Problems with the proposed new safety procedures

Hi SBW committee,

When trying to decide what is best for the club I have always applied four maxims, which are shown in the paragraphs below.

1. If It Ain't Broke, Don't Fix It
2. KISS (Keep It Simple, Stupid)
3. Don't Make Leaders Do Unnecessary Work
4. Do No Harm *

In my opinion, the proposed safety procedures violate all four of these maxims - mainly because of the inclusion of the procedures related to PLBs and the safety contacts registered with them, and to defining trigger times - all of which are way too complicated.

I appreciate that a lot of work has been put into formulating the proposed new safety procedures, but we shouldn't accept the procedures merely because of the work that was put in - we should only accept them if they are good for the club.

During the past couple of months I have heard a lot of comments like "he said this" and "other clubs do that" and "we have to cover our butts" and "we have to impress our insurance company" but at the end of the day, we only have to read the advice given by the Bushwalking Australia website and the insurance questionnaire that their insurer sends out every year. Nothing else is relevant!

So here is my analysis of the proposed new safety procedures, and at the end of this massive email I give a few suggestions that arise from what I've read on the Bushwalking Australia website and in the annual insurance questionnaire.

The Good News
I have no major problem with section 2 of the new procedures which deal with "Accidents / Injuries / Incidents". These are pretty much identical to the current protocol on the website anyway. The main difference is one added sentence saying "Details of all incidents are reviewed by the Risk Management Officer". This extra sentence doesn't have to be there - because we have a standing resolution which states "Accident / Incident reports shall be reviewed at the committee meeting immediately following the receipt of the incident report" - so it is already being done by us all.

The Bad News
Many of the things I am about to mention might seem fairly trivial, but they all add up to show that the proposed new safety procedures need to be examined and discussed by the committee in great detail before we even consider accepting any part of them.

1. Andante Walks
People who haven't been in the club very long might not understand that Andante means "at a leisurely pace". It doesn't mean "on track and always within mobile phone coverage". The Andantes can go where they like, and some of those places might be Off Track and require taking a PLB. In fact, one of the first walks ever done by the Andantes was a primarily Off Track walk to Churinga Head overlooking Ettrema Gorge. I'm not sure what the mobile phone coverage is like at Churinga Head, but if I was leading a walk there I would definitely be taking a PLB. By denying PLB access to the Andantes, the new safety procedures limit all Andante walks to areas with mobile phone coverage.

How would Andante leaders know that an area has mobile phone coverage? They'd probably have to do a reccie to find out. And on that reccie they should probably take a PLB just in case they find that the area doesn't have mobile phone coverage!

2. On Track Walks
The points raised above also apply to the On Track walk that doesn't have a PLB. There are On Track walks that may go to areas without mobile phone coverage, like Mt Bushwalker, the track from the top of the Crackenback chairlift to Mt Kosciusko, the Kangaroo River Firetrail, the track to Beehive Point, the Old Burrier Firetrail, Yalwal, Coolendel etc.

3. The supposed "summary"
There is information in the box containing the summary that doesn't actually appear in the actual safety procedures e.g. "For andante walks, the description in the live program is sufficient".

4. Why is the summary box included in the procedures?
If the procedures were straight-forward and easy to understand, why do we need a summary box? Is the summary box meant to be included in the new safety procedures document on the website, or will it be removed? Doesn't the addition of a summary box mean we are just repeating the information contained in the rest of the procedures? Is important information missing from the summary box, and if it is, why wasn't it included in the summary? Will people be tempted to just read the summary rather than the rest of the safety procedures?

5. Location of club PLB holder information
If the summary box is staying in the procedures, why do we need to have the club PLB holder information at the end of the document in section 4? If the summary box is not staying in the procedures, why is the club PLB holder information in the "Protocol for PLB response"? Shouldn't it be in Section 1 of the safety procedures where the PLBs and their safety contacts are first mentioned?

6. Why is the PLB pool system being abandoned?
Our pool of four PLBs was divided into two PLBs in Nowra, and two PLBs in the Bay and Basin area. The new procedures abandon this system, and instead assign PLBs by walk type - two Off Track PLBs - one in the Nowra area and one in the Bay and Basin area, one Hybrid PLB in the Bay and Basin, and one Ontrack PLB in the Bay and Basin. This means that On Track leaders and Hybrid leaders from Nowra or further north must now travel an extra 60 kilometres to pick up a PLB, and an another extra 60 kilometres to return it!

7. There is nothing in the procedures that state that a PLB must be carried or even when it should be carried
I've looked - but I couldn't find anything. Of course, the procedures are pretty complicated, so it could be in there somewhere.

8. Trigger time #1 - extra work for leaders
The "30 minutes after dark" trigger time we currently use was originally decided upon because it meant the club responded much more quickly in winter when days are shorter and colder and the consequences of a "night out" are likely to be more severe than during the warmer months. It also means that our response in warmer months is delayed, as a late party has a lot more daylight available to them to overcome any problems they might have, so an earlier response might be inappropriate. And remember that this trigger time was decided in the time prior to PLBs - this will become important later on in this critique.

The proposed safety procedures define the trigger time as 3 hours after the "expected return time". Each leader is expected to give "the Safety Contact sufficient details of the proposed route and a realistic estimate of the expected return time". The Safety Contact is defined in the procedures as "the number 1 emergency contact registered for the PLB". The new procedures also require a leader to notify "the Walks Completion Contact of an appropriate time to trigger a walk 'overdue'".

All of this is unnecessary extra work for leaders. Why does the Safety Contact need to know the expected return time? They will be contacted if the PLB goes off, but they will not be sitting at home watching the clock as the expected return time approaches. The only person who needs to know the trigger time is the Walks Completion Contact.

9. Trigger time #2 - why so many trigger times?
The new procedures say "If the Walks Completion Contact has not heard from a walk leader by the agreed trigger time, OR 3 hours after sunset, OR earlier, depending on conditions, then the Walks Completion Contact will contact the Safety Contact to confirm that the walk is overdue based on the 'expected return time' on the Attendance/Waiver Sheet. This means that we are making a leader decide on an expected return time, then send it to two different people, both of whom could change depending on whether their walk is a Wednesday walk or a weekend walk, or whether they are taking the Hybrid PLB or the Off Track PLB#1 or the Off Track PLB#2 - and then the trigger time could be their trigger time or any other trigger time depending on the judgement of the Walks Completion Contact!

10. Trigger time #3 - what happens if the trigger time is reached and a walk hasn't returned?
The new procedures say "If the Walks Completion Contact has not heard from a walk leader by the agreed trigger time ... then the Walks Completion Contact will contact the Safety Contact to confirm that the walk is overdue ...". Why does the Walks Completion Contact need to contact the Safety Contact for confirmation? The walk is either overdue or not overdue, depending on the judgement of the Walks Completion Contact. Perhaps this has been included so that the Walks Completion Contact makes sure that the PLB hasn't been activated, but even this is unnecessary as surely the Safety Contact will contact the Walks Completion Contact if the PLB goes off!

11. Trigger time #4 - wrong assumption #1
The new procedures seem to make a couple of wrong assumptions. The first wrong assumption is that a leader of a day-walk will set the expected return time on the same day as the walk. This will not necessarily be the case. If I am leading a walk and I have a PLB, I will probably set the expected return time as midday the next day. If I have a life-threatening emergency, I will activate the PLB, but if my walk is merely delayed and we have to spend a night out, a midday expected return time gives me time to walk out the next day without the need for the involvement of the Walks Completion Contact or the Safety Contact. I simply ring the Walks Completion Contact before midday to confirm the safe return of my walk.

12. Trigger time #4 - wrong assumption #2
The second wrong assumption is that the trigger time should always be set 3 hours after the expected return time. If I set a midday the next day expected return time, I want people to start looking for me at midday - not 3pm! Do I then change my expected return time to 9am because I actually want the search to start at midday? Do we change the definition of the trigger time as "either your expected return time plus 3 hours if the expected return time is on the same day as the walk, or exactly your expected return time if your expected return time is the day after the walk"? That would be nice and simple ...

13. Trigger time #5 - is it important?
"Trigger time" is not mentioned in the Summary box, and all references to it only appear in section 3 - Protocol for Overdue Walkers. It's a bit late then - it needs to be mentioned earlier in the procedures.

14. Expected Return Time - is it important?
"Expected Return Time" is not mentioned in the Summary box.

15. Protocol for Overdue Walkers #1
The references in this paragraph have been mentioned before, but have been included here to show how the whole protocol needs to be revised. The paragraph on "Setting a trigger time for action" should not be here - it should be in the first section - "Safety Procedure" (for leaders). "Reporting end of walk" should not be here - it is already in the first section too. The Protocol for Overdue Walkers is actioned when a leader hasn't reported in, so a reminder in this protocol to report in is pretty silly. The sentence containing "agreed trigger time, or 3 hours after sunset, or earlier, depending on conditions" as mentioned earlier is ridiculous. Having the Walks Completion Contact contact the Safety contact to confirm a walk is overdue is unnecessary.

16. Protocol for Overdue Walkers #2 - the Police
The safety procedures state that "police will want to know details of the planned walk route, names, and number of walkers - and possibly fitness levels and equipment carried". Really? They might want to know the route and the number of walkers, but will they really want to know their names?

17. Protocol for Overdue Walkers #3 - Route on the attendance sheet?
The safety procedures state that "Route, names and numbers will be on the Attendance/Waiver sheet lodged with the Safety Contact". At the moment the route is not included on the Attendance/Waiver sheet.

18. Protocol for Overdue Walkers #4 - role of the Safety Contact
The safety procedures state that "Route, names and numbers will be on the Attendance/Waiver sheet lodged with the Safety Contact". As mentioned before, the Attendance/Waiver sheet doesn't need to be sent to the Safety Contact. The route of the walk will be on the program, which the Safety Contact will not necessarily be able to access. The names of walkers don't need to be known by the police or the Safety Contact. The Safety Contact only needs to become involved if a PLB is activated. If this happens, they should give AMSA the contact details for the Walks Completion Contact. We've had about 5,000 walks go out in the past 20 years without one of our PLBs being activated - sending 5,000 attendance sheets to Safety Contacts during those two decades would have been a total waste of time and effort, when all that was needed was for the Safety Contact to provide the phone number of the Walks Completion Contact to AMSA.

19. Protocol for Overdue Walkers #4 - Walkers return to mobile coverage area
The safety procedures state "walk leaders should have the telephone numbers of the Walks Completion Contact and the Safety Contact with them on the walk to enable appropriate calls to be made as soon as telephone coverage is available". This procedure should not be in the Protocol for Overdue Walkers - it should have been included earlier. It actually doesn't need to be mentioned at all, because the leader will have the Attendance/Waiver sheet on the walk, and it lists the phone numbers of the two Walks Completion Contacts. And why would a leader need to contact the PLB's Safety Contact?

20. Protocol for PLB response #1 - names?
The protocol notes "NOTE: If the number 1 contact is not available, AMSA will call the number 2 contact and then the number 3 contact. It is important that the three emergency contacts have each other's names and telephone numbers as well as the name and number of the Walks Completion Contact". Why do the three emergency contacts need to know each other's names and telephone numbers? If there is a reason, could that reason be included in the procedures?

21. Protocol for PLB response #2 - do we need to notify Safety Contacts
In the big scheme of things, notifying any of the Safety Contacts - 1, 2 or 3 - about the route, names, numbers, fitness levels and equipment carried - is not really necessary. Even if AMSA can't contact anybody, the search and rescue will still go ahead.

22. Protocol for PLB response #3 - necessity?
Do we really need to have a Protocol for PLB response? It's pretty much out of our hands once a PLB is activated.

23. Reccies
Reccies open up a whole swathe of possible safety procedures, and I don't believe that they are covered adequately in the new procedures. The carrying of a PLB on any reccie for any type of walk should be compulsory, because the leader obviously doesn't know what sort of terrain / risks that will be encountered.

24. Question 1 in the new procedures #1 - capability
Question 1 says "Prior to the walk, leaders should ask themselves ... 1. Do I have the capability to lead this walk?" This goes without saying - a leader would not put on a walk that they are incapable of leading. If their physical or mental capacity was reduced between the time the walk was submitted and the actual walk itself i.e. through injury or illness, it goes without saying that a leader would either cancel their walk or try to find an alternate leader. It would be silly to include this question in the protocol - things that go without saying shouldn't be said.

25. Question 1 in the new procedures #2 - reccies
Question 1 In the new procedures states "Prior to the walk, leaders should ask themselves ... have I done a reccie?" This too goes without saying - a leader would know whether or not they have done a reccie! I would suggest changing this question to "Should I do a reccie?" or even better to "Leaders should reccie the walk if they believe it may have potential safety concerns".

26. Question 2 in the new procedures #1 - how many walkers
Question 2 in the procedures should change from "How many walkers can I safely lead on this walk?" to "Leaders should determine the maximum number of walkers that they can safely lead on this walk".

27. Question 2 in the new procedures #2 - minimum numbers
The note to this questions says that Bushwalking NSW recommends a minimum of 3 walkers. The minimum number of walkers for Shoalhaven Bushwalkers has always been 4 walkers. If a person is injured but not seriously enough to use a PLB, and help is needed and mobile phone coverage is unavailable, this allows one person to stay with the injured party while two people walk out or find an area where mobile coverage is adequate. A minimum of 3 walkers is unsafe, with one person having to walk out solo. I think our insurers would be more impressed if our minimum was 4 rather than 3!

28. Question 3 in the new procedures - experience and capability
The format used in this section of asking questions is terrible. The format works if a question is asked and instruction is given depending on the answer, but just asking the question is dumb. For example, question 3 says "Have I done what I reasonably can to check the experience of walkers whose capabilities I do not know?" The leader could answer "No" - and the procedure has been followed - but nothing has been accomplished. What is needed is a follow-up question such as "If the answer is no, check the experience of walkers whose capabilities you do not know". A better solution is just to get rid of the question format, and say exactly what the leader must do.

29. Change all the questions in Section 1 to statements
Changing the questions into statements produces a much more logical format. With this in mind, and arranging the requirements in a more logical chronological order, the protocol in section 1 becomes as follows -

Prior to the walk
1. Leaders should include enough details of the proposed route in their walk description to enable a precise search area if necessary.
2. Leaders should determine the appropriate "trigger" time when the walk will be overdue and include this in the walk description.
3. Leaders should reccie a walk if they believe it may have potential safety concerns.
4. Leaders should set a limit for the maximum number of walkers that they can safely lead on the walk.
5. At the time of registration, leaders should assess the capability of all walkers to safely complete the walk, and reject them if necessary.
6. Immediately prior to the walk, leaders should reject walkers if they are not appropriately dressed for the proposed route and forecast weather conditions.

30. Point #5 in Section 1 of the new safety procedures - are we a nanny state?
This point says "Check that all walkers are aware of appropriate clothes and equipment for the proposed route and forecast weather conditions (eg, thick bush so recommend against shorts; showers forecast so bring wet weather gear)? Ask walkers to ensure that they have sufficient food and water plus extras for emergencies or delays. Remind walkers to bring a First Aid kit".

The club requires its walkers to be aware of their responsibilities. The leader should include the need for anything extra in their walk description. We should not require the leader to constantly remind walkers of their responsibilities. Should we really make leaders remind walkers to bring a first aid kit?

31. Emergency Procedures
We have a PDF file called "Emergency Procedures" on our website. It gives some procedures on what a leader / group should do if lost, if someone is injured, or if someone can't or won't continue on a walk. None of this is mentioned in the proposed new safety procedures.

32. What did I mean by "Do No Harm" in my introduction in this email?
I think that if the proposed new safety procedures are implemented as they are, they will cause some leaders to stop leading - and that would harm the club.

I haven't proof-read these comments, so I apologize in advance for any errors, typos etc. but I think you will get the gist of my arguments. I would suggest that the points listed above should be enough to convince committee members of the need to question everything in the proposed new safety procedures.

If you are still reading this, here is a suggestion for an alternate set of additions to our current safety procedures that would bring them up to date ...

1. Require our walk leaders to have a PLB - any PLB - on every walk that goes to an area without mobile phone coverage.

2. As stated in section 5.3 (k) of the BA Risk Management Guidelines, we should schedule a review of the club's risk management procedures and forms at a committee meeting once per year, and refresh all office bearers' awareness of risk management plans.

3. As stated in section 7.8 of the BA Risk Management Guidelines, we should set rules on which types of activities should be cancelled and under what conditions, i.e. heat policy, bad weather policy, fire policy.

4. We should include our current "Leader Responsibilities" in our Safety Procedures, and add the points mentioned in 29 Prior to the Walk (above) if required.

There are probably a few other minor tweaks that need to be made, but that's about it.

And finally, can somebody answer this question ...

How does an Attendance / Waiver sheet in the hands of a Safety Contact or even a Walks Completion Contact make anyone on that walk safer?

Cheers,
Brett