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:
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
sleepwhenwearedead 
My submission – in case anyone wants to use it or parts of it.
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General feedback
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I have several fundamental issues with the GPGs in general, and also the Canyoning GPG.
The first issue is the sheer size of the GPG (Core + Canyoning). At over 120 pages, it is simply way too wordy. For the GPGs to be useful, they need to be accessible, and at the moment, they are an overload of information. To be fair, this is as much – if not more – of the fault of the Core GPG, than the Canyoning GPG. But both documents are over 50 pages.
Compare this to the NSW Canyoning AAS at 25 pages, or the NZ Canyoning ASG at 50 pages. They are much shorter, and much more readable.
I’m not saying the information in the GPGs is not right, but if no-one reads it, it may as well not be there.
Looking at the Canyoning GPG specifically, there is too much technical detail, mainly through section 7. There is a lot more technical detail than say the NSW AAS, or the NZ ASG. While I don’t necessarily disagree with most of it, it takes the GPG from a guide to a practice manual. I appreciate the decision of what to include or not include is a tricky one, but if you’re going to specify competences, then people who are competent should already know much of this stuff.
The appendices don’t add anything useful to the document. They are information that if needed to be accessed, can be found on the internet, but otherwise just add to the page count.
The second issue is the concept of dependent participants, and that it should fundamentally change how you plan a trip as a leader. The notion of dependence is of course built in to all of the GPGs, including the Core. In the Canyoning GPG it is referenced in the first two parts of section 1. Introduction.
Unfortunately, the GPGs try to treat dependence as binary. You’re either dependent or you’re not. However, it’s just not the way things work in the real world. Trips – and the skills of individuals participating – lie on a continuum.
>From a bushwalking club point of view, there is almost always some degree of dependence on a trip, but it varies from trip to trip, and within a trip.
While the core guide states explicitly that “the degree of dependence may vary during an activity”, this is the only place that the GPGs acknowledge the potential for a continuum. They don’t explain how this continuum should affect the planning of the trip.
As a bushwalking club leader and canyon leader, I plan the trip based on the skills and abilities of the party as a whole. I may modify or cancel the trip if I don’t get people with the necessary mix of skills signing up. I will reject people whose skills aren’t sufficient for the trip, or if I need a particular set of skills. I will then help co-ordinate the trip so that people are not being required to act beyond their skill level.
Basically, I don’t see people as dependent or independent participants, and I think it’s an unhelpful basis for the GPGs. I see people as individuals with a set of skills and weaknesses that need to be collectively managed over the trip, to get a good outcome for the trip and the party.
I understand that for commercial groups and groups leading children, this might be an appropriate way to plan. But if this document is also to be applicable to bushwalking clubs and recreational groups, you need to think more broadly.
The third issue is something that I call the “Dominant Leader Paradigm”. It’s the idea that the leader will do everything that requires a level of responsibility, and that participants will do only as much as they need to do. Unlike the previous issue, this is not something that is explicitly stated in the GPGs, but it comes across implicitly when you read the documents as a whole.
Having been on a few commercial trips, this is the way that commercial trips run. The guide provides all of the gear, checks the anchors, rigs all of the abseils, belays all of the participants, pulls and coils the ropes, provides food, and probably does a host of other things as well.
It’s not the way that bushwalking club trips run. The leader is to some extent also a co-ordinator, and everyone else is expected to contribute to the trip according to their skills and abilities. On a trip, it is not unusual for me as a canyon leader to set or pull none of the ropes for abseils, or provide none of the belays.
Lastly, I would note that even though the document is supposed to be for “activities involving dependent participants”, the document is definitely implicitly targeted at the existing practices of commercial groups. Some examples:
– requirement for top belays (most recreational and club groups would bottom belay)
– hygiene procedures for equipment (most recreational and club groups would have participants supply their own gear)
– equipment checks (again, the way it is written implies that the activity provider is providing the equipment)
– use of “guide” rather than “leader” in the Leadership section
– references to allocating activity leaders (recreational and club trips simply don’t work that way)
– the fact that food is listed under group equipment, rather than personal equipment (recreational and club participants would be expected to bring their own food; the leader may carry emergency food)
Feedback on specific sections
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1.0.4 (my own number since the heading isn’t numbered!) Interpretation of the Standard and Good Practice Guides
The language used in the Standards/GPGs is not really approachable. Compare to similar documents like:
– NSW AAS for Canyoning ( http://outdoorsnsw.org.au/wp-content/uploads/NSWAASforCANYONING.pdf)
– NZ Canyoning ASG (http://www.supportadventure.co.nz/system/files/Canyoning%20ASG%20v2.pdf)
which are much more readable.
Issues include
– writing everything in the passive tense
– use of MUST
– use of “MAY include but are not limited to” – could just be replaced by “include”
The document is a guide – it would be better written in everyday English.
For example, if I take a particular section and quickly rewrite it to be more friendly:
“5.9.4 – Be considerate of your hosts and other visitors
• actively manage groups to minimise impact
• avoid blocking access to other users
• negotiate with other users regarding shared use of a site
• only carry out the installation of permanent artificial anchors or equipment with the permission of the Land Owner or Land Manager.”
3.1 Canyoning activity plans
“guide’s recent familiarity with route”
“Guide” has not been referenced as a term – should be “Leader”
3.2 Canyoning emergency management plan
There is an implicit assumption (“mapping of access and escape options”) in this section that the leader will have previously completed the canyon. This is probably always the case for commercial groups, but is not necessarily the case for recreational or club groups.
5.2.1 Grading system used in this document
I question the value of including a specific grading system in the document.
5.9 Environmental sustainability procedures
Some of this duplicates or almost duplicates items from “Appendix J – Environmental sustainability procedures” of the Core GPG
6.1.3 Other Equipment
“Procedures MUST identify the appropriate equipment required for the activity.”
What is this even referring to? This clause seems redundant.
6.2.1 General equipment use
“Training in the use of equipment used MUST be provided to activity leaders and participants.”
By whom? This sentence is unclear.
“Procedures MUST be used so that relevant provided equipment is hygienic.”
When it says “provided equipment”, what does it mean? In recreational and club groups, equipment is mostly participant supplied. I certainly wouldn’t expect the participants to have taken any special hygienic precautions with their equipment.
6.2.3 Helmets
“An appropriate helmet MUST be worn while canyoning grade V2 or higher and/or A4 or higher.”
A4 includes canyons like Wollangambe (“Prolonged immersion in cold water.”) – not sure why it would need a helmet. It would be better to rephrase this requirement with reference to the specific aspects of canyoning that need a helmet, rather than by reference to the grading system.
6.4.3 Connectors – practices relating to use
“Carabiners MUST be used so that no load is intentionally across the gate.”
This should already be covered by 6.2.1 (“All equipment MUST be used with reference to the manufacturers’ instructions.”)
6.4.6 Rescue systems
“Abseils that involve running waterfalls MUST use releasable rigging.”
Almost every abseil in a canyon involves running waterfalls. The nature of the waterfall in relation to the abseil is the important factor in choosing the rigging system. For example, if the abseil completely avoids the path of the water, or the water is just a trickle, then releasable rigging is less important. The wording could be improved.
7. Leadership
See comments in “I cannot support this” as to why this section should be cut back.
7.1 Naming conventions
The use of the terms “Canyoning guide”, “canyoning instructor”, and “Assistant Canyoning guide” seem to be very much aimed at the commercial sector. They are not terms that would be used by clubs or recreational groups, who would use the term “leader”, similar to the Core GPG.
7.2 Competencies
I acknowledge that the issue of leader competence has been specifically called out to try and clarify that a training qualification is not the only way of recognising competence:
http://australianaas.org.au/leader-competence-4-ways-to-make-sure-leaders-have-the-right-skills-and-knowledge/
However, I still have the concern that listing competencies that are linked to specific qualifications is likely to mean that the qualification ends up being the requirement, rather than the competency. It would be better to independently write the competencies, rather than using training package unit descriptions.
This is the one area that I would advocate adding to the document rather than cutting from it!
7.5.2 Knowledge of site
“The knowledge and experience of the activity site that activity leaders require before leading participants at
that site, SHOULD be considered when allocating activity leader roles.”
This statement doesn’t make sense for bushwalking clubs or recreational groups. Activity leaders self nominate, they aren’t allocated.
7.6.3 Unprotected climbing
Is this the same as “rock scrambling”?
7.6.8 Abseiling specific
“The belay method used MUST be a releasable top belay system, unless other considerations indicate another belay method is more appropriate.”
This seems very much aimed at commercial groups. Few recreational or club groups would use a top belay system. Surely the guide should address the considerations for using each of the choices of belay system, and leave the ultimate decision to the leader.
7.6.9 Abseiling with bottom braking
“Participants operating a bottom braking belay SHOULD be avoided.”
Participants who are not competent should not be operating a bottom belay. But I fail to see why competent participants should not be operating the belay. Again, this is an example of how commercial trips are run, not how club or recreational trips are run.
Glossary
The NZ ASG “assumes the reader has technical knowledge of the activity, and defines only those terms that may be unique to this guideline, are used in a specific way, or that would otherwise be open to interpretation”. We should probably do the same in this GPG, as the glossary is excessive!
Appendices
See general comments in as to why these should be removed.
Appendix 1 – Canyon grading system
See comment above re 5.2.1
Appendix 2 – Equipment lists
Should not be part of the GPG. Much of the equipment used is already referenced in the body of the document.
Appendix 3 – Equipment relevant standards
Should not be part of the GPG.
Appendix 4 – Equipment load ratings
Should not be part of the GPG.
Appendix 5 – Fall factors
Should not be part of the GPG
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Good job Craig!
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