LETTER TO FLORIDA DIVISION OF PARI-MUTUEL WAGERING RE: KENNEL COUGH

Apr 26, 2003 - Greyhound Protection League
P.O. 669 Penn Valley, CA 95946
888.842.4404

April 25, 2003

Royal Logan
Chief Operations Officer

Florida Division of Pari-Mutuel Wagering 850.488.0550
1940 North Monroe Street
Tallahassee, Florida 32399-1035

Dear Mr. Logan:

The Greyhound Protection League has been closely monitoring the recent outbreak of kennel cough at Florida dog tracks. This is the same disease that ravaged the entire dog racing industry in 1999 and 1992 and led to the death of dozens of greyhounds nationwide. The death toll this time around is at least three and mounting. This year's kennel cough outbreak took on epidemic proportions when it spread to seven of the ten Florida racetracks currently open for live racing. Then it moved to racetracks in Alabama, West Virginia, Rhode Island and Connecticut. If past experience is any guide, it may continue its insidious spread to even more racing facilities.

The spread of the sickness into other racing states has been attributed in media reports to the transport of contagious Florida racing dogs to racetracks in other states. Similar well-founded allegations were made when a distemper outbreak spread from Florida Kennels to Kansas and killed over 100 Kansas race dogs six months ago. Now the racing world is awash with rumors that the recent dispersion of sick Sarasota dogs at the close of the meet has brought kennel cough to greyhound farms in the Midwest. A more alarming rumor is that Florida is covering up the real number of greyhounds that died during the current kennel cough epidemic.

One would think that this kind of negative publicity would be cause enough for implementation of stringent infectious diseases control measures. But the adverse effects are even more damaging in ways that should be of great concern to your agency. Mismanagement of the outbreak on the part of the many Florida racetracks directly undermined the primary purpose of the Division of Pari-Mutuel Wagering - to ensure the integrity of the betting system in order to protect the gambling public and to protect the welfare of Florida racing greyhounds. The health of racing animals is intrinsic to both of these mandates.

To fully comprehend why proper management of contagious disease is critical for racing dogs, one has to keep in mind the following points:
1. Stress is a major contributing factor to the severity of disease. Racing dogs live and perform in an extremely high stress environment which includes:
a. Life in a track compound of more than 1,000 dogs, with kennel buildings holding 60 more dogs in cramped quarters.
b. The physical demands of racing performances, sprinting and schooling races.
c. Confinement in the kennels and in the paddock area.
d. Competition in the turnout pens where dozens of dogs are turned out together to relieve themselves and get a drink of water.
e. The frenzy that takes place in the kennel at feeding time.

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2. The kennel and racing environment is a dangerous haven for the unavoidable spread of contagious disease:
a. Contagious diseases are by their very definition readily transmittable to other animals through a wide variety of mechanisms.
b. Contagious diseases thrive in conditions where animals live in confined, close quarters.
c. Race dogs are constantly exposed to other dogs in the kennel buildings, turnout pens, transportation vehicles, paddock and weigh-in areas, as well as during racing activities.
d. Racing compounds do not offer any form of isolation for sick animals.
e. Lack of cleanliness is a major contributor to the severity and spread of disease. It is virtually impossible to maintain an acceptable level of cleanliness in the large kennel environments that exists at racetracks.
3. The duties of track veterinarians are very limited:
a. Track vets are not charged with caring for sick dogs in the kennel compound
b. Track vets primarily determine which dogs should be scratched from the race card, stabilize race injuries and euthanize dogs with catastrophic injuries.
c. Track vets are on site during the limited hours of official races only.
d. Care of sick animals is dependent on the financial resources and knowledge of
individual kennel personnel.
e. Outside veterinary care for sick animals must be sought and paid for by the kennel operator. Few can afford this expense for dozens of dogs at one time.
4. Without strictly enforced regulations, financial considerations can easily override appropriate infectious disease control and animal welfare decisions:
a. Racetrack revenues are dependent on the number of racing performances.
b. Management has a vested interest in offering a maximum number of race events.
c. Purse money for kennel operators is greatly reduced when fewer dogs are racing.
Therefore, kennel personnel may be temped to disregard signs of sickness.
d. The financial viability of tracks and kennels is dependent on the movement of
dogs from one track to another; consequently, there is significant temptation to
disregard self imposed quarantines in order to get rid of unprofitable animals and
bring in new stock.

All of these factors appeared to be in play during the recent kennel cough epidemic. Unfortunately, Florida racetracks were given free reign to address the sickness in any manner they saw fit. In our view, the handling of the outbreak was rife with mismanagement of a highly contagious disease in a high-risk environment. This poor judgment put thousands of animals at risk and, at a minimum, violated the spirit of the pari-mutuel mandate. The following considerations put our concerns into perspective:
* The industry failed to develop a formal infectious disease prevention and control protocol in spite of the devastation caused by other epidemics during the last decade. Such a program would have drastically limited the scope and severity of this outbreak
* Tracks failed to impose an immediate quarantine upon first detection of the illness and allowed the disease to spread throughout Florida and into other states. The epidemic is
prima facie evidence of the failure of a self-regulated quarantine system which is, after
all, only as effective as the vigilance and intent of those enforcing it. (Orange Park, the
one track that did impose a quarantine early on never experienced any sickness).

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* Racetrack management failed to inform kennel owners and trainers of effective infectious disease controls and treatment when the outbreak first occurred.
* At the onset of illness, management failed to recommend that cultures from infected animals be sent to the University of Florida to determine the cause of the illness.
* Racetracks failed to immediately cease live racing in spite of accepted veterinary recommendations that infected and exposed dogs be given complete rest and be kept in strict isolation. As a result, infection rates continued to rise dramatically, ultimately infecting thousands of animals.
* Worse yet, several Florida tracks never discontinued their racing schedules in spite of severe sickness in their kennel compounds.
* By continuing to hold live racing events most Florida tracks risked the integrity of fair gaming offered to the betting public. Many greyhounds that raced during the epidemic were very likely in the sub-clinical, carrier phase of the illness - experiencing general malaise without the overt signs of illness. It is impossible to calculate how much of the public's money was placed on animals that were not racing at the peak of their capabilities.
* Tracks that continued their racing schedules unabated further risked the health and performance of the dogs by decreasing the number of rest days between race cards when fewer and fewer dogs were available to race.

Dr. Bradley Fenwick, Kansas State University veterinarian and consultant to the National Greyhound Association, recently drafted a paper on the proper management of kennel cough in the racing environment; this information is based on the extensive research he has done on both current and previous outbreaks. His recommendations include the following:
1. The implementation of good infectious disease control that includes the restriction of any movement of people, dogs or equipment between kennels, and the utilization of a two-step cleaning and sanitation process.
2. Closure of all infected kennels for 10-14 days AFTER the last dog stops coughing.
3. All dogs exposed to infected dogs throughout the entire cycle of racing should be considered at risk if allowed to race. Mr. Fenwick notes that if these dogs are allowed to race, they risk life-threatening secondary infections.

It is our observation that Dr. Fenwick's recommendations, as well as readily available standard veterinary advice were ignored by the majority of Florida racetracks. A detailed review and investigation of the following data and/or information will aid in evaluating problem areas:
* Race results to determine the extent and duration of illness.
* Individual racing lines to identify patterns in the decrease of rest days between races.
* Infectious disease controls implemented during racing periods when contagious animals were transported throughout the compound and into racing preparation areas during race performances, schooling races and sprint activities.
* Management decisions to hold live racing throughout the duration of the outbreak, the impact of such decisions on the severity and scope of the illness, the health implications to the dogs and the effect on racing performance.
* Euthanasia records maintained by track veterinarians, as well as local independent veterinarians to determine severity of outbreak and the actual number of deaths.

With respect to Division of Pari-Mutuel Wagering enforcement powers over health issues, a recent review of the rules and regulations leads us to conclude that health issues and the adverse

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effect of widespread sickness on performance animals fall well within the Division's mandate: "To ensure the health, safety and welfare of the public, racing animals, and licensees through efficient, and fair regulation of the pari-mutuel industry."

If it is concluded that the Division does not currently posses the power to intervene in such matters, we strongly recommend revision of the rules and regulations so that in the future your office will have the authority to:
* Require a stringent preventative vaccination regimen.
* Require immediate reporting of sickness at all Florida greyhound tracks.
* Impose a state enforced quarantine at the first indication of a contagious disease outbreak.
* Seek expert veterinary advice early on to ascertain the precise cause of the sickness, so that the correct treatment can be administered.
* Implement and enforce a predetermined, comprehensive infectious disease protocol specific to conditions in the greyhound racing environment.
* Disallow misleading assurances to the public by track public relation persons.
* Cancel racing activities for whatever period of time is necessary to fully protect all dogs (both active and inactive) from continued spread of the disease, relapse, the stress of exercise and racing.
* Require immediate reporting of disease related deaths.
* Cancel races when it is determined to be in the best interest of the betting public.
* Require that racetrack owners supply the necessary funding to kennel operators so that the dogs will continue to be fed, medicated and cared for during the shut down.
* Lift quarantines and resume racing only when it is deemed advisable by an independent, authoritative veterinary source that does not have a financial interest in racing revenues.
* Impose substantive fines for violation of these rules.

The other issue that is of particular concern to those of us in greyhound protection is the devastating effect that rampant, uncontrolled disease has on adoption efforts. Ineffective quarantine measures in Florida caused spread of the kennel cough to at least one adoption facility. Fears that there would be contamination to other rescue facilities, created a virtual shut down of adoption efforts for Florida racing greyhounds. This is a devastating consequence in a state where thousands of unprofitable greyhounds are killed every year. If the outbreak had been contained at its origin, the lives of many more Florida greyhounds might have been saved.

We are confident that these issues are as great a concern to the Pari-Mutuel Division as they are to greyhound advocates. We look forward to your reply.

Respectfully,

Susan Netboy, President Lenka Perron, President
Greyhound Protection League Michigan ReGAP

Enclosures: List of Florida greyhound tracks
2003 advisory by Dr. Brad Fenwick on greyhound kennel cough epidemic
cc: Governor Jeb Bush

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