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Health & Safety - Am I Being Unreasonable?

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Quick introduction to this: I'm the Expeditions Coordinator for the SU's Duke of Edinburgh's Award Society. I've been mountaineering for about a year now, and have completed my Mountain Leader Training. I've been doing walks and camping etc for the past 13 years in Scouting. I lead walks and such for a number of societies and in Scouting.

Now, DofE is split into regions, then into Operating Authorities, or OAs, which are responsible for the award scheme in their area. Our society is governed by the Nottinghamshire OA.

For each expedition group going out, you require an Assessor (nationally accredited through a course run by DofE, which is 1 day PowerPoint + half a day assessed assessment); and a Supervisor (accredited by each OA).

Nottinghamshire OA requires Supervisors to obtain their Mountain Leader / Walking Group Leader Award, otherwise they won't let participants "pass" their expedition.

To get your ML award, you need to have been mountaineering for at least 12 months, and won't really get far without 18 months, plus 40 Quality Mountain Days (you're unlikely to pass Assessment without 60, as they write off a load as not being Quality), plus a 16-hour outdoor First Aid qualification.

If this all makes sense, then my dilemma might also make sense: Students are at university for say 3-4 years on average, and many people drop responsibilities in their final year to concentrate on work. So we have a timespan of around 1.5-2.5 years for people to decide to become a Supervisor, to get 60 Quality Mountain Days, a 2 day FA course, 2 days of DofE training plus the 6 days ML Training and 6 days ML Assessment.

As a result, our group has no Supervisors. We're unlikely to ever get more than 1 Supervisor, which is useless, because for Gold groups, you need 1 Supervisor per 1 group, and we currently have 3 groups. By the time we get somebody trained up as a Supervisor, it's time for them to graduate and we're unlikely to have their help anytime soon.

Having no Supervisors means no groups can go out on their expeds, and that's pretty much what the society exists for, because people tend to complete the other DofE sections themselves.

Now that's all the H&S aside, here's where I wonder if I'm being unreasonable: I've asked the OA if we might apply for exemption, and offered to go on a couple of days' walk with somebody to show competence in navigation and emergency situation skills, as well as group management, leadership and people dynamics. The OA has flat-out refused on the basis that they have an AALA licence which requires people to get a qualification.

The people we have willing to supervise groups currently lead groups out in the hills and mountains on a very regular basis during term-time, are clearly skilled and experienced individuals and competent to be leading groups on 4day expeditions.

The society is close to going down the drain for jumping through hoops, whereas just a few years back it ran perfectly smoothly without anyone having to get their ML.

Am I being unreasonable in asking for this?

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