Professional Ropes Course Association (PRCA)
www.prcainfo.org
July 17, 2006
Anne Caldas
Secretary, ANSI Executive Standards Council (ExSC)
American National Standards Institute - ANSI
www.ansi.org
25 West 43 Street, 4th Floor
New York, NY 10036
acaldas@ansi.org
212-642-4914
Fax: 212-840-2298
Dear Anne Caldas,
Per the appeal of the Professional Ropes Course Association (PRCA) ANSI American Standards
Developer (ASD) status requested by the Association for Challenge Course Technology (ACCT)
complaint, please find herein our response to the allegations asserted before you and our numerous
supporting documentation that will validate our position. We are confident that we have gone
above and beyond in our responsibilities to include as many affected individuals in our process.
We are confident that our supporting information and actions will show that the appeal is without
merit. Our documentation will prove that the ACCT has been controlling of vendors in their
association and has caused and contributed to this stale mate between our two associations.
Furthermore, it will become self evident that the very information ACCT desires to take credit for,
in fact, has been available with the ropes challenge course industry for many years preceding their
formation and creation of standards and that the allegations of borrow standards is without warrant.
Statement of Facts – EXSC 6631
History of ACCT Standards
Paragraph #1
In addition to the ACCT version, it should be noted that ropes challenge courses have been
operational in the USA since around 1971, with Project Adventure (PA) (founder Karl Rohnke)
and 1977 Treeline (founder Rob Rubendall) being some of the very first ropes challenge course
companies, some twenty-three (23) years prior to the first ACCT standards. At the inception of the
PRCA, Karl Rohnke, most often referred to as the inventor of the modern day ropes challenge
course, was contacted and asked of his support for another ropes challenge course association. Mr.
Rohnke was even offered an honorary Board of Directors position to include the industry founder.
Regretfully, Mr. Rohnke has retired from the industry and is currently battling cancer. We wished
him the best of health and left the door open for his future participation.
During the time between 1971 and 1994, the Association for Experiential Education (AEE)
[www.aee.org] had published a red jacketed manual outlining minimum and best practices for
ropes challenge course construction, authored by Simon Priest and Tim Dixon and entitled “Safety
Practices in Adventure Programming.”(1) Outward Board at various locations and other programs
(15, 16) had also produced operations manuals that spoke to practices, operations, construction
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materials, and installation methods. Please note that a PRCA Board Member, Joel Cryer, is listed
as a contributor to this document (1). Rob Rubendall (2), the PRCA Board President mentor in
1990, also had input into this document on August 3, 1990. Within this document, there was a
section on ropes challenge courses and it stated items such as wire rope type, clamps, Safe
Working Loads, operational practices, back-up systems, and other information on challenge course
maintenance that had already been open and “common knowledge” in the industry, long before the
ACCT published their guidelines / standards in 1994 or the ACCT formation in 1993. For
additional support, herein is a copy of the George Williams College, OWLS Campus, Supervisor
Training Agenda (3) collated by Rob Rubendall, Cathy Coster, Gary Cwidak, and others at the
program, all whom had been in the industry for upwards of 5 - 11 years prior to the formation of
ACCT. These professionals also acted as mentors to numerous intern professionals over the years,
consulting on building, inspection, maintenance, and operation. The document clearly shares
information about ropes challenge course construction, materials, and Safe Working Load data
four years prior to the ACCT published standards of the time. Further, the ACCT was an informal
sub-group under AEE in its early years of formation and AEE is the largest association within the
industry of experiential education. ACCT maybe viewed as a sub-set of this industry as well could
the PRCA.
Many of the individuals who sit on the PRCA Board of Directors, contributed to the first PRCA
standards published in April 2004 and/or sit on the current Consensus Body, all are highly
qualified professionals and carry high levels of pertinent industry experience. Further, these Board
members and initial document reviewers had been within the ropes challenge course industry from
one to fifteens years (1-15) prior to the first publication by ACCT. We assert it not fair and
improper representation that ACCT suggest they created or are the only source of industry
knowledge, and by default, the PRCA standards had to have been sourced from their document.
Much, if not all, of this information has been available for numbers of years prior to the formation
of ACCT (15, 16). Herein is a copy of the version of the PRCA standards (4
[PRCA_Standards_April_2004.pdf]) available in April 2004. At the time PRCA first made
standards available to its membership, ACCT’s contemporary standard was the ACCT Fifth
Edition, January 2002 (5). It is clear that the PRCA standards had incorporated much more
information than the ACCT January 2002 standards as referenced and opinions can be made that
the ACCT May 2004 (circulated in August 2004) standards more clearly copy the PRCA format,
drawings, and content as a way borrow from the PRCA and to keep up with a new association.
Additionally, the ACCT January 2002 standards are not really standards as ACCT themselves call
them standards but yet the application warning calls them “guidelines.” (5A)
Paragraph #2
While the ACCT has spent much time and a great deal of association funds for the development of
their standards, in many cases the ACCT has only shared results of the research underlying their
standards with ACCT Board Members and Professional Vendor Members (PVM) as noted in their
letter. It’s the PRCA’s opinion that it is an unfair practice to take funds from the general
membership and then selectively share the results from the funded research with only select
vendors and/or members they choose. It should also be noted that the ACCT began as a trade and
marketing association. Their PVM’s (Professional Vendor Members) used to be entitled Preferred
Vendor Members and/or Voting Members. These PVM’s receive many special marketing
advantages. They receive the research data, publicity and marketing in the ACCT newsletter, on
conference handouts, and on the ACCT website. Becoming a PVM is meant to be a voluntary
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process for review, yet the net result is the promotion of select companies and the denigration of
others (non-PVM’s). This process is anything but fair and voluntary.
Paragraph #3
ACCT is correct that they only receive feedback and input from their Board Members and PVM’s.
If you have a descending voice, you are kept out of the association peer review process, ridiculed
to other vendors, and/ or uninvited from attending conferences workshops or conversations. This
provides for a large gap between the ACCT and the remaining industry. This in itself warrants and
validates the need for a second industry association that can be a voice for the other vendors and
programs that do not have equal representation within ACCT, as defined by the ACCT. Many of
the changes the ACCT is now working on and claim as fair practices are a direct result of a second
association providing services the ACCT currently does not provide. The PRCA has been a
healthy addition to the industry as a whole.
History of PRCA Standards
Paragraph #1
The PRCA was informally created in September 2003. It incorporated on April 6, 2004 in order to
receive membership dues and circulate standards published. The first PRCA standards, September
2003, (6) had been already written and circulated among the PRCA Board of Directors for
approval.
The PRCA formally submitted for ANSI ASD status July 2005 after working with Jim Thompson
from ANSI since March 2005, preparing the PRCA procedures to a point ready for submission to
ANSI and the review process. At the time PRCA began the process, it was asked of Jim
Thompson if the ACCT was currently under review or showing active interest. The reply was
negative and the PRCA decided to proceed.
Paragraph #2
The PRCA Standards and labeled in versions. Versions are depicted of smaller content changes,
the correction of typos, or sentence wording to become easier to understand.
Per the break test standards referenced and alleged by ACCT that the PRCA obtained ACCT
information in a method not professional or ethical, we must reject this assertion. Per the ACCT
complaint letter, ACCT never shared the results. Therefore, PRCA founder, Steven Gustafson of
EBL, conducted independent destructive tests and video taped the results from an independent lab
in Rockford, Illinois. A short sample video may be viewed on the Internet at
www.eblropes.com/break_test_web_1.wmv to document said tests. These are the results
referenced in the PRCA standards. Additionally, the PRCA Standards under review and all
previous version clearly list over sixty-five reference sources within the document. The ACCT
was not a resource for the development of the PRCA standards and are therefore not listed.
Coincidently, ACCT was aware that a PRCA vendor, EBL, had conducted break tests and
produced training videos in 2001 and viewed without permission, yet continued to accuse the
PRCA in this appeal of obtaining break test data improperly. In January 2006, it was
acknowledged by the current ACCT Prseident, Dan Prevorse, Board Member Tom Leahy, and past
President Tim Kempfe, that EBL was “wronged” by ACCT on this matter. The PRCA does not
speak for EBL, but it is an interesting chain of events that has bearing on the allegations to date.
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Paragraph #3
Per the additional examples referenced by the ACCT, again, the 80% redundancy standard has
been common industry practice since before ACCT published their first standards on March 27,
1994. Further, the PRCA promotes 80% as a minimum, 100% as ideal.
Paragraph #4
The PRCA has not disclosed it membership information to ACCT for a variety of reasons. First,
ACCT has never requested that information. Second, the ACCT is not a member of the PRCA.
Thirdly, the membership information changes regularly as new members sign on through the
PRCA website. Lastly, the ACCT does not always provide their membership lists or Board
minutes to its membership upon written request. It should be noted that the PRCA had online
membership registration and membership data areas before the ACCT. Again, this is yet another
example of how having two associations has forced the ACCT to change and improve its practices.
And at this point we are not certain what our membership roster has to do with being an ANSI
ASD.
The standards committee, prior to ANSI ASD approval, had been compiled of interested parties
that responded to PRCA invitation to participate on a first come, first serve basis. The committee
was comprised of less than fifteen members at the time. Once the PRCA became an ANSI ASD, a
call to all vendors (7) listed on the ACCT website and on industry lists serves was placed on
December 8, 2005, looking inclusion and contribution. An ACCT Board Member quickly replied
to ACCT Executive Director electronic mail (8) to all PVM’s that ACCT should operate as a
whole, not individual PVM’s. On December 16, 2005, the same ACCT Board Member sent out an
electronic mail (9) to the ACCT Board, formulating an attack against the PRCA. On December
28, 2005, the PRCA sent another invitation to ACCT PVM’s to participate (10). On December 29,
2005, the ACCT responded by sending its PVM’s a letter, instructing them not to participate. (11)
This is clear evidence of collusion and control between the ACCT Board and the PVM’s. It is at
minimum, a disservice to the industry which ACCT claims to represent in good faith, and at worst
may border on being illegal. In the same letter referenced earlier, they also call for information
from any vendor who had been approached by the PRCA or who had accepted the invitation. We
can only presume this was a way to control their PVM’s and prevent partnership with the PRCA.
The PRCA believes this practice to assert dominance on the industry and is in direct violation of
the ANSI spirit to participate.
Of the respondents to the call for participation, the PRCA quickly filled the committee at fifteen
persons within a matter of hours. Any additional names were placed on a waiting list. Days later,
a letter from ACCT demanding a seat on the committee was received. The waiting list, also called
our At-Large Review Committee, established fairness; large and small vendors all have equal
opportunity and voice. This list filled on a first come, first serve basis. Any person beyond the
fifteen were placed on the At-Large reviews committee and instructed that they would be called
upon, in order, should the review committee decrease in size. Some original Consensus Body
members did indeed drop off the list. The first two individuals in line on the waiting list were Josh
Tod of Ropes Works (ACCT PVM level 4) and Dan Pervorse, Signature Research, (ACCT PVM
Level 4 and ACCT President of the Board). Both parties declined to participate when contacted by
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the review committee chairperson in May 2006. It is the PRCA’s belief that ACCT has limited its
own involvement within the PRCA standards, pressured the ACCT PVM’s to not contribute, and
that the PRCA is being falsely accused of limited open contributions from the industry.
Paragraph #5
The PRCA removed the listed vendors as the review process was being overhauled. In the spirit of
being fair and because the PRCA received feedback from Josh Tod (ACCT PVM Level 4) and
James Liggett (ACCT PVM Level 4) that our process seemed to favor select vendors, the listed
names were removed. That removal has been misrepresented to imply something more than it is.
The PRCA would assert that it is attempting to receive feedback from ACCT PVM’s and to
address concerns for fairness despite the fact the PRCA had no obligation to do so.
As to the members on the review committee, it should be noted that almost all of them had active
memberships with ACCT, including most of the PRCA Board. ACCT did have membership and
PVM representation on the review committee from the very beginning.
ACCT’s Attempt to Be Included in the Standards Development Process
Paragraph #1
The ACCT was clearly informed that only a select few from their leadership could not adequately
represent the interests of all their PVM’s fairly. Further, when ACCT PVM’s names came up in
the list to serve, they declined service.
Paragraph #3
The first public review was not sanctioned by ANSI due to the fact the PRCA PINS document was
still under circulation. The BSR-8 form filed by the PRCA was not active and the first public
review period by the public did not count. To correct this misunderstanding, the PRCA contacted
Jim Thompson of ANSI (12) to address a corrective action. This entailed a completely new and
longer second review which followed the PINS time period and at which time the BSR-8 form was
accepted by ANSI. Again, on January 13, 2006, a letter was sent out on industry listserves and to
all ACCT PVM’s (13 & 13A) explaining the misunderstanding and the corrective action that
would take place. This corrective action met with the approval of Jim Thompson. Thus, the first
public review was not recognized by ANSI, but the second public review was recognized by
ANSI. Of the two public reviews, the PRCA references only the second one as this is the one
ANSI endorses. The PRCA and Jim Thompson believed this to be a fair and the proper corrective
action.
Paragraph #4
It is unfortunate that the ACCT began to challenge the PRCA. They instructed their PVM’s not to
participate and rejected overtures to collaborate with the PRCA at the ACCT annual conference in
January 2006. The PRCA believes it acted in the spirit of openness, in an effort to ensure fairness
for large, small, listed or non listed ropes course organizations alike, without prejudice to company
size, demographic, or other bias.
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Professional Ropes Course Association (PRCA)
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Appeal of PRCA’s ANS Developer Status: Standing Section
Point #1
The PRCA provided three separate invitations to all ACCT PVM’s and on industry listserves. The
ACCT decided to direct those PVM’s not to participate with the PRCA. This is a decision of
ACCT’s, not the PRCA. Further, the PRCA had made offerings to work with the ACCT via
ACCT Board Members in electronic mail and in person to the past and current ACCT President’s
of their Board of Directors. These overtures were rejected almost immediately.
Hypothetically, if the PRCA Consensus Body lacks proper industry representation, it is due to the
actions of the ACCT to block vendor participation. Further, the ACCT has been contacting
industry professionals asking for their support and to denounce the PRCA. Further, ACCT PVM’s
have taken it upon themselves to send out letters to their clients asking them to support only the
ACCT (14). This propaganda campaign uses very close if not similar language and wordings that
the ACCTs uses showing a very suggestive pattern that ACCT is leveraging their PVM’s in an
unethical and conflict of interest for they industry. This very stance only supports the business of
the ACCT and the vendors of the ACCT. This goes directly against the spirit of open sharing and
the non-dominance criteria mandated by ANSI Essential Requirements.
The PRCA did not exclude “some of the most knowledgeable practitioners in the industry.” All
PVM’s listed on the ACCT website had been sent three separate invitations to participate. ACCT
instructed their PVM’s not to act individually and therefore, the lack of any representation falls to
the responsibility of ACCT. The ACCT was acting inappropriately when coaching the direction
and decisions of private enterprises.
Point #2
Again, the PRCA invited all ACCT vendors to participate and made public notices on two industry
listserves reaching some 2,500 professionals in the industry. The PRCA fulfilled its responsibility
to seek a balanced Consensus Body. ACCT instructed vendors not to participate and supplied
suggestive actions of how to thwart and derail the process. Lastly, when ACCT PVM’s listed on
the alternates list were called to serve on the Consensus Body, Josh Tod of Ropes Works and Dan
Prevorse, Signature Reseach and ACCT Board President, they declined the invitation to sit on
the Consensus Body.
Point #3 A
As earlier noted, the first public review of the PRCA standards were not endorsed by ANSI due to
an unpublished BSR-8 form until the PINS had expired. Further, all the feedback from the first
review period was included in the revision of standards and sent to each and every Consensus
Body member at the time. Further a call for input and commentary from Consensus Body
members was requested, with no meaningful responses or request for alterations or to vote on the
version being circulated during the second public review. Again, the core of the PRCA standards
had already been circulated for two years prior to the ANSI process and much of the content had
already been reviewed and accepted by default. The ANSI process is being utilized to formalize
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the PRCA standards to make them industry standards, of which, all the ACCT vendors had been
invited to participate. ACCT instructed their vendors not to participate.
Point #3 B
PRCA members had been informed that the PRCA was undergoing the ANSI accreditation process
PRCA newsletters, LIVE Chat! For members on the PRCA website, and in direct conversations at
PRCA and AEE conferences. As to the details of the ASD process, it was lengthy and involved
numerous exchanges of electronic mail and telephone calls between the PRCA and ANSI. Since it
was such a daunting process, we were not certain the PRCA would achieve the ASD status, and
were hesitant to make too much of the process until it was complete. No one likes egg on their
face. Therefore, the PRCA found it relevant to notify it membership and the industry in a more
formal manner via electronic mail, newsletter, and the PRCA conference once a decision was
issued from ANSI that the PRCA had indeed gained accreditation. Once that announcement had
been received, the PRCA quickly moved to notify the entire industry, quickly and accurately as to
allow for a proper 15 day appeal period. In addition, the PRCA complied with all ANSI
notification procedures and demands made for public notification as outlined by the ANSI
ER and in direct consult with Jim Thompson of ANSI.
Point #4
The PRCA procedures adhere to the ANSI ER to a point that ANSI deemed them valid enough to
accredit and pass the procedures via a positive vote. The PRCA worked hand-in-hand with ANSI
via Jim Thompson to clearly draft procedures that meet all the ANSI qualifications.
As for the PRCA members to be notified of the standards for the allowance of comments, this
would have showed a bias towards PRCA members in the standards development process. The
PRCA believes that members and non-members should be handled equally and that PRCA
members should, in the spirit of fairness be required to follow the same public review procedures
as everyone else.
Finally, as to any alleged “deficiencies in the makeup of the PRCA Consensus Body, and limited
participation of its members,” the PRCA has shown ample evidence that the ACCT conspired with
its vendors to thwart, block, attack, and reject any and all actions of the PRCA. The ACCT clearly
represents a conflict of interest toward fair private enterprise, when a selective Board of Directors
or a couple Board individuals can control all association vendors to a point that ripples down from
industry vendors to the end user. Again, the ACCT has only itself as a responsible party for any
lack of representation on the PRCA Consensus Body.
Point #5
There is a compelling need for another industry association. Professionals consistently sign up as
new members and old members renew their memberships. Clearly the PRCA has something fresh
or new to offer to warrant these memberships. Secondly, as the evidence clearly illustrates the
ACCT as a dominating and controlling interest in the actions of their vendors, a non-controlling
association is more than necessary.
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Appeal of ACCT’s Exclusion From the Consensus Body
The ACCT is in receipt of the PRCA’s rational of allowing individual vendors or interested parties
to serve on the Consensus Body. To date, the ACCT has been a self serving marketing group,
advancing the business of their approved vendors, rather than the industry as a whole. The ACCT
would have ANSI believe that they are the industry rather than there is an industry that operates
without the ACCT and despite the ACCT. The ACCT and the PRCA are in formation to serve the
challenge course industry rather to have an industry tied together via endorsed vendors by which
only support the ACCT. The PRCA finds this operation and practice to be improperly reversed by
the ACCT.
Further, the PRCA Board President was authorized by the PRCA to forward overtures of
collaboration to the ACCT past and present Board President at the ACCT conference in January
2006. A summation of this encounter was sent to ANSI, via Jim Thompson (15) to ensure proper
notification of attempts for collaboration of PRCA as an ANSI ASD to include ACCT. In
conclusion, we feel that the evidence provided by the PRCA clearly proves that the ACCT has at
every opportunity (and continues to with this appeal), attempted to block, defame and control the
PRCA, the Consensus Body, the standards and industry business. Based on its track record and its
current actions, it appears that the ACCT’s highest goal is to retain its heavy-handed control of the
ropes course industry, the very industry it claims to serve. The truth is, the PRCA followed every
procedure placed upon it by ANSI, without question, and fulfilled each and every timeline,
notification, and invitation to participate, in the spirit, of the ANSI E.R. and as outlined by the
PRCA procedures. As recently as a few weeks ago, the PRCA, following its approved procedures,
offered Consensus Body positions to two ACCT PVM’s. One is the current ACCT Board
President and both are materially interested parties. Both declined to serve on the Consensus
Body. Shortly there after, this appeal was filed with ASNI.
The PRCA would request that ANSI also take under consideration the improper fabrication of
documentation by the ACCT after their appeal was filed in the end of May 2006. Only under
repeated request for this information by the PRCA, did the ACCT create and forward an affidavit
from James Liggett dated June 26, 2006, clearly after it was referenced in an earlier appeal
document. Is it the ethical or common practice to fabricate documentation after the fact? It is also
labeled a draft and is without a notary seal. This highly suggestive behavior and unprofessional
action is yet further evidence of the heavy handed dominance of the ACCT and an example of their
ongoing mode of operation. Further, this document only states facts to the best knowledge of
James Liggett who requested a position on the Consensus Body after the group was already formed
and conducted work. It is no surprise he is working with limited or outdated information.
The current standards under review and following the procedures and are in the hands of the
Consensus Body. All documentation is being retained for the anticipated BSR-9 audit at
completion and submission of the American National Standards.
Respectfully Submitted,
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Professional Ropes Course Association (PRCA)
www.prcainfo.org
The PRCA, Board of Directors
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