In March this year, when he was speaking about the (then unpublished) regulations, he said that he did not want anyone to go through what those in the Lyme Bay incident had suffered. Quite how these regulations will prevent a repetition has yet to be explained; indeed, just one death at an activity centre which has been inspected is enough to show that no inspection regime is a guarantee againstaccidents.
More fundamentally, the regulations have the same two-faced quality as national curriculum Orders: they are so important that everyone must abide by them, except those who don't have to. While some operators, including voluntary bodies with no regular income, have to fork out a minimum of around Pounds 500 for registration and inspection, others don't. Even the exemptions are inconsistent:
* If I take pupils from my local school trekking, I need a licence, but if I take pupils from my own school, I do not.
* If a voluntary organisation provides activities which are open to any young person, it needs a licence, but if it gives out membership cards it does not.
* If the most highly-qualified instructors in the country take out a group, they need a licence, but put them all in a cadet force uniform and they don't. Who can honestly say that this is the product of a serious attempt to improve safety?
A study of fell-rescue incidents in one mountainous area in 1994 showed that of 65 incidents involving people under 18, 42 would have definitely been exempted from the regulations, while only five were within their scope. The other 18 comprised those out of the regulations' scope (through absence of payment, as in family groups) and those incidents for which relevant information was not available.
This small piece of statistical evidence appears to sum up what many people are now realising: the adventure activity learning regulations are a sledgehammer to crack the wrong nut.
Cullercoats, North Shields