In this connection, “independent” means that they should not rely on race tracks and trainers for their livelihoods. It is also essential that proper records of injuries to greyhounds are kept and that these      records are made available for public scrutiny on an annual basis in a format that will allow them to be compared and used to improve welfare. It is absolutely unacceptable that greyhounds should be transported over long distances in cages too small to allow them to stand up or turn around.  This must be the criterion, rather than an arbitrary minimum size of cage since greyhounds vary considerably in stature.   The report by the Associate Parliamentary Group for Animal Welfare (APGAW) in 2007 found that “the .... racing industry produces, at a minimum, a ‘surplus’ of 13,478 dogs in England and Wales each year [plus] an additional number of unwanted dogs produced by the         independent sector”. And “.. a minimum of 4,728 dogs are unaccounted for each year” – these are presumed killed by the age of three or four – when their racing days are over.     The average life span of a healthy greyhound is around 14 years. Despite decades of ear marking the industry still fails to track their dogs reliably. So we      consider it vital that all greyhounds should be permanently identified at 4-6 weeks, and a single central record kept of them through to retirement so that numbers entering and leaving the industry can be more accurately recorded and also made publicly available. We are convinced that many greyhounds are put down unnecessarily. These regulations should require that greyhounds only be euthanased by a vet if an injury is untreatable or    rehoming is not possible.   There is a rising tide of public unease about this issue and increasing pressure on the        industry to improve its ways and not regard dogs as disposable commodities. Self-regulation by a portion of the industry will not work – it will not stop another Seaham. We urge ministers to apply statutory regulation by an accountable independent body to all the greyhound indus- try as a matter of urgency.   Please find attached our formal response to the consultation questions………………………… Supporters can read our full submission on our website:   http://www.greyhoundsinneed.co.uk/ natureofproblemLetter2DEFRA_20jul09.pdf   24