NZRA Position on the AARS
In 2010 Operators agreed on 8 industry safety principles that underpin safety in the Adventure activity sector. These principles continue to provide the foundation for our advocacy position for the sector:
- Operators have a positive safety culture driven by committed leaders
- Operators have a safety management system (SMS) relevant to their operation
- Operators have an external assessment before commencing operations
- Operations have ongoing external assessments
- Operators have competent staff
- Operators communicate risks and responsibilities
- Operators have well maintained equipment that is fit for purpose
- Operators share safety information
Benefit versus cost of the audit process
The AARS Performance study carried out by Galloway Research asserts that the AAR scheme has driven an improvement in safety in the adventure activity industry. Improvements were predominately related to operators managing safety via structured/systematic safety management plans however gains were made in practical operational procedures too. We do however note with concern that the AARS Performance study also revealed that 66% of operators don’t think the benefits of undergoing the audit process outweigh the costs. 25% feel very strongly so.
We encourage an effort to increase the understanding within industry of the safety gains that have been driven by the audit process, including the role that written safety management plans play in supporting operational safety.
Cost of audit
In the majority of cases, operators are willing to pay a fair price for audits that add value to their operation and/or the wider industry. It is therefore concerning that the largest source of discontent with the scheme is the cost of audits.
The most costly and inefficient audits are those carried out by both and auditor and a technical expert. Ideally, both of those functions should be carried out by the same person. The utilisation of a Technical Expert in addition to the Auditor should only occur on rare occasions when an auditor does not have the requisite technical expertise of the specific activity.
We encourage the Adventure Activity Audit providers to prioritise and incentivise the utilisation of Auditors that can also serve as Technical Experts.
Audit providers, qualification providers, industry groups and industry training organisations should encourage Technical Experts to become auditors and Auditors to gain the technical expertise to assess a variety of activities.
Allowing for a ‘declaration of conformity’ between audits, strikes the right balance of cost and utility for operators. We encourage operators to use audit providers who actively include the option for a declaration of conformity for surveillance purposes. A field visit should not occur in between full audits unless it is fully justified on the basis of safety risk.
The model of private sector delivery of this mandatory regulatory audit is unique and presents the sector with an ongoing risk in terms of cost. NZRA will continue to monitor audit costs and the overall regulatory cost burden on adventure activity operators.
NZRA acknowledges the efforts made by audit providers to streamline their costs, in order to reduce the financial burden on operators. NZRA commends the audit providers commitment to the financial sustainability of the adventure activity industry, as evidenced by the steps that have taken to seek efficiencies and cost-savings.
It is our view and that of the AARs performance study, that WorkSafe should continue to provide support for safety in the industry. At a minimum, this support should include the provision of the widely used SupportAdventure website, and regular review and updates of the Activity Safety Guidelines and the SMP template.
We are actively encouraging WorkSafe to fund the provision of this Industry support.
We agree with the AARs performance study recommendations that TE’s receive ongoing training, and believe this needs to extend to auditors wherever possible. The audit scheme is unique internationally; it is a complex model which requires the use of judgement at many stages of its implementation. More oversite and training from the regulator is required to ensure that the scheme delivers the safety assurance and value that it should.
Many of the auditors and the vast majority of TE’s are new to auditing in general and certainly to auditing of this nature. One full round of audits has been completed and the next round will soon begin. Training of the auditors and TE’s is required to enable learning from the first round to be incorporated into auditing good practice for the future.
We are actively encouraging WorkSafe to fund this ongoing training of auditors and technical experts.
To give us your views on this issue, contact our Advocacy Manager.