General Guidance on Standards for Applicants

1. General

This Guidance sets out the minimum safety and quality standards expected of any business accredited as a Registered Outdoor Activity Member (‘ROAM Cumbria’). Cumbria Tourism believes that publishing guidance will help applicants to understand what is expected of them, and to prepare for the accreditation process.

The aim is not to create a whole set of identical businesses, but simply to provide an assurance to clients that when they look for the ROAM Cumbria logo they can expect certain minimum standards of service and safety, in line with universally accepted good practice.

It’s important that the whole process of accreditation is both consistent and transparent, hence the reason for publishing this Guidance. There will also be some ‘Guidance for Assessors’ that applicants and members can access at any time as further evidence of Cumbria Tourism’s commitment to consistency and transparency.

Both sets of Guidance (for applicants and for assessors) will be ‘live’, working documents and will continue to evolve with the Scheme. This may be to accommodate new types of business, and new activities, but ROAM Cumbria is committed to staying current, and needs to be able to respond to the introduction of new technology and equipment, and to changes in accepted standards of good practice.

The most up to date versions of both sets of guidance will be found here on the website, and significant changes in either will be notified, by email, to existing ROAMers.

2. The Assessment

Depending on the size and location of the business, and where the activities are taking place, this process will generally take between 4 and 7 hours, and will consist of a number of parts:

2.1 The assessor will observe activities taking place, and talk to clients and instructors/workers. The assessor may participate on occasions if appropriate!
2.2 There will be some sort of ‘management interview’, which, for a large business will normally take place at their administrative base, but for a sole trader this could be done at home, in a café, or even in the front of a minibus! The assessor will discuss the business with senior managers and instructors, and will probably want to look at some documentation and records
2.3 The assessor will sample some activity equipment, which may be in stores, or being used on session.
2.4 There will be a closing review of the assessment, after which the assessor will complete a recommendation to Cumbria Tourism, along with any requirements or advice. A copy of this will be left with the business.
2.5 A more detailed report will be forwarded to the business shortly afterwards.

3. Principles of Accreditation

At this early stage in the ROAM Cumbria Scheme, there are two types of outdoor activity service that can be accredited:

• Coaching, Teaching, Instructing, Leading or Guiding
• Artificial and/or Managed Activity Facilities

Many businesses will confine their provision to just one of these areas, but some may be involved in both. For example, a climbing wall that is both:

- open to the public, and
- runs climbing courses

will need to meet the standards in both areas to become a Member of ROAM Cumbria. There is not an option to present just one of these areas as the basis for accreditation. Clients need the assurance that if a business is accredited, all its services are up to standard. Cumbria Tourism’s database, and associated marketing material will show each of the assessed categories for each Member.

Within each category, there are certain generic groups of standards that form the basis for the accreditation. These are:

- Activity Safety
- Quality, Value and Customer Service
- Insurance
- Environmental Impact

Although there is bound to be overlap within these specific areas, the following general points apply under each heading:

3.1 Activity Safety
Outdoor activities are often perceived by society as gratuitously dangerous. Although experienced outdoor practitioners know that the reality is different, and that most people actually face far greater real risks in other, more ‘normal’ aspects of their lives, this is still the area where clients need the most reassurance, and the one where standards are the most demanding. ROAM Cumbria recognises this and will only accredit members whose safety standards match current norms.

This does not mean that the adventure element needs to be ‘dumbed down’ – indeed real, well-managed adventure is an essential component of any quality provision – it just means that whatever service is being provided, and at whatever level, it must follow well-established Approved Codes of Practice (ACoP’s). Fortunately, Cumbria Tourism does not need to write these Codes; they already largely exist courtesy of the various Trade Organisations, Statutory Authorities and National Governing Bodies. ROAM Cumbria simply uses these standards as yardsticks.

Nobody is perfect, and ROAM Cumbria doesn’t expect its Members to be either. Nobody can, or should, give an absolute guarantee of safety to their clients, particularly when operating in a constantly changing, uncontrollable natural environment. ROAM Cumbria status can’t give this absolute assurance either.

Outdoor adventure activities do go looking for excitement, and this inevitably means encountering significant hazards, with potentially high associated risks. However, by careful management, the significant risks will be reduced (but not removed) so that the outcome is an acceptable level of safety.

Of course, genuine, unavoidable accidents can happen in any activity, but providing Members have been following good practice and have taken all reasonable precautions to reduce the foreseeable risks to an acceptable residual level, then serious accidents will be rare.

3.2 Safety and other relevant Regulation
When assessing activity safety management, ROAM Cumbria will use, as a template, the basic principles outlined in the Adventure Activities Licensing Regulations (2004), as interpreted progressively over the eight years of the Scheme by the team of inspectors working for the Adventure Activities Licensing Authority (AALA). This template is explained in more detail in Section 4 below, and there are a number of relevant documents on the AALA website that can be accessed on the Links Page of the ROAM website.

Good Practice as propagated by National Governing Bodies is also fundamental to ROAM, and links to these relevant bodies can also be found on the Links Page.

There are, of course, other safety issues not directly related to activities; for example, fire safety, transport, food hygiene etc. Some of these may be legal requirements and some may not, but ROAM Cumbria will focus the accreditation process on those safety issues that relate specifically to activities.

Outdoor activity businesses, like any other, do of course have to comply with relevant general aspects of the Health & Safety at Work Act (1974). For information on some of the more relevant areas of Regulation, refer again to the Links Page.

In addition to those areas of Regulation listed on the Links Page, ongoing European Legislation in the form of ‘European Directives’ will continue to affect all businesses, including those operating in the Outdoors. The latest Directive on ‘Temporary Work at Height’ is still the subject of much debate and UK Regulations to implement it have still to be finalised (at March 2005).

And of course, like all businesses, outdoor activity service providers will need to comply with:

• UK Road Traffic Laws regarding tax, insurance and driver competence, particularly in relation to minibuses and other PCV/PSV’s ;
• Planning permission for premises, and business registration for some of the larger businesses.
• Food Hygiene Regulations, etc

However general business Regulation, and other law is already subject to inspection and enforcement by the Police, Local Authorities and the Health and Safety Executive (HSE). As a purely voluntary, non-statutory accreditation process, it is not ROAM Cumbria’s intention to try to take over, or duplicate these existing powers. The only power that Cumbria Tourist Board has is the power to accredit or not, and even that is open to appeal.

If however, in the course of visiting a provider, an assessor encounters something that is obviously wrong and clearly dangerous, either on activities or elsewhere, this will be pointed out, and in the more serious cases may result in an immediate referral to the relevant enforcement agency.

The one area of Regulation that will be checked as a matter of routine is Adventure Activities Licensing – if your business falls within scope of the Adventure Activities Licensing Regulations (2004), you must hold a current Licence and it should be on display.

3.3 Quality and Customer Service
It is possible to provide a service which is safe, yet of poor quality. Here are a few examples:

- you keep scruffy, torn, wet, dirty clothing for clients’ use. It may not compromise their safety, but it’s certainly not the level of quality that visitors (or ROAM Cumbria) would expect, or;

- a visitor may book on your 2 hour introductory kayak session, only to find that they’re part of a group of 20 with one instructor, who takes them out on the water in groups of 5, with the other 15 watching from the shore. In effect they only get 30 minutes paddling for their 2-hour session. Not unsafe, but probably not acceptable either;

- the advertising leaflet for your climbing wall says you have a café that’s open whenever the wall is open, but you regularly shut it when there aren’t many clients. Again, this is poor service to those people who have turned up to climb and socialise;

- the remains of yesterday’s (or last week’s!) group’s packed lunches are squashed on to the floor of your minibus. Probably not illegal, but certainly not very nice!

And there are many more examples of poor customer service. Obviously, it is difficult to set objective standards to measure the quality of provision, and the level of customer service that visitors receive, but as a general rule, assessors will be most concerned where:

- The actual adventure experience itself is of poor quality (such as the example with the over-booked kayak session above)

- There is an accumulation of cases of ‘not very good’ customer service, any one of which would not be a particularly serious issue on its own, but cumulatively they begin to paint a picture of sub-standard provision overall.

The assessor will normally point out and discuss any isolated examples of poor quality that could easily be improved, or of poor service to the customer. This may then result in some advice being given, perhaps in the form of ‘top tips and handy hints’ but is unlikely to result in a failed accreditation - assuming of course that the provider is prepared to address the problem. A whole raft of issues like this could, though, result in a refusal to accredit.

3.3.1 Value for Money
To some extent, quality and price go hand in hand. The old phrase ‘you only get what you pay for’ has to be borne in mind when purchasing services. Assessors do not expect everything to be of the very highest quality – cheap and cheerful (as long as it’s safe) is a perfectly reasonable approach to business, and one that will be respected.

3.3.2 Advertising
What is not acceptable though, in quality terms, is to claim to offer the very highest standards, and to charge accordingly, but then to deliver a sub-standard product. For example, if a business advertises 5-star hotel accommodation and guided walks using only qualified BMG/IFMGA Mountain Guides, with no more than two clients each, but in practice uses a B&B, and sends clients out in groups of eight with just one Mountain Leader (Summer), they cannot expect to be accredited - and they’re probably breaking the law as well.

Assessors will look at your website, any printed leaflets and brochures, and a sample of adverts in the press/media and compare what you actually offer with what your advertising claims.

3.3.3 Communicating with Clients
Advertising is just one part of an essential two-way process that will contribute to a safe, good quality experience for clients in Cumbria - The Lake District. The following elements are also common parts of this process:

- two-way exchange to confirm that what is being offered is appropriate (is the level and nature of the activity matched to the client’s age, fitness, skill level and experience?);

- contract letter, or booking form, stating clearly what’s being provided (probably by reference to a brochure, poster or leaflet) and how much it will cost;

- collecting information from clients on existing medical conditions, special dietary requirements and other special needs in order to provide a better service, tailored to their needs;

- parental consent from parents/guardians so that young people can participate on their own;

- joining information to clients prior to the activity, including such things as a list of clothing and equipment they will have to provide for themselves;

- an honest and open statement to clients about the ‘residual risks’ involved, so they are quite clear that, whilst everything reasonable is being done to look after them, there are still things that can go wrong. Sometimes called an ‘Acknowledgement of Risk’, this is not a legal disclaimer, but simply a reminder that our wild natural environment is not always comfortable (e.g. rough footpaths, big drops, cold water, inclement weather, rough forests, breaking waves etc) and outdoor activities have the potential for high risks;

- feedback/evaluation procedure, including a facility for clients to record complaints.

Of course, not all of this is appropriate for all types of provision, but the embodied principles are relevant to all, and the assessor will expect evidence of an appropriate and effective channel of communication between business and client. Some providers work on a ‘turn up and do it’ basis, and it is obviously inappropriate to go through a major paperwork exercise before the visitors can get started. However, a slimmed down version is still possible and may be desirable.

3.4 Insurance

3.4.1 Employer’s Liability Insurance: – this is a legal requirement, and it must be on display. Applicants will be asked to confirm their compliance with this.
3.4.2 Public Liability and/or Professional Indemnity: although not a legal requirement, it is both sensible and standard practice for all outdoor activity businesses to take out cover against anticipated claims in the Civil Courts. For accreditation purposes, ROAM Cumbria expects, and may check, evidence that this form of insurance is held.
3.4.3 Personal Accident: it is unusual, although some providers do offer it, for this to be included in a course or session fee. It is normally the responsibility of individual clients, if they require cover, to arrange it for themselves. Good practice suggests that this should be made clear to clients at the booking stage. It may also be helpful if providers can offer, to those clients who ask, a simple pre-arranged deal with a known insurance broker.

3.5 Environmental Impact
Cumbria – The Lake District is a beautiful natural area, but has come under increasing pressure in modern times. Housing, Industry, Transport, Power Generation, Water Supply, Farming and Tourism have all had a huge impact on our environment, here in this land of Lakes and Mountains.

It can no longer be described as a ‘wilderness area’, and is becoming increasingly fragile in its sustainability. It may not quite be another M25 just yet, but there are certainly times in the Central Lakes when the only difference between the road and the car park is that you don’t have to pay when you’re stopped on the roads!! !

So it’s especially vital that businesses whose existence is crucially dependent on this wild, natural environment - and the visitors that this attracts - are at the forefront of environmental awareness.

The ROAM Cumbria Scheme will therefore expect Members to:

3.5.1 Make efforts to minimise the impact of their own businesses on the local environment. This will involve consideration of issues such as:

a. Pollution - litter, chemicals, noise, light, vehicles etc
b. Waste - re-using/re-cycling
c. Erosion – paths, bridleways, green lanes, river banks etc
d. Awareness of particularly sensitive areas, and species
e. Avoid further overcrowding of the ‘honey pots’

3.5.2 Actively support and promote the principle of environmental sustainability (‘Sustainable Tourism’) within Cumbria - The Lake District.
3.5.3 Carry out an ‘Environmental Audit’ of the business, then draw up and implement a ‘Green Action Plan’, however seemingly insignificant that may be, based on what can realistically be achieved.

4. Safe Management of Adventurous Activities

In order to be accredited, anyone that offers adventurous outdoor activity services involving instructing (taken, in this document, to include teaching, training, leading, guiding, coaching, facilitating etc) must follow well established approved codes of practice (ACoP’s). Most activities have a National Governing Body (NGB) or well-established Trade Association, and many have schemes of training and assessment for instructors at different levels. These schemes are the mechanism by which ACoP’s are developed, refined and promoted.

4.1 Competence
The key to providing activities that are both safe and adventurous lies in using competent instructors. Competence is not necessarily the same thing as qualification. Full competence requires a combination of hard and soft skills (as evidenced by a qualification) together with experience and local knowledge. Instructors can be competent without a qualification, and qualified instructors may not always be competent in all situations.

4.2 Risk Management and Safety Policies
Depending on the size of the business, there is a need for a system to manage these competent instructors: to select the right people; give them a proper induction; provide further training as required; monitor what’s happening in the field; and use various forms of feedback to fine tune the ‘system’. This process is normally summarised in what is often called a ‘Safety Policy’. It may also include sections on operating procedures, emergency procedures, equipment policy, incident reporting etc.

A large organisation with lots of staff will need a more complex management system (and the Safety Policy is likely to reflect this), whereas a competent sole trader may simply be able to ‘get on with job’. The aim of a business document is to share and communicate key issues. This is usually done best by a document that answers the following three questions:

Is it NECESSARY? Are you telling people what they already know, or what they don’t need to know?
Is it CONCISE? Or is all the important information hidden amongst a lot of interesting but irrelevant waffle?
Is it EFFECTIVE? Does it achieve what it was produced to do?

4.3 Risk Assessment
In an industry where excitement and adventure is the product, it’s inevitable that there will be risks, and these need to be analysed and managed so that the benefits of taking part far outweigh the potential costs. Risk assessment used to be just a ‘buzz word’, but now it’s part of everyone’s daily vocabulary. ROAM Cumbria expects risks to be identified and managed, but it does not assume that the safety of visitors is assured by having a lengthy document called ‘Risk Assessment’ sitting on the shelf. It’s more important to have experienced instructors who, based on this experience, their training and their local knowledge, are constantly assessing the changing risks and taking decisions minute-by minute when working outdoors. Safe adventure in a hazardous natural environment like that of The Lake District is all about judgement.

4.4 Adventure Activities Licensing
After the Lyme Bay canoeing tragedy, statutory Licensing was introduced to protect children from another multiple fatality in the outdoors. Progressively, over the eight years of Licensing, the inspectorate (Adventure Activities Licensing Authority - AALA) has evolved a benchmark, based on the general guidance in the Regulations, for the safe management of adventure activities.

Many providers in Cumbria hold licences. In fact, during 2005 some will have been inspected for the ninth time, and know exactly what is expected of them. Some may have made certain changes to the way they operate over this period, based on requirements, or advice from AALA.

As Licensing is widely understood and generally accepted, there is no sense in trying to establish a different set of principles. ROAM Cumbria does not plan to re-invent the wheel, but will use the experience of Licensing to guide its own approach to the management of safety.

Licensing only has a narrow remit – it only applies to the (mainly) commercial provision of:

- the most common activities (climbing, trekking, canoeing, sailing, caving);
- above a certain minimum operating level;
- to under 18 year olds.

Many of the businesses in ROAM Cumbria will be outside the scope of the Regulations, either because they only work with adults; or because they are a voluntary organisation; or because the activities they offer are either not covered by the Regulations, or are only provided at a low level (e.g. canoeing on a canal, or rock climbing on an artificial wall).

Nevertheless, the basic principles of Licensing are quite general and can be applied to all forms of provision.

As new activities appear in Cumbria – the Lake District, or within the Scheme, ROAM Cumbria will publish (or cross-reference to) specific guidance on these activities so that businesses are clear about what is expected of them.

5. Principles of Adventure Activities Licensing

As with all Regulations, what the general public needs is a translation! The following points are based on the Licensing Authority’s interpretation of the Guidance supplied by the Health and Safety Commission in 1996 (with minor revisions in 2004). These principles also include various aspects of industry ‘good practice’ that have been absorbed by the Licensing inspectorate. ROAM Cumbria businesses will be assessed according to these criteria.
In listing and explaining these assessment criteria, it is assumed that the applicant is a ‘business’, ie they need to employ instructors and/or other staff at times. These instructors may be permanent, seasonal, contracted (freelance), trainees, volunteers etc.

Some of the criteria below may not apply to those businesses that operate as genuine sole traders, or small partnerships (up to three genuine partners), but the principles represent good practice and apply to everyone, even if the precise detail does not seem strictly relevant to your particular business.

5.1 Staff Competence
As already indicated, good staff are an essential requirement for safe, high quality provision and before an instructor is deployed to work with clients, there are some important principles that should be followed:

5.1.1 Recruitment
a. References – should be sought and followed up, even if only informally. This could just mean as little as a couple of phone calls to people in the industry that you know and trust.
b. Qualifications – check them, preferably by seeing the originals. Are they relevant to the work, and are they still valid? (see Section 5.1.6)
c. Experience – do they have the right kind of experience, preferably in the local area, or a similar environment, and have they worked with your sort of client group, using similar equipment, before?
d. Criminal Records Bureau (CRB) www.crb.gov.uk/ – it is normal nowadays for instructors who work with young people, to be ‘police cleared’. This normally means an ‘Enhanced Disclosure’ – some businesses are themselves registered to seek such disclosures, or some instructors may have their own from previous employment. This is not a legal requirement, but it is certainly advisable to check police records where the instructor may be required to work unsupervised with young people.

5.1.2 Induction
Even people with the right qualifications and relevant experience are not normally set to work on their own without some form of induction. By all means explain the policies and routine procedures back at base, but the induction process is incomplete without a practical component.
Good practice suggests that a progressive transfer of responsibility is likely to work best: the new instructor observes an experienced practitioner running a couple of sessions first; then they gradually take over responsibility for more and more of the session, still under the guidance of the experienced person. Only when both are happy is the decision taken to ‘approve’ the new instructor to work unsupervised, or as a session leader.

How long this process takes depends on the amount and relevance of previous experience – it could be a couple of days, or it may be a year. A useful concept here is ‘margin of competence’ (or perhaps you might like to think of it as the ‘Comfort Zone’). How much ‘spare capacity’ does the instructor have in relation to what he or she is being asked to do? If the margin of competence is high, the induction process may be relatively short & simple: but if the instructor is to be deployed close to their limit of competence, then a much more extensive induction will be needed.

It is expected that there will be an outline record of this process – who?, where?, date?, plus the occasional comment on anything significant and unusual. As with any effective record system, this needs to be kept very brief and simple. The purpose of the record is primarily to keep track of where things are ‘at’ in the induction process itself. It may also be useful evidence for assessors of one sort or another; or in the worst-case scenario, to prove to a Court that you have ‘taken all reasonable steps’.

ROAM Cumbria managers are therefore expected to carry out a reasonable process of practical induction before deploying new staff. ‘Reasonable’ should reflect the perceived ‘margin of competence’ of the new instructor. Once the new instructor has been fully inducted, and set to work, that isn’t the end of the process – you now need to think about deployment, on-going training and monitoring/feedback.

5.1.3 Deployment
Staff must only be deployed ‘within the remit of their competence’. This means that, as they broaden their skills and gain experience, ie become more competent, they can be deployed at a higher level, or to lead a different activity, or to work with more difficult clients etc. This is likely to mean further training, and further induction before they can be ‘promoted’ to work at higher levels.

5.1.4 Staff Training
The competence of leaders and instructors will develop naturally in time through further experience. In the outdoor activity field, much of this experience is gained by doing the activity in one’s own free time, but there are aspects of this development that may need to be professionally directed. The following are elements of further professional development that a good business will identify and provide for its staff. This in turn will be reflected by an improvement in the quality of service offered to clients, and help the business to grow.

A: Individual Personal Development: it is good practice to make time available for instructors to further their own experience and qualifications. This may involve in-house collective training (such as running a First Aid course, or a BCU Canoe Safety Test in house), or simply encouraging each member of staff to work on their own NGB awards by giving them time (or a grant) to go on courses.
B: Staff Team Development: getting all the instructors together from time to time and doing some practical, job-related training in the field is of great value. There are both technical and team benefits from this, and it often doesn’t matter greatly what it involves.
C: Worst-case Scenario Training: this is a pro-active form of training that asks ‘What If?’. Once a potential problem has been ‘foreseen’, some of the staff get together in the field and explore the problem and the various solutions. They then communicate their findings to the rest of the team. Examples of this are:-

- ‘How do we get a heavy, weak person into the rescue boat?’ or
- ‘How do we lower someone who refuses to put their weight the rope?’ or
- ‘How do we deal with someone half way up the climbing wall who discovers they haven’t tied on properly?’ or
- ‘Can we really sail this rafted pair of canoes up Windermere in a southerly Force 7, and what happens if we gets swamped?’ or
- ‘What do we do if the 4x4 stalls when crossing the ford in spate? etc, etc.

Of course, the ‘cost/benefit’ analysis must always be considered when looking for problems to solve – there is little point in spending huge amounts of time, money and effort on solving a problem that is, realistically, never likely to happen, and the consequences of which are non-serious in any case.

D: Incident Related Training: this is a re-active form of the above training scenario – the ‘what if’ has actually happened, and the solutions at the time were far from perfect. It is a very specific form of training, and is an essential follow-up to many significant incidents. As in type C, it involves getting the staff together and solving the problem practically.

As with the Induction process, it is good practice to keep a brief record of staff training – who attended, an outline of what was covered, where and when.

ROAM Cumbria managers are expected to provide training as necessary in categories C and D above as part of a normal safety management system. The larger businesses are also encouraged to make some provision for categories A and B, but the amount and cost of this ‘bonus’ training will obviously need to be based on business turnover.

5.1.5 Monitoring & Feedback
A lot of outdoor activity provision takes place with lone workers or small teams operating independently in remote locations. Furthermore, it is commonplace in this industry for many instructors to be engaged on a contract freelance basis, chosen from a sizeable pool of similarly experienced people. This can involve a lot of occasional staff working out of sight of managers for months on end. Although there should not be a problem with competent, experienced staff, management nonetheless still has a responsibility to know what’s going on, how their systems are working, and to gather evidence to support changes where necessary.

One of the most effective forms of feedback is direct observation by managers or other senior members of staff. In a good business, this process will not be seen as ‘policing’ but as ‘further professional development’, where senior staff observe, discuss and circulate good new ideas that they’ve seen. This process is also very useful for identifying further training needs.

There are other forms of feedback that can complement direct observation by managers, and these include such things as ‘peer monitoring’; chatting to staff when they return from activities; listening to the clients; session evaluation reports; accident and incident reports; noting damaged equipment; etc etc.
Once the feedback has been gathered and processed, it may be necessary, after discussion and due consideration, to make some changes in the way the business operates. The final part of this ‘Experiential Learning’ cycle is to circulate information on the changes to all relevant staff.

ROAM Cumbria managers will be expected to have an effective arrangement for obtaining feedback on sessions, and this should include some sample monitoring by direct observation. Once again, it is a good idea to keep a brief record of sessions that are monitored, because looking back over this record can help in planning or prioritising future observations. Managers are also expected to have some system of informing their staff of ‘need to know’ information arising from analysis of the feedback. This is likely to be verbal, face-to-face, for very small businesses; or in staff meetings and/or by written notices, memos, staff newsletters, email, or whatever, for larger businesses. The same method of distribution can be used for passing on a whole range of useful information to staff.

5.1.6 Qualifications
Where a particular activity has a well-established scheme for training, assessing and qualifying instructors (normally through a National Governing Body, or an equivalent Trade Association), then these qualifications will be taken as a benchmark of technical competence. ROAM Cumbria will expect members either to:

• use instructors with the recognised national qualification for the activity (where such a qualification exists), or
• provide for each unqualified instructor, a ‘Statement of Competence’, supported by some evidence, and signed by a suitably qualified and experienced ‘technical adviser’ (see below)

Where the activity has no national, independent, instructor training scheme, then the Member will need to provide evidence of the instructor’s relevant experience, and of their ability to operate in line with ‘good practice’. A person of ‘technical adviser’ status should confirm this evidence.

5.1.7 Technical Adviser or Activity ‘Specialist’
Every business should have access to sound advice at an appropriate level, for every activity they are involved in. A ‘Technical Adviser’, or an ‘Activity Specialist’ is a first point of contact for this advice. Typically this person should be very experienced and hold a higher-level qualification than is necessary to work at the operational level of the business, whatever that may be. Note the phrase ‘have access to’ – this doesn’t necessarily mean ‘employ’!!

For example, a business that runs kayaking on ‘Sheltered Inland Waters’ would normally deploy a BCU Level 2 Inland Kayak Coach as an instructor. In this case, technical advice should be available from a person who holds a BCU Level 3 Inland Kayak Coach award, as a minimum.

Or a business that leads groups on the high fells, using qualified Mountain Leaders Summer (MLS) - or leaders with an equivalent competence - would need to consult an experienced Mountain Instructor Award (MIA) holder, who is also a Mountain Leader Winter (MLW) should they need advice. In this case, the climbing qualification of the MIA allows the specialist to advise on the boundaries between walking/scrambling/climbing, and the MLW can advise on activities on the margins of winter conditions.

For activities where there are no well-established national instructor schemes, then a person of technical adviser status should have evidenced experience (both personal and instructional) at a higher level than that offered by the business.

For businesses that offer a range of different activities, they may need to have access to a number of experienced people covering all of the activities.

These ‘Specialists’ may be managers, or employees of the business, or may be independent and external. They do not need to be contracted, and they are not expected to provide advice unless management seeks it. If external, they should not need to be paid a retainer, but will quite reasonably expect a fee if they are asked for significant advice (such as, for example, training and assessing instructors and producing ‘statements of competence’, or providing general staff training).

5.1.8 Statements of Competence
Where a person’s competence is based on experience alone, or on a lower level of qualification than is normally expected, a Statement of Competence (SoC), signed by someone holding a higher level of NGB Award for that activity (the Specialist, or Technical Adviser), is required for each unqualified person. This SoC will probably be a single side of A4 with:

a) evidence to support the issue of the SoC
b) a clear statement of the level of approval, and any limitations on the scope of the statement (eg ‘Lake District hills in summer conditions only’, or maybe ‘Single pitch climbing and abseiling only at Lindale Slab’, etc)
c) name, signature and relevant qualification of the Specialist, or Technical Adviser
d) date of issue, plus its duration of validity

The ‘evidence’ in a) above could be a brief paragraph such as ‘I have been involved in training John Smith for ‘The Great Outdoors Ltd’, and have paddled with him personally on a number of occasions, both on rivers and in surf. I am aware that he has a current first aid certificate, and I have watched him run a safe and enjoyable kayak session with a group of Scouts on Windermere’ – or something similar.
Note that all ‘Statements of Competence’ are in-house only, and are not transferable to other employers in the same way as an NGB Award.

5.1.9 Evidence of Competence
Your ROAM assessor will expect to be shown some evidence that activity leaders are competent, and this will normally mean keeping staff records – ideally these will involve copies of qualifications and/or statements of competence, along with details of their induction, records of in-house training and assessment, plus any notes recorded after sessions monitored by senior staff. Note that ‘in house statements of competence’ are not transferable to other employers, as are NGB qualifications.

5.2 Activity Safety Policy/Operating Procedures
Most businesses will need to write something about the standards to which they operate, and to provide information to their staff about how they expect them to work. For a sole trader, this may just be one side of A4 – bigger businesses may need considerably more. Although a document like can be helpful, it is what actually in the field that matters. As a guide, the following sections should generally be included, even if they only consist of one line.

5.2.1 Measures of Competence
State what qualifications (or equivalent statements of competence) your leaders and assistants will hold for all the activities you offer, at each of the various levels.

5.2.2 Statement of Policy on Staff Induction, Training and Monitoring
A short paragraph setting out what your policy is (see above).

5.2.3 Group Sizes and Ratios
ROAM is aware that this is not a ‘one size fits all situations’ matter. However, you should have some standards that are broadly consistent with normal good practice, and your operating procedures need to explain the degree of, and reasons for, any flexibility. It is also important to explain clearly and unambiguously what you mean by any ratios that you may quote – for example, does 1:6 mean one leader plus one assistant, plus one other responsible adult and 18 clients? Or is this more accurately described as 1:18 with a competent assistant and one other responsible adult? This is an area where it is possible, by clever use of words, to mislead, or confuse clients.

5.2.4 Activities
It is useful to include a short section for each activity you do, with a few key bullet points. A good benchmark for what to include is to ask yourself ‘Is there anything about the way we do this activity which wouldn’t be a completely obvious way of working to a qualified and experienced, but new, instructor or worker?’ If there is, note it down – if there isn’t, it may be sufficient to state that you follow ‘normally accepted codes of practice as established by the NGB’ or something similar. A good example of this is the wearing of helmets for kayaking/canoeing on flat water – the BCU is not prescriptive about this, but your business may wish to be, one way or the other (or you may even leave it to the discretion of the instructor on the day?), so you should make a statement.

5.2.5 Assessing Risk
All businesses and workers are obliged to identify hazards, assess the risks that these hazards pose, and apply controls that reduce these risks to acceptable levels. Although ROAM members will be expected to have some sort of record to show that this process takes place, and is routinely reviewed, there is no one ‘right’ way to format this record. Normal good practice in the outdoors relies heavily on the ‘dynamic assessment of risks’ that is (or should be) carried out instinctively by competent instructors on a minute-by-minute basis during sessions. Obviously, this process cannot be recorded.
The normal ‘generic risks’ inherent within specific activities are controlled by staff who have trained, and been assessed by National Governing Bodies (or other respected organisations). It should not be necessary for a business that deploys demonstrably competent staff, to carry out generic risk assessments in order to arrive at controls measures that these NGB’s have refined over many, many years. Your ROAM assessor will not expect to see such detailed generic risk assessments – a simple cross-reference to practices promoted by a respected NGB or Trade Association will be quite sufficient
What is useful, however, is to write down those aspects of your business that pose risks which are both significant and unusual – the sort of thing that may not be obvious to a qualified practitioner. These may include:

- particularly problematic clients groups (special needs, senior citizens, behavioural problems, drunks etc);

- unusual activity locations (sewage outflow, tendency to flash flood, bull in a field, savage downdraughts, exceptionally slippery in wet conditions, irregular tidal flow, etc).

- special ways of working (unaccompanied groups, no safety boat, competitive activities, no drying room, operating from under canvas, water must be collected from streams, etc);

- or any other ‘problems’ that past experiences (or ‘near misses’) have flagged up.

A simple (and acceptable) assessment of risk might have just two columns:
Column 1: Here’s the problem;
Column 2: This is what we’re going to do about it;
And it is Column 2 that is important, because this is the outcome of your assessment of risk, and as such, it forms the basis for your business’s safe working practices.

5.2.6 Reporting of Accidents and other unusual ‘Incidents’
As well as your statutory requirement under RIDDOR (The Reporting of Incidents, Diseases and Dangerous Occurrences Regulation) to notify the Local Authority, or the HSE, in the event of a serious occurrence, it is important to encourage a culture within your business where all accidents and other safety-related incidents (including ‘near-misses’) are routinely reported to management. Genuine accidents will always happen, no matter how careful you are, just as they do in all walks of life, but if you are to learn from experience, all incidents must be reported and discussed.
It is also standard practice to keep some sort of record of these occurrences, and your policy should explain how this is to be done. Your ROAM assessor is likely to ask to see your accident and incident records, and may wish to discuss specific incidents, and what you have learned from them.

5.2.7 Emergency Procedures
This shouldn’t be a repeat of standard practice as embodied in First Aid and NGB Training Courses, but should be specific to your business. It should be based on what you do, and where you do it, and should reflect the specific sorts of emergency that you might reasonably foresee. For example, if you go underground, it is reasonable to anticipate that one day, a group may fail to surface as expected. Your emergency procedure may therefore include details of what action should be taken and when, both by management, and by the group leader in the event of this occurring.
Of course, it’s always useful to issue a handy outline procedure for whom to contact? When? And how? And for a sole trader operating in a remote environment, someone needs to know where they are and when they expect to return so that the emergency services can be alerted in good time if necessary.

5.2.8 Change of Plans – ‘Plan B’s’
Inflexible programmes can lead to the wrong activity taking place with the wrong group on the wrong day, in the wrong place – with potential consequences for both the safety and the enjoyment of the participants. Managers in an outdoor business need to build some flexibility into activities in order to accommodate the particular client or group, and the conditions on the day; whilst at the same time, retaining a degree of control of who’s doing what and where. There should always be a Plan ‘B’, and it is important that clients understand the need for this, and they may not always be able to do what they had hoped and paid for. A statement to effect is generally useful in promotional material and other information supplied to clients.
Your ROAM assessor may ask about arrangements to change activity plans: the level at which such decisions are made/approved, at what stage in proceedings, and who need to be informed.

5.2.9 Special Needs
If your business works with clients who may have a range of special needs (visual impairment, physical disability, chronic illnesses, nervous disorders, behavioural problems, lack of English language etc, etc), you will be expected to be well-informed of these needs in advance, have arrangements in place to accommodate them, and to pitch activities at an appropriate level. Amongst other things, you may need to increase the staffing/supervision levels.

5.3 Equipment
With a few exceptions, straightforward equipment failure is rarely responsible for accidents in the outdoors. It is more commonly misuse, or inappropriate use, rather than failure that causes the problems – hence once of the reasons why ROAM assessors will be looking for competent staff who know what they’re doing. It has been said by people in high authority within mountaineering that ‘the rope never breaks’ – even a very old one! But if you do a swinging abseil over a sharp slate edge you can cut through a rope in seconds – and that would apply equally to a rope straight out of the shop.

There are, however, some pieces of equipment which can and do fail, and where failure can be catastrophic. Generally the more complex a piece of equipment is, the more there is to go wrong, and certain failures in items such as mountain bikes, motor vehicles, air ‘craft’ of one sort or another (including parachutes), divers’ breathing equipment, ocean going yachts, etc can indeed be very serious if not fatal.
Your ROAM assessment will expect all your equipment to be in good working order – ‘fit for purpose’. It doesn’t have to be new, or shiny – it simply has to work efficiently without breaking. This will involve you in:

5.3.1 Inspection and Maintenance
Cursory inspection should take place at the point of issue, or use – more thorough inspection and maintenance will be required on a regular basis. The meaning of ‘regular basis’ will be governed by factors such as: the likelihood of faults developing, the frequency of use (or abuse), and the nature of this use. This is likely to vary from ‘after every session’ to ‘once a year’, depending on what it is and how it’s used. And if untrained personnel are asked to do inspections, they will need a clear checklist of exactly what to look at, and the likely problems that may be found. A record of inspections, by item, should be kept – this allows minor defects to be noted and checked at the next inspection.

5.3.2 Usage Logs
Whilst this may be helpful for budgetary purposes (how long does a particular brand last?), or if maintenance intervals must be accurately based on usage (as advised by respected organisations such as the Department of Transport, or the Civil Aviation Authority!), it is not generally a safety issue for traditional items of outdoor equipment (tents, ropes, kayaks, etc), and ROAM businesses will not be expected to maintain such logs for this sort of equipment. However, a record of when each item of equipment was commissioned is useful when considering the working life of some items.

5.3.3 Manufacturers’ Recommended Maximum Working Life
Your ROAM assessor will not insist that members adhere rigidly to manufacturers’ guidelines in this area, unless they can see evidence that equipment is no longer ‘fit for purpose’. However, older equipment will need more frequent inspection and more maintenance, and evidence of this will be sought. It is sometimes advisable to do some ‘sample destructive testing’ from batches of old equipment. Results of this can support your decision to continue using it – or maybe confirm that it should all be thrown away!

5.3.4 Storage
Equipment should be stored in a way that does not cause unnecessary deterioration – some things need to be dried before storing; others need to be kept away from light and heat; batteries may need to be fully discharged every so often; etc. Storage of critical safety items should be ‘secure’, particularly in areas where there is a high risk of vandalism or tampering.

5.3.5 ‘Quarantine’
There needs to be a clear arrangement for removing defective items from use until they have been repaired (or destroyed). A clearly marked quarantine area, or container, and/or a ‘label system’ for large items, is normal good practice. But whatever system is used needs to be quick to implement when a defective item is identified – instructors are not good at filling in complex report forms!!

5.3.6 Hired In Equipment
If you ‘hire in’ certain items, then your business has the same responsibility to your clients that you would have if the equipment were your own. Consequently, it may be advisable to carry out some sample checks of your contractor’s equipment, and to check their arrangements for inspection and maintenance.

5.3.7 Quantity of Equipment
Generally you will need more equipment that you expect to use at any one time to allow for defective items, or in the case of sized items (boots, buoyancy aids etc), where everyone turns up with size 9 feet! A good range of sizes of items like buoyancy aids will allow them to be properly fitted. A badly fitting buoyancy aid (or indeed a walking boot) can be a safety issue, and may be unacceptable for ROAM.

5.4 Suitability of Activities
When observing activities taking place, your ROAM assessor will want to see that the level of activity is appropriate for the particular clients – climbing overhanging ice may be fun for a Mountain Guide, but it may not be so appealing for (most!) 6 year old girls! This is obviously an extreme example, but the aim of ROAM is to help visitors to Cumbria to buy a service that does provide a challenge, yet is both desirable and achievable at the same time.

6. ‘Work in Progress’

NB: ROAM aims eventually to provide brief notes on minimum acceptable levels of ‘normal good management practice’ for each particular activity. This is not the same thing as telling leaders/workers what they should be doing on session – these notes aim to give managers an indication of what advice and support they should be giving to their staff in the form of very concise, activity-specific guidance and operating procedures. These will be published gradually over the first couple of years of the Scheme, and will reflect, to some extent, the findings of the assessors during the early part of the accreditation process.

This ‘consultation approach’ is in line with the intention that this Scheme should be defined by the outdoor industry itself, and not by Cumbria Tourism or its assessors. We know that the standards already exist in the field: Cumbria Tourism is neither competent to write them, nor does it need to. Existing standards will simply be used as the benchmark.

1 March 2005