland. CPR has sent this and further damning comments regarding Meramist made by the TAWWG in this report to the EU Commission and DAF, as further evidence against Meramist.

P14. The TAWWG found knackeries could play a useful role if they had experienced operators who could kill a horse humanely and facilitate the disposal of the carcass. TAWWG notes, however, that Racing NSW remains committed to its rule that prohibits industry participants sending horses for slaughter.
CPR: CPR supports Racing NSW position. However, it is fact that NSW horses do continue to end up at knackeries demonstrating enforcement is lacking and that not enough is being done to prohibit horses ending up at the knackery once passed on to someone outside the industry. There is also no information being provided by Racing NSW on where the approximate 4,000 horses who exit racing in NSW alone each year are going, making it difficult to believe they are all finding safe homes.

P14. Horses are highly mobile animals: they may be born in one state, race in two more, before being rehomed in a fourth. But the industry’s governance structure means its response to the welfare challenge is essentially decided at state level, which is an impediment to achieving the best welfare outcomes.

P14. A key observation of many participants, regulators and those outside racing and breeding was the lack of a national and collaborative approach to welfare.

P15. It is the TAWWG’s strongly held view that there is an urgent need to establish a single, national organisation dedicated to the development, and implementation, of a national welfare strategy. The panel suggests such a body be called Thoroughbred Welfare Australia (TWA).

P21. It is the thoroughbred industry’s responsibility to ensure thoroughbreds are cared for appropriately from birth to end of life. That is the central responsibility of the industry – to look after the horses it breeds. This is not being done adequately now. Unless that changes, the economic, emotional and social benefits of horse racing will evaporate. The TAWWG recognises that more needs to be done to fulfil that responsibility.

P21. Racing is an economic powerhouse, with the industry’s direct and indirect contribution to wealth calculated at around $9 billion annually.

P21. There are more than 100,000 individual owners, meaning about one in every 247 Australians owns a share in a racehorse. Such investment is unparalleled in any other racing nation.
CPR: A reminder that horses are viewed by many as an object to invest in, not a individual living being. Investments are made for financial returns, creating the culture of use and discard.

P22. Financially, the industry is in a strong position, especially compared to jurisdictions overseas, with prize money for the 2019-20 season at $808 million.

P22. … : some 4,000 yearlings were sold at public auction in 2020, for a total purchase price of $426,883,298 and a median value of $55,000. However, this success in Australian breeding barns and on the track creates a significant challenge for the thoroughbred industry with thousands of relatively young horses leaving racing every year

P25. As of September 2021, Racing NSW and Racing Victoria, combined, had fewer Facebook followers than the Coalition for the Protection of Racehorses, and Animals Australia had 26 times more Facebook followers than both organisations combined. The TAWWG considers the consequences of not meeting community expectations is significant.

Among the evidence heard from across the industry, including major race clubs, wagering operators, auction houses and stakeholder groups, was that failure to meet community expectations on welfare would likely result in:
• declining participation in the industry because of adverse publicity
• community pressure to increase regulation
• reduced wagering as a result of welfare concerns
• reduced corporate value of the sport, with declining sponsorships and income from media deals.
CPR: CPR has no doubt that this has already started and is the reason why this report was commissioned in the first place.

P25. A wagering operator provided a good example of such impacts. It said a 2020 survey of its customers found 44% were less interested in betting on horse racing because of equine welfare concerns.

P26. One of the challenges that became apparent early in the TAWWG’s work was the lack of an agreed industry view of its responsibility for thoroughbreds after they had finished racing or breeding. Without such agreement, it is difficult to determine where responsibility begins and ends, and impossible to develop a consistent view of the initiatives the industry would support. While some submissions stated the industry should be responsible for all the horses it produced until the end of their lives, others pointed to the fact that many thoroughbreds would spend most of their years outside of breeding or racing and therefore their owner was responsible for their care at any given time. A number of senior racing administrators made it clear that the industry had a wider responsibility for the welfare of horses beyond their time on the track. The executive general manager, integrity at Racing Victoria, Jamie Stier, said: “In our view, it is impossible to decouple racing from both the before and after.” Racing SA’s submission stated the body operated under the Equine Welfare Framework (EWF), which has three phases: before racing, during their racing career, and after racing and retirement.

P28. Brendan Parnell, the chief executive officer of Racing Queensland, told the panel: “The smaller Principal Racing Authorities (PRAs) like Tasmania, South Australia and Northern Territory are not as well equipped commercially to support a certain level of [national] standards.” There is a pattern of horses that begin their careers in the major racing states of New South Wales and Victoria but are not competitive in city-class races. So they move to regional racing and states where there is weaker competition and the costs associated with racing, such as training fees, are significantly lower. The migration of these horses to Queensland, Tasmania, South Australia, Western Australia and the Northern Territory also creates a mismatch between the aftercare welfare task and the resources to carry it out.

P28., The TAWWG heard that Racing Australia (RA) cannot oversee a national welfare regime because it does not have a remit from its shareholders and members, the state racing authorities, to carry out such a role.

P28. RA representatives provided a submission and attended a consultation meeting with the TAWWG. The panel is grateful for their insights, which have informed this report. RA refused consent for publication of any comments from either process.

P29. The current state-based welfare programs are not based on agreed national standards or protocols, do not report in a nationally consistent, transparent manner to the industry or the public, and their impact has yet to be empirically demonstrated. The activities are extensive, but disparate and largely uncoordinated.

P29. There was also strong support among stakeholders, including the steering group, for wagering service providers to make a contribution to funding TWA. With $29 billion bet on horseracing in Australia last racing season, setting aside a very small percentage of turnover for welfare could easily make a significant funding contribution.
CPR: CPR made a submission to Racing Australia back in 2013, proposing this very thing – with 1% of all betting turnover being directed towards horse rehabilitation and rehoming. By todays standards, this would raise over $210 million for horses per year. The industry refused to adopt such a scheme yet have since adopted a 1% prize money levy to be directed to an equine welfare fund. This raises a tiny portion of what is required.

P33. A $300 welfare levy on all foals when breeders complete the foal ownership declaration. Unlike a levy on sales, this ensures all breeders contribute.
CPR: This is one of several levies directed at industry participants by the TAWWG to fund the proposed national body Thoroughbred Welfare Australia (TWA). In our submission to the TAWWG, CPR proposed a $2000 foal levy as a means of not only contributing to better welfare outcomes but also to deter indiscriminate breeding. $300 is too low a contribution for breeders who bring these lives into the world only to wipe their hands of any responsibility of them. Other industry participants, including trainers, owners and jockeys would also contribute under the suggested model.

P37. The Five Domains are nutrition, environment, health, behaviour and mental state.
While previous models of animal welfare, such as the Five Freedoms, have focused on minimising or eliminating the negative experiences of animals, such as thirst, hunger and pain, the Five Domains model incorporates the assessment of positive experiences, such as satiety, contentment and curiosity. Thus, the model provides a means of evaluating the welfare of an individual or group of animals in a particular situation, with a strong focus on mental wellbeing and positive experiences.
CPR: The Five Domains model is an improvement from the Five Freedoms model, however, horse racing as it currently stands, and perhaps even at its fundamental core, is the antithesis to both frameworks eg. traumatic foal and mare separation, whipping, spurs, bits, tongue-ties, concentrated diets, confinement and isolation, exercise-induced pulmonary haemorrhage, extreme physical exertion, breaking/training methods (coercive at best), racing-related injuries/deaths and so on.

P27. While most of the rules that govern racing and breeding are national, industry welfare policy is drawn up and implemented at a state level by the PRAs. An example of how this can lead to differences in approach is the fact that only four of the seven PRAs have adopted the Five Domains welfare philosophy.
CPR: Further to the point above – four of the seven PRA’s have adopted the Five Domains philosophy, yet the racing industry, as it functions day to day through the experience of the horses, is the same across the country. This further highlights that, on paper, such improvements sound good, but on the ground within the racing industry, they have little to no meaning.

P35. The TAWWG review of the animal welfare regulatory regimes applying to thoroughbred horses exposed some fundamental weaknesses. Firstly, there is no agreed definition of horse welfare. This is a problem both for governments charged with creating a legal framework for welfare, and for racing authorities when drafting rules for the care of horses. The development and implementation of an effective welfare regime for horses depends on a clear and agreed definition of welfare. Without it, it is difficult, if not impossible, to articulate a welfare policy both within the horse industry and to the broader community. Secondly, there are no national enforceable welfare standards for horses. There are rules for some other species that provide minimum standards for animals and, when supported by legislation, are enforceable by state governments. Without these standards for horses, their only legal protection is through broad, non-specific, animal cruelty legislation. The TAWWG’s view is that cruelty legislation does not provide sufficient safeguards for thoroughbreds (or any horse), nor sufficient protection to meet community expectations.
CPR: It is appalling, but not surprising, that horses do not have legal protections specific to their welfare needs. Australian animal welfare legislation needs a complete overhaul, and a well-funded Independent Office for Animal Protection must be established as a matter of urgency, for the sake of all animals.

P36. Welfare assumptions are also implicit in the attitudes and approaches of those whose everyday work involves handling horses, including breeders and their staff, trainers, stablehands, track riders and jockeys. Industry leaders should seek to develop organisational cultures that encourage staff to speak up about welfare issues, and be open to making changes where warranted.
CPR: It is quite telling that for an industry that has existed in Australia for well over 200 years, and that has profited so significantly from the exploitation of these animals, that no efficient welfare policy has ever and still does not exist. For the industry, that makes perfect sense.

P36. “Good welfare for horses and a life worth living can be achieved by considering physical and functional wellbeing as well as giving horses the opportunity to experience positive emotions in all areas: nutrition, health, environment, behaviour, and interactions with humans.” Australian Veterinary Association submission.
CPR: The AVA is referred to often in the TAWWG report, including as a recommended party to help select the TWA steering committee. CPR has little faith in the AVA considering they openly support not only horse racing, but also jumps racing and the use of whips in their policies.

P37. ….at present, nationally applicable standards for horses do not exist. State animal welfare laws give horses only minimum protections against overt cruelty and neglect, except in Tasmania and Victoria.
CPR: Still, CPR believes that if the very minimal standards of legislated animal welfare that exist were actually enforced, that it would be difficult to see how horse racing could exist. 

P38. Governments and horse industry stakeholders began work on the development of national standards for horses and got as far as publishing a draft standard in April 2009. However, unlike the livestock industries, work on horse standards was suspended in 2011 following a lack of agreement among horse industry groups over funding the work. The failure of this process clearly did not help improve horse welfare. The TAWWG sees the development and implementation of national enforceable animal welfare standards for horses as an essential component of a national horse welfare regime.

P43. Thoroughbreds must have speed and stamina. As such they have high risk for self-inflicted injury and injuries from high-speed activity both when in the paddock and racing.

P43. Currently, though, there are no national enforceable standards of care for thoroughbreds when in the breeding and racing industry. Instead, there are rules of racing that relate to welfare but the TAWWG’s view is that these fall short of what is required to provide the proper regulatory framework to ensure good welfare.

P43. The TAWWG notes that despite the current version of the rules of racing being some 180 pages long, there are few references to animal welfare, and most of the rules on this subject are contained in section AR231: Misconduct in relation to the care and welfare of horses. This section states a person must “not commit or commission an act of cruelty to a horse”. It goes on to say that those in charge of horses must exercise reasonable care or supervision to prevent cruelty; provide adequate feed and water; take steps to alleviate pain or suffering, and provide veterinary treatment where necessary. Only participants in the racing industry – such as owners, trainers, strappers and jockeys – are bound by the rules of racing. Therefore, once a thoroughbred has exited the industry and is in the care of somebody who is not bound by the regulations, these rules no longer provide any protection for its treatment.
CPR: This entire section implies that the racing of horses, as it currently exists, is not fundamentally and inherently cruel, and the act of committing cruelty to a horse only becomes a concern when horses leave the industry. It fails to acknowledge the use of whips, bits, spurs, tongue ties, harsh training regimes (although this is mentioned elsewhere), pushed so hard they suffer EIPH, heart attacks and catastrophic injures – just to name a few. As racing currently exists, it is impossible to not commit or commission an act of cruelty to a horse.

P45. Other groups, including Animals Australia, the Coalition for the Protection of Racehorses, and the RSPCA, also said breeders should be licensed. But some breeders, owners and trainers argued passionately that breeder licensing was against the spirit and traditions of Australian thoroughbred racing.
CPR: Licensing breeders could subject them to more rigorous welfare regulation protocols and ideally capped breeding numbers to help address the lack of homes available to retired racehorses. This appears to be less important to some industry participants than the “spirit and traditions” of horse racing.

P47. Given the submissions and evidence to the TAWWG, especially from some racing authorities, it is the panel’s view that there is still some confusion about what regulatory framework breeders are captured under.

P48. Despite the popularity of the concept with the PRAs and others, the TAWWG is unconvinced that licensing (breeders) is the best option for achieving this objective.
CPR: Not licensing breeders has and will continue to make it impossible to control breeding numbers. Until there is a home available for every single horse born for the entirety of their lives, then breeding numbers must be reduced and controlled.

P51. While all thoroughbreds are permanently identified with a microchip and are traceable while in the industry, the lack of accurate data on thoroughbreds once they leave the industry means there is no way to fully understand the life history of many former racehorses. This means the industry cannot accurately say how long racehorses live in retirement or monitor their treatment. Such information is vital to convincing the community that racehorses are properly cared for and not simply a commodity to be discarded when their racing careers are over.

P55. As RA, the body responsible for all data collection and national reporting for the industry, told the Senate committee, thoroughbred racing and breeding have the most detailed record keeping of any equine industry in Australia. But the TAWWG also heard evidence that the reliability of this data was questionable, with regulators and participants stating there were issues with compliance, and with how data was collected, that undermined the effectiveness of these traceability rules. This lack of accuracy raises a number of challenges for the industry. It cannot give credible information on the outcomes for horses if it does not have confidence in its data. Nor can it assure the broader public or politicians that horses are well cared for without robust and reliable information on where they are, and in whose care. High quality data is the foundation of sound policy development. This lack of credible information makes it difficult to accurately assess the success of welfare, retirement and rehoming initiatives.

P58. Many submissions and consultations said RA and Australian Stud Book (ASB) records were incomplete and inconsistent. Racing Victoria said a 2020 audit of horses that were recorded as not having raced or trialled in the previous six months found nearly one-third were documented incorrectly and needed to have their status updated. Similarly, an audit of Victorian broodmares covered in 2015 found 10% had not had a mare return lodged. Furthermore, the Racing Victoria audit found:
• poor knowledge among trainers of stable return requirements
• ambiguity in the “transferred’’ status about who is responsible for a horse at any given time
• possible under-counting of the foal crop
• mares can be covered again even if there is no recorded outcome of the previous covering
• stallion owners sometimes hold back registration papers in lieu of payment, if the mare’s owner cannot pay the stallion fee, meaning the foal goes unregistered
• insufficient penalties to discourage poor record keeping.

P58. During the Senate inquiry into horse traceability, RA was asked questions on notice about its retirement data. RA said it was unable to provide a figure. Instead, it said a figure would be obtained when it engaged a consultant to examine the “completeness and accuracy of Racing Australia’s horse records”. Similarly, when asked, RA did not provide the committee with the number of thoroughbreds listed as active, but which had not raced or trained in the past 12 months. TAWWG understands RA has not yet engaged a consultant to review the accuracy of its horse records.

P58. The Martin report highlighted the lack of confidence around retirement data as a particular problem. It stated: “The unreliability of retirement data for racing horses is a critical issue that the racing industry needs to address as a matter of collective priority. Without it, meaningful decisions about managing the welfare of retired racing horses is difficult and determining the amount of effort and investment it will require is impossible. A 2020 audit of horses that were recorded as not having raced or trialled in the previous six months found nearly one-third were documented incorrectly. Racing Victoria “Without it, the industry has been unable to defend itself against public and media backlash and the inquiry has been unable to accurately assess the size of the problem that it was established to address.”
CPR: It has been almost two years since the report and recommendations from the Martin Inquiry were published. This TAWWG report indicates its recommendations to Racing Australia are being ignored. This leaves little room for confidence that this TAWWG report will be any different.

P59.The Thoroughbred Breeders Association (TBA) submission called on RA to urgently embrace technology and described many of its systems as belonging “in the past century”.

P61. It is essential the industry has proper record keeping. Under its rules and obligations, it should know where all horses are and who owns them while they are racing or breeding. By racing regulators’ admissions, this is not the case.

P63. But while the number of horses born each year is published, data on the number of horses exiting racing and breeding is surprisingly hard to find, with no information publicly available on the number retired from racing or breeding. Nor is there detailed information available about those thoroughbreds that do not become racehorses, nor the fate of horses exiting the industry.

P65. If extrapolated to the whole foal crop, the findings would suggest upwards of 10% of the total foal crop – more than 1,300 thoroughbreds a year – may die before they turn four without ever entering training for a racing career.

P65. Congenital malformations are the most significant reason for death in the newborn period and remain significant during the rest of the first year of life, along with digestive conditions and fracture. Fractures in horses are serious because of the difficulty of managing horses with these injuries, meaning euthanasia is usually the most appropriate course of action. Fracture is the largest reason for the death in one- to four-year-olds.

P71. “There is currently no available evidence that the foal crop needs to be reduced in size.” Dr Meredith Flash, University of Melbourne.
CPR: If countless horses found at the sales each year are ending up in the hands of kill buyers due to no homes being available, and the NSW and VIC assisted on-site euthanasia program for horses who cannot be rehomed is not evidence enough that there are more horses than there are homes available, then we do not know what is.

P72. In her extensive studies, Dr Flash found 59% of racehorse retirements were voluntary, i.e. not associated with injury or behavioural issues. She noted the median age of retirement was five, irrespective of sex or whether the horse began its racing career at two, three or four years of age. She concluded: “The finding that the majority of horses (68.5%) are using three years or less, of a potential 11 years of racing, combined with the finding that they are predominantly leaving for voluntary reasons suggests that there is capacity for the industry to make changes to race programming and prize money distribution to positively influence racing career duration.”
CPR: This supports CPR’s findings that the vast majority of racehorses do not make money for their owners let alone cover their own living costs. To propose racing them longer to keep them alive and avoid rehoming requirements also supports our position that horses are simply not wanted by owners and trainers when they are not making their connections money. The 59% statistic means there are a remaining approximate 4,700 horses are being taken out of racing each year due to injury or “behavioural issues”.

P73. The TAWWG received a submission from RA and met with its executives. The TAWWG then requested a detailed breakdown of RA/ASB statistics to inform this report. RA refused to provide any of the information requested.

P73. The TAWWG’s analysis of retirement and aftercare needs is limited by its lack of access to official records.
CPR: Whilst Racing continues to claim to be ‘open and transparent’, data will not even be provided to industry-initiated research.

P74. The TAWWG believes the likelihood of producing excessive numbers of horses is increased because there is no medium- to long-term sustainable breeding and racing plan to ensure alignment between breeding, the needs of the domestic industry and Australia’s export market. The TAWWG also believes that fundamental to any sustainable breeding and racing plan must be provision for the long-term welfare for all horses produced under that plan.

P74. This plan should not only consider how many thoroughbred foals are needed to meet the needs of the racing industry, but it should also fully and properly consider the industry’s responsibility to provide adequate and appropriate post-racing and breeding opportunities for all the horses it produces. As noted earlier, the thoroughbred industry must accept responsibility for the lifelong welfare of all the horses it breeds. If the plan advises that the number of foals born each year can be reduced while still providing sufficient horses for the racing industry, then reducing the foal crop would lessen the aftercare welfare need and help improve the welfare of all thoroughbreds. Such an outcome should be seen as a win-win by the industry, as it would decrease the burden of trying to ensure appropriate outcomes for the horses it produces.
CPR: Whilst the TAWWG acknowledges more select breeding as a way of reducing the number of foals born each year and therefore the number of homes needed, they also advocate for racing horses more often and for a longer period, increasing the risk of injury and the amount of time a horse is subjected to the day to day life of being a racehorse. As the report itself states, unsound horses are harder to rehome. This reinforces CPR’s position that the horse racing industry is fundamentally flawed and whilst improvements can be made, they can lead to creating other problems and ultimately the core issues remain.

82. A large number of industry participants said it could be difficult to know what options were available for rehoming, with many trainers and owners stating they relied on relatively small networks to find a suitable home for a horse. Queensland trainer, Tony Gollan, called on the industry to establish better pathways to assist this transition. He stated: “The biggest problem racing faces is the transition of horses out of the industry, and into secondary careers or homes. There’s not a clearly defined pathway or framework in place. That’s why Jane [Gollan’s wife] set up her foundation, because there’s a big void between the racing industry and the off-the-track industries. It’s not easy to rehome a horse, from a financial perspective but also from a knowledge perspective. A lot of trainers or owners in this country wouldn’t have a clue how to go about it.”

P86. Most PRAs have also established their own retraining and rehoming programs but these are generally in the early stages. According to figures published by RA in its annual report for 2019-2020, just 2% of horses retiring from racing exit into a program run by a racing authority. A number of industry participants said there was little or no available information on how industry funds were spent on these initiatives. Nor was there any way to assess whether these were successful. Trainer Tony Gollan said in his submission: “We have 1% of all prize money allocated to an equine welfare fund, but nobody really knows how that money is being spent.”

P90. In its submission, Racing Victoria called for research into why horses bred for racing become unwanted, arguing, “the horse industry in general and racing specifically must take responsibility for the unwanted horse … understanding what makes certain thoroughbreds unwanted following their racing career will focus initiatives on ensuring horses retire from racing with the best possible opportunities for a successful post-racing career, therefore reducing the number of thoroughbreds ending up in this ‘unwanted’ category”. The submission cited the work of US researcher Dr Tom Lenz who predicted that “euthanasia at the request of the owner, because they no longer want or can afford to care for an unwanted horse, may become a recognised action of a responsible owner in the future”. The British Horse Society already lists “change in owner’s circumstances” as an acceptable reason for euthanasia.
CPR: Whilst Racing Victoria advocate for changes that will help horses be rehomed once they exit racing, they are also stating that when a horse is simply unwanted that they view this as a justifiable reason for killing them and are encouraging this position be adopted in the panel’s recommendations.

P90. Racing NSW has invested significantly in four rural properties that provide indefinite homes for thoroughbreds unsuitable for rehoming. There is little publicly available information on the operations of these properties.
CPR: Racing NSW does not provide details on these programs including how many horses they are caring for or successfully rehoming through them.

P112.  In Australia there are no consistent animal welfare laws, no national animal welfare standards for horses, no national industry welfare standards for thoroughbreds, no horse-specific welfare standards for abattoirs or knackeries, and no effective welfare standards for transporting horses.
CPR: The horse racing industry has never been concerned about this.

P112. The absence of an enforceable welfare framework adds to the challenge of making the best end-of-life decisions which, in the thoroughbred industry, rarely involve ideal options. Typically, these decisions seek to balance a horse’s welfare with practical and financial considerations, which are sometimes in conflict.

P118. It is clear the industry needs to provide transparent information on its welfare standards and programs, and also communicate reliable information on actions taken against those who breach those standards. Put simply, the thoroughbred industry needs to provide credible information to the Australian public on how it is seeking to ensure the care and welfare of thoroughbreds meets the community’s expectations.
CPR: This finding supports CPR’s ongoing reports to the public that whilst the industry claims to care for the horses they exploit, they refuse to provide any transparency as to how they do this. CPR has emailed and made phone calls to the various PRA’s and RA hundreds of times, requesting information on the deaths of horses on track, concern for broodmares being sent to slaughter and many other issues only to be repeatedly ignored.

P119. Unfortunately, the TAWWG and the broader public cannot readily access official industry data that shows the exact number of horses. It is unclear whether accurate data even exists. Nor is there any information or data that provides a reasonable estimate of the number of new opportunities available each year for thoroughbreds leaving racing and breeding in the wider equestrian, recreational riding and broader horse community.

P122. The submission from TBA criticised the industry’s defensive mindset, stating: “Too often, ours is an industry that is inward looking: its default position to any questioning or scrutiny is defensive and dismissive.” It added: “It is important we take responsibility for putting accurate information in the public domain, with the proper context, so that people can make up their own mind on our industry. There may be areas where this is uncomfortable for the industry: mortality rates of young horses, fatalities on the racecourse, the number of horses that are unsuitable for a second career and euthanised, but such issues need to be addressed.’’
CPR:  CPR agrees with the TBA on this. People have a right to know what they are choosing to support or not support. It should never be the job of CPR or any not-for-profit organisation to expose the truth about an industry – especially one that is supported by tax-payer dollars. The reality of horse racing is as grim as we continue to expose – actually, it is much worse. We therefore do not expect such transparency to come any time soon. Having said this, like some sectors of the animal agriculture industry are currently attempting to achieve, transparency can for some, also lead to the normalisation of what are ultimately unjust practises, so even full transparency would still demand the industry and its inherent cruelty be battled head on.

P117. Every individual who handles thoroughbreds should have an understanding of horse behaviour and welfare. Many workers in the industry play a key role in horse development and behaviour. Often many have had little formal training. Improving the skills of the workforce will improve welfare outcomes.
CPR: Inexperienced staff, often with little to no knowledge of horses and horse welfare are often responsible for the day-to-day care of these horses. Horses are commonly ‘juiced’ (given sedatives) before being put out for trackwork, due to insufficient foundation training and inexperienced hands being allowed to manage them. Track riders have reported them to be unsteady on their feet, making them more susceptible to injury, and more skittish on race day when sedatives are not used.  

End of Life
CPR: Chapter 10 of the report (from P101) is dedicated to ‘End of Life’. This chapter covers the benefits and limitations of the different ways, locations and carcass disposal methods available in relation to killing horses and the search for what can be considered most “humane”. Whilst CPR recognises the reality that some horses become ill and must be euthanised, while others simply die of natural causes and their bodies need to be dealt with, this section is mostly relevant to the killing of horses who are simply unwanted. It highlights yet again, the inherent issues of breeding 13,000 plus horses into Australia each year, whose natural lifespan is approximately twenty-five years, but who, on average, will only be wanted for less than five years. We recommend you read this section for yourself to understand this additional unethical situation the horse racing industry creates and the challenging difficulties that then surround it.

However, we must make the following comments:

1. The TAWWG make it abundantly clear that no horse should be sent to the Meramist slaughterhouse in Caboolture QLD citing the dangers and suffering caused by long distance transport and the lack of handling and killing standards specific to horses. CPR has sent these observations along with the report’s findings regarding the lack of horse traceability in Australia to the EU Commission as further evidence as to why the import of Australian horse meat into the EU is in breach of the EU Commission’s own regulations for both food safety and animal welfare. Our letter can be read here. We have also noted this in a letter to the Department of Agriculture and Fisheries.

2. In an industry that attracts over $21 billion in wagering turnover and whose direct and indirect contribution to wealth is calculated at around $9 billion annually, there is absolutely no justification for a racehorse to ever be killed outside of on-farm humane euthanasia by the true sense of the word ie when the horse cannot be helped and death is the only option to relieve their suffering from injury or illness. Being unwanted and unable to find another home is not and will not ever be a justifiable reason, especially so long as this industry is making any amount of profit and so long as it continues to breed more horses into the world.

3. In relation to killing horses deemed to be a danger to humans  – patient and extensive rehabilitation should first be a requirement. Killing must only be allowed if all avenues for rehabilitation have been exhausted. Further, any horse who has been found to be incapable of being rehabilitated to a level that will allow them a life worth living, should result in an investigation of previous trainers, owners and breeders to determine if poor treatment, and violent and aggressive training methods contributed to the horse’s condition.

4. CPR will never support sending horses to a knackery or slaughterhouse. In the circumstance where a horse is suffering from injury or illness and cannot be helped, and a veterinarian can not make it to the horse in a timely matter to euthanise via lethal injection (due to remote location for example), only then should a skilled firearms holder perform an on-site kill. The horse should always be sedated prior to any method. Horses should not be allowed to be kept outside of a reasonable vicinity of a veterinarian in the first place.

5. In all of the above scenario’s a veterinary certificate that euthanasia (by the true meaning of the word), was required must be provided – even if that must be via postmortem.

6. If a barbiturate is used, a horse cremation service should be engaged where burial is not possible, safe or in line with EPA requirements. If the owner cannot afford this cost, it should be covered by the relevant racing authority. Not covering such an expense, that will help towards ensuring a truly humane and dignified death and safe body management/disposal in a multi-billion industry is not acceptable.


We must reiterate that whilst we support the majority of recommendations, we do not believe that the industry is capable of any kind of legitimate, meaningful and sincere reform, nor that any kind of reform can ever go far enough. Horse racing is a gambling industry that is inherently cruel, using these horses for human gain. Whilst its harm may possibly be reduced, it can never be made kind, fair, or just for the horses.