It aims to include activities and centres outside the statutory licensing scheme, which has started slowly. About 100 Scottish providers have applied.
The Stirling outdoor education conference, organised by the Scottish Environmental Education Council, heard that providers are organising activities such as raft-building, ropes courses, team building and gorge walking, which are not within the "scope" of the legislation.
Piste skiing is also excluded. But the apparent flaw in the legislation was highlighted last month when two 16-year-old snow boarders were lost overnight at Cairngorm. The case for exclusion rests on the assumption that rescue services are close at hand.
Outdoor organisers also underlined that safety concerns, ironically, were not especially about risk activities on the mountains or water. Many minor accidents occurred in showers or rooms.