Adventure Activities Regulatory Regime Review | Adventure Activities Regulatory Regime Review

Nov 2021 - Thank you to all members who contributed to our feedback on the "Adventure Activities Regulatory Regime Review".

The NZISM response on behalf of members has now been submitted to MBIE.

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The New Zealand Institute of Safety
Management (NZISM) Submission to MBIE
Adventure Activities Regulatory Regime Review
Author: Selena Armstrong, Chief Executive Officer, representing members of NZISM
Contact: ceo@nzism.org, mobile: 0220 290 313
Please find below our response to the questions proposed in the consultation document
Managing Natural Hazards
Q1. In your experience, how well do you think natural hazards are currently being managed
in the adventure activities regime?
There is a difference between how the Regulatory regime manages natural hazards and what is done
by individual operators. We don’t believe that at present this is being well managed through the audit
system. There is a lack of a framework for understanding how to factor in the implications of natural
hazards that are not easy to predict on activities. The audit regime tends to focus on having a system
for risk management but not necessarily on awareness of the critical risks involved in these activities
and practical application of the hierarchy of controls. We believe a review of the audit system should
be undertaken.
Q2. How do you think we can use mātauranga Māori to support good management of
natural hazards within the adventure activities regime? Are there other perspectives on how
natural hazards should be managed that should be considered?
This is definitely relevant, and we believe there is an opportunity for increased knowledge and
understanding of Te ao Māori and mātauranga Māori to support better management of risk with
natural hazards. Good management practices should also be competency lead and assessed.
Duties for operators in managing natural hazards
Q3. Do you think an explicit requirement for operators to assess and manage natural hazard
risks will improve safety in the adventure activities regime? Why/why not?
Yes, we would like Worksafe to take a firmer hand and produce the guidance that sets out their
expectations, that if applied will enable the industry to meet legal obligations. However, what we
want operators to be aware of is their moral and ethical obligations and not purely focus on their
legal obligations when managing the risk of hazards. We believe this is an important component to
operators understanding good risk management.
Making this explicit would be helpful as long as the approach is practical, easy to understand and
linked to a clear set of objective criteria. Very few natural hazards are easily predictable in terms of
the impact on a particular location or activity so the obligation might need to be framed around
ensuring operators have timely access to best available sources of information and demonstrate an
approach to dynamic risk assessment as circumstances change. This in turn will focus more on
contingency plans for all foreseeable circumstances.
Through the audit process there should be a pre-employment competency assessment or skill
requirements, matching this up with suitable employers and establishing a strength and weaknesses
template for employees involved in the adventure activities at every grade. This should be an
ongoing register.

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