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TIF Examines Changes Suggested By Horseracing Integrity And Safety Authority

Many across racing might be wondering how American horse racing under the Horseracing Integrity and Safety Authority (HISA) could change.

To date, there are many questions and relatively few answers.

But two recent interviews with Dr. Tessa Muir, director of equine science for the United States Anti-Doping Agency (USADA), offer a glimpse into a possible future for the sport.

The suggestions Muir makes, while understandably qualifying that it is far too early to assess USADA's exact role with HISA given the lack of a contract between the two and no rule base in place just yet, are concurrently exciting and ground-breaking for American racing.

While there is much to be determined, one thing is certain: if Muir's early suggestions are close to the reality of USADA's likely involvement as HISA's enforcement agent, American racing is due for seismic changes, even if those are not fully in place by July 2022 when HISA is due to launch.

The Thoroughbred Daily News published the first piece on Aug. 29. Dan Ross posed several thoughtful questions to Muir about USADA's role, a focus on adopting a transparent approach to testing and results, and how their execution of anti-doping measures in human sports might translate to racing.

“It's probably a little too early to delve into specifics. There are things we've discussed with the Authority. If you take USADA's example of what there is with human sports, you can search any individual athlete by name, and you can see how many times they've been tested within that breakdown.”

“You can also look to other racing jurisdictions where they already publish some of this data, such as in Racing Victoria. After the race day, they publish a report on what horses got tested, pre-race and post-race.”

Using the example of Melbourne Cup Day in 2020, blood was drawn from 38 horses before racing (to be analyzed after the race), urine was drawn from six more and post-race samples from every race winner, along with the second and third finishers in the big race.

As it stands in U.S. racing now, few stakeholders know which horses are tested, with the exception of race winners. A ledger of out-of-competition tests is not available. Muir gives the impression this will change under USADA's role in HISA.

“There's a need for transparency in competition–for race day and in the out-of-competition component. If you look at USADA's history, they've been huge advocates for transparency and for sharing testing data.

“If you look on their website, you can search for an individual athlete and see how many times they've been tested in a year or in a quarter, which I think is a really positive thing.”

“On the equine side, we definitely want to publish testing data. I think there's a balance–you want to publish and be transparent to the point it doesn't compromise the integrity of the independent testing program you've got in place.”

The status quo, however, has been far different.

In a recent court filing (see page 16 of the document), prosecutors from the Southern District of New York argued indicted Standardbred trainer Nick Surick entered horses in races where he believed post-race testing would not be done for substances which he used in his horses.

Natalie Voss from Paulick Report drew attention to transcripts in the recent filing which indicated the indicted trainers may have been tipped-off, regularly, by track security staff of possible searches.

Knowing which horses are tested, when and how often is a crucial step towards improving overall confidence in the sport.

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Three days following the publication of Ross's Q&A with Muir, she outlined more of the possibilities in an interview with Ray Paulick, citing USADA's “whereabouts” program which requires human athletes to report their daily schedule, enabling doping control officers to locate them for out-of-competition testing.

This would revolutionize testing in American racing, and require tremendous administrative attention from trainers and their staffs. Muir's remarks on this topic, to Paulick, are below:

“The intent of the (federal law) is that horses are accessible at any time at any place from the point of their first workout until they retire from racing. In order to conduct that 'no-advance-notice' testing anywhere at any time, you need whereabouts information in order to find the horse.

“That really is a critical underpinning for prevention, deterrence and detection of misuse of substances. Whilst specifics of how that may look are currently not finalized, if you look at any good anti-doping program in the world, whereabouts is a really key component. And that requires locations, not just while horses are in training but when they are in other locations resting or pre-training.”

USADA's “Whereabouts Policy” details the degree of specificity required by human athletes to ensure they can be located for testing.

Athletes must submit accurate contact information, providing a full schedule including “each location where the Athlete will train, work or conduct any other regular activity (e.g. school), as well as the usual timeframes for such regular activities.” In addition, they must identify one hour each day between 5 A.M. and 11 P.M. “during which the Athlete will be available and accessible for Testing at a specific location.”

Complete details of every overnight location must be provided on a quarterly basis, delineated by day. Any amendments to these plans must also be filed. The Whereabouts Policy document notes:

“The athlete must provide sufficient information to enable a doping control officer to find the location, to gain access to the location, and to find the Athlete at the location. For example, declarations such as 'running in Rocky Mountain National Park' are insufficient.”

Failure to comply with USADA's entire “doping control process” for human athletes can lead to suspensions of up to four years “and other consequences.”

In 2013, track and field athlete Trey Downing was suspended for 18 months for failing to provide a sample at a doping control officer's request.

In December 2020, UFC athlete Yair Rodriguez was suspended for six months for violating the UFC's Anti-Doping Policy by accruing three “Whereabouts” failures in each of the first three quarters of 2020. According to the release of the sanction, “Rodriguez was eligible for a reduction in the period of ineligibility because his conduct did not raise suspicion that he was trying to avoid being available for testing.”

Introduction of such a policy across American racing is difficult to comprehend given the status quo and will leave HISA and USADA, not to mention trainers, with a mountain of administrative work to assure compliance over time.

The recently released transcripts of conversations from trainers Jorge Navarro and Jason Servis, as well as veterinarian Kristian Rhein and other indicted individuals highlight the importance of doping control agents having routine access to horses, and this includes knowing where all horses are supposed to be at all times. Navarro and Rhein both pled guilty in August and are due to be sentenced in December.

In one of the wiretapped calls from June 5, 2019, Servis tells Rhein that testers, presumably from the New Jersey Racing Commission, were looking for Sunny Ridge at Monmouth Park on June 3, more than a week after he won the Salvator Mile (G3) there. Servis told Rhein that the horse was not there, but at Belmont. He then wonders incredulously why the testers took a sample from a juvenile that had not run well.

Standardbred trainer Nick Surick hid horses to evade out-of-competition testing, according to a recent filing in the case by prosecutors. Paulick Report posted the full filing and it can be accessed here (Surick evasion details are on page 17 of the document).

Whereabouts policies, and penalties assessed for failures to comply with them, increase the difficulty of evading detection.

A national voice leading a unified effort to educate horsemen on a single set of rules has not been a feature of the American racing landscape.

New rules and new procedures will require outreach the likes of which the American racing industry has not witnessed previously. USADA offers a series of documents which outline the polices and procedures of their anti-doping control programs – some for athletes, coaches, health care professionals – and include details of testing and results management, rights and responsibilities, whereabouts and whistleblower policies, investigations principles and more.

Dr. Muir told Ross “the education component of any anti-doping and medication program is a foundation to the success of the program. There's a variety of ways to actually deliver that information in an effective way. Something we'll be looking to is [to have] a level of education in place ahead of the first of July 2022.”

While acknowledging that nothing has been developed as of yet given the lack of rules, USADA's expertise in communicating policies and procedures is well-established.

Muir acknowledged USADA is cognizant of the need to produce materials in Spanish and that outreach efforts goes well beyond just trainers.

“There are a lot of parties beyond just the trainers and the grooms who touch these horses on a day-to-day basis, and therefore, we want to be in the best position possible to give people the tools to comply with the rules.

When HISA begins to operate, with USADA as its expected enforcement agent, there is no expectation that all of the elements of the programs Muir outlined are fully operational.

“Achieving what she calls a 'gold standard' program will not happen overnight,” wrote Ray Paulick. “Muir puts an 18- to 24-month timeline on that goal.”

Among the education efforts, Muir notes that participation from the industry, including via anonymous tip lines, will be needed to supplement formal efforts to maintain an improved sport. A USADA-administered tip line won't be racing's first – but it will be the first under a new, unified rule set, and one run by an organization with actual, nationwide control.

“The testing investigations comes under the responsibility of the enforcement agency (presumably USADA), but the tip lines and other things must have industry ownership,” Muir said. “When it comes to the responsibility for clean racing and preventing, deterring and detecting people who might be doing the wrong thing, it's the responsibility of the whole industry to call that out and prevent it and to stand up for clean racing.”

Undoubtedly, the question of cost comes into consideration.

A robust approach to anti-doping efforts in American racing will be more expensive under HISA than the present. But Muir told Ross that the current state-by-state approach has made it challenging to understand how much is spent at present on these efforts, making future cost projections all the more difficult.

“I think one of the challenges at the moment is that there's not any one currently accepted understanding of what the total cost and total amount currently being spent is. So, getting a handle on that is quite difficult to know: How is it going to be more expensive, and by how much?

“As the [HISA] chairman [Charles Scheeler] alluded to at the [Jockey Club] Round Table, he said publicly that they anticipate the costs are going to go up, and of course, that's to be expected for an enhanced and more effective program of the scale we're looking at here.

“It's a comparatively small investment–I'm not saying it's necessarily a small amount of money, not to belittle the amount–but a comparatively small investment in protecting the fairness of clean racing for all our horsemen and obviously the health and welfare of the horses and the longevity of the sport in the future.”

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Letter to the Editor: Bryan Langlois DVM

I, like everyone else who has seen it, was utterly disgusted with not only the video depicting the actions of trainer Amber Cobb against one of the horses but also the almost complete ignorance of the Delaware Racing Commission in reducing her suspension for those actions. How this industry continues to manage to shoot itself in the foot repeatedly is just mind boggling to me. Actions that are as heinous as those displayed by Ms. Cobb require only one action, and that is immediate revocation of her license to train horses anywhere in this industry (or any other equine industry for that matter).

Why it seems so hard for Commissions to do the right thing in banning these bad actors for life is something I will never understand. I am a veterinarian licensed in the Commonwealth of Pennsylvania. If a video surfaced of me committing those acts, I would not have my license suspended for months or even two years. It would be gone permanently in a heartbeat, and I likely would not have the ability to obtain one in any other state in this country.

What occurred in that video is blatant animal cruelty (something I have been involved in assisting the prosecution of for the last 15 years). It can be looked upon as nothing less and should be dealt with accordingly by both law enforcement and the Racing Commissions. Sadly, that did not happen in the case of the decision of the Delaware Racing Commission.

HISA, if and when it is finally in full effect, will hopefully put an end to this concern once and for all. In the meantime, just because an issue like this occurred in one state does not mean other states that she is licensed in cannot act on their own. Every state in which Ms. Cobb is licensed needs to start the process of immediate revocation of that license. I am fully aware of a person's due process rights and what can happen when racetracks or commissions take away those rights via their actions in some suspensions (the NYRA Bob Baffert case for example). I am also aware that anyone who is accused of or charged with a violation of any kind is entitled to their full due process. I urge the Commissions to due their proper investigation and due diligence on this case, and then render their decision quickly. To me, the only decision that it can be is immediate and permanent revocation of the license.

Another thing I have learned over the years is the true power that we as the public can have in matters before a racing commission. I learned this after the intense pressure put on the PA Racing Commission by so many to get the license of the trainer of a horse named “Silent Ruler” permanently revoked after the horse was found in a state of severe pain and neglect from a non-attended to sesamoid fracture. Therefore, I urge everyone who sees this letter to please write into or contact your State Racing Commission and politely but firmly urge them to not allow this cruelty to continue by revoking Ms. Cobb's license to train horses in that state if she holds one and to not consider granting her one if she does not.

We hear all the time how Commissions and those in the industry want to bring back integrity to the sport. The Delaware Racing Commission has failed miserably at this. It doesn't mean that others must follow that lead.

Bryan Langlois, Past President, PVMA, Board Member, ThoroFan

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USADA’s Dr. Tessa Muir: Industry Confidence In Anti-Doping Program Key Element To HISA Success

How will equine medication rules and enforcement be different once the Horseracing Integrity and Safety Authority becomes the federally mandated regulatory body for Thoroughbred racing next year?

For starters, for the first time, regulations related to medication, testing and enforcement will be uniform in every racing state. That's a tremendous achievement in itself.

Efforts to form uniform rules go back decades to the days of the National Association of State Racing Commissioners (predecessor of the Association of Racing Commissioners International). There has been incremental progress, through development of model rules that only went into effect if individual state racing commissions and sometimes legislators bought into them. Too often they didn't adopt them as written.

The enabling legislation creating the Authority, the Horseracing Integrity and Safety Act, overcomes those hurdles. The Authority is a non-governmental agency that will have federal oversight from the Federal Trade Commission, especially in its formative stage. Prior to July 2022, when the Authority is scheduled to be operational, the FTC will be required to accept, reject or amend the rules that the Authority is now developing to regulate medication and safety policies.

Dr. Tessa Muir, who joined the United States Anti-Doping Agency as head of its newly created equine program earlier this year, is part of the team developing those regulations. While USADA does not yet have a contract with the Authority, it's fully expected that it will be the agency named to that position, enforcing anti-doping policies in much the way it does for athletes in the Olympics, Paralympics and UFC fighters from the world of mixed martial arts.

Muir has worked as a regulatory veterinarian with Racing Victoria in Australia and before then spent six years with the British Horseracing Authority as a veterinarian assistant and anti-doping manager.

“We are diligently working with the Authority,” Muir said in an interview with the Paulick Report. “The core rules that we are developing will form the basis of the program. Implementation is that final step in bringing HISA to reality.

“Alongside the rules,” Muir added, “we are working with the Authority and hope to have a contract in place with them ASAP.”

In parallel with development of medication regulations, which will lean heavily on existing guidelines from the International Federation of Horseracing Authorities and the Association of Racing Commissioners International, Muir said USADA and the Authority are also working through a business model to determine staffing or contract labor needed to enforce its program. Among other things, there will be a need for investigators and what USADA refers to as doping control officers.

“One of the really great things with combining USADA and its human side with its equine side – assuming we do have a signed contract with the Authority – is that there will be some crossover between what goes on in the human world and the equine world,” Muir said. “Clearly, there are a lot of things that are also different, but again, where possible, we'll be trying to leverage resources sensibly to make it as streamlined as possible.

“What we are looking to do is to take the best elements from good anti-doping programs, whether they be equine or human, and create consistent, thorough and robust rules that fit the U.S. Once we have those rules, we can enforce them to ensure clean racing, the health and welfare and long-term soundness of our equine athletes.”

USADA and the Authority will also need to establish laboratory standards and an accreditation program before determining which of the existing drug testing laboratories will be utilized. While laws in some racing jurisdictions currently require testing to be conducted at in-state university labs, the assumption is that the enabling federal legislation will supersede such state laws.

Muir said post-race sampling will continue to be a part of a USADA anti-doping program, but it's obvious a significant focus will be on out-of-competition testing. Achieving what she calls a “gold standard” program will not happen overnight. Muir puts an 18- to 24-month timeline on that goal.

“A lot of it relates to collection of the data and to have a smart testing program, whether that be in or out of competition,” Muir said. “You have to develop the technology and the information and intelligence from the investigations to form that big picture on how you conduct testing.”

Muir describes best practices out-of-competition testing as an “anywhere, anytime”program that will be accompanied by a “whereabouts” requirement. That means the location of horses may need to be reported to the Authority or to USADA at all times so that surprise visits by doping control officers may take place.

“The intent of the (federal law) is that horses are accessible at any time at any place from the point of their first workout until they retire from racing,” Muir said. “In order to conduct that 'no-advance-notice' testing anywhere at anytime, you need whereabouts information in order to find the horse. That really is a critical underpinning for prevention, deterrence and detection of misuse of substances. Whilst specifics of how that may look are currently not finalized, if you look at any good anti-doping program in the world, whereabouts is a really key component. And that requires locations, not just while horses are in training but when they are in other locations resting or pre-training.”

Muir said testing is not the only way to catch violators, since some substances can be very difficult to detect.

“When you look at blood doping agents or illicit substances, it's not just things like EPO that are potentially difficult to detect,” she said. “There are other substances such as insulin, which have relatively short detection windows but potentially a much larger window for effect.

“In general terms, detection of a prohibited substance in a sample is only one of a number of different anti-doping rule violations. That detection isn't necessarily the only way to determine that someone has broken the rules.”

Muir listed anonymous tip lines as an important tool, though realizes that racing, like other sports that have struggled to control performance-enhancing drug use, there seems to be a de facto code of silence among many participants.

For that to change, Muir said, the industry will need to buy in to the principle that clean racing is better for everyone.

“The testing investigations comes under the responsibility of the enforcement agency (presumably USADA), but the tip lines and other things must have industry ownership,” she said. “When it comes to the responsibility for clean racing and preventing, deterring and detecting people who might be doing the wrong thing, it's the responsibility of the whole industry to call that out and prevent it and to stand up for clean racing.”

Muir admits that won't happen if the industry lacks confidence in USADA and the Authority.

“People have got to have confidence in those enforcing the rules, that they are acting on and doing the right thing,” she said. “I've had a lot of respect for USADA for a long time: that voice for the clean athletes and those doing the right thing. On the equine side it's the same proposition: standing up for the good people who are doing the right thing. They need to have trust that those enforcing the rules are going to help stand up for their rights.”

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Q&A with USADA’s Dr. Tessa Muir

Last month, the United States Anti-Doping Agency (USADA) announced that in Dr. Tessa Muir, it had plucked from foreign shores a new hire to head its equine program at a time when the agency plays an integral role in implementing the Horseracing Integrity and Safety Act (HISA), overhauling the industry's governing status quo.

Before Muir joined the USADA staff roster, she had hopscotched her way up the industry ladder, from exercise rider to private veterinarian to head of the British Horseracing Authority (BHA)'s anti-doping program between 2013 and 2019. Her last position was as a regulatory veterinarian in Australia, for Racing Victoria.

Currently in the process of earning a master's degree in sports law, Muir faces an even tougher task in bringing to life the enforcement arm of racing's new regulatory framework. That's because there's much to do within a worryingly short amount of time.

Though the official implementation of HISA is set for July 1 next year, a baseline set of uniform rules–medication standards, laboratory testing accreditation rules, and racetrack safety accreditation standards–need to be squared away by the end of the year in order to meet tight administrative deadlines.

What's more, it's still unclear exactly who the enforcement agency will be when the law goes into effect. “No final agreement on USADA's involvement as the enforcement agency is currently in place,” Muir said, in a video presentation for the recent The Jockey Club Round Table Conference.

For her part, Muir tipped her hat during the Round Table to the “enormity of the task” ahead of her, saying that “USADA and myself personally are absolutely committed to our role in the inception of HISA, whether that ultimately sees USADA running the program, or contributing its expertise to the development of harmonizing rules and best practices in anti-doping.”

The Horseracing Integrity and Safety Authority–the broad non-profit umbrella established by the law and commonly referred to as just the “Authority”–is expected to unveil important program specifics at an unspecified date this fall.

To try to elicit some details before then, the TDN this week sat down with Muir. The following has been edited for brevity and clarity.

Coady

DR: What's your initial takeaway from these first few weeks on the job?

TM: I actually started with USADA in April, so, I've been working with them for a while. The first month here [in the U.S.] has been a little bit of a whirlwind getting settled into a new country.

I've been really excited and encouraged by the engagement we've had with the people we've spoken to. Of course, we've started working with the Authority and their anti-doping and medication control committee, and then, I spent a week in Saratoga leading up to the Round Table, spending time with their state commission vets and the racetrack vets.

We've had our head down working really hard to deliver on some of the other things we need to. There are some challenges that are not unsurmountable if everyone works together and collaborates.

DR: Okay, so when it comes to HISA, given how we don't yet know who will run the enforcement arm of the law, what can you tell industry stakeholders looking at the ticking clock and worrying about the current lack of available specifics?

TM: As I've alluded to, we've got our heads down working really hard with the Authority to develop a set of rules. As you'll have heard, with what the chairman of the Authority [Charles Scheeler] said, the intention is that they'll be ready for socialization to the industry this fall.

HISA passing is the first component of it. The development of these rules and regulations is the second part. Then [comes] the specifics for USADA, and USADA becoming the enforcement agency.

I think we're all keen to get there ASAP. Of course, the rules go into effect on the first of July next year. But as you and the industry can appreciate, there are a number of things to work through given the expanse of the program for it all to come together.

Coady

DR: How well placed is USADA to manage what would appear a significant increase in testing volume, even if it's just in an oversight role? Does it have the necessary personnel?

TM: The intent is not to totally reinvent the wheel. There are good practices in place that can be leveraged. We will look to utilize existing infrastructure–for example, in testing barns where it's possible.

I think something else that comes into the mix is how technology might play a key role in running the program. To some extent, when you look at USADA's team, they've begun to expand the team to administer the program. But certainly, there's going to be a need for people who can leverage the existing structures.

DR: When it comes to HISA's approach to the public reporting of testing, what can we expect? Will there be greater transparency concerning all horses who are tested and not just the positives, for example? How will you approach the reporting of out-of-competition testing?

TM: There's a need for transparency in competition–for race day and in the out-of-competition component. If you look at USADA's history, they've been huge advocates for transparency and for sharing testing data.

If you look on their website, you can search for an individual athlete and see how many times they've been tested in a year or in a quarter, which I think is a really positive thing.

On the equine side, we definitely want to publish testing data. I think there's a balance–you want to publish and be transparent to the point it doesn't compromise the integrity of the independent testing program you've got in place.

DR: Are you able though to talk about what you think may be made public?

TM: It's probably a little too early to delve into specifics. There are things we've discussed with the Authority. If you take USADA's example of what there is with human sports, you can search any individual athlete by name, and you can see how many times they've been tested within that breakdown.

You can also look to other racing jurisdictions where they already publish some of this data, such as in Racing Victoria. After the race day, they publish a report on what horses got tested, pre-race and post-race.

Coady

Without saying we've landed on a specific final picture of what it might look like, I think that gives you a nice example of where there are standards already set where we can look and say, 'Where can we expand on that to give the public transparency?'

Note: Click here for USADA's athlete test history database.

Click here for an example of a Racing Victoria post-race day stewards' report.

DR: You said in your Jockey Club Round Table presentation that it'll take a while before USADA's “gold standard” anti-doping infrastructure will be implemented. What kind of timetable are you envisaging?

TM: We've got the first July deadline for next year. We need a program in place that's robust and covers the essentials. One of the big bits are the rules that need to be in place to get that uniformity. Looking forward, maybe it'll take 18 to 24 months to reach that gold standard of our independent program.

You've got to look at developing laboratory standards and their capabilities, the intel and investigations of course take shape over time, and a smart testing program similar to what USADA use in their human world–you've got to develop that data to drive that forward. And again, we'll be looking at technology as one of the key components to finesse that program.

As is the case with the human program, things never stand still. We work hard every single day to continually improve and adjust and refine the program.

DR: You use that 18-month timeframe. On a very practical level, what tangible differences can industry stakeholders expect to see between implementation on July 1 next year and then 18 months from then?

TM: The real tangibles you'll see on day one is the uniformity in the rules and some of those basic interactions and processes.

The development is still to be determined in many ways–as much as we can get in on day one the better. But of course, things like the smart testing program and refining how you select horses for testing, and the things you learn as you collate and collect data, it will of course evolve over that period of time.

Getting all the laboratories to a baseline and then developing that side of it–that's probably not the front-facing side of it, it's probably the development and the refinements behind the scenes.

The labs are really good ones to look at because developing new methodologies, investigative equipment and all that kind of stuff, takes time, and so, we're looking at: What do we need on day one for the program to function as a robust program? And then, how can we look to develop that going forward?

Coady

DR: Anti-doping deterrence costs money, and I think it's fair to say the financial component is of central concern to most stakeholders. What specifics can you share about what they can expect when it comes to costs, and specifically anti-doping deterrence and prevention costs?

TM: I think that's slightly two questions. The prevention and deterrence side is multi-factorial. It's not an isolated area. We've got education, out-of-competition no-notice testing, tip lines and investigations.

It's not an expensive cost per-se developing those rules and having those consistent results management arbitration processes–sanctions that deter those bad athletes. That covers deterrence and prevention as a whole.

On the question of the cost, that's probably the number one question that everyone asks. I think one of the challenges at the moment is that there's not any one currently accepted understanding of what the total cost and total amount currently being spent is. So, getting a handle on that is quite difficult to know: How is it going to be more expensive, and by how much?

As the chairman alluded to at the Round Table, he said publicly that they anticipate the costs are going to go up, and of course, that's to be expected for an enhanced and more effective program of the scale we're looking at here.

It's a comparatively small investment–I'm not saying it's necessarily a small amount of money, not to belittle the amount–but a comparatively small investment in protecting the fairness of clean racing for all our horsemen and obviously the health and welfare of the horses and the longevity of the sport in the future.

As far as what the actual dollar amount is, as [Scheeler] said, that's still being worked on at the moment. It's hard not having that really clear-cut number on what's currently being spent. There's money being spent in a lot of different areas currently.

DR: When it comes to the everyday adjudication of medication violations, Jockey Club vice chairman Bill Lear told me recently there'll likely be a tiered approach in the beginning, with the severity of the infraction governing which set of regulatory personnel–either the state's or USADA's–will handle the hearing. Could you elaborate on that?

TM: From a top-level look at it, the results management and adjudication process will come under the banner of the enforcement agency, so assuming that is USADA, USADA will be responsible for any of the anti-doping rule violations that occur.

As [Lear] alluded to, certainly looking at a tiered approach for that. The specifics will be made a lot clearer when the socialization process happens with the industry.

Sarah Andrew

DR: Obviously, a key issue with the current status quo is the glacial pace at which violations are adjudicated. Do you see a scenario whereby that process is expedited come July 1 next year?

TM: The intention is to have a streamlined process, but of course, there is the [matter] of due process, and that's something that is probably better answered by someone [in the] legal [department]. Obviously, we have a legal team at USADA that deals with the human side. The processes and the streamlined nature of that will become more evident when the arbitration procedures and the rules are socialized in the fall.

DR: One of USADA's big selling points is its educational programs for human sports. What will HISA's education outreach look like for racing? And how will you make sure everyone in the sport–irrespective of language barriers–gets access to the necessary information?

TM: You've made a great point that the education component of any anti-doping and medication program is a foundation to the success of the program.

There's a variety of ways to actually deliver that information in an effective way. Something we'll be looking to is a level of education in place ahead of the first of July 2022, because people will need to understand what the new requirements are. And of course, some of that will be developed beyond that.

The point about language is a really good one. That's something we're cognizant of as we look to start developing and creating education materials, ensuring that those people who need to be communicated with, and to engage with the process, can do so.

There are a lot of parties beyond just the trainers and the grooms who touch these horses on a day-to-day basis, and therefore, we want to be in the best position possible to give people the tools to comply with the rules.

DR: Have you started putting these materials together?

TM: Specific materials? No. First of all, before you can design educational materials, we need rules that we can educate people on. And so, at the moment, it's not our number one priority.

But as far as concepts and looking at good ideas–I've certainly done a few of the USADA education tools online to get an idea of some of the things that might be great to leverage.

Read part one and part two of our recent series digging down into the particulars of HISA.

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