Non-sterile alcohol-free wipes: risk of infection

The UK Health Security Agency (UKHSA) and Medicines and Healthcare products Regulatory Agency (MHRA) are reminding the public not to use 4 specified non-sterile alcohol-free wipe products under any circumstances due to an ongoing risk of infection associated with their use.

Providers of adventure activities may have these products in their first aid kits.

The affected products are:

  • ValueAid Alcohol Free Cleansing Wipes
  • Microsafe Moist Wipe Alcohol Free
  • Steroplast Sterowipe Alcohol Free Cleansing Wipes
  • Reliwipe Alcohol Free Cleansing Wipes (Burkholderia strain not related to the outbreak cases)

Newsletter Autumn 2025

Autumn 2025 newsletter

Learning Through Loss – Sector-wide reflections on safety

A recently published article from British Caving Association, British CyclingMountain Training, and Paddle UK presents some joint reflections on fatal incidents during instructed/guided adventure activities. The article urges all leaders to reflect on these events—and consider what must change.

Our Role at Adventure RMS

As an inspectorate, we see this as a useful initiative. It’s in keeping with our commitment to support providers in embedding safety culture, beyond meeting compliance. It is a theme we have addressed  through conference presentations and workshop sessions over the past few months.

You can read the original article here.

Being ‘Late’ – the implications

Applications for renewal should be received by the AALA not less than 3 months and not more than 6 months before the expiry of the current licence. 

Ensuring an application has been accepted on time (during this period) means the licence will remain in force until such time as a decision is made. 

Not having an application accepted within this window means the applicant risks: 

  • Being unlicensed and therefore unable to legally provide activities for which a licence is required 
  • Not being awarded an ‘additional’ year duration – if it expires during the review period 
  • Returning to a 1-year duration (or less) – if it expires before a renewal application is accepted 

In a recent example a provider who would have received a 3-year licence, had the application been made in good time, has been issued a licence with an 11-month duration!  

Emerging themes in licensing reviews

Over the summer we have become aware that managing poor water quality is an issue for many providers. 

Contaminated water is a persistent and increasing hazard to health, with heightened concern following regional discharges, algal blooms, and cases of leptospirosis. Things providers should be considering include: 

  • Poor water quality as a foreseeable risk  
  • Control measures to manage risks which might include; amended session plans, location alternatives, alert systems, tidal cycle planning, alternative activities and cancellations 
  • The possible need for instructors to respond to contamination observed during a session 

Recent revocation of AALA licences – understanding Licence Conditions

Only those who can meet and maintain the relevant safety standards are permitted to hold an AALA licence, and non-compliance is taken seriously. This summer AALA revoked three licences. The circumstances for each were slightly different, however in every case the provider had failed to comply with the conditions on the licence.

All licences are issued with ‘conditions’, which are described in Regulation 9 of the Adventure Activities Licensing Regulations 2004 (AALR) and are set out on pages 2 and 3 of the licence.

Maintaining Safety Management Arrangements  

The conditions require licence holders to maintain suitable and sufficient arrangements for the management of safety. In particular the conditions relate to:

  • The implementation, control, monitoring and review of the measures they will use to manage risks
  • Appointing sufficient, competent instructors
  • Giving safety information
  • The provision, maintenance and storage of suitable and sufficient equipment
  • Providing first aid and dealing with emergencies.
  • Appointing a competent person to advise on safety

It is crucial that licence holders ensure safety management remains in the hands of competent persons. Those appointed can be in-house or external, but they should be both competent and, in a position to ensure that the control measures the organisation has identified to manage the risks of its activities are implemented, controlled, monitored and reviewed – throughout the period of the licence.

In short, the conditions require the licence holder to maintain the arrangements under which the licence was granted in the first place – this doesn’t necessarily mean the same people, doing the same things with the same equipment. BUT it does mean that management arrangements that determine the way things are done, maintain the same standard of safety.

Non-Compliance and Licence Revocation 

If at any time the AALA considers these conditions are not being met it may consider the revocation or variation of licences. A variation might mean a change or reduction in the activities on the licence. A revocation means the provider is no longer licensed and is not permitted to provide any licensable activities unless they are successful in applying for a new licence. When a licence is varied or revoked AALA’s public register is amended to reflect this. The recent policy change on licence durations that rewards ongoing compliance means that, if successful in obtaining a new licence the provider will only be eligible for a one-year licence.

As well as losing the licence, a provider who provides licensable activities while being non-compliant with the licence conditions is committing an offence under the AALR 2004, and in most cases, they will also be committing an offence under the Health and Safety at Work etc Act 1974. Offences of this nature can be punishable by a fine and/or imprisonment. Enforcement of the legislation is the responsibility of HSE and the local authorities, and AALA will inform them of any potential breach.

Licence holders are reminded to read the conditions on the licence document and ensure they are continuing to comply with the conditions under which the licence was granted.

Updates & Workshop Opportunities 

Our head of service delivered a series of updates and workshop sessions throughout the 2025/26 winter period, both at sector conferences (AHOEC, SAPOE and Expedition AAP) and directly to organisations.

These sessions are designed to support providers, share insights from recent licence application reviews, and encourage thoughtful dialogue around safety management in adventure activities. 

Licensing Scheme & Inspectorate Role 

Our update sessions provided an overview of the current work of Adventure RMS as well as the key changes introduced to the AALA licensing scheme in April 2025 and thoughts about the implications of these changes for licence holders. 

Reflecting on recent fatalities

These focus on the issues raised by recent fatalities during instructor-led activities. While each incident is unique, there are common themes that apply across all forms of adventure activity provision. 

Workshop discussions will explore: 

  • Safety management in the context of location and participant needs
  • Identifying shared themes across serious incidents
  • Risk and benefit in activity planning
  • Practical steps for decision-makers

Delegates are reminded that effective safety management doesn’t need to be complex—it requires competent people to do straightforward things.  

Adventure RMS presentations and, in some cases, workshops will be taking place at events on the following dates: 

12th & 13th January 2026 

  • The Association of Heads of Outdoor Education Centres (AHOEC)

12th February 2026

  • AIM Member Event

We are also able to deliver sessions to groups of activity-specific providers and other organisations.  

If your organisation or network would benefit from a tailored workshop or briefing, please email info@adventurerms.org.uk

Recent revocation of AALA licences

Compliance with licence conditions

Only providers who meet and continue to meet the required safety standards are permitted to hold an AALA licence. Non‑compliance is treated seriously.

AALA revoked three licences in summer 2025. While the circumstances differed, each case involved a failure to comply with the conditions attached to the licence. All licences are issued with specific conditions, as set out in Regulation 9 of the Adventure Activities Licensing Regulations 2004 (AALR). These conditions appear on pages 2 and 3 of every licence.

Maintaining safety management arrangements

Licence conditions require providers to maintain suitable and sufficient arrangements for managing safety. In particular, licence holders must ensure:

• Effective implementation, control, monitoring and review of risk‑management measures
• Appointment of sufficient, competent instructors
• Provision of clear safety information
• Provision, maintenance and appropriate storage of suitable equipment
• Providing first aid and dealing with emergencies. 
• Appointment of a competent person to advise on safety

It is essential that safety management remains in the hands of competent individuals. These may be internal or external, but they must have the competence and authority to ensure that control measures are implemented, monitored and reviewed throughout the duration of the licence. In practice, this means maintaining the safety management arrangements under which the licence was originally granted. This does not require the same people, processes or equipment—but it does require that the organisation continues to operate to the same standard of safety.

Non‑compliance and licence revocation

If AALA considers that licence conditions are not being met, it may vary or revoke the licence. A variation may restrict or reduce the activities permitted. A revocation means the provider is no longer licensed and cannot offer licensable activities unless they successfully apply for a new licence. Any variation or revocation is reflected on AALA’s public register. Under the recent policy change on licence durations, a provider that has had a licence revoked and subsequently reapplies will only be eligible for a one‑year licence.

Providing licensable activities while non‑compliant with licence conditions is an offence under the AALR 2004 and, in most cases, also under the Health and Safety at Work etc. Act 1974. These offences can result in fines and/or imprisonment. Enforcement lies with HSE and local authorities, and AALA will notify them of any potential breach.

Reminder to licence holders

Providers are strongly encouraged to review the conditions on their licence document and ensure they continue to comply with the arrangements under which the licence was granted.

Remote inspections – information from HSE/AALA

The HSE/AALA provided the following responses in relation to frequently asked questions about remote inspections to all licence holders in January 2025.

  1. Why are you making this change?

We want to make sure that the impact of the assessment process on applicants is proportionate and we want to introduce some flexibility to take into account circumstances when the inspector feels a site visit is unnecessary to make a decision. HSE successfully uses remote inspections for some other aspects of its business and remote inspections were previously adopted by AALA during the Covid19 lockdown period. They were found to be effective and efficient.

  1. Will the savings mean a reduction in the licence fee?

No, the fee will not be reduced. AALA is subsidised. The licence fee has remained unchanged since 2008, and has not kept pace with inflation. Any savings made by this change in policy are small and with increasing costs, will not significantly reduce the subsidy AALA receives.

  1. Can you provide examples of what could trigger a site visit?

Things that could trigger a site visit include:

  • A first time application
  • A significant change since last application, e.g. use of a new and unfamiliar location, changes to key staff or staffing arrangements, a radical change to the type of activities being offered.
  • A serious accident or justified complaint since last application
  • The Inspector requires information that cannot be obtained remotely
  • The Inspector has reason to doubt information provided, e.g. conflicting or unreliable accounts from different people interviewed during the process or inconsistencies in submitted documents.
  • Information supplied, e.g. about operating or emergency procedures that are unusual, unfamiliar or unclear.
  1. Under what circumstances would you not carry out a visit for a first applicant, and why if a visit was deemed of no material value for a first time applicant, would it offer value at the first renewal (assuming no changes are made to the application)?

First-time applicants cannot offer licensable activities until the licence is granted, so there may be nothing to observe. Some first-time applicants have no other (non-licensable) activities to observe as a comparison, and some have no activity centre. Occasionally it may not be a good use of inspector’s time to travel to someone’s home, or to an office for conversations that can be conducted online. In these circumstances a visit will take place when renewal comes around, once activities are up and running and venues confirmed.

  1. Can you explain what “where appropriate” means, e.g. would high staff turnover be a consideration, or level of risk such as grade 4 white water or multi-pitch versus single pitch climbing?

HSE has proposed that “remote inspections will be used where appropriate”. This means that remote inspections will not be used unless the inspector is confident that a decision can reliably be made without going on site. Remote inspections may be appropriate in the following scenarios

  • The provider has had a site visit recently for another reason, e.g. a complaint investigation or a licence variation.
  • The inspector is familiar with the applicant’s provision and is satisfied that there have been no material changes since the last inspection.
  • The centre is closed/no activities occurring and there is no added benefit to going onto site.

Ultimately it is for the inspector to decide whether a site visit is necessary to make a decision.

  1. Will there be a maximum period of time between site visits?

No, there is no one size fits all programme of visits. Site visits will occur where necessary, but they will not be imposed where there is no value to the decision-making process.

Local authorities to target unlicensed adventure activity providers

This year, local authorities across Great Britain are targeting unlicensed adventure activity providers that may be operating within scope, and in contravention of the Adventure Activities Licensing Regulations.

This campaign aims to ensure that anyone providing licensable activities has had their safety management systems assessed by an AALA inspector. It is an offence to provide licensable activities without a licence and anyone found doing so can expect the authorities to take enforcement action including the use of Notices to stop provision of the activity in question, and if appropriate, prosecution.

Those who hold a valid licence are unlikely to receive a visit, so licence holders are reminded to make sure their licence is valid and check the expiry date. To allow uninterrupted provision of licensable activities, they will have to submit their renewal application at least 3 months prior to the expiry of their existing licence. Licence holders are also advised to check that their licence permits them to provide all the licensable activities they offer. If it does not, they should inform AALA immediately by emailing AALA-Applications@hse.gov.uk

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