Illustration: Matt Golding
The Australian Rugby League Commission will receive a report on December 11 detailing an investigation into drug protocols at the NRL's 16 clubs and may table recommendations on sanctions against clubs, coaches and medical and training staff who have breached anti-doping rules.
If so, the ARLC could be expected to announce any bans and punishments before Christmas.
The investigation has been headed by the new general manager of integrity and general counsel, Nick Weeks, a lawyer recruited from the Australian Rugby Union.
The December 11 ARLC board meeting will be its last for the year, with chairman John Grant anxious to finalise the code's governance issues.
Should there be any bans against coaches and head trainers, requiring the appointment of new club staff, the ARLC would want them to be in position before training resumes in the new year.
Weeks's questioning of clubs and officials has been independent of any investigation carried out by the Australian Sports Anti-Doping Authority.
ASADA and the NRL were jointly involved in interviews with players but the two organisations reached a fork in the road with regard to investigations of support staff, with Weeks conducting his own inquiries.
The ASADA investigation into players is on-going, with infraction notices to be served when the anti-doping authority is confident it has compelling evidence.
NRL rules against clubs on anti-doping violations include fines to $1 million, suspended fines to $1 million, deduction of points (including those yet to be earned), a suspended sanction of points, exclusion from the competition and a deduction of financial grants.
While Weeks held interviews with all NRL clubs over doping procedures, the probe into the Cronulla Sharks was more detailed.
It followed a report, commissioned by the old Sharks board, following sensational allegations at an Australian Crime Commission press conference in February. The Kavanagh report found that 27 Sharks players could have prima face committed anti-doping rule violations between rounds two and 12 in 2011, being administered with two banned drugs, GHRP-6 and CJC-1295, via injection, creams and lozenges.
The board subsequently sacked four officials and stood down coach Shane Flanagan before reinstating him. Flanagan would be the most high-profile target for any action by the ARLC.
Flanagan's culpability, according to the Kavanagh report, began with him and trainer Trent Elkin informing the Cronulla players on the eve of a round two match in 2011 that the club was embracing a new supplements regime.
Sports scientist Stephen Dank was the architect of the new drugs plan, which he called a ''player welfare'' program.
It appears the staff of the under-resourced club made no steps to consult with ASADA whether the drugs were banned, or even approved for human use.
Only one Sharks official - checking the labelling on the drugs - recorded the names of these banned substances but did not check with ASADA until after the ''blackest day in Australian sport'' bombshell.
The Kavanagh report indicates Flanagan distanced himself from any use of the banned substances and states there is insufficient evidence for ASADA to issue an infraction notice against him.
Hypothetically, as head coach, the ARLC could charge him with bringing the game into disrepute in that he allowed Dank to introduce a program of banned drugs.
Flanagan was not party to the early email exchange when club officials first became concerned about Dank's activities.
He was told of the significant reservations of club doctor Dave Givney on April 6, 2011 and did act on May 29, 2011 when he attended a meeting of the club training and medical staff where it was resolved that Dank's services be instantly dispensed with.
The Kavanagh report claimed Dank threatened to sue if Flanagan said or implied he was involved in any wrong-doing.
Because Cronulla did not have a chief executive in 2011 and had limited resources to assist a coach to fight a charge of defamation, this may have inhibited Flanagan from reporting this to his board, or the NRL. Should action be taken against Flanagan, comparisons are inevitable with the one-year suspension the AFL handed Essendon coach James Hird after their joint investigation with ASADA.
If Flanagan received the same ban, it could be perceived as harsh.
While both coaches were inexperienced in the role and hired Dank on the recommendation of their trainers, Essendon's injection program lasted a year, compared to Cronulla's five weeks.
Hird continued to support the off-site program of multiple injections, despite early protests from the club's doctor who became marginalised.