The draft Canyoning Good Practice Guide (“the Guide”) has been released under the Australian Adventure Activity Standards (AAAS).  Feedback or submissions on the document are due by 12 November 2018.  

 

While the standards are currently voluntary, they can be adopted by land owners, regulatory agencies such as National Parks and Wildlife Services, insurers, etc.  They are also a bar against which a Court or Judge can compare a provider’s or leader’s negligence. 

 

The Guide is clearly written by and intended for commercial providers, yet it applies to Clubs and any recreational trip with dependent participants.  Most club members on a canyon trip would be considered dependents under the Guide.   

 

Whilst the Guide is not legally binding at present, we can foresee a time when canyoning will be so popular that a permit system will be applied to many of our most visited canyons, like Empress and Claustral.  If this document was enforced by National Parks and Wildlife Services for example, no Club trip would meet the standards for us to be able to visit these natural beauties freely.  Canyoners would have no other choice but to pay a commercial provider to attend these canyons.  For example, to comply with them the Club would be required to own, maintain, store and retire all the equipment used on canyoning trips such as harnesses, ropes, descenders, carabiners, etc.  Leaders would have to be qualified in various units / courses and know the canyon being visited beforehand.  It would effectively be the end of exploration and the bush would be covered in more unwanted red tape. This would of course be detrimental to every canyoner, member of a Club or not.  

 

We believe canyoners, recreational organisations, clubs and its members should oppose the Guide.  

We note that Bushwalking Australia recently issued a policy opposing the Bushwalking AAAS  (link:http://www.bushwalkingaustralia.org/images/docos/Policies/Bushwalking_Australia_Policy_-_AAAS.pdf)   

 

The same would be a desirable outcome from Clubs and Associations regarding the Canyoning Guide.  

 

Commercial providers have a higher duty of care to their paying customers than volunteer groups.  The Guide should only apply to them.  

 

Below are Craig Flynn’s and my submissions on the Guide.  If you agree with our objections, please copy (amend if you like) and paste the submissions in an email to: info@australianaas.org.au (RE: Submissions on the Canyoning Good Practice Guide) 

Here is the link to the full Guide: 

http://yoursay.australianaas.org.au/canyoning/?fbclid=IwAR2uj3ucSIj33Ij60KBcqZ7q87VxfpSEhREHu0Bydg_zi97Voh5OmSGXKms

http://yoursay.australianaas.org.au/canyoning/wp-content/uploads/sites/10/2018/10/Canyoning-GPG-v1.0-public-consult.pdf

SUBMISSIONS 1

 

It would be extremely difficult, daunting and in some cases even impossible for volunteer groups such as Bushwalking Clubs to comply with the provisions contained in the Canyoning Good Practice Guide.

 

The Guide has the following MANDATORY requirements for example: 

 

1)    Equipment MUST be checked that it is serviceable before each activity or before being used (Rule 6.5);

2)    Appropriate procedures MUST be in place for inspections (Rule 6.5);

3)    Equipment and inspections MUST conform with the law and regulations (Rule 6.5)

4)    Equipment MUST be stored with reference to the manufacturer’s recommendations or instructions (Rule 6.6)

 

Analysis:  On Club trips members purchase, provide and look after their own equipment, including storage. These provisions would be impossible to comply with.

 

5)      Requiring certain Competencies from leaders (Rule 7.2)

 

Analysis: Requiring accreditation in certain units or courses to lead a canyon could only apply to Commercial Activity providers.  Most clubs are constituted by volunteer hobbyists with no formal accreditation or qualification.  This requirement would make leading a canyon by a recreational group extremely difficult.  

 

6)    Requiring knowledge of the site (Rule 7.5.2)

 

       Analysis: This provision fails on 2 fronts for recreational groups:

 

   a)    It refers to factors the provider should consider when allocating activity leaders to a trip.  However, in Clubs the trips are organised or volunteered by the members and NOT allocated;

 b)    While commercial groups are expected to have previous knowledge of a canyon, recreational canyoning frequently involves exploration.   Again, this provision is an example of a requirement that cannot apply to a recreational group. 

 

7)    Unprotected climbing MUST only be used where the risk is acceptably low of a fall from height indicate the climb does not require the use of a fall protection system or spotter (Rule 7.6.3)

 

Analysis:  Many climbs in canyons in the Blue Mountains involve exposure and unsafe heights.  A fall protection system or spotter is many times not possible.

 

8)    To reduce the potential for falls from height, procedures MUST include designating what areas that are not to be entered (Rule 7.6.7)

 

Analysis:  Recreational groups would not be able to limit the members’ mobility in certain areas, even if unsafe.  

 

9)    Abseil belay systems MUST use at least one belay method to protect the abseiler if they lose control of the descent and the belay method used MUST be a releasable top belay system, unless other considerations indicate another belay method is more appropriate.(Rule 7.6.8)

 

Analysis:  Requiring a belay system on every abseil is very onerous.  Recreational groups may not belay the first person or use a top belay over a bottom belay in many instances.     

 

Conclusion:

 

An exclusion clause in the Guides would be appropriate, such as:

 

“The Canyoning Good Practice Guide does not apply to Independent (Non-Commercial) Participation in Canyoning Adventure Activities in NSW”  

 

By Gabriela Faura

 

SUBMISSIONS 2

 

 

If you rated the Good Practice Guide ‘I cannot support this’, please provide your reason:

The document is poorly worded (It’s “voluntary” but you “must”) with no scope to define exactly who it applies to.

“Dependent” and “Activity Provider” are grey terms which the document fails to clearly define.

It appears written by commercial interests for commercial interests. Under current legislation it would be unenforceable towards volunteers and recreational groups however I foresee a time when canyoning becomes so popular a permit system will be applied to the most popular canyons and this document could then be used as a minimum requirement by land-managers when issuing permits.

Unfortunately, several sections of the document become completely impracticable in a recreational or club setting which may then exclude such groups from obtaining said permits.

eg.

3.2 Canyoning emergency management plan. A documented emergency plan is impracticable for recreational groups. Specific clauses such as escape route mapping are not practical when exploring rarely visited canyons.

6.2.1 “Training in the use of equipment used MUST be provided to activity leaders and participants”. In my recreational group who provides this training to the leader and participants? This is clearly written towards commercial parties or youth groups/clubs offering skills instruction.

6.4.5 “A procedure regarding participant supplied equipment SHOULD be developed.” Completely irrelevant to recreational groups

“6.4.6 Rescue systems Anchor systems and belay systems MUST be rigged for a timely and effective rescue. Abseils that involve running waterfalls MUST use releasable rigging” Again, less practicable for recreational groups where the level of “dependence” is far less than in a commercial setting

6.5 Maintenance of equipment Again, completely impractical for recreational groups where each person is expected to look after their own equipment.

6.6 Storage of equipment Again, completely impractical for a leader of recreational groups where each person is expected to look after their own equipment

7.1 Naming conventions. This is clearly written towards commercial parties or youth groups/clubs offering skills instruction with no relevance to recreational groups.

7.2 Competencies. Completely irrelevant to recreational groups

7.4 Supervision ratios. Irrelevant to recreational groups

7.4.2 Supervision of belay systems Less relevant to recreational groups

 7.4.3 Assistant canyoning guides and supervision ratios Irrelevant to recreational groups

7.4.4 Single activity leader – all canyoning Irrelevant to recreational groups

7.4.5 Single activity leader – vertical canyoning Irrelevant to recreational groups

 7.5.1 Progression through a canyon Procedures MUST be used to reduce the potential of: This is clearly written towards commercial parties or youth groups/clubs offering skills instruction and completely irrelevant to recreational groups

7.5.2 Knowledge of site Completely irrelevant to recreational groups who may be doing an exploratory trip or visiting a canyon for the first time (whether using a guide book or beta from others). If this clause was in play previously canyons would not have been explored in the first instance.

7.5.3 Canyoning activity information for participants This is clearly written towards commercial parties or youth groups/clubs offering skills instruction and less relevant to recreational groups

7.6.5 Deep-water belays Procedures to assess the suitability and safety of deep-water belays MUST be developed and used. This is clearly written towards commercial parties or youth groups/clubs offering skills instruction. Procedures are completely irrelevant and impracticable to recreational groups

7.6.7 Abseiling and Climbing To reduce the potential for falls from height, procedures MUST include: This is clearly written towards commercial parties or youth groups/clubs offering skills instruction. Procedures are completely irrelevant to recreational groups

7.6.8  through 7.6.18 While offering a handy guide of what should be done the use of the word “Must” limits it relevance to recreational groups who may choose to use different methods and systems.

7.7 Aquatic canyoning activity management.  As above This is clearly written towards commercial parties or youth groups/clubs offering skills instruction. Most of the clause are less relevant/impracticable for recreational groups. Procedures are completely irrelevant to recreational groups

 

Are there any topics that should have been included but were not? 

If the document is to be adopted in any from it requires a scope that clearly defines who it is intended for. My suggestion would be something along the lines of “This guide applies to Commercial groups, youth group such as scouts, rovers, guides, recreational clubs (but only when the primary purpose of the trip is skills instruction)…… While it is a handy guide for recreational canyoners it is not expected to be applied to independent or co-dependent recreational groups”

I also feel the definitions of “Dependent group” and “activity provider” provided in the core guide are vague at best and clearer definitions need to be developed.

 

Are there any topics that were covered that you do not think need to be? 

Grading system.

There are 2 simple grading systems already in use in Australia, Jameison’s 1-5 and Brennan’s Easy,Medium, Hard

I feel these are more than enough to cover the relatively small diversity of difficulty in the Blue Mountains and the introduction of a new, more complex grading system only adds confusion.

 

What are your key concerns regarding the activity Good Practice Guide, if any?

A cynical person might suggest the guide is written by commercial interests to make it harder/less appealing for Recreational clubs and youth groups to compete with them.

 

My concern is if land managers decide to adopt the guide as a minimum standard for allowing recreational groups continued access to canyons. This decision could well be made by persons with little actual knowledge of canyoning who assume that as there is a published guide it would be applicable to all canyoning groups.

 

Other concerns include the document having an over use of the word “must” in a guide that is meant to be “voluntary” and the fact it tries to aim itself at groups and organisation that current legislation would view as exempt from it. Thus it is an impracticable document that exists for the sole purpose of existing.

 

Issues with the core guide

Incident reporting Not always practicable for recreational groups

Planning Management and approval of activities. Less relevant and practical for recreational groups

Activity plans . Less relevant and practical for recreational groups

Purpose of activity. Less relevant and practical for recreational groups. I’d like a clear purpose for this document though.

Emergency management planning Refers to procedures. Documented procedures are completely irrelevant to recreational groups

Reporting notifiable incidents Completely irrelevant to recreational groups

Work health and safety Completely irrelevant to recreational and volunteer club based groups

Activity leader required documentation Irrelevant to recreational groups

Consent Less relevant to recreational groups

Trigger points. Documented T.A.R.P.s and trigger points are not relevant to recreational groups

Equipment and logistics Less relevant to recreational groups with some clauses being impracticable.

Naming conventions and roles Less relevant to recreational groups with some clauses being impracticable.

Competencies Less relevant to recreational groups with some clauses being impracticable

By Craig Flynn

Regards,

Flynny and Gabby