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26/06/2009 - Sport England to ask RoSPA's view of the ARA's response to the Safety Review (Stephen Blockley)

On 30th April 2009 Sport England met with the ARA for an in depth review of the ARA's response to the RoSPA Review of Rowing Safety. Following this Phil Smith, Director of Sport for Sport England, wrote to our MP, Mr David Heyes, on 18th May, quote: "In respect to your question regarding whether this (ARA)response is both appropriate and adequate, given the obvious significant context and nature of the Review, I do not feel that it is currently within my gift or expertise to determine whether the response can be considered either at this stage. In light of this, Sport England, together with the ARA will be asking RoSPA for their opinion on this. As the body responsible for the original review, I am sure they are best placed to discuss the ARA response to the Review and its future plans in detail. I would hope this exercise will enable me to have a greater understanding and assurance on the adequacy and appropriateness of the ARA response, and indeed help the ARA to take any actions necessary. In addition, Sport England will also be monitoring progress made with the implemetation of the ARA's water safety sub committee action plan as an integral part of our ongoing monitoring of our investment in the ARA over the next four years." At the time the Review was commissioned, the then Minister for Sport, Richard Caborn, personally assured us that the ARA would have to comply with the Review's recommendations. His successor, Gerry Sutcliffe, officially charged Sport England with the responsibility to monitor the response from the ARA. Sport England channels funding for sport, so has the ability to set targets and increase or decrease funding as it sees fit. We now await further details of Sport England's terms of reference for RoSPA's renewed involvement. Given that the ARA has not complied with the RoSPA recommendations on buoyancy (for a testable, tested and effective buoyancy standard for all racing rowing boats, both old and new), it seems obvious to us that, so far, the ARA's response has been inadequate. We will keep you posted!

01/05/2009 - ARA response to "In at the Deep End" and its implications (Stephen Blockley)

Our circulation of "In at the Deep End" to ARA affiliated clubs has drawn an unwise response from Stuart Ward, Chair of the ARA National Water Safety Committee. On 25th March 2009, he included an official response in the ARA Spring Mailing to all clubs and events, and also posted it on the ARA website: Mailing to Clubs from Stuart Ward In that mailing Mr Ward alleges that "In at the Deep End" (about the deficiencies of the ARA Row Safe document)contains "errors, confusions and misleading statements". We always do our utmost to ensure that everything we say or write is evidence based,so are surprised and disappointed by these allegations. Our response to Mr Ward, dated 28th March 2009, is here: Letter to Stuart Ward re Row Safe In this letter, we have included the evidence base for our statements made in "In at the Deep End", and ask that Mr Ward withdraws his his allegation. So far he has only sent an acknowledgement of receipt. We are still awaiting his substantive response.

20/02/2009 - Answer to anonymous enquiry on "Support Us" page (Stephen Blockley)

We have answered the points made by "Rower and Coach" on our "Support Us" page on the rec.sport.rowing newsgroup: Answer to anonymous enquiry We would prefer that enquiries are emailed to us directly so that we can be sure the answer gets to the right place. We will always respect confidentiality.

09/02/2009 - In at the deep end? (Stephen Blockley)

We have been working to raise awareness at club level, of the safety issues arising from the ARA's Row Safe publication. We have sent the following flyer to as many of the ARA affiliated clubs for whom we could find email or snail mail addresses. Click on this link to download the document. In at the deep end? (PS We have not sent it to individual Oxford and Cambridge college clubs, because, as we understand it, they already have to follow their university-wide safety regimes.)

29/11/2008 - ARA fails to implement RoSPA Safety Review recommendations (Stephen Blockley)

The new ARA Row Safe Guide which replaces the old Water Safety Code has been published. It is a great disappointment – an opportunity missed. It seems to have decided to withdraw from the concept of regulating on safe practice or equipment standards, it apparently declares it will only “advise”, and is putting the onus of responsibility, and therefore blame, onto individual clubs and rowers. Row Safe fails to address the vast majority of the recommendations in the RoSPA Rowing Safety Review. In particular, there has been no improvement in the ARA attitude to buoyancy regulation – and almost all of the RoSPA recommendations on this subject have been ignored. Once again, it seems the ARA has failed to respond to nationally recognised expert independent advice – in the same way it failed to implement certain recommendations from FISA, from the Salvage Association, and most of those contained in two Coroner Rule 43 letters consequent upon the avoidable deaths of two of its members. The ARA also appears to have cocked a snook at the Minister for Sport – who spelled out their duty to regulate on safety matters in the adjournment debate in parliament. What follows is a detailed review of the new Row Safe Guide, giving our analysis of its successes (a few) and its failures (many). We start with an overview, which is followed by a list of the ARA response to each RoSPA recommendation. Overview. 1) Status The introduction leaves the reader confused as to the status of the document. It says “All decisions about safety at rowing clubs and competitions should be based on ‘risk management’ as no ‘book of rules’ can possibly cover all situations”. Fine, but it is not clear whether any core basic rules still exist. Row Safe is referred to as a “guide”, and the sections are largely in the confusing form of “Minimum standards to be adopted” and “Further good practice” with no explanation as to why there is this distinction, or if the status of each is different. To add to the confusion, in places embedded in the document clubs are just advised to set their own rules. Status is important as “guidance” cannot be enforced, but rules can be. A safety policy should as a minimum, include a core of basic rules of practice and equipment standards which are essential to reduce exposure to those significant risks to life and limb which are avoidable by reasonable means, without significant impact on practice and enjoyment of the sport. Such rules must be backed up by a system of checking and enforcement nationally – to give a ‘level playing field’ for clubs and equipment manufacturers. It seems the ARA expects clubs to pick and choose from the guidance and set their own safety rules to enforce locally. Such a ‘free-for-all’ system encourages and allows the lowest common denominator. 2) Structure The ARA has adopted a common format to all the different sections. At first glance this promises clarity and ease of use, but it fails to deliver. The desire to stick to this common format appears to have been given priority over the need to convey actual information. Teasing out all the sections on ‘personal’ responsibility largely reveals a list of ‘read document x, follow standard y, be aware of procedure z’ etc. A reader will be not much the wiser, than before. (There is a separate leaflet entitled “Row Safe – Key points for your safe rowing” which is aimed at the individual – but, with the exception of detailed advice on clothing, it also largely just gives a series of lists, without actually imparting much in the way of actual information.) Division of guidance into “Minimum standards to be adopted” and “Further good practice” is arbitrary, some basic essentials being relegated to the latter category and vice versa. For some things, differing sections give differing recommendations or advice e.g. the wearing of life jackets. 3) Readability and content After reading the document throughout, Joe or Jane Rower would be unlikely to feel much better informed. Yes they would understand they have responsibilities, and they must think about safety – good things indeed – but they wouldn’t necessarily know how to put it in practice. a) There are many examples of excess verbiage with little information. Here is one: “5.1 Sunburn, Heat Stroke & Exhaustion Responsibilities – personal - Comply with the minimum standards below and bring to the attention of club officials or competition officials any significant issues relating to sunburn, heat stroke and heat exhaustion. - Take personal responsibility for precautions against sunburn, heat stroke and heat exhaustion." b) Some “guidance” lacks clarity, is questionable and varies in different sections: For example - Life jackets for rowers: - Section 1.8 (Cold water immersion and Hypothermia – Further good practice) PFDs are advisable in high risk situations in low temperature conditions e.g. beginners – they could minimise the effects of swim failure (wrong – may reduce the consequences of swim failure, but would not prevent its onset. Why only beginners? Elite rowers end up in the water also). - Section 1.9 (Swimming and capsize/swamping training – Minimum standards) Participants unable to demonstrate the minimum standard (of swimming?) must wear a PFD. - Section 2.1 (Safety aids - Minimum Standard): Junior beginners must wear a PFD until they have completed a swim test, received training in capsize procedure and reached a satisfactory level of competence in, for example, a single sculling boat. - Section 2.1 (Safety Aids - Further guidance): Adult beginners should be offered the use of a PFD. Those training on their own away from immediate help should wear a PFD, especially in cold conditions (but no definition of how cold is cold – and why only those on their own? Sikander Farooq died because of cold water immersion in full view of a coach and several rowers). - Section 3.1 (Beginners - Further good practice): Policy on wearing of PFDs for beginners and juniors – set one and communicate and enforce. - Section 3.2 (Juniors - Further good practice): Policy on wearing of PFDs for beginners and juniors – set one and communicate and enforce. - Row Safe – Key points for your safe rowing: PFDs should be worn by beginners when skill levels are low, and the risk of capsize is high. So – what exactly are the basic rules, and who is to set them? Have they really considered what is the purpose of wearing a PFD? All this jumble of guidance, advice, and further suggestions re-enforces the general idea that PFDs are for junior-beginners and non-swimmers only, so that NOT wearing one is a symbol of a rower’s status as an adult experienced rower. This is the wrong message. FISA indicates that everyone should have a PFD with them if water temperatures are below 10ºC – this is more sensible advice – actually wearing it would be even better. Also, the advice on how to adjust heel-restraints is wrong. ------------------------------------------ Response to RoSPA Rowing Safety Review recommendations. Taking each recommendation in turn: 9.1 Systems and Guidance 9.1.1 Risk assessment and safety management - There is SLIGHTLY MORE emphasis on this than there was in the old Water Safety Code (WSC). 9.1.2 ARA Club auditing process - NO CHANGE in the pre-existing system. - Independent reviews or club safety officers auditing neighbouring club rather than their own – APPARENTLY REJECTED 9.1.3 Club management and structure - GOOD EFFORT to spread responsibility for safety throughout the club. - NO IMPROVEMENT to advice on systems of work for maintenance and boat repair activity. 9.1.4 Rowing boat transportation and competition attendance - Guidance to manage risk of towing trailers to be made more widely available – NO CHANGE from before (was in the old WSC). - Awareness of the issues relating to driving long distances to compete to be flagged as a safety issue – NOT INCLUDED. 9.1.5 Rowing boat identification, craft registration and adherence to navigation authority rules - That the Tideway craft registration scheme be extended to all regions – DONE. (not in Row Safe – but listed in the ARA Rules). - Codes similar to the PLA Tideway Code to be drawn up for other complex waterways – NO INFORMATION on this. 9.1.6 Incident reporting - NO CHANGE to their pre-existing online incident report form. It doesn’t appear to have been developed in any way. - There is NO INDICATION that the ARA is moving towards a system anywhere near as comprehensive as that operated by BSAC . In particular there is no indication that rowers will ever be able to see incident reports, or any analysis or review of such. 9.1.7. Hypothermia, cold water shock and capsize - SOME IMPROVEMENT in the quality of advice, but still short on actual information. We cannot find any other ARA documentation on this, other than what is in Row Safe. - Refers to the 1 minute 1 degree code, but doesn’t explain what it is! - There is STILL UNCERTAINTY about capsize drills. It is clear all participants should be instructed in safe capsize technique, but no clear guidance on need for or frequency of repeat practising. 9.2 People and Roles 9.2.1 ARA Water Safety Code (WSC) and strategy and role of regional water safety advisors (WSA) WSC to be revised: - To be more user friendly: SOME IMPROVEMENT. - To take on the recommendations of the RoSPA report – OVERALL FAILURE - To contain sections aimed at specific sections of rowing community – FAILS INDIVIDUAL ROWERS. - ARA to foster a more collective view of safety – GOOD EFFORT. - ARA to produce additional guidance for clubs on hypothermia and capsize management – NONE APPARENT so far. If anything there is less now than there was before. - Role of Regional WSA – NO INFORMATION on this. 9.2.2 Supervision of water activities - ARA to guide on documented daily launch decisions – NOT DONE. - Logging of boats and crew onto and off water – NO GUIDANCE. - Introduce named nominated officer of the day – NO GUIDANCE. - Review communication systems between coaches, boats on the water, clubhouse and/or officer of the day – NO GUIDANCE. - Clubs and the ARA to specifically differentiate between coaching and supervising roles – NO GUIDANCE. 9.3 Equipment 9.3.1 Boat buoyancy - ARA, together with manufacturers to develop a test of swamped flotation of fours and eights, similar to ISO 12217-1 – NO INDICATION THIS HAS BEEN CONSIDERED. - ARA to promote such test to ISO - NO INDICATION THIS HAS BEEN CONSIDERED. - ARA to modify policy on boat buoyancy to state that all boats should be buoyant – NOT DONE. (The ARA has modified their definition of buoyancy – but it is still imprecise and of dubious testability – “all newly constructed boats must have sufficient inherent buoyancy, together with their oars and sculls, to support a seated crew of the stated design weight, such that the rowers’ torsos remain out of the water and the boat can be manoeuvred.” We wonder what is their definition of torso – the dictionary says all but the arms, legs, neck and head – so when seated, as rowers are, where precisely does the torso begin? In addition they say new boats may conform to either their requirement or that of FISA.) - ARA should have an agreed policy for retro-fitting of existing boats – NOT DONE. - Develop a system for dispensation for non-buoyant boats – SUGGESTED as “Further good practice” in section 2.3 - but no detail given, and NO ADVICE as to the factors to be considered (as listed by RoSPA). - The ARA considers the implementation of a 5-year period for all boats to meet a new buoyancy standard – NO PLAN TO IMPLEMENT. - Rules and regulations to be introduced to: A. Require each model of fours and eights to be subject to and pass the test prior to sale as required by the EU Recreational Craft Directive (RCD) and builders to complete a Declaration of Conformity – manufacturers required to label boats, but NO REQUIREMENT FOR BOAT TO HAVE PASSED THE TEST i.e. can label boat as for racing only and claim exemption from RCD. B. Require each owner of competition four or eight to periodically test, and for the boat to pass the EU RCD, and to complete a Declaration of Conformity - NOT REQUIRED. C. Set out a regime for the inspection of Declarations of Conformity, with penalties for non-compliance – NOT REQUIRED. D. Ensure boat builders address their obligations to the RCD - MANUFACTURERS ASKED TO LABEL BOATS, as above. 9.3.2 Rowing boat and equipment manufacturers and suppliers - The ARA and/or manufacturers to attempt to create a trade association or similar – NO INFORMATION.

16/06/2008 - Rowing Safety Review is released for publication (Stephen Blockley)

SAFETY REVIEW RECOMMENDS FULL BUOYANCY FOR ALL RACING ROWING BOATS. The independent national Rowing Safety Review commissioned by the government Minister for Sport has given a clear recommendation to the ARA that they should implement a policy of full buoyancy for ALL racing rowing boats to a defined performance standard. To this purpose, the ARA is recommended to set out a regime for testing and inspection, with sanctions for non-compliance. Furthermore the ARA is urged to promote the buoyancy standard to the International Standards Organisation (ISO) for inclusion within the next edition of the ISO Standard. The review includes many other recommendations for the improvement of rowing safety, including: - the national roll out of boat indentification - a complete rework of the ARA Safety Code - improvements to the incident reporting system - changes to the club auditing system - better awareness and education on hypothermia, cold water immersion and capsize - modification of roles for ARA Regional Safety Advisers (who currently have an impossible task) - specific recommendations to clubs to improve safety. The over-arching message is that the sport must develop a more inclusive and collective safety culture. A copy of the report is being sent to FISA. The Minister for Sport has asked Sport England to monitor the ARA's implementation of the Review recommendations. Our campaign has been fully vindicated! Here is the link to the full document. It is lengthy and detailed. For a quick overview we recommend reading chapter 9 which lists all the recommendations. Rowing Safety Review