While the report said “An unequivocal statement on the biomechanics of injury by whips in general is not possible because of the many physiological and physical factors determining tissue damage”, it followed this with “It is, however, possible to develop general principles about a whip’s potential to injure which can be used in a more objective assessment of abuse, thereby allowing the Rules of Racing to be modified to exclude whips with a greater potential to injure” (our emphasis). It is disappointing that the authors’ suggestion that “Non-invasive techniques, including thermography and ultrasound … could be useful … to assess whip damage potential and to quantify whip injury after suspected whip abuse” has not, to our knowledge, yet been undertaken.
4.1. Frequency and Location of Whip Rule Breaches
We found whip rule breaches were recorded by Stewards in NSW/ACT in 2013 in 1% of starts; 6% of races; 31% of race meetings, and at 53% of racetracks. Only a small number of starts with breaches had second breaches in the same race (11%), and over 90% of horses were the only horses in their races with a breach or breaches.
In a study by McGreevy et al. [4
] using side-on high speed footage (2000 frames per sec) of 15 race finishes at 2 P NSW race meetings in 2011, 28 whip rule breaches in 9 horses were identified that were not recorded by Stewards. Using the Race Diary [21
] to obtain the number of starts in these races, we calculated 6% of these starts had at least one whip rule breach. For the same starts, Stewards recorded a breach frequency of 1% that corresponded to one whip rule breach in a horse that ran tenth and hence was not included in the McGreevy study. Given this study used footage obtained from only one side of the track, and at race finishes, it provides strong evidence that the Stewards under-reported whip rule breaches in the 15 races studied in 2011. As the same surveillance techniques were also used by Stewards in 2013, it is possible that the 1% frequency of whip rule breaches recorded by Stewards for that year, may also underestimate the actual number of whip rule breaches. Of course, it is possible that the breach frequency observed in the small number of races looked at by McGreevy et al. was an anomaly, but it may also indicate the need for faster footage than that currently examined by Stewards (25 frames per sec) [4
], which views races head-on. It may also be possible that Stewards focus on the worst offending rider in a race, perhaps because of time pressures, and as such may overlook other riders who are also breaching whip rules. Current surveillance methods should be investigated to ensure these are not failing to detect breaches.
The UK Review found a breach percentage of 0.74 for flat turf racing between 2004 and 2011, which appears slightly higher than the raw 2013 NSW/ACT percentage. However, it needs to be considered that the UK whip rules set a maximum of 15 whip strokes per race [12
] (p. 14), whereas that was not the case in 2013 in Australia, nor is it the case now where “In the final 100 m of a race … a rider may use his whip at his discretion” (AR. 137A. (5)(b)).
Following this Review, whip use was further restricted in the UK and is currently capped at 7 strikes per flat race, but penalties are imposed at the discretion of the Stewards [29
], as also occurs in Australia. In 2015, the number of UK whip offences, expressed as a percentage of total rides, was 0.61% compared with 1.12% in 2010 [29
]. As Racing Australia (RA) does not publish these data, it is not currently possible to say whether the number of whip breaches in NSW/ACT is increasing, decreasing, or static. This shortcoming should be addressed by an industry commitment to reporting, or by mandatory reporting, as part of incremental improvement in racehorse welfare and racing integrity.
Our study found starts at C locations were significantly less likely to result in a breach being recorded than starts at P and M locations, and starts at M locations were significantly more likely to result in a breach being recorded than starts at C and P locations. We were advised there was no difference between the level of surveillance used by Stewards to detect whip breaches at these locations [30
] and that Stewards are not attached to individual tracks. Instead, a Stewards panel based in the metropolitan area services M and P race meetings and, in regional centres, Stewards are based in five locations [31
]. It is possible, therefore, that reported differences in breach frequencies at C, M and P locations may reflect true differences in the numbers of breaches occurring, or they may reflect behavioural differences in reporting among individual Stewards or between the two pools of Stewards. Further studies are needed to confirm this.
We thought total prize money on offer might incentivise whipping, but our results did not demonstrate this. As Racing NSW describes the BOBS as “the most popular racing incentive scheme in Australia” [32
] (p. 30), we also investigated whether it might incentivise whip breaches, but again this was not the case. However, it is possible that the desire to win might have been an incentive, as we demonstrated riders of horses finishing first, second, or third had significantly more whip rule breaches recorded against them than riders of horses finishing in other positions. While our findings support those of Evans and McGreevy that “whippings were associated with superior performance and that there was an association between final placing and the number of whip strikes in the final 200 m section” [3
], it should be remembered that in that study, only whip-rule-compliant whip use was included and race footage was not examined by the authors. In this instance, we would want to exclude the possibility that Stewards may tend to focus on the horses running first, second or third, and, as such, possibly miss whip rule breaches by riders of other horses.
4.2. Types and Location of Whip Rule Breaches
Our findings also characterise the types and locations of whip rule breaches recorded by Stewards in NSW/ACT in 2013. We now know that the whip rules most commonly recorded as first breaches were forehand whip use on more than five occasions prior to the 100 m mark (Code 17), and using an action that raises the jockey’s arm above shoulder height (Code 8), which accounted for over 45% and 25% of first breaches, respectively. The finding that 70% of first breaches consisted of breaches of only two whip rules deserves further attention, as does the finding that 55% of first breaches consisted of breaches of Code 16 (Forehand whip use in consecutive strides prior to the 100 m mark) and Code 17, which also applies before the 100 m mark.
Possible reasons for these findings include that these breaches may be more easily detected than some others, as Stewards view the race footage head-on [4
]; Stewards prioritise these breaches (this does not appear to be the case from the Racing NSW Rider Penalty Guidelines for Whip Rule Breaches (see Appendix A
] that were used in 2013, but discretionary biases might occur in practice), or simply these breaches are what might be expected if whip strike frequency and force are perceived to be needed for a horse to win: that is, there is an increased number of whip strikes, and an increased number of more potentially powerful whip strikes with the whip wielded above the jockey’s shoulder. However, McGreevy et al. [4
] stated “It is not clear how much, if any, amplification in force that whipping from this height creates. From the perspective of force and therefore pain, the recoil of the whip may be more important than the height from which it descends during its trajectory”. Given we found over a quarter of all first breaches involved whip use when the jockey’s arm is raised above his shoulder height, this question regarding the force of these whip strikes requires clarification.
Importantly, an increase in the number of whip strikes prior to the 100 m mark does not tell us about the actual number of whip strikes used in the final 100 m (except it seems unlikely riders would decrease whip use in this crucial race segment). This contention is supported by Evans and McGreevy [3
] who found 98% of horses were whipped in the final 200 m of five sprint races at an M location in NSW, when they were slowing. Evans and McGreevy concluded their data “make whipping tired horses in the name of sport very difficult to justify”. Our data also show whip breaches occurring when horses are likely to be fatigued.
While Whip Rule AR 137A. (3) (Code 6) prohibits excessive, unnecessary, or improper whip use throughout the race, only 3% of first breaches fell into this category. This might suggest such whip breaches do not occur frequently in the critical last 100 m of the race, but this is unlikely given even a cursory examination of race finish footage in the media. One of Australia’s leading sports journalists, Patrick Smith, wrote: “as the rules are now, jockeys will whack their horses non-stop down the straight from the 100 m post…” [17
]. The low number of breaches recorded for this whip rule might also reflect problems in detection (as suggested by McGreevy et al. [4
]), or simply the Stewards’ discretion.
It is also unclear what constitutes excessive, unnecessary, or improper whip use (AR 137A. (3)) (Code 6), given AR 137A. (4) prohibits whip use (a) forward of horse’s shoulder/vicinity of head (Code 7); (b) that raises arm above jockey’s shoulder height (Code 8); (c) when horse is out of contention (Code 9); (d) when horse is showing no response (Code 10); (e) after passing winning post (Code 11); (f) causing injury to the horse (Code 12); (g) when horse is clearly winning (Code 13); (h) when horse has no reasonable prospect of improving/losing position (Code 14); and (i) in such manner that the seam of the flap is the point of contact with horse, unless rider satisfies Stewards this was neither deliberate nor reckless (Code 15).
Considering that, in 2013, AR 137A. (5)(a) prohibited (i) forehand whip use in consecutive strides prior to the 100 m mark (Code 16) and (ii) forehand whip use on more than five occasions prior to the 100 m mark (Code 17), it appears by default that Code 6 breaches involving whip use in consecutive strides and excessive numbers of whip strikes applied only to the final 100 m of the race. The very low frequency of Code 6 breaches (excessive, unnecessary, or improper whip use) recorded in 2013 provides an impetus to investigate at what stages of races these breaches are reported in, what constitutes these breaches, and in general what percentage of all breaches occur and are recorded in the final 100 m.
Additionally, Code 6 breaches raise the important issue of what Stewards consider to constitute “unnecessary” whipping. This notion logically relies on the concept of “necessary” whipping and there remains a paucity of peer-reviewed evidence to support this, either for safety, or to improve performance [8
]. Further, there is a legal argument to consider in relation to what constitutes “unnecessary” under the NSW Prevention of Cruelty to Animals Act 1979
]. Section 5
prohibits cruelty to animals, including racehorses, and Section 4
(2) explains “…a reference to an act of cruelty committed upon an animal includes a reference to any act or omission as a consequence of which the animal is unreasonably, unnecessarily or unjustifiably:
beaten, kicked, killed, wounded, pinioned, mutilated, maimed, abused, tormented, tortured, terrified or infuriated,
over-loaded, over-worked, over-driven, over-ridden or over-used…
inflicted with pain”, where “pain” includes suffering and distress (Section 4
It appears critical this question of whether whipping racehorses could constitute cruelty under the POCTA is considered. Jones et al. [8
] discuss “necessary” in relation to animal welfare legislation by using the leading case on this question—Ford v. Wiley, an English High Court decision from 1889 that developed a test to determine when suffering caused to an animal could be deemed to be unnecessary in a particular set of circumstances. It would appear overdue that this be applied to whip use in horse racing in Australia, and particularly in relation to the regulatory outcomes for Code 6 breaches (excessive, unnecessary, or improper whip use).
We also found significant differences between the likelihood of certain whip rule breaches being recorded at the three race locations. Starts at M locations were significantly more likely to result in Code 8 first breaches (Using an action that raises the jockey’s arm above shoulder height) than starts at C locations, and starts at C locations were significantly less likely to result in Code 16 breaches (Forehand whip use in consecutive strides prior to the 100 m mark) than starts at other locations, and significantly more likely to result in Code 17 first breaches (Forehand whip use on more than five occasions prior to the 100 m mark) than starts at M locations.
As discussed in relation to the significant differences we found in the frequency of whip breaches recorded between locations, the significant differences in the types of breaches being recorded at the different locations may reflect true differences in the types of breaches occurring, or perhaps differences in detection and recording amongst individual Stewards or between the two pools of Stewards. Further studies should investigate this.
We found no differences between locations for the recording of Code 9 breaches (Horse whipped when out of contention), which comprised 13% of first breaches. This may reflect our earlier discussion that the desire to win, or possibly not to come last, may lead riders into this whip use, and that these incentives apply at all locations. It is also possible Stewards may be more likely to record a Code 9 breach for a horse that runs last at any location, as it may be more obvious the horse was out of contention than for other non-winning/non-place getter horses. It is worth noting that being out of contention is an holistic evaluation that many observers could arrive at, despite the difficulties in providing a quantitative approach to this rule.
When we examined the types of breaches recorded in horses that ran last, we found most were Code 9, and conversely most Code 9 breaches were recorded in horses that came last. Not surprisingly, horses with these breaches recorded won significantly less money than horses with other breaches in races at all locations.
McGreevy et al. [9
] provided insights into Code 9 breaches when they noted in relation to UK and Australian horseracing “…no definition of being “out of contention” is offered by either set of rules and therefore is open to considerable interpretation”. Evans and McGreevy [3
] further highlighted the conundrum facing a jockey to both “ride his horse out (i.e., ensures the horse gave of its best) to the end…” in accordance with AR 137. (b). It appears that in 2013 these issues had not yet been sufficiently clarified, and this remains the case currently.
In interpreting our data on second breaches, it must be remembered that while the level of surveillance may be the same at all locations, Stewards may use their discretion to order first and second breaches differently at the three locations, or there may be no difference in the importance of what breach is recorded first. Notwithstanding this, we are able to say that where two breaches were recorded in one start, over 75% involved the same two whip rules (Codes 16 and 17) and hence occurred prior to the 100 m mark. Attempts to clarify what determined the order of two breaches recorded in a start and whether this affected what penalties were imposed, were answered simply as “both penalised” [30
]. This highlights the need for a transparent prosecution policy or penalty guidelines in Australia, as now provided in the UK by the British Horseracing Authority (BHA) [35
]. Likewise, our examination of Stewards Reports showed a need for greater consistency in how information is recorded between racetracks.
Several whip rules had no breaches recorded. In some cases this may reflect a lack of clarity of the rules, or difficulties in detection, rather than indicating a 100% compliance rate (though that is probably the case with AR 137A. (1) and (2), which pertain to the correct, padded whip being used).
For example, in the same study that revealed indentations in the skin of horses in over 80% of whip strikes in 15 race finishes at two P NSW race meetings in 2011, McGreevy et al. [4
] raised concerns “the seam rule” (Code 15) “is virtually impossible to police, even using significantly more detailed footage than is usually reviewed by racing Stewards, and its inclusion is therefore futile”. The authors noted “the number of times breaches of the seam contact rule have ever been prosecuted since the current rules were established is negligible”. Our finding that there were no breaches of this whip rule recorded by Stewards in 2013 supports McGreevy et al.’s contention, and further questions the adequacy of monitoring of this rule by Stewards, and the validity of the rule itself.
Similarly, it appears likely that current methodology employed by Stewards is not sufficiently sensitive to detect tissue injury caused to horses from whipping, except in extreme cases where a weal (or welt) is visible to the naked eye. This may explain why there were no recorded breaches of the “injury” whip rule (Code 12) in 2013, despite evidence that whip use in racing frequently indents the skin of horses and as such may injure it [4
Currently, horses that have raced are examined by industry veterinarians before they are removed from the racecourse. We argue this may fail to expose inflammatory processes and, hence, ensure whip rules prohibiting injury to the horse are complied with. Where feasible, the examination of horses the day after racing with advanced tools, such as thermography, would help clarify the extent of whip-related injuries.
In their 2012 study, McGreevy et al. also showed that the unpadded section of the whip made contact with the skin of the horse in 64% of impacts, and challenged the notion padded whips (as prescribed in AR 137A. (1) and (2)) prevent injury to the horse. The reason proponed was the padding is held onto the shaft of the whip with unpadded binding that strikes the horse whenever the padded section does [4
Our study considered whip use that was recorded by Stewards as breaching the whip rules and, hence, in all likelihood analysed only a small proportion of whip strikes overall. This can be easily appreciated when you consider AR 137A. (5)(b) allows the rider to use “his whip at his discretion” in the final 100 m of every race, where the rules restricting the number of strikes and whip use in consecutive strides do not apply. The Stewards reports show therefore that the minimum number of horses whipped in NSW/ACT in 2013 was 384 (including 37 horses in which second breaches were recorded). In light of McGreevy’s findings [4
], our contention is that these horses would also have been struck with the unpadded part of the whip in many of these impacts. Indeed, we argue that this would also have been the case in many of the whip strikes that did not breach the whip rules and hence were not the focus of our study.
Likewise, another of McGreevy et al.’s findings [4
] was that the horse’s flank (abdomen) is “twice as likely to be struck with the entirety of the whip than is the hindleg”. There is no evidence to suggest this unintended whip action was not still occurring in 2013. As McGreevy et al. highlighted, although this area of the horse is regarded as being “particularly sensitive to tactile stimulation”, and UK whip rules restrict whip use to the quarters of the horse, no similar safeguard is provided in Australia. This is surprising given Australia is one of 49 countries that signed the International Agreement on Breeding, Racing and Wagering [36
], which prohibits the use of the whip on the flank. It is unclear why flank strikes are not reported under Whip Rule AR 137A. (3) (Code 6), which prohibits improper whip use. It may be bilateral race footage is needed before any assurance about proper whip use can be provided.
Similarly, the International Agreement’s prohibition on the use of the whip with excessive force cannot be effectively policed in the absence of whips that detect force. One such electronic whip, which counts whip strikes and their force, is currently being advertised [37
]. While this type of device might work to limit the force of whip impacts, it would be unlikely to prevent possible injury resulting from repeated strikes to the same area, or take into account differences in pain thresholds and susceptibilities to injury in individual horses.
Further, as the Stewards did not record any breaches in 2013 involving whip use when the horse was showing no response (Code 10), this implies firstly that the Stewards are able to detect such responses, even when horses are slowing; and secondly, that all whipped horses responded to the Stewards’ satisfaction. The training and evidence-base required to produce and assess this skill should be critically examined.
These problems in the detection and enforcement of whip rule breaches raise important issues about Australian whip rules. The need for laws (or rules) to be clear is the first Rule of Law Principle identified by the Law Council of Australia [38
] (p. 1). This is not only so those who are regulated understand what they cannot do, but also to prevent arbitrary enforcement and erosion of respect for the law. Sophocles warned “What you cannot enforce, do not command”, and this is relevant to the integrity issues facing racing today. Given the industry is currently permitted to self-regulate, it is even more important that the AR are clear, enforceable, and enforced fairly and consistently. If breaches of rules are hard to quantify, then the rules need to be reworded to allow detection without quantification so that a binary (yes/no) outcome can be recorded.
4.5. Breach Outcomes
Overall, breach outcomes or penalties were low in our view. Reprimands were the most common outcome for first and second breaches, with less than a third of first breaches resulting in fines, and even then the total was a modest $25,600 (median value $200). Further, all Code 6 first breaches (Excessive, unnecessary, or improper whip use) resulted in cautions or reprimands only.
The four most commonly recorded first breaches had variable outcomes. For example, Code 8 first breaches (Whip use that raises arm above jockey’s shoulder height) had the highest fines imposed overall (2 × $800), while fines were rare for Code 9 breaches (Whip use when the horse is out of contention), with the highest fine imposed being $300.
In 2013, Stewards imposed only 13 suspensions for whip rule breaches, which ranged from 5 to 14 days, and all resulted from breaches of Codes 16 and 17. No cautions were issued for Code 16 breaches, and only one was issued for a Code 17 breach, which might imply Stewards regard these more seriously than other whip breaches.
We sought the Stewards’ “prosecution policy or similar” that helped determine the penalties imposed for whip rule breaches in 2013, as this was not available on Racing NSW’s website. The resultant advice was there “is only a guideline” (see Appendix A
], and this related to Code 16 and 17 whip breaches only. Although not stated in the Guidelines, suspensions appear to be a serious outcome and are not suggested as outcomes for breaches of Code 16 (Forehand whip use in consecutive strides prior to 100 m mark) or Code 17 (Forehand whip use on more than five occasions prior to the 100 m mark), until the sixth offence for both 4–5 whip strikes in consecutive strides (Code 16) and 4–5 whip strikes in excess of the five allowed under Code 17; for the second offence for six or more whip strikes in consecutive strides (Code 16), and for six or more whip strikes in excess of the five allowed under Code 17.
While Guidelines were provided to us for only these two whip rules, it may be possible Stewards use additional guidelines. Penalties are also always at the Stewards’ discretion. Nonetheless, it is telling that in 2013 suspensions were imposed only for Code 16 and 17 breaches, and thus were for whip breaches that took place prior to the 100 m mark.
Although Stewards can impose loss of winnings and earnings on riders breaching whip rules (AR 196. (2)), this did not occur [41
]. Overall, the penalties imposed for whip rule breaches in 2013 appear low, with the majority not involving fines or suspensions, and when these were imposed they appeared insufficient to act as serious deterrents (as seen in, what the current authors consider to be, the high number of repeat offenders).
4.8. The 2015 Whip Reforms and the Current Situation
In 2013, backhand whip use, where the whip is held like a ski pole, as opposed to forehand whip use, where the whip is gripped like a tennis racquet [9
], was exempted from AR 137A. (5)(i) and (ii) (Codes 16 and 17). McGreevy et al. opined in 2012 [4
] that it was possible “that the rules have inadvertently encouraged jockeys to use the backhand rather than the forehand actions to avoid being penalised”. The veracity of this concern was reinforced by whip rule reforms enacted on 1 December 2015 by RA. In a letter to jockeys, John Messara AM (Chairman, RA) said:
“Since the introduction of the 2009 reforms, riders have become increasingly proficient at whipping in the backhand manner. Many backhand strikes can be equated in force with forehand strikes.
Australia’s current whip rules are not best international practice when benchmarked against other major racing jurisdictions. Racing is accountable for the highest standards of animal welfare, in line with community standards. Community standards require a new regime of whip usage which is tailored towards principles of horsemanship rather than punishment. Australia has an international reputation for leading the world on animal welfare issues and we want to maintain it”.
An RA Media Release on 23 October 2015 further explained:
“In respect of Australian Rule of Racing AR. 137A., the Board has decided:
To remove the distinction between forehand and backhand whip strikes so that there is a limit of five forehand or backhand whip strikes prior to the 100 m.
To introduce stronger penalties for whip offences including greater emphasis on suspensions for serious breaches and for breaches in Group and Listed races.
The rule changes are largely an extension of the whip reforms of 2009. The changes to the whip rules in 2009 introduced limits on the number and manner of whip strikes which in conjunction with a padded whip has ensured the welfare of the horse.
However, too great a reliance on the backhand application of the whip has developed in response to the limits imposed on the forehand application. After careful consideration, the Board decided that backhand strikes should be treated in the same way as forehand strikes so as to leave no room for misinterpretation of the rules against excessive use”.
Unfortunately, the 2015 reforms do little to assist interpretation of what constitutes excessive/unnecessary/improper whip use (Code 6-AR 137A. (3)), including in the final 100 m. While whip rule reforms were much needed, it is also unfortunate the reform process was not evidence-based, more transparent, and inclusive to stakeholders including scientists, welfare groups, and the community. What the reforms tell us, though, is that our 2013 data very much underestimated the true extent of whip use prior to the 100 m mark, because backhand strikes were excluded. This is concerning, especially as McGreevy et al. [9
] found that while the forehand versus backhand action does not influence the force on impact when using the non-dominant hand, when using the dominant hand, the jockeys in the study (using a model horse), struck with more force in the backhand.
We briefly reviewed the fines and suspensions imposed in the first four months of 2016 with those in the similar 2013 period in NSW/ACT, given RA’s 2015 pledge to introduce stronger penalties for whip offences. We found there were four suspensions (range 7–10 days) and 35 fines totalling $9400 in 2013, and in the same period in 2016, there were 15 suspensions (range 4–21 days) and 115 fines totalling $42,650 [20
]. It is beyond the scope of the current study to consider this in detail, but given the increase in the number and $ value of fines, and the number and length of suspensions, these data should be examined further. While RA has been very vocal in justifying the higher penalties it imposed at this year’s Autumn Racing Carnival [44
], industry reporter Adrian Dunn wrote that for this period “NSW—which has held more meetings than any other state—is not facing the same issue as Victoria and Queensland. While NSW has issued more whip-infringement suspensions (12) than Victoria, it has delivered only 99 fines—less than half that of Victoria” [45
On 24 June 2016, RA announced a review of the new whip rules since their introduction last December [46
]. Hopefully, this will examine the reasons for the cited jurisdictional differences above, as well as evaluate whether the reforms have achieved the intended outcomes, which presumably include rectifying the assessment that Australia’s whip rules, prior to the reforms, were “not best international practice” [42
Based on our findings from 2013, when the whip rules were the same as they were immediately prior to the December 2015 reforms, there is a case to argue that a review of all the whip rules is warranted, and not just those pertaining to whip use prior to the 100 m mark. Any review should be science-based and include independent comparison with the UK where, unlike Australia, the total number of whip strikes is restricted. Nonetheless, the increased number of fines and suspensions in the 2016 period may indicate a step toward better regulation of whip use and welfare, even if it is just that backhand strikes are now being penalised.
Knight and Hamilton [47
] stated in relation to the UK Review that “The conclusion that the whip contributes to rider safety has important implications under Australian Work Health and Safety legislation and therefore affects the ability of racing authorities to change the rules relating to whip use”. We argue this makes it all the more important that studies that direct policy and regulatory change are based on peer-reviewed studies using race data, much of which are already being collected by industry. Some whip use information is not currently available, but must be if properly informed decisions are to be made about the use of whips in racing. In 2012, McGreevy and Ralston raised the case “for publication of the numbers of official whip strikes per horse per race, a move that is likely to increase transparency in the activity of stewards” [39
Further, in her paper “Sustainability, thoroughbred racing and the need for change”, Bergmann wrote: “Improving transparency and regulation is important and can improve welfare outcomes, if transparency and regulation go beyond the aim of protecting the integrity of the race and shift the focus on protecting the horse” [10
]. Similarly, in their paper “Science alone is not always enough; the importance of ethical assessment for a more comprehensive view of equine welfare” [11
], Heleski and Anthony quote Grandin’s saying that it is easy for “bad to become normal” [48