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Cumbria Tourism
ROAM – Registered Outdoor Activity Member
Accreditation Scheme for Outdoor Activity Providers
in Cumbria – The Lake District

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Aims of the Scheme

In March 1993 a school trip to an outdoor activity centre on the south coast of England ended in tragedy as four young people perished on a coastal canoe trip in Lyme Bay. The subsequent public, media and political outcry resulted in the passing of The Activity Centres (Young Persons’ Safety) Act 1995 which has required, since 1996, certain categories of outdoor provision for young people to be inspected and licensed.

Prior to Lyme Bay, there were no nationally accepted standards for outdoor activity provision, and despite a number of generally short-lived voluntary schemes, the industry was largely unregulated - except of course for the generic requirements of the Health & Safety at Work Act (1974), and recent sets of specific regulations on the Management of Health & Safety.

Since 1996, the Licensing Regulations as administered by the Adventure Activities Licensing Authority (AALA), have become widely accepted as a standard for safe practice within that part of the sector than works with young people. As a result, members of the public, and perhaps more importantly, schools and other youth organisations, now look for evidence of a licence as a matter of routine.

However the Licensing Regulations only apply to a small slice of the sector – to those providers who offer;

a) instruction or leadership
b) in a small number of traditional outdoor activities;
c) above a certain ‘hazard’ level;
d) to young people (under 18 years of age)
e) on a commercial basis.

If the provision doesn’t meet all of these criteria, and consequently doesn’t fall within the scope of the Regulations, the provider cannot legitimately hold a licence. There are 84 licensed providers in the Cumbria area (2005), but it is estimated that there at least that number of other similar providers operating legally, outside the scope of licensing, and consequently without a licence to reassure their clients or support their advertising.

Licensing only applies to provision that has an element of instruction or leadership: it does not, for example, cover managed artificial (or natural) facilities such as climbing walls, or off-road cycle trails that are open to the public; nor does it cover businesses which hire activity equipment to the public; or any of the other services and facilities that visitors make use of to complement their outdoor activity experiences in Cumbria.

The public has a right to expect high standards from businesses that offer services in what is generally perceived as a potentially hazardous area of recreational activity. Licensing has provided this assurance, at least as far as safety is concerned, for one part of the outdoor activity industry. ROAM aims to extend this assurance to the whole sector within Cumbria, ultimately embracing all types of service.

The aims of the ROAM are therefore to:

  • extend the principles of licensing and good safe practice to all outdoor and adventurous activity provision within Cumbria;
  • check some aspects of provision not currently covered by Licensing;
  • provide a single, consistent kitemark for the reassurance of visitors to Cumbria who may be looking for a wider range of outdoor activity services.

Cumbria Tourism will make the final decision on which businesses come under the ‘outdoor activity’ umbrella and thus be considered eligible to apply for recognition under the ROAM scheme.

Benefits of Membership

This is a purely voluntary Scheme, and potential Members will need to consider the benefits of membership to their businesses. Obviously, if there is perceived to be no benefit, the Scheme can, and will be ignored. However, Cumbria Tourism believes there are a number of factors that have the potential to assist the development and profitability of local outdoor activity businesses. These include, amongst other things:

  • a ‘one-stop’ kitemark to reassure potential clients
  • membership of Cumbria Tourism, and its associated marketing advantages;
  • access to a whole range of discounts and services (on insurance, finance, advertising etc) as a member of Cumbria Tourism;
  • the opportunity to consult with an experienced outdoor professional during the assessment process, and at other times;
  • reassurance that your business is following nationally (and locally) accepted good practice;
  • a written report on the assessment;
  • a Certificate of Membership and various ROAM stickers for display to the public
  • use of the ROAM logo in advertising

Applications

In the first instance, contact Cumbria Tourism who will pass your details to the organisation responsible for assessment.

An assessor will then contact you directly (usually by email) and ask you to complete an application form. This will normally be done ‘online’, although for those few businesses that do not yet have internet access, a completed form on paper will be accepted.

At the same time, a cheque for the membership fee is to be sent to Cumbria Tourism.

Once the fee and the application form have been received and checked, and your eligibility confirmed, you will be notified, as a new (or lapsed) applicant, that you have ‘Provisional Member’ status. You now have two options. You may either:

  • pre-empt your assessment and use the ROAM logo in your advertising. However, if you do this, in every case the Logo must be accompanied by the statement "Provisional Member subject to Assessment"
  • wait until you have been assessed, and once successful, use the Logo freely without the restriction above.

The ‘Provisional Member’ status does not apply to businesses that are re-applying without a break in membership (see ‘Duration of Membership’ below)

The assessor will then arrange a mutually convenient date and time to carry out the assessment. This can only be done when the business is ‘operational’, ie when activities are taking place.

Assessment

This will be a single visit by an experienced outdoor professional and assessor, and will normally consist of three key elements:

  • Observation of activities taking place, with the opportunity for the assessor to talk to clients, instructors etc
  • Management interview with one or more key personnel to discuss the application and the business’s operational procedures
  • Looking at equipment, facilities and other resources.

This process will normally take between two and six hours depending on the size and complexity of the business, and what’s happening on the day. Before the assessor leaves, you will be given a short written ‘action plan’. This will have three categories:

  • Significant pieces of general advice, none of which will affect the decision to approve your membership.
  • Issues that need to be addressed as a condition of membership. If there is anything in this category, the application will be approved, but some evidence of compliance may be required if membership is to continue.
  • Issues that are so serious that membership cannot be considered at this time. This will normally be the result of serious concerns safety. To continue after this outcome, the applicant will need to re-apply (paying another fee) once they have addressed the issues in the action plan. This second application will require a further full assessment.

The assessor will submit their report to Cumbria Tourism’s Outdoor Activities Working Group with a copy to the applicant. Cumbria Tourism will confirm (or reject) the recommendation and notify the applicant of their decision.

For applicants who also hold activity licences, Cumbria Tourism will try, where possible, to arrange the assessment alongside, and as part of, the licensing inspection. For one-year licence holders, this should always be possible; for two-year licence holders it will be possible if the expiries are in step; for three-year licence holders, the two assessments will only coincide every six years. However, the 2004 changes in the Licensing Regulations now allow more flexibility in the timing of licensing inspections, so there is now greater scope for combining the two assessments.

Duration of Membership

Your membership status will last for 2 years/seasons. The starting point for all memberships is March 1st of each year. After 2 years/seasons you will need to apply (between November 1st and March 1st) for reassessment and to pay any fees relevant at that time. You will be reminded (by email) of the need to re-apply in October of the year prior to your membership expiry.

If your renewal is submitted before your current membership lapses (ie before March 1st), then you may use a modified and much simpler application form. Your full status as a Member will continue without the need to go through ‘Provisional Member’ status, and without having to qualify your advertising with the phrase "Provisional Member subject to Assessment"

If you lapse your membership and re-apply after a break of a year or more, you will be treated as a new applicant. Re-applications (and payments) received after April 1st will be treated as ‘new applicants’.

If you choose not to re-apply, you will be advised that you must amend your advertising for the year in which membership lapses to remove all references to ROAM. Websites must be updated at expiry, and an ‘errata’ statement prepared for inclusion in all pre-printed literature that contains references to ROAM. This statement is to say "Membership of the Cumbria Tourism ROAM Scheme lapsed on March 1st 20**, and has not been renewed". The Certificate is to be removed from display, and all stickers taken down.

Code of Practice for Outdoor Activity Members

1) Communication with Customers

a) Communication with customers should be clear and courteous. Responses to enquiries, both verbal and written, should be prompt.
b) Advertising and marketing (printed brochures, information sheets, websites, displays etc) must:
i) accurately reflect the product or service provided
ii) only use logos of professional bodies where there is a clear entitlement to do so
iii) not make claims about the service that cannot be fulfilled
c) It must be clear to customers exactly what they are buying, and exactly what it costs. This should be made clear in printed material, or for specially tailored programmes, in a written letter or electronic equivalent. If there are extras (compulsory or optional), these need to be pointed out clearly.
d) Customers should be asked to provide information on any significant medical conditions that they may have, or significant injuries they may have suffered recently. This information must then be passed on to leaders and instructors to help them look after the clients, both proactively and reactively.
e) Risks and responsibilities are to be explained to customers. In some instances, customers may be expected to acknowledge this formally.
f) Providers may need to ask for background information on customers’ previous experience, particularly where they will make unsupervised use of hired equipment or facilities, or where activities at a high level are planned. If a particular level of experience is required, this needs to be clearly stated and checked.
g) Explain that advertised or arranged activities might need to be changed, or even cancelled, for safety reasons outside the provider’s control (weather, conditions, staff illness, etc).
h) Where participants are required to provide their own equipment or specialist outdoor clothing, this must be explained clearly. It is normal good practice to provide information on this, and other important matters, in the form of ‘joining instructions’ communicated in advance.
i) For young people under 18, it is normal to require written parental consent if a parent or legal guardian is not present during the activity.
j) A formal procedure will need to be in place to deal with any complaint that cannot be resolved by talking it through and coming to a mutually acceptable conclusion.

2) Accepted Codes of Practice

a) Members follow the basic principles used by the AALA under the Licensing Regulations, as a template for the safe management of all activities, even where these activities and/or the client group are outside the scope of the Regulations. Guidance on these principles can be found in the Health & Safety Commission’s booklet L77, "Guidance to the Licensing Authority on The Adventure Activities Licensing Regulations 1996" , with further interpretation on the Licensing Authority’s website at www.aala.org under the title ‘Collective Interpretations’.
b) For established activities that have one well-respected National Governing Body (NGB), Members are to follow that NGB’s guidelines in respect of safety.
c) For facilities where there is a single, representative Trade Association with an associated and published Code of Practice, Members will follow it.
d) Where an activity or facility comes under a number of nationally recognised Trade Associations, Training Organisations, or other collective bodies with published Codes of Practice, Members may choose to associate with, and follow the guidance of any of these which reflect the consensus of national good practice.
e) For activities or facilities for which there are no Trade Associations or other established and respected representative bodies, Members are to operate in line with basic safety principles and work practices that would meet with the approval of the UK’s most experienced practitioners in that field.
Cumbria Tourism has compiled a ‘working document’ that outlines (or makes reference to) the key principles and guidelines on generic good practice for most of the common activities. This document can be viewed on line (at ***********) and can be thought of as ‘work in progress’ because it aims to be current, and constantly changing to reflect changes in modern practices.

3) Managing Activities

Cumbria Tourism will focus its assessment on what actually takes places ‘in the field’, although some documents will also be sampled to check that practice matches theory. In this whole process, the importance of using competent staff cannot be overstated.

a) Staff Competence

i) For activities where there is a well-established NGB, with its own instructor training and assessment scheme, Members will be expected to be qualified themselves (sole traders), or to deploy staff who hold the relevant qualification (larger providers).
ii) However, it is equally acceptable for appropriately experienced, but unqualified staff to hold an ‘in house’ Statement of Competence signed by, and based on criteria chosen by, a well-qualified Specialist or ‘Technical Adviser’. This Statement of Competence is only valid when the holder is working for the organisation that commissioned it – it is not a transferable qualification like an NGB award.
iii) For activities with no NGB, and no qualifications structure, Members will need to provide evidence of the experience and competence of their chosen Specialist. This person may then be responsible for assessing the competence of other leaders and instructors in this activity when they are working for the Member organisation.

b) Selection, Induction, Training and Monitoring of Staff

i) Selection : Members will take steps to check the suitability and technical competence of instructors and leaders before agreeing to take them on.
ii) Induction : before new staff are deployed as activity leaders, Members will carry out a process of progressive, practical induction under the guidance of more experienced senior staff. Some of this induction process will involve familiarisation with facilities, sites and areas to be used, and typical clients.
iii) Ongoing Training : Members will provide relevant training for their staff in dealing with foreseeable emergency situations, and in response to operational incidents which may occur. Larger businesses may also be able to provide further professional development opportunities for individual members of staff.
iv) Monitoring : Member businesses that employ instructors and leaders - particularly (but not exclusively) those contracted on a freelance basis - have a responsibility to ensure that activities are being delivered in line with good practice and with the organisation’s principles. This will involve members of the senior staff team in monitoring a sample of sessions from time to time, and providing training input as necessary.

c) Deployment of Staff
Member organisations will only deploy instructors (and leaders) to work within the remit of their experience and qualifications, at sites and in areas that they are comfortable with. The use of unfamiliar sites and areas should be restricted to those members of staff who have a good ‘margin of competence’ – defined as the difference between the level at which they are competent to operate, and the level at which they are actually being required to operate.

d) Flexibility
Members organisations will deploy staff with appropriate experience and sufficient ‘margin of competence’ to be able to respond to the conditions (of weather, terrain, clients etc) that they meet on the day, and if necessary, to change their plan. This requires a ‘Plan B’ to be thought out in advance and initiated if and when necessary.

e) First Aid
Members are to ensure that at all times, participants have access to a trained first-aider within a reasonable time. ‘Reasonable’ is always a function of the situation, but taking as a benchmark the time before a blocked airway will cause death or disabling injury, then this response time should be measured in minutes. In effect, this means that, for any activities remote from ‘base’, the actual leader or instructor must be trained in First Aid. Ideally, the training course should be one that involves dealing with injuries in remote environments with no immediate prospect of help from the emergency services.

f) ‘Soft Skills’
Although the assessment in most well-respected NGB Coaching and Leadership awards does consider the candidate’s ability to communicate with and relate to clients, the emphasis is chiefly on ‘technical skills’. However, when selecting and training and monitoring staff, Members of the ROAM Scheme will be expected to pay particular attention to this important area of work, and to be aware of all the full impact of adventurous activities - physical, social and emotional – on the client.

g) Internal Communication
Larger Member organisations will have two-way systems for the communication of ‘need to know’ information between managers and staff. This will involve, amongst other things:

i) procedures for staff to feedback information about the conduct and outcome of sessions, including the opportunity to raise concerns about safety issues;
ii) a system for reporting and reviewing accidents and other safety-related incidents;
iii) an arrangement for managers to inform staff about important issues such as changes in procedures; current safety (and other) problems at particular sites; accidents and incidents that may have occurred within the business; advice on the use of particular items of equipment; possible impact on working practices of generic incidents and issues picked up from other sources; etc

h) Principles of Documentation
Members will need three basic types of documentation:

i) Operating procedures: these define and communicate how the Member business will function.
ii) Logs and Records: for the routine recording of important operational information.
iii) Other important evidence that is kept on file; e.g. copies of qualifications; certificates of insurance etc

For operational effectiveness, documentation should be restricted to a necessary minimum. Paperwork within a business generally serves three main purposes:

i) For larger more complex businesses, it is likely that some information will need to be documented as an aid to communication.
ii) As a consistent point of reference so that everyone, both managers and instructors/leaders, are clear about what is expected of them.
iii) As a tool for external agencies (such as Cumbria Tourism, or AALA or some client groups) as a reference point for their checks on compliance and good practice.

Members of ROAM should consider the following three questions when designing, or assessing the suitability of their documentation:

i) Is it necessary – does it meet one or all of the three purposes above?
ii) Is it concise – or are the important bits lost in a sea of words?
iii) Is it effective – does it actually contribute anything to the business, or is it just a token folder on a shelf?

The list of essential documentation (below) might only comprise a single sheet of A4 for a single activity sole trader - or it may run to a sizeable volume for a larger business with a significant number of employees and a range of different activities.

i) Essential Documents and Records

i) Outline operating procedures for each activity, covering amongst other things:

(1) required measures of staff (including assistants) competence;
(2) group sizes and ratios;
(3) typical areas and venues;
(4) level of activity;
(5) statements on common operating practices where there is not a universally accepted approach (e.g. helmets for open canoeing?).

ii) Risk assessment (see section below)
iii) Staff files, with evidence of competence, including in house training and assessment
iv) Very brief records of staff induction, training and monitoring carried out – Date? What? Who? etc.
v) Procedures to be followed in the event of an accident or emergency, including a procedure to ensure that the emergency services are alerted in good time if a leader fails to return with their group from a remote location.
vi) Records of accidents and other significant incidents and ‘near misses’ (including a section for ‘action plans’ resulting from subsequent investigations).
vii) Equipment inventory, with records of routine maintenance inspections of critical safety equipment.
viii) Risk Management Summary – a document giving outline details of the business, available for clients who require it. The aim of this summary document is to avoid clients asking for copies of all your paperwork (a ‘template’ can be seen in the Collective Interpretations section of the Licensing Authority’s website www.aala.org)

The list above includes everything that Cumbria Tourism considers ‘essential’, although some businesses may have other useful documents and records, such as:

  • Session evaluation forms
  • Equipment usage logs
  • Minor First Aid treatment records
  • Safety memos
  • Client records
  • Completed client feedback questionnaires

j) Risk Assessment
The basic principle of risk assessment is very simple:

  • What’s the problem?
  • What should I do about it?

Safety in outdoor activities depends on knowing the hazards and the risks they pose, and then taking steps to keep these risks within an acceptable level. Members will be required to show that they do this, both as a business, and more importantly, by employing instructors and leaders who can do this dynamically in the field. Members will be expected to:

    i) use well-established, generic good practice for each activity. Deploying instructors and leaders who have been trained and assessed by NGB’s (or through an equivalent in-house scheme) is the normal generic risk management strategy. Businesses are not required to ‘re-invent the wheel’ by going back to first principles to assess well-known and well-controlled generic risks;
    ii) Identify, and implement control measures for significant unusual risks associated with:

    (a) Particular sites and venues that are used regularly
    (b) Particular unusual types of client group; for example, the elderly, or blind people, or maybe those with behavioural problems.
    (c) Unusual methods of working that are specific to the particular business.

    Members will be expected to comply with categories i) and ii), although their documentation of risk control measures will focus on ii). Specific reference to well-established generic codes of practice (where these exist) and the use of competent leaders and instructors will normally be sufficient for i). The outcomes of this process of identifying hazards and controlling risks will, in effect, be the operating procedures that determine good working practices.

    Members will also be required to show that they have a reliable means of informing their staff of particular control measures (safety precautions) that are to be taken to manage the category ii) risks. Competent staff should not need to be told how to control risks generic to the activity.

    Cumbria Tourism recognises the role that the experience-based judgement and decision-making of competent practitioners plays in the management of safety. This ‘dynamic risk assessment’, which is a minute-by-minute evaluation and re-evaluation of risks, and the ability to respond to a constantly changing natural environment, is the key to the safe management of activities. Volumes of comprehensive and neatly documented ‘risk assessments’ are no substitute for good instinctive judgement in the field, based on the accumulated experience of competent leaders and instructors.

4) Accommodation

Those Members who provide accommodation will need to comply with the following practices:

a) The business’s own accommodation (or sub-contracted accommodation if used) must have been inspected and given Tourist Board approval.
b) If it is of a type that is not normally inspected, (eg dormitories, bunkhouses, camping etc) then clients are to be informed of this in advance.
c) Where accommodation is merely recommended (not provided within the cost of the activity package), the client must again be informed if this recommended accommodation does not have Tourist Board approval.
d) At the booking stage, it is to be made clear to clients exactly what is provided within the price. This will include a fair description of the nature of the accommodation, what meals are included, and anything that will be charged as an ‘extra’.
e) Where young people (under 18) use permanent sleeping accommodation without a parent or guardian present, one or more suitable and responsible adults must be resident on site.

5) Facilities and Equipment

a) Where the public pays for ‘unsupervised’ use of facilities, Members will be expected to carry out sample monitoring checks of activities, and to use the feedback from these to make changes where necessary.
b) All safety equipment is to meet the relevant nationally accepted standard – UIAA, CEN, BSI, BMIF etc
c) All facilities and items of critical safety equipment are to be routinely inspected and maintained. The frequency and intensity of routine inspections will need to consider:

i) Normal good practice within the sector as defined by NGB’s or Trade Associations.
ii) Manufacturer’s recommendations.
iii) Likelihood of equipment failure
iv) Consequences of equipment failure
v) Type of use (abuse?)
vi) Amount of usage
vii) Age of equipment in relation to its normal working life

d) A record of all inspections is to be kept, with a note of those areas or items that may need particular attention at the next inspection.
e) A system must exist for the immediate isolation of items found to be defective, at whatever stage.
f) Equipment is to be replaced when it is no longer ‘fit for purpose’.
g) Transport: where this is provided it must be in good condition and comply with all legal requirements: tax, insurance, MoT etc. Members are to ensure in particular that they meet the current complex regulations on the use of minibuses (and other PCV/PSV’s), and trailers.

6) Insurance

a) Employers’ Liability Insurance is a legal requirement for any business that employs staff, and it must be on display.
b) Members are also required to hold public liability and third party insurance (plus product liability and professional indemnity if relevant) to an appropriate level of cover.
c) Members may wish to provide access to schemes of personal accident insurance for those clients who are interested in such cover.
d) The application form will request details of insurance cover, and the assessor may ask to see evidence of these at assessment.

7) The Environment

a) Businesses that by their very nature, depend on an environment as fragile and heavily used as The Lake District, must make every effort to minimise the potentially damaging impact of their own businesses on our vital local environment. Members must consider issues such as:

i) Pollution - litter, chemicals, noise, light, vehicles etc
ii) Waste - re-using/re-cycling
iii) Erosion – paths, bridleways, green lanes, river banks etc
iv) Awareness of particularly sensitive areas, and endangered species
v) Overcrowding of the ‘honey pots’, and sensitivity to other users

b) Actively support and promote the principle of environmental sustainability within Cumbria - The Lake District.
c) Carry out an ‘Environmental Audit’ of the business, then draw up and implement a ‘Green Action Plan’, however insignificant it may seem, based on what can realistically be achieved. Your assessor will ask you about this.

8) Appeals Procedure

a) It is expected that the vast majority of applicants will meet the ROAM Scheme standards without needing to make significant changes to the way they operate.
b) However, a number of Members may have issues to address following assessment. This will not prejudice their membership providing they have agreed an action plan for addressing these issues at the assessment. There will therefore be no need of Appeal in these instances.
c) If these issues in question are numerous and/or serious, and cannot be resolved in discussion at assessment, then the business will not be admitted to membership. The sort of issues that would prompt this course of action are most likely to be safety-related, but might also include other things such as: clear and deliberate breaches of the Law; regular and repeated customer complaints; poor treatment of customers; providing a very inferior product to the one advertised and sold.
d) If you disagree with the assessor’s ‘fail’ recommendation, you have the right to appeal. The procedure is as follows:

i) Write to Cumbria Tourism explaining, citing evidence, why you believe that the issues detailed in your report on the assessment should not result in a refusal to grant membership. Enclose with this letter an Appeal Fee equal to the amount already paid with your application. This fee will be refunded if the appeal is upheld.
ii) Cumbria Tourism will arrange a second assessment, with a different assessor. This assessor will have access to your first report, and will have had discussions with your first assessor. You may arrange for a representative of a relevant NGB, or a senior manager from another ROAM approved organisation to attend and moderate the second assessment as an independent witness.
iii) You will receive a written report on this second assessment. If this also recommends that membership is not accepted, the two reports, together with any written submissions from you or your independent witness will be considered by an Appeals Panel under the chairmanship of a member of Cumbria Tourism and consisting of three other panel members: another member of ROAM; a person of ‘technical adviser’ status in relation to the main area of concern; a representative of a relevant Trade Association or statutory body.
iv) You may, at the Panel’s discretion, be asked to attend the Appeal meeting. The Panel may, at their discretion, also choose to invite either or both of the two inspectors, and/or your independent witness to attend their meeting.
v) The Appeal Panel’s final decision will be based on a majority vote of the three members. The chair will not have a vote. The decision of the Appeal Panel will be final, and you will be formally notified of the outcome in writing.
vi) If the Appeal is not upheld, no further application may be submitted until 12 months after the date of the Appeal Panel’s decision, at which point you will be treated as a ‘new applicant’ and assessed in the normal way. However, you may not advertise your ROAM status in any way until you have actually been assessed and membership has been confirmed. ‘Provisional Member’ status will NOT be accorded to businesses that re-apply after a previous failure to be accredited.

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