Barriers to Ocean Literacy in NSW High Schools - Managing Risk

Risk management in schools greatly impacts on student activities related to ocean literacy in terms of allowed activities, the ease with which teachers can facilitate different activities, the paper work associated with activities, and the cost associated with control measures. Most of this is covered by the NSW Department of Education's Specific sport and physical activity guidelines, although there are a number of other issues addressed in other policy documents which are relevant. While there are policies and documents to guide decision-making around excursion approvals, school leadership is made up of a team of humans with their own concerns, including about their own legal liability, the school's legal liability and their individual responsibilities and accountability as leaders.

In my previous role as a deputy principal, part of my role involved approving excursions, working through risk assessments with teachers to identify possible issues and workable measures to control or eliminate risks. The risk management process has evolved throughout my career - over time many more risks are expected to be identified and teachers are expected to implement much more rigorous control measures. Teachers are often frustrated by expectations around this process, particularly around water-based activities, which I can understand given the time pressures teachers are under, but I also know how important they are.

Anaphylaxis
Let's start by thinking of a very simple activity related to ocean literacy - walking along a beach collecting shells, seaweeds or seagrasses, or exploring rock pools in the intertidal zone. Around 2005, very strict rules and and rigorous training was put in place for all schools and education providers regarding anaphylaxis. While the initial professional learning around the issue was heavily focused on peanut allergies, it also included anaphylaxis and allergies related to shellfish. Prior to even undertaking simple activities with students, teachers and facilitators need to obtain medical information of students to ensure there are no students with shellfish allergies. Any students with identified allergies/anaphylaxis must not handle oysters, mussels, etc. or anything that may have residue of shellfish (this could also relate to activities such as oyster dissections, oyster filtration demonstrations, etc). This restricts a student with this condition from participation, and alternate activities need to be provided. Obviously both teachers and facilitators need to carry epipens and ASCIA Action plans, and ensure up-to-date training. While the learning activity seems quite simplistic, the ramifications of not managing this risk correctly are extreme.

Swimming, snorkelling, scuba diving
Obviously the best way to engage students in ocean literacy is to actually get them in the water! As a very early career teacher, I had the privilege of taking one of my first HSC classes to the Great Barrier Reef. I convinced an experienced head teacher to come along with me - I was in charge of the trip organisation and learning activities, and he was in charge of the discipline, and there in case anything major went wrong. Even back then - over 20 years ago, the trip involved a 12-page risk assessment, and the trip wouldn't have gone ahead without rigorous control measures in place. Despite this, the measures are much more strict now.

Most schools run the obligatory excursion to a local beach to study coastal processes or rock platforms, but often curriculum-based excursions to the beach don't include students getting into the water. This is mostly due to risk management and legal liability for excursion providers, and also often due to schools taking a whole year group out at a time, which makes it too difficult to manage (up to 150-200 students). A few school camp providers offer surfing and snorkelling for large numbers of students where they can be rotated around different activities so they can keep the staff to student ratios down.

School activities with smaller numbers like school sport or smaller elective or senior classes, can more easily facilitate water-based activities. A few schools offer surfing or kayaking as part of organised sport, and elective and senior classes in subjects like Marine Studies, Geography, and Biology may be able to facilitate snorkelling. In additional to regular equipment maintenance (if owned by the school), the risk management strategies required for these activities mainly involve student ratios and swimming assessment prior to the activity, both of which can substantially increase the cost per student, and organisational requirements for teachers. The most impressive recent example I've seen is Erina High School whose 2026 Year 12 Marine Studies class have been working towards their Open Water Diving certification and who scuba dived with grey nurse sharks at Terrigal Haven earlier in the year.

Below is a list of some of the strategies to manage risk that are required of schools. The information below is current at the time of posting, but different education systems and individual schools may have their own strategies and restrictions, and requirements can change over time. This is not a comprehensive list.  

Swimming
Some of the risk control measures for swimming include:
​- a reasonable assessment of student swimming ability before the activity
- safe participation of weak or poor swimmers must be addressed

Qualified instructor to student ratios are:
- supervisor to student ratio in any swimming activity is not to exceed 1:15.
- minimum of 2 adult supervisors with appropriate training
- At beaches or inland waterways, at least one supervisor must possess a current SLSA Bronze Medallion or SLSA Surf Rescue Certificate or APOLA School Surfing Supervisor Award; and one accompanying teacher must have CPR National Accreditation HLTAID009.
- All other supervisors must have one of the following: RLSSA Bronze Medallion, SLSA Patrol Bronze Medallion or SLSA Surf Rescue Certificate, APOLA Ocean Safety Surf Coach Award, Surfing Australia Level One Coaching Certificate or AUSTSWIM Teacher of Swimming and Water Safety or ASCTA Swim Teacher Australia  Certificate.

Snorkelling
Some of the risk control measures for snorkelling in open water include:
- visibility must be more than 3 metres
- currents must be less than 0.5 knots
- unbroken waves must be less than 0.5 metres.
- depth of water must not exceed 5 metres unless students have completed an Ocean Snorkel Diving Course.
- snorkelling should be within 200 metres of the shore or within 100 metres of a boat.
- students must enter at safe entry and exit points
- students must be able to swim continuously for 200 metres, using any stroke, then perform survival sculling, floating and treading water for 10 minutes without the use of fins (this swimming assessment needs to occur prior to the activity).

Qualified instructor to student ratios are:
- snorkelling instruction in a pool - ratio 1:12
- snorkelling - open water - chest deep, optimal weather and water conditions, easy entry/exit - ratio 1:10
- snorkelling - general open shallow or deep water - ratio 1:8

Any students with medical conditions that place the student at risk in the water must not participate.

Scuba Diving
Risk Management for scuba diving is complex. Regulations can be accessed here: https://app.education.nsw.gov.au/sport/GUIDE_SCUBA-DIVING for teachers in DoE schools.

Stings & bites
Water-based activities in tropical areas have always taken into account stings from marine organisms such as box jellyfish and irukandji, and as a result it is always better for students to wear stinger suits, even out of stinger season to minimise risk. With warming waters and movement of some tropical species southward, extra precautions could be considered to reduce risk outside of traditional locations that require them. 

Sharks
The recent spate of shark activity in and around Sydney Harbour has raised some additional issues for schools wanting to undertake water-based activities. Additional tagging and public access to information about monitoring of shark movements, both through apps and by drone/social media has increased community awareness of shark activity. Media campaigns around increased risk associated with reduced water clarity and run off following rainfall have occurred. Some risk averse school executive teams raised concerns or cancelled some activities during this period, and additional risk management measures have been put in place for some activities. Most schools will prefer for students to swim and snorkel within fully netted areas (e.g. harbour netted swim sites).

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Risk management and implementing appropriate control measures can be a barrier for schools to implement engaging, immersive ocean literacy activities. For teachers organising water-based activities that support ocean literacy, the risk management strategies, on top of the usual school excursion planning processes can be very onerous, and many teachers will put them in the "too-hard basket". Regardless, these processes are necessary to reduce the risk of injury or death to students. We all sometimes complain about the risk management processes in place, but they are there for a reason.

How can these issues be addressed?
- the Department of Education should develop standard procedures to simplify approval processes for water-based activities. This could include:

• students undertake mandatory swim tests at the beginning of each year (this could be part of a swimming carnival,  mandatory organised sport activity, or integrated into PDHPE programs (as appropriate).
• downloadable, standardised risk assessment documents for set activities, e.g. snorkelling, surfing, scuba, etc.
• approved/preferred swim/snorkel/scuba businesses who align their processes/practices with DoE procedures and ensure they meet all requirements.
• identified, approved open-water locations in each directorate/region.

- programs related to ocean literacy can be developed with small interchangeable teaching modules that can be switched in or out depending on student characteristics such as anaphylaxis (shellfish), poor swimming ability, non-swimmers, etc.
- teachers should set up excursions with multiple, set back-up dates to take into consideration changes to weather conditions, ocean conditions, etc. so that the excursions can easily be rescheduled.





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