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Thursday, April 9, 2009

Timing is Everything...

It's the skeptic in me, I promise. Granted, I do have some pretty good instincts when it comes to things like accreditation, based on my 23 years of being an auditor and participating in certification of standards. The big announcement came down today from the hallowed halls of Lexington's finest trade group that Churchill Downs has received FULL accreditation from the NTRA Safety and Integrity Alliance. Now, first, let me go on record to state that I think that the Code of Standards ("the Code") they have put together, and first circulated to the member tracks seeking accreditation on February 25th of this year, is an EXCELLENT document and that the end result is one worth striving for and the Code itself is a positive step for the safety of the racehorse.

BUT, wait for it, here it comes....

I just don't buy that CD could become FULLY accredited in less than two months. Let alone before their spring meet even takes place. This smells of wanting the timing of the release to coincide with the runup to the Derby when the sport is on the front burner....but that's just me. Being someone who has certified companies to a rigorous standard (and one that was newly designed), I can tell you that Rome doesn't get built in a day (or two months for that matter). Of course, the definition in the Code for full accreditation is that Members must satisfy "substantially all conditions.....provided Member continues to adhere to Alliance standards during that time period." The key word in that definition being substantially, which does not constitute ALL. It begs the question, "Were ALL of the conditions met, or were substantially all the conditions met?

I was actually surprised to hear that CD achieved full, and would have expected "provisional" or "probationary" accreditation (as defined on page 4 of the Code) wherein certain future implementation or a curing of deficiencies would be necessary. If the accreditation was truly a rigorous audit, I would think some findings or deficiencies would have been noted, of course this wouldn't have made such a public relations splash. Some of the conditions (yeah, i read the doc) require reporting, and CD has not conducted a meeting since the Standards were released, so I wonder how they could prospectively test for compliance? For example, Standard 1A states that upon adoption of this Code, Member shall immediately commence reporting injuries sustained and fatalities suffered at a Racetrack Members' racetrack(s) during any Race Day. Are they retroactively testing for the these items? I would think this would put you in a provisional category, pending the CD spring meet reporting requirements? You?

They call former Governor Thompson, an independent monitor, but is he really independent when he works for the NTRA? I do commend them for using non-NTRA personnel such as Jennifer Durenberger, DVM and racing official Richard J. Lewis to conduct part of the review, I assume neither has a dog in the hunt.

Typically when testing for compliance to a standard you have two main thrusts to test. One being approach and the other being deployment. Approach is typically defined as the processes, practices and procedures used to meet a standard. This, I would think could be easily audited and/or tested and I would venture to guess are in place at Churchill. Deployment is how extensively these approaches are used or implemented in practice. This is where I question how they could grant full accreditation when the spring meet commences on April 25th. Could they actually be testing data prior to the actual adoption of the Code in February? Seems odd to me.

I sure would love to get my hands on the report, it would probably answer a lot of the questions posed here, but I just have to question the timing.

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