there is, and I am against using the phrase “loop hole”, but an exception where “local expertise” can be used in place of an qualification.
perhaps it is no longer valid, but I seem to recall hearing in a bar on a course, or camp somewhere that that Dartmoor moors requires an ML, clearly not because of the relief of the ground, but because of its remoteness, ie it is outside of BEL remit and thus could only be ML qual that counted.
but some Staff were about to get an exception to this by having “local expertise” - I am sure there was a more formal sounding name for it, but allowed Staff who had years of experience operating in a area to continue to do so, a bit like Grandfather rights when the NGBs came in but ML was a hell of an effort to do.
a flexible WATTO could visit and offer an assessment of the training suggested and allow an evenings walk around a park with map and compass with the strict restriction it was only valid for that location and that activity.
I have said this many a time.
rather than punish the majority for the errors and mistakes of a minority (often an individual), by forcing changes to systems and activities which have occurred without problem or issue, and in some cases bare no measurable difference to the safety or success of the event why not strike off the idiot in the first place and then consider was this bad judgement of the individual, perhaps going beyond their experience, competency and/or qualification or simply down to their own (lack of) understanding and/or foolish approach?
the organisation looks at individual A with Qualification X and believes individual B is capable of making the same errors - capable yes, but should it be that black and white? should individuals (qualifications) be measures by their weakest performer?
I am sure there are plenty of examples where the individual has been a tit, and idiot or not followed a procedure and rather than focus on the individual, perhaps remove the qualification, suspend or restrict what they can do with it and offer retraining, the easiest option is to get everyone to jump through a new hoop because someone, somewhere proved without that hoop problems can occur without perhaps considering why the individual allowed the problem to occur in the first place.
I am not just talking about AT here, but all qualifications, shooting being the obvious one with additional hoops which have occurred over the decades with no measureable indication it has become safety or more successful.
An example which comes to mind, is the tragic case of the AEF pilot who didn’t have full movement in his neck and thus could have missed the chance to see a nearby glider - the result was the aircraft collided and lives lost.
one of the outcomes was to stop all pilots over a certain age (65?) from flying cadets to stop such an case occurring again.
now I am not going to speak ill of the dead and call the pilot an idiot for flying, but is a very specific and individual case which was created by the individuals actions (and that of the Dr who signed him off as fit despite knowing about the restricted movement in his neck - from what I recall that Dr was suspended from approving “fitness to fly” certificates).
does a pilot suddenly become a danger at the age of 65?
is a Cadet at danger by visiting the local park with a map and compass with someone who is not “trained and qualified” in organising a full day walk and overnight camp?
of course it is the easy route to take to change policy.
it avoids difficult conversations with the individual who messed up. in this organisation it avoids telling off a volunteer who might leave if told “no you can’t do that anymore” and no one wants to be the Senior Officer who was the person who kicked out CI Bloggs