Thoughts on the Adventure Policy (GR). September 2020 - p1


A lot of progress has been made on the Adventure Policy in the sept 2020 GR

adventure-tourism policy english version pdf file 

But a lot more need to be done . These are our thoughts 

Ps we are just observers over the past 15 years .

Blue :- quotes from the GR 

Black :- our thoughts 

Page 2

3. The following categories of organizers:

3(8). Individuals who organize adventure activities

Over the past 4+ years we have seen trekking organisation moving from the cities to the base villages . Where the base village guides now advertise on facebook and instagram on their own and bypass the city organisers . So 3(8) needs more detailed sub sections.

There are different categories

1) Organisations 

some organisations started directly as an organisation. Some started as a charity then became a company. Some started as college group trekking (TTMM) then grew to an organisation (very few) 

2) College groups

3) Part time trekking groups who only trek in the monsoon 

4) Part time Trekking groups where organisers have full time company jobs and organised treks part time. Some organisers become full time trek organisers after getting good response (2015-2019).

5) Village guides who turned organisers . Sandhan Valley is the best example. They used to take city trekkers as a guide . This changed when Some city groups decided to fully outsource to the village guides on a commission sharing bases (this is very common in many of  the very small groups ) some of the local guides who can give you a better idea on the growing local local trekking business at the base villages around forts.


Pg 3

         Temporary Registration is mandatory for all Adventure                       Activities. using certified equipment, trained staff, all required infrastructure and following Safety Guidelines.

Those observing the waterfall rappelling will know that these points are not available to some organisers   .To explain further organisers manage with what ever gear is available to them in their budget and available locally. Also 40% of waterfall rappelling is outsource to village organizers (sandhan valley/rajmachi/bhandradara etc) . And 100% waterfall rappelling is outsourced for about 10 major organisers(please share main organisers name with us thanks)  


page 3  will have to apply for Temporary Registration by paying a fee of Rs. 1000/-

 page 6 :- A fee of Rs.3,000/- for the Final Registration Certificate must be paid for each category of Adventure Activity (such as Land, Air and Water). This means that if an applicant is registering for only one out of the Land, Air and Water activity, he will be charged Rs.3,000/- as registration fee.

2. If the applicant is applying for Registration for more than one adventure medium, he must pay a fee of Rs.6,000/- (for two media) or Rs.9,000/- (for three media).

This is going to be costly to those experienced trekker who are starting their own organisation and also the base village organisers/guides.

One of the reason is the thin margins , and also a huge number of organiser are almost broke and could maybe pay this amount after organizing a few treks and getting customers. 

Small organisers have already bypassed the system by outsourcing 100% to village organisers . This means these groups will never come under the umbrella with these rates and restrictions. With covid more and more trekkers will turn organisers to help their families. 


temporary registration certificate will be issued by the Office of the Director

No clarity yet on where exactly do the organiser go for registration. Also it will be very difficult for the base village organiser .  

Application must be made with attaching

the following documents.

  • Shop Act License
  • IT Returns

looking at the list of Trekking groups in Maharashtra this would leave out a large section of the trek organizers who do all their organizing from their mobile phone .or by village organisers who post on social media 

 Page 6 Individual participants as well as those organizers who are actually present at the site of adventure activity must have adequate insurance cover.

  • Insurance cover again an expense . 
  • Temporary registration cost 1000
  • Permanent registration cost 3000
  • Insurance cost ?
  • Village organiser cost   ?
  • first aid certification cost ?
  • basic NIM training cost  18000


Pg 11 Organizers that promote adventure activities through social media and conduct such activities also must follow process of registration. Organisers conducting adventure activities without registration / in an unauthorised manner are liable for penal action.

The point with the threat of penal action will mean these organisers who some times do not even display their mobile number on social media will go even more underground .  


Pg 13 It is essential that the adventure tourism service providers shall have full time experienced, efficient, trained staff.

This is all good if the total organised set up in run in a city (mubai/pune) and the organisation has the funds to fund the staff training and also keep the staff full time on their rosters.

The reality is 1% of organisers are running their trekking organisation full time  . 90% of their staff is on a profit sharing bases / profit sharing on trek to trek basis . 


pg 14 The organisers shall also arrange for sufficient insurance cover for field workers, guides and other professionals concerned with the adventure activity.

See explanation of point 13  


pg 15 It is mandatory for the adventure tourism service provider to have a list of the nearest dispensaries / list of doctors.

 Anyone who has trekked in the sahyadris know this is very difficult . But it can be done with the help of full time database collectors who can go in their car all over the area around the forts and activity area mapping the nearest hospital /doctor. 

The books  The Sahyadri Companion  Saangaati Sahyadricha   are more than 20 years old and out of print (no longer available) this give you the idea of the state of the data trekkers have right now . Most depend on local villagers to help in times of emergency 


pg 18 Organization should form a Risk Management Team comprising of experienced members to look at all the aspects of risk management. 

See explanation of point 13   


pg 19  Mail Runners, in case of very remote locations for quick communication and reporting 

No idea what this means


Pg 19 Contact numbers of nearby Medical centers, Medical professionals, Government authorities (Police stations), Rescue teams / organizations, transporters 

See point 15  

I do not think this database (pg19) exist . Most needs government help to compile this database . Please share if they exist  .


Pg 23

Participants fitness Certificates & medical history from Registered Medical Practitioners, personal information like blood group, allergies, emergency contact details etc.

These are important but i dont think 99.9% organisation have these records. Also do these breach the privacy of the individuals ** ? maybe with the new government health stack( all india medical online database it could be possible in the future) 

Privacy breach . **  (If all companies get a copy of a individuals medical history and most offices throw away copies after a year . so this data can fall in anyone's hands )


pg 24 

Organization should define process of communication within and with external agencies (Police, media, public and government agencies) in Emergency situations.

I do not think this is possible without the government help to get all this information .  Maybe MAC can help create this database?


pg 25 

It is recommended that the organization should issue written Work Orders to its Service Providers for outsourced Services. The Work Order should clearly specify

I do not know how many trekking adventure companies have this facility . 1% ?


  • organiser a person with a mobile phone taking bookings
  • service provider a village guide with mobile phone 


 pg 30 It is important that all the members of the Mountaineering mission are qualified enough to take the initiative in this endeavor. The primary training certificate issued by  national training Institute will be considered sufficient for the same.The leader of mountaineering institute should have adequate qualification accredited by National Mountaineering Institute.

Though desirable . It will need local training options and government grants  

Taking a look at the present cost for training at NIM 18000 per person.


pg 30 The tools used for mountaineering and trekking must be UIAA certified or accredited by Indian Mountaineering Institute.

pg 159 Climbing and mountaineering Equipment - Technical details


pg 32  The below Table can be used by Organisations as a reference to arrive at its own Leader to Participant ratio  for each Adventure Program it conducts.

This need to be modified to local ratios? or is it practical . Anyone who has seen the crowds at the camping locations know this is not possible. 


pg 38-40 Guideline for Leave Minimum Impact & Leave No Trace Seven Principles

Good . but dont know how many follow or event know about them as of sept 2020  . Some organisation will need to hold work shops for the same .


pg 42-47  Safety Guideline for All Terrain Vehicles (ATVs)

PPE required for Leaders and Participants, and other equipment 

needs to be modified for local conditions ?


pg55-78 trek guidelines (need to take a more close look) 



pg 79-82 camping guidelines
Pg 79
1 * Approach to campsite, and whether Participants need escorts to reach and exit from campsite 
2 * Back-up plans which can be used in emergencies (like alternative routes and/or activities)
3 * Criteria for monitoring and/or decision on expulsion/evacuation of Participant that are relevant to
4 * Intoxicated person
5 *Person who refuses to follow safe practices

The issues is the camp owner and the camp organiser are different . one camp owner takes booking from 50+ organisers . People ask for alcohol at these camp site or get their own. some organisers even write byob.  -- Guide lines need to distinguish between organiser (camp booking) and camp owner and camp supplier( who supplied food etc usually a different villager)  

These needs to be worked on by group . Right now how many follow. Point 5 :- Looking at a lot of camping events for new years and other times .   


pg 80 

 Strongly recommended:

First Aid Certification (valid  certificate)

This is good . But MAC /Government will need to reach out to camp organiser and conduct regular courses . 

The main question is the campsite owners . 


  • Basic Mountaineering Course

  • Outdoor Leadership Course 
  •  Wilderness First Responder / Wilderness First Aid & CPR

 These courses are costly and will not be possible for 90% of camp organisers . Unless MAC or the government sponsors these courses apart from NOLS usa . i do not know if any other place in india conducts the leadership course and wilderness first responder .If you know please share . 

Sahyadri Trek Leader Course




pg 84 Safety Guideline for Basic Rock Climbing

Pg 84 All Leaders to have undertaken basic rock climbing course from reputed organisations or having equivalent competence and experience in rock climbing and related activities


Pg 87 Chief Leader to review contract signed with outsourced Service Provider


Chief leader - person taking booking on a mobile phone or via social media messages (whatsapp ,facebook,instagram) 

service provider ;- village organiser 


pg 90 Safety Guideline for Pinnacle Climbing

pg 98 Safety Guideline for Rappelling (Dry Surface)

Emergency Response Plan

c. Emergency Response Procedure

d. Critical Incident Report form

e. Medicine-use report form Chief Leader: Basic Rock Climbing Course from a reputed organisation/institute or  equivalent competence; First Aid & CPR Certification (valid certificate);

ph 100  Rope usage logs will be maintained.

pg 102 Policy on tobacco, alcohol & other intoxicants .Implement recommendations of Risk matrix 

pg 101 Chief Leader to review contract signed with outsourced Service Provider 



pg 104 Safety Guidelines for Waterfall Rappelling

pg 105 

Chief Leader: Basic Rock Climbing Course from a reputed organisation/institute or equivalent competence; First Aid & CPR Certification (valid certificate);

ph 106 . Organisations should exercise judgment while purchasing and using equipment. Leader‘s first aid certification and c) medico-legal aspects that are relevant to the region that the activity is being conducted


pg 109 Safety Guideline for Permanent Ropes Course

pg 120 Safety Guideline for Temporary Ropes Course

pg 130 Safety Guideline for Valley Crossing / River Crossing

pg 136 Safety Guideline for Permanent Zip Line

pg 146 Safety Guideline for Caving or Cave Exploration

pg 154 Safety Guideline for Wildlife Safaris

Chief Leader to have current certification in Wilderness First Responder / Wilderness Advanced First Aid & CPR from reputed organisation


pg 172 Sample Standard Operating Procedure (SOP) for Rappelling on a 90 ft. cliff

pg 177 Sample Standard Operating Procedure (SOP) for Waterfall Rappelling on a 100 ft. cliff

pg 183 7. Lost Person Protocol



pg 290 Equipment - Storage, Maintenance and Inspection

The documents needs to be separated into 3 parts land /water/ air / as a lot of the pdf is irrelevant to the trekking community . 

Final thoughts . It is good start . but needs a lot of support from government , incentives for first aid courses ,incentives for other training . 


 other discussions by other trekkers