Our recent post on Abseiling at Dinas Rock unintentionally but incorrectly stated that Adventure RMS had issued ‘advice’ to users of the venue. Tim Morton (Head of Service at Adventure RMS) has pointed out that it is not the role of Adventure RMS, or that of inspectors who undertake work on their behalf, to issue direction or guidance – see his full statement below.
Nevertheless, SWOAPG still suggests that “providers might wish to have a conversation with their technical advisors to check whether additional measures may be appropriate to demonstrate their staff competencies at the left end of the crag” on the basis that this area could be considered outside the RCI/SPA remit. We are still investigating the possibility of running a workshop for all SWOAPG Members to explore / recommend / train possible ‘options’ for this issue (while acknowledging that a solution for one provider might not work for another). Watch this space for further updates – or feel free to contact us in the meantime to express interest…
Statement by Tim Morton
“Those who wish to hold a licence must decide how and where they wish to operate. The inspector’s role, in reviewing licence applications, is to explore the applicant’s arrangements and to judge their compliance with the regulations. How the provider chooses to comply is for them to decide”.
“It is inevitable that the process of reviewing an AALA licence application leads to professional discussions between the inspector and the applicant. Applicants often find this process useful, but it remains the applicant’s responsibility to decide on the arrangements they will implement and the inspector’s responsibility to judge whether these meet the expectations of the regulations.
“Where an inspector judges that an applicant’s arrangements are insufficient, then Adventure RMS would hope to explain this situation sufficiently well to allow the applicant to make alternative arrangements, or to accept that a particular activity or location cannot be licensed. The Adventure RMS application review process takes place over a 56-day period, in part to allow time for such work to be undertaken, and therefore, avoid circumstances where an application may have to be refused.
“In the context of demonstrating instructor competence a provider needs to be able to demonstrate that the individuals they deploy to deliver activities are appropriately competent to do so, including the competence required to deal with foreseeable incidents and emergencies. There are several ways this can be achieved, including nationally recognised awards, internal training and assessment processes, statements of competence issued by technical experts and others. Each of these will require varying levels of site/provider specific induction. It is for the provider to decide the method which works for them and to ensure, whatever approach is taken, that:
- “The arrangements provide evidence that instructors possess the full depth and breadth of competence required for the activity and the environment/location in which they are deployed. In short, the evidence of competence matches the demands of the activity and location.
- “Where internal or external experts are involved in assessing instructor competence, those making such judgements are themselves appropriately experienced and competent to do so.
“While several providers may use the same venue, each may have different arrangements for demonstrating the competence of the instructors they deploy to operate there. It is quite possible that arrangements in place with one provider may not be appropriate for another, as the competence of instructors is part of a broader safety management system which needs to ‘hang together’. Adventure RMS, and the inspectors working with them, are required to make judgements in this broad context; therefore, an approach defined by one provider could satisfy the inspector whilst the same apparent approach used by another provider may not, due to the broader context in which it is being applied.
“Issuing direction or guidance to all providers is, therefore, inappropriate in the context of AALA licence applications; doing so would risk undermining an organisation’s ability to fulfil its legal duties and define its own safety management arrangements.”