Among other issues raised by the Hubbell safety advisory released in spring 2021 was the role of standards in the aerial adventure and challenge course industry. When we asked industry manufacturers, inspectors, operators, and those active in standards development about the industry’s future after Hubbell, several suggested that regulation would be key to taming the industry’s “Wild West” aspects. And standards are essential to that. If Hubbell was one step in the maturation of the industry, standards will take the process many more steps forward.
PARTICIPATING AND CONTRIBUTING PANELISTS:
1. Kathy Haras, Vice President, AdventureWorks
2. Erik Marter, Co-CEO, Synergo
3. Rich Klajnscek, Owner, Sea Fox Consulting
4. Steve Gustafson, CEO, EBL
5. Jeff Borba, Owner, Precisioneering
6. Emily Goff, Owner, Arizona Zipline Adventures
7. Keith Jacobs, CEO, Experiential Systems Inc.
To explore Hubbell’s impacts, Adventure Park Insider convened two group calls via Zoom in September. In addition to co-authoring both articles in this series, Experiential Systems CEO Keith Jacobs participated in both calls and helped assemble participants, who spanned a range from operators and builders to inspectors, consultants, and standards-writers, all hailing from across North America. We addressed many issues raised by the Hubbell advisory in the Fall 2021 issue of API (“Is This The Wild West Or Not?”); here, we focus on the role that standards and regulation play in the industry’s maturation. In addition to the Zoom participants, we gathered insights from Professional Ropes Course Association (PRCA) co-founder Steve Gustafson, who was involved in developing the PRCA’s ANSI/ PRCA standard.
There are currently three primary standards utilized in North America for the design, installation, inspection and operation of structures, systems, courses, and parks: the collection of standards published by ASTM, primarily led by F2959 The Standard Practice for Special Requirements for Aerial Adventure Courses; ANSI/ACCT 03-2019 Challenge Courses and Canopy / Zip Line Tour Standards; and ANSI/PRCA 1.0 – .3-2014.
How well do these standards serve the various branches of the aerial adventure world? How might standards help tame the “Wild West” aspect of the industry? Is it possible to allow for creativity and innovation while also controlling risk and guest safety? Can any one standard apply across all the different branches of the industry? These were among the questions our panel wrestled with.
MAKING STANDARDS PRACTICAL
AdventureWorks Associates vice president Kathy Haras, who is also chair of the ACCT Design, Performance, and Inspection Standards Committee, offered a broad overview. “I don’t know that we necessarily need different standards, but we for sure need standards that recognize that a high-speed, high-tension auto-braking zip line has different requirements than a whale watch. It’s possible to write those standards intelligently, but it also then requires the people enforcing or regulating that to understand that these are different activities.”
The highway analogy. “One of the analogies I like to use,” Haras continued, “is we’ve got a highway system, and sometimes you can have bicycles on that. You can have motorcycles on that, you can have 18 wheelers on that, and you can have your family minivan on it, but you need a different license to drive each of those vehicles.
“I think we’re at the point where we don’t have different licenses yet for the different types of vehicles out there because we haven’t done a good job of identifying them yet. We’ve kind of said, ‘Ooh, we’re using wire rope for all this stuff, it must go together and it must be exactly the same.’ And it’s not exactly the same—but man, it’s awfully similar.”
Construction vs. operating standards. From a construction and installation standpoint, Haras noted, “There’s lots of ways to get to the right outcome from a math numbers and a forces perspective. That’s the easy part.
“It’s the operating part that folks are really struggling with,” she continued. “Once you move into the operational realm, that’s where the differences exist. And I think where we do have the Wild West problem is where we don’t have enforcement, and where the regulator is engaged in the wrong enforcement.”
Haras cited examples of inappropriate enforcement, such as when engineers might be required to do a cycle test on a gravity brake zip line to prove the brake system is working. “Well, that doesn’t make any sense,” she said. “The thing you ought to be doing is a weighted test hang in the belly.”
Do we have too many standards? Gustafson, who is also CEO of Experience Based Learning and host of “Zip Away” TV, believes so. “Currently there are too many chefs in the kitchen and the soup is oversalted,” he said.
Gustafson said that the PRCA initially began its process to publish an ANSI standard because “it recognized the movement toward regulation and identified that if states were to regulate without a nationally recognized standard, it was going to lead to a 50-state solution, where a single solution would be preferred for manufacturers and operators.”
Of course, the industry wound up with a 50-state and 13-province-and-territory solution anyway. “Today,” Gustafson said, “we have three standards and have unnecessary confusion in the marketplace regarding what standard could or should be used. This then leads to the frequent use of standards based on popularity and/or familiarity, and not the use of the required or perhaps most relevant standard in the jurisdiction or industry.”
He also noted that the attempt to write one standard for the entire industry can be problematic. Gustafson believes that ASTM subcommittee F2959 “overreached” when it tried to do away with the F2959 standard’s exemption for summer camps and teambuilding. “The standards became less about education and industry or product relevance and an honorable mission for safety, and apparently more about standards sale or industry dominance,” he said.
The playground analogy. Is there a case for having separate standards for different branches of the industry? Playgrounds provide evidence for that. Jacobs, who is also a member of the ANSI/ACCT Consensus Group, said, “I’ve always compared this industry with the playground industry, where as a child I played on galvanized metal structures, with tires, chains, and treated wood. And today my kids play on powder-coated orange and purple plastic structures with fiber-coated activity wires.
“This is an industry that has three separate standards—one for backyard playgrounds, another for playgrounds at public schools, and an ASTM standard for amusement environments.” “The playground industry is a great analogy,” agreed Synergo CEO Erik Marter. “A commercial adventure park that has 300 people on it every single day, 365 days a year, is drastically different than a summer camp that might get 300 uses in three weeks. And they only operate for eight weeks in the summer. Plus, campers are under very strict, constant supervision, whereas at a commercial adventure park you’ll have less supervision.
“So we’re starting to see wear and tear in places in an adventure park type activity that we wouldn’t normally see on a challenge course. Same thing regarding recreational zip lines versus a summer camp zip line,” said Marter.
Defining a standard’s scope. One solution is to carefully describe the type of operations to which a specific standard or set of rules applies. For example, said Jeff Borba, owner of engineering firm Precisioneering and an active member of the ASTM committee F24 on Amusement Rides and Devices: “If you look at the scope for ASTM 1487, the backyard playground standard, it clearly states that it is for two- to 12-year-olds, and to not follow it for amusement industry locations. For those locations, follow one of these other standards. The best place to define who is subject to a particular standard is in the scope.”
“In our industry, we’ve tried to put everything in one bucket,” Marter observed. “We haven’t started pointing that much. Maybe we could.” He noted that ASTM F2959 is looking at that approach with via ferratas, an activity that “is a little bit into its own little world,” he said, and that requires a specific set of unique guidelines for attaching components to rock and how belays are handled, he added.
The amusement park example. Borba noted that the aerial adventure and challenge course industry is in a similar position to that of amusement parks in the 1990s, when rapid growth coincided with a steady increase in ride-related injuries. And that led to rapid change in the industry’s standards. “When you look at a lot of old ASTM standards, the manufacturing standard 1183 was one page and the design standard was two pages. Once the [Consumer Products Safety Commission] started looking into it, our design standard went from two pages to 60 pages in a matter of just seven years.”
Risk assessment is a part of any installation, Borba added, and an essential one to get right. (It’s also a part of all standards, he noted.) “The joke that we used to say is, where do you stop looking for possible safety issues?” he said. “Some people would say the meteor strike, because you can’t do anything about that. I’ve seen risk assessments 900 pages long, and they really did stop just short of a meteor strike.” The idea, of course, is to imagine how a system or component might fail, or how a guest might defeat any safety measures built into a design, and then mitigate any issues that turn up. “Never have the engineer do his or her own risk assessment,” Borba cautioned. “They’re not going to find any problems. You want a second set of eyes. You have to go through from the start to the end of the attraction. You have to think negative when you do a risk assessment, because you really have to imagine how an operator or guest might do something they’re not supposed to do.”
BALANCING SAFETY AND OTHER FACTORS
Whatever standard is used, the design review and overall regulatory process has to promote public safety without overburdening builders and operators, Borba said. That requires a certain amount of flexibility in the regulatory process. He cited the example of a jurisdiction that has adopted both new and old design standards for amusement park rides—60 pages and two and a half pages, respectively—then determines which applies based on the complexity and risk aspect of the ride.
“They look at a Zamperla Mini Jet, which is not very expensive, and say, a 60-page design standard would cost a lot,” he said. “So they look at the forces on the passengers and everything else about the ride.” And if the ride is relatively benign, the regulators apply the simpler standard.
“With standards, it’s all about the end user, the jurisdiction, how they’re enforcing it, what do they see? So, to me, it’s the jurisdiction working with the manufacturer and the owner operator to determine, ‘how are we going to do this correctly? We don’t need to make the documentation cost four times what the ride was budgeted for,’” Borba concluded.
“If safety is the main goal, if they have a certain budget, you want to give them something safe for that budget and give them an experience that matches their goals,” added Rich Klajnscek, owner of Sea Fox Consulting and chair of the ACCT TIRE committee, which helps guide the development of the ANSI/ ACCT standards. “That’s still possible.”
Adventure and risk. One of the biggest challenges for standards-writers is trying to balance adventure and risk. Many operators, of both commercial adventure parks and experiential programs, seek to offer an adventure (or experiential education) and make it as safe as possible, without guaranteeing safety. Translating that into a standard has proven difficult.
Even defining adventure is a challenge. Marter, quoting an online source, termed it “an unusual and exciting, typically hazardous experience or activity.” He continued, “What makes an adventure an adventure is the sense that if I’m not doing things right, I can possibly get hurt. That’s what makes it a little intriguing for people.”
Marter contrasted a rollercoaster, “where they really set those up so it’s really, really hard to get hurt,” with an adventure park, where “if you go to try to jump across one activity to the next and land on a platform, you might bang your shins or get a little snag on your arm.”
Borba has a different view. “I think there’s also another definition of adventure that doesn’t use the word ‘hazardous,’” he said. “’An exciting and noteworthy event that one experiences firsthand’ is another term for adventure. I’ve seen adventure have a lot of definitions.”
Klajnscek split the difference between those two views, saying, “It has to be ‘to provide experiences with minimal risk.’ But it still has risk. And it’s got inherent risks.”
THE LIMITATIONS OF STANDARDS
It’s important to note that standards, by themselves, can’t solve all safety-related problems. Operators themselves are responsible for implementing sound procedures. Operator responsibility. Regarding a recent zip line operator death and what role standards development can play in preventing that type of accident, Gustafson said that “these tragedies were all avoidable, but in regards to staff, we have opportunity, frequency, and complacency working against us.”
“Coupled with the expansive growth this industry has seen,” Gustafson added, “this is not a standards problem, but rather the problem reflects a gap in quality training, quality education, and quality control, regardless of standard utilized. New operators, I’m afraid, too quickly jump to doing their own training and remove the qualified third-party before they are ready. That third-party involvement in inspection and training makes a real difference in keeping people safe.”
Lax or non-existent regulation. Then, too, not all jurisdictions apply standards rigorously. Some, of course, have no standards in effect at all. “The Wild West lives at adventure parks and challenge courses in places where there is no jurisdiction, or at a camp in a state that doesn’t care or doesn’t know,” said Marter. “And these jurisdictions just want the simplest answer, or no answer at all, and then leave it to the designer/ builder. Or the regulators just pick the strictest standard they can find just because they figure it’s the safest one, but that can make it unattainable financially for a small camp.”
Education may help to avoid some of these scenarios. “I’m trying to educate the jurisdictions, and tell them that all standards are good,” said Borba. “They’re all there for the right reason. One’s not better than the other. It’s just, you need to have, I don’t want to say common sense, but common practices. I’m trying to help the jurisdictions understand how things are done in other states, so they can be better for their own state.”
For operators, inspectors are an important resource for standards education. “When I’m inspecting, I’m motivated to teach people as much as I can. I just feel a responsibility more and more to do that,” said Klajnscek. Without regulation and enforcement, though, an inspector can only help so much. “Right now, particularly if your jurisdiction isn’t regulated, your outside inspector is really acting as a consultant,” said Haras. “So, as an inspector, I can write the report, but I’m not the standards police, I can’t make you do anything. Other than writing you a sternly worded letter, I can’t do anything to fix the situation.”
Of course, many operators want to do the right thing, and standards help in that regard. Emily Goff, owner/operator of Arizona Zipline Adventures, said that “in Arizona, we aren’t regulated as in other places, so we have to do our very best to pay attention to what is going on around us. When we built our course, we built it to or exceeded the current standards. Today, we are members of ACCT, we get Adventure Park Insider, we do our best to stay up to date on what is going on around us. It’s really just trying to set good systems in place and be aware of what’s going on. That’s the best thing that we can do.”