posted by Dave Reeve
In this essay I intend to present a set of reasons why the free-wheeling, outdoors-loving, climbers of our community should embrace that bane of their work-a-day lives, the world of paperwork, spreadsheets and conformance, at least, in as far as demanding that it apply to the fixed infrastructure on which we confer such trust. Sometimes, paperwork is exactly what is needed.
However, don’t panic, I’m not suggesting that we have to stop climbing and start filling out forms, but, I am saying that we need to get used to paying others to do the paperwork for us. In the case of climbing bolts this means we need to get used to paying a premium for an EN 959 / UIAA 123 compliant product.
It seems strange to me that Australian climbers have accepted the enclosure of ropes, harnesses, slings, carabiners, cams and nuts within a regulatory framework imposed by the European Union without so much as a murmur. At no point has anyone suggested that such safety standards are a restriction of their right of free choice, that, really, a length of rope from the local hardware would do just fine. On the other hand, looking over the same period of development of the sport, the imposition of an similar dictate with respect to bolts has been to the larger extent ignored, and, as a consequence, today’s climber can be confronted on the rock with a bewildering array of fixed protection of unknowable provenance and uncertain performance.
Why is this? Is it because there is a difference between what we would do for ourselves versus what we would do for anonymous others – because ropes and gear are exclusively personal property and cliff infrastructure is not? I’d like to think not. I’d like to think that, as a community, we were smarter than that.
Finally, I should state that we in Queensland have been lucky to have had a decade of leadership and guidance through the active community initiative of Safer Cliffs Qld. This initiative has tracked evolving ‘best practice’ and done much to discourage ‘rogue’ bolting within the State. Thus, I see my call for a move to standards compliance as something that builds upon the efforts of Safer Cliffs, not as a criticism of them.
Product safety standards in a nutshell
I’ll briefly put on my safety engineer’s hat. Trust me, this will be painless…
In drawing up a safety standard for say, a climbing rope, the first thing that needs to be done is to define how the rope will be used within the intended application space. We safety engineering geeks like to define formal use-cases within a formal domain. The idea of this is that it allows us to be very clear about what is normal use and what is abuse. Thus, doing things like using the rope to tow your car, or to tie up the dog, are outside the domain, whilst taking whippers when working a sport climb is within the domain.
Within the restrictions of the domain, we then consider what the properties of the rope should be, given that risk to the climber is to be mitigated. For example, given a worst case fall of factor two, the impact force on the climber should be less than the nominal 12kN considered as the upper limit of survivability for the human body. Accordingly, we see prescribed within the standard for dynamic climbing ropes, a drop test, and an associated maximum impact rating of 12kN.
In a nutshell –
In conforming with a product safety standard, a manufacturer vouches that his product is ‘fit for purpose’ within the restrictions of a particular domain.
It is worth pointing out that the domain reference is critical, and it is absolutely unsafe to take products from one domain to another. For example, a standard applicable to the integrity of an anchor employed in the height-access domain, should not be taken as applicable within the recreational climbing domain and vice versa. Similarly, a nice shiny stainless steel carabiner product from your local ships chandler is not fit for the purpose of a climbing anchor lower-off.
Product safety standards are kryptonite
Firstly, I’ll discuss a viewpoint that is perhaps uncharitable, but nonetheless a reality that comes with exposure to the public gaze. So, I’m standing at the base of the cliff at KP and, as far as I am concerned, minding my own business, when I am confronted by a self-important fellow who wants to share with me the insight that climbers, and by inference, myself, are few pence short of the pound. “What makes you think those fixtures in the cliff will hold your weight? What makes you think that rope is strong enough?” And so on. “Ah…. ok…. time to unwrap the krytonite”, thinks I. So I point to the figures on the spine of a biner…”Oh look it has a CE mark. Oh look 23kN, strong enough to lift your car into the air”. The corporeal dimming is evident as we move on to study the dyneema sling at my waist…”Oh look, another of those CE marks. Oh look 23kN again, that’s another car off the ground”. By this stage my antagonist has diminished to a mere wraith, so I finally hit out with, “And those fixtures on the cliff are EN 959 compliant you know, strong enough to hang your car on” to conclude the vaporization process.
When, as climbers, we are confronted in the manner above, either by members of the public or by officialdom, we often find a cultural divide that is hard to bridge with words alone. However, citing a standard legitimizes our activity, and suddenly everyone is happy. I know this is bizarre, but it is something I have seen work time and again. When the lycra-clad super-hero, defender of the common decency, arrives to challenge your behaviour, it is good to have kryptonite to hand.
Recreation on the public estate
Whilst it is personally satisfying to tranquilize the officious, it is better from a public policy point of view to understand the arguments that can be made regarding the recreational values of the public estate. In this regard, we can say that bolting a bunch of sport climbs at an otherwise unfrequented crag undeniably adds to the recreational value of the area. Such value will increase into the future as the popularity of the sport grows, but it comes with a maintenance cost that has to be borne by the public purse. These costs range from that of having to manage increased visitor impacts, through to the payment of public liability claims.
As a community, we need to be adept at arguing the case for climbing as a net value-add recreation. We need to understand which of our actions add value, and which work to minimize potential costs. The value-add of bolted infrastructure is easy for us climbers to comprehend, the issue of public liability, less so, especially given that, for most climbers, the taking on of personal responsibility for the control of risk is a big part of the appeal of the sport.
However, It is inescapable that the act of ‘putting on the mantel of land manager’ brings with it a plethora of issues over which the manager is obliged to exercise ‘duty of care’. These obligations are neither trivial, nor straightforward, being under-pinned as they are by the very broad principles of Common Law. And where that land manager is a government agency, failure to provide ‘duty of care’ can elevate public liability claims to being a substantial drain on the public purse, and ultimately the tax payer.
Of particular relevance to the climbing community, is the issue of the public liability associated with bolts. This one issue alone, has dampened the development of recreational climbing within the NPRSR estate over the last twenty years. I have written a long piece on the history of this subject here. In recent years, the ‘Civil Liability Act’ of 2003, and the ‘Nature Conservation and Other Legislation Amendment Act (No. 2) 2013’, have been introduced with the intention of reducing the stifling effect of a litigious public environment on the development of outdoor recreation. And it is pleasing to see indications that this is starting to happen.
However, put yourself in the shoes of the land manager sitting at his desk in George St. You know items of infrastructure are being installed throughout the estate you manage, and the best you can do is hope that a) the installers are adequately discharging their ‘duty of care’ , and b) if they aren’t, the ‘dangerous activity’ provisions of the Civil Liability Act will be sufficient to shield the public purse.
More kryptonite, please
Enter the kryptonite – nothing discharges ‘duty of care’ like a an international standard. It brings independent, third party, internationally recognized opinion to the table. That being said, we need to flag the corollary that nothing leaves lingering questions about the discharge of ‘duty of care’ like the failure to apply a standard when one exists. Step into the land managers shoes again for the moment. What would you rather do? – get involved in arguing the details of the specification of a bolt, or stand back and apply internationally recognized third party opinion? And how much does that third party opinion cost when it is built into a EN 959 conforming bolt? Lets say $3 extra per bolt, times eight bolts, is $24 for a typical sport route. With a life span of twenty years and one thousand ascents per year that comes to an amortized cost of 0.12 cents per ascent. One has to wonder why we even need to discuss this.
EN 959 and UIAA123 – the standards for climbing bolts
EN 959 is a standard produced by Technical Committee CEN/TC 136 of the European Union. On the other hand, UIAA 123 is a standard of the International Mountaineering and Climbing Federation. The latter builds upon, and adds further requirements to EN959. In practice, the differences from the manufacturing point of view are minor, and thus we find that commercially available bolts, if rated, tend to be rated for both standards.
We don’t need to sweat the engineering details, and instead, can concentrate on what these standards do for us. A conformable bolt will withstand at least 15kN (EN 959) or 25kN (UIAA 123) outward pull when properly set in the rock. There are other desirable features of a climbing bolt, but this performance figure is the big one.
Unfortunately, UIAA and CEN/TC don’t show their working, and thus we don’t know the reason for the minimum load values they specify. However, it is possible to show that using a UIAA/EN conformable dynamic rope, harness, slings, carabiners etc, that the possibility of generating a force in excess of 15kN on a bolt is extremely remote. Of course, we have every reason to want to quantify ‘extremely remote’. With thousands of folks out climbing most days of the week, you’d think it likely that someone is going to get unlucky.
Firstly, anecdotal evidence shows that even with the fairly patchy bolting standards of the past, severe harm arising directly as a consequence of bolt failure is very rare. The reason for this is that the exposure to harm is not as great as it might seem to the casual observer. Climbers are taught to avoid exposure to single point failure and will employ redundant safety systems to the greatest extent possible.
Secondly, when we calculate the probability of a load exceeding 15kN at a bolt, we find it is very, very low. I know this from the probabilistic models I have built in my attempts to quantify the risks associated with bolt failure. For example, if we assume a typical mix of male and female climbers, each category having a typical distribution of body weights, and we have them climb using some ten to twenty different ropes each of different impact force rating, and then have them fall at different heights above bolts set at a range of heights above the ground, we can estimate the distribution of impact forces experienced by a typical first bolt, a typical second bolt and so forth. As we might expect, the forces involved with first bolts, far and away exceeds that at the higher bolts due to the dominant effect of the fall-factor.
For a typical first bolt, we can show that less than one in one million falls on that bolt will exceed the 15kN limit. For second and third bolts the chances of failure are vanishingly small. Given that the majority of climbers are not going to fall on all the first bolts we have out there, it would take a participation rate of millions of ascents per annum before the EN 959 specification could be shown to be insufficient.
Thus we can see that –
EN 959 provides a specification that ensures compliant bolts are ‘fit for purpose’ within the recreational climbing domain. The level of structural integrity can be considered just right for the application space.
Can home-made bolts be EN959 compliant?
Yes they can, but there are caveats. To fully understand the gravity of the caveats we need to take a look at how product safety works within the European Union, because this is the framework that is driving the safety standards of recreational climbing equipment worldwide.
Without getting mired in European law, we need to understand that the standards applicable to things like dynamic climbing ropes, harnesses, biners, in fact most items of gear, are drafted to support a presumption of conformity with the Personal Protective Equipment (PPE) Directive, 89/686/EEC, of the European Parliament. Whilst the PPE Directive is the law, the standards themselves are not law. However, by complying with the standards, a manufacturer can argue that they meet the requirements of the law, and thus should be free to apply the CE mark to their product, and likewise free to place it on the market within the European Community.
In practice, the PPE Directive holds up two further hurdles one must clear. These are generic process requirements which reflect the seriousness of the consequences of failure to conform with the applicable standards. The first of these is that conformance of a sample with the standards must be confirmed by a type-approval body at random intervals of not less than one year. The second is that a quality system must be in place to oversee the manufacture of the product. This is where the paperwork, and additional cost comes in.
These latter hurdles appear insurmountable for any small operation wishing to manufacture bolts, but there is “wriggle-room”. Personally I don’t believe such wriggling is good for the climbing community, or the industry, but I’ll describe it so we can understand what is possible here, and especially what claims can be made for a product that comes into use.
The most obvious room in which to wriggle can be found in the fact that although a harmonised standard, EN 959, exists for bolts, the standard is not called up here as a means of compliance with the PPE Directive. Now it can be argued that Article 1.3 of the PPE does not extend to the means of attachment to the rock –
Any system placed on the market in conjunction with PPE for its connection to another external, additional device shall be regarded as an integral part of that equipment even if the system is not intended to be worn or held permanently by the user for the entire period of risk exposure.
Thus ropes and slings are clearly in, but points of attachment to the rock such as bolts, maybe, not so much. Yet we have harmonised standards for pitons, ice-screws, cams and nuts called-out as supporting compliance with the PPE Directive, but not bolts. Go figure! It looks like EN 959 fell into the EU ‘too-hard-basket’.
So if you market a piton in Europe, then there is no escaping the need for it to be CE marked indicating its compliance with 89/686/EEC, which in turn means it is has to be EN 569 compliant. But a climbing bolt? No such requirement exists. Of course, the usual principles of product liability would apply, but the fact remains you are not going to have anyone chasing you because it is not CE marked.
Thus, provided the home workshop yields a product that conforms with the design requirements of EN 959, there is no reason why EN 959 compliance can’t be claimed for this product. In my opinion this is both a good thing and a bad thing – good because it sets the bar for acceptable bolt design at a level that is robust, inexpensive and within the capabilities of folks who like to do their own thing – bad because, whilst the design is specified, the manufacturing process is not, and without things such as compositional analysis of incoming stainless steel stock, we can expect to see a lot of ‘rogue’ stainless ending up on our cliffs.
Can home-made bolts be UIAA 123 compliant?
No they can’t, or more exactly, they can’t carry the UIAA certification mark. The UIAA standard requires samples be submitted to the UIAA certification authority for inspection. It also goes further than EN 959, and places a requirement for the verification to type of incoming steel stock. In this sense, the UIAA standard has more of the intent of a standard pendant from the PPE Directive. Thus UIAA 123 compliance involves a quality system and paperwork, a show stopper for the small home workshop.
Where to from here?
New route developers are a special breed – highly individualistic, and given to ‘secret squirrel’ bolting operations. Because not all of this group will embrace standards, we can expect to see that as new routes spring up, there will be some with good bolting, and others less than good. Personally, I don’t see this as a problem because the risk from bolt failure is strictly proportional to the traffic, and if a route is ignored, the bolts are a matter of tiny concern. Providing the bolting itself is not visually intrusive, the route will fade into obscurity.
However, not all new routes are doomed to oblivion, and if a crag offers sufficient quality routes, and if it is within 20 minutes of a car park, it is inevitable that it will become popular. At some point in the growth of its popularity, the integrity of the bolting will become an issue. It is this second phase of crag development where standards are clearly appropriate.
Firstly, being popular, the crag will be on the radar of the land manager who rightly will have concerns about the bolting quality. If a crag is to be shut down, it will be at this emergent stage of its existence. Thus, being able to point to an international standard for the infrastructure is invaluable.
Secondly, being popular, if there is to be an accident arising from bolt failure, this is when it is most likely to occur. That is, at the point when there is a marked increase in traffic on aging or incompetent hardware. On the positive side of the equation, however, we have the fact that it is far easier to raise the funds needed to rebolt a popular crag than someone’s pet project. So the issue comes down to one of community awareness and leadership.
We are well into this second phase, a maintenance phase if you like, for a number of crags in South East Queensland.
It should be obvious that replacing one lot of poor quality bolts with another does little more than line up a third phase of maintenance, and beyond that, a fourth and so on every five to ten years down the track. I would hope that, as a community, we have sufficient vision, and are sufficiently caring for the climbing generations that follow, that we don’t entertain a course of action that creates the pock-marked mess of continual bolt replacement that we see blighting some overseas climbing destinations. The UIAA are onto this problem, and are addressing the issue of bolt life span with a view to specifying bolt designs which should achieve a truly inter-generational service life of fifty years. This seems a very worthy aim, and if such bolts could be installed at the second phase, imagine what it could do for the sustainability of a crag over several generations. Surely this is an initiative we can all support.