Safety and emergency procedures
One document a new guide can follow: the route and its hazards, weather and heat limits, what stops a tour, who calls triple zero and where the nearest hospital is. Review it when a route, venue or supplier changes.
TOUR OPERATOR INSURANCE
Risk Management for Tour Operators
The controls an underwriter asked for on a tour operator we placed, the legal duty behind them, and the published standards and free templates you can build them from.
5 controlsWhat the underwriter asked for on the case we placed
s 19(2)The WHS duty to people who are not your workers
Before 9amKings Canyon Rim Walk start on days forecast 36°C or higher
Premiums and outcomes described are specific to this client and indicative only. Your own terms will depend on your circumstances and the insurer.
THE SHORT ANSWER
What risk management does a tour operator need?
A tour operator needs risk management that is written down and used on every tour. On the case we placed, the underwriter asked for five controls: safety and emergency procedures, participant declarations where appropriate, pre-program briefings, checks on guides, suppliers and service providers, and incident, accident and complaint reporting. A legal duty sits behind them. Under the model work health and safety laws, a business must ensure, so far as is reasonably practicable, that its work does not put other people at risk, and your guests are other people. A death or serious injury arising from the business must be notified to the regulator immediately. Published standards and free templates give you a starting point.
General information only. It doesn't take into account your objectives, financial situation or needs, and it isn't legal advice. Work health and safety law differs by state and territory, so check with your regulator. We do not claim these controls earn a discount.
- Underwriter's asks
- Five controls on one placement
- Legal duty
- WHS duty to other persons
- Serious incident
- Notify the regulator immediately
- Where to start
- Published standards and free templates
Participant declarations where appropriate
A plain description at booking of the walking, stairs, heat and pace, so guests can judge for themselves whether the tour suits them, a way for a guest to tell you anything they want the guide to know, and an allergy question where food is served. Anything a guest tells you has to reach the guide on the day, not sit in the booking system.
Pre-program briefings
The same points every time: the plan for the day, the real hazards, what guests must not do, and what to do if they feel unwell or get separated. Check it was understood.
Checks on guides, suppliers and service providers
Reference checks and qualifications for guides. A certificate of currency from every coach company, venue and ground handler at the start and each year. At least one specialist tour operator wording we place expects contractors in Australia to hold at least $10 million of their own liability cover.
Incident, accident and complaint reporting
A register of every injury, near miss and complaint, written up the same day. Report anything that could become a claim to your broker straight away, and do not admit fault without the insurer's consent.
The placement is set out in our cultural tour operator case study. One past placement. Your price and terms depend on your risk. For the full list of underwriting questions, see what you need for a quote. For declarations and risk warnings, see waivers and booking terms.
| Duty | What the Act says | On a tour |
|---|---|---|
| Duty to other people | A business must ensure, so far as is reasonably practicable, that the health and safety of other persons is not put at risk from its work (s 19(2)). | Guests are other persons. So are bystanders and the staff of venues you visit. |
| What must be notified | The death of a person, a serious injury or illness of a person, or a dangerous incident (ss 35 to 37). The Act says a person, not a worker. | Serious injury includes one needing immediate treatment as a hospital in-patient, a serious head injury or a spinal injury. |
| When and how | Immediately after becoming aware of a notifiable incident arising out of the conduct of the business, by the fastest possible means (s 38). | Keep a record for at least five years. The site is not to be disturbed until an inspector arrives or directs otherwise (s 39), other than to help the injured or make it safe. |
Safe Work Australia's handbook says other people at a workplace, such as clients, customers, visitors or members of the public, may be involved in incidents that must be notified.
Victoria has its own Occupational Health and Safety Act 2004. An employer must ensure, so far as is reasonably practicable, that people other than employees are not exposed to risks from the business (s 23), and must notify WorkSafe immediately after becoming aware of a death or listed serious injury at a workplace under its management and control (ss 37 and 38). Western Australia's Work Health and Safety Act 2020 took effect on 31 March 2022.
Safe Work Australia has published wider model notification triggers, which apply only once a state or territory adopts them.
| Resource | Who publishes it | What it gives you |
|---|---|---|
| Australian Adventure Activity Standard and Good Practice Guides | Outdoor Council of Australia | A voluntary standard for led outdoor activities where participants depend on the provider. Not legally binding of itself, but a permit, licence or client can make it a condition. A 2026 Core Good Practice Guide is available. |
| Quality Tourism Accreditation standards | Australian Tourism Industry Council | Asks for a risk management statement (a template is supplied), documented emergency and evacuation procedures, an incident report form covering injuries and near misses, at least one first aid trained staff member on duty, and $10 million public liability. |
| Emergency management plan template | business.gov.au (Australian Government) | A free template with a continuity plan, an emergency action plan and a recovery plan. Prompts for emergency contacts, evacuation procedures and insurance details. |
| Tourism insurance and risk table | Tourism Council WA | A three-column table operators can copy: the possible risk, the role of insurance and the category of insurance. |
| Model Code of Practice: First aid in the workplace | Safe Work Australia | First aid needs, kits and training. Says to consider people at your workplace who are not your workers, and to plan for remote or isolated work. |
| National Principles for Child Safe Organisations | Australian Human Rights Commission | Ten principles with free tools: a self-assessment, a policy template, an example code of conduct and e-learning modules. |
| WELCOME Framework | Austrade, with states and territories | Steps for reducing barriers for guests with accessibility needs, with links to operator toolkits. |
First aid. Safe Work Australia's first aid code says CPR should be refreshed annually and first aid qualifications renewed every three years. Where access is difficult because of travel time, poor roads or weather, it says arrangements should include aerial evacuation.
Remote communications. The model WHS Regulations require a system of work with effective communication for workers who are remote or isolated, which can include a guide leading a group out of phone coverage. The Australian Maritime Safety Authority recommends a GPS-equipped distress beacon and says to register it before you take it out. At least one published Australian tour operator wording makes a charged communication device and a first aid kit on every tour a condition of cover. Wordings differ, so read your own.
Heat. Watarrka National Park runs a heat management strategy in the hottest months, September to March. On days forecast at 36°C or higher, Tourism NT says walkers must begin the Kings Canyon Rim Walk before 9am. Build the land manager's limits into your itinerary and your cancellation rules.
Site rules and guide habits. An NT coroner examined the death of a young visitor who fell at a staged photo stop on a guided Kings Canyon rim walk in 2014. The coroner found guides had been trained to run the photo stop, that park signage said to stay away from the cliff edge, and that a warning letter from the parks agency four years earlier had not changed the practice. The control is plain: written no-go rules, checked in the field, and action when a land manager warns you.
Allergens and diets. Ask about allergies at booking, pass the answers to every venue in writing, and have the guide confirm them on the day. See food and alcohol on tours.
Suppliers. Collect certificates of currency, and for coaches the operator's accreditation. See contract guides, coach companies and suppliers and vehicles and passenger liability.
Child safety. The National Principles for Child Safe Organisations set out ten principles, with free tools from the Australian Human Rights Commission. Screening checks are state based. They are triggered by child-related work in listed categories, such as transport services for children and overnight camps for children, so a school or youth tour is treated differently from a general public tour.
| State or territory | Check | How long it lasts |
|---|---|---|
| NSW | Working with Children Check | 5 years |
| Victoria | Working with Children Check | 5 years |
| Queensland | Blue card | Check with Blue Card Services |
| Western Australia | Working with Children Check | 3 years |
| South Australia | Working with Children Check | 5 years |
| Tasmania | Registration to Work with Vulnerable People | 5 years |
| ACT | Working with Vulnerable People registration | 5 years |
| Northern Territory | Working with Children Clearance (Ochre Card) | 2 years |
Accessibility. Section 24 of the Disability Discrimination Act 1992 makes it unlawful for a person who provides services to discriminate on the ground of disability by refusing to provide them, or in the terms or manner in which they are provided. Services include recreation, transport and travel. There is a defence of unjustifiable hardship, which the person claiming it must prove.
The Disability Standards for Accessible Public Transport 2002 list buses and coaches as conveyances. The only vehicles they exclude by name are charter boats, limousines and self-drive rental cars. Whether a particular tour coach service is caught depends on the definitions, so ask your coach operator how its vehicles comply.
Self-drive 4WD group trips on K'gari
Three young overseas visitors died in two rollovers on the eastern beach. In each case the self-drive hire vehicle was driven by a fellow tourist driving on a beach for the first time. No guide was involved. Rules introduced afterwards included a cap of eight occupants on hire 4WDs, with no roof loads. Lesson: when guests drive, the briefing, the vehicle and the load are your controls. The coroner recommended checking that briefings are understood.
Snorkelling on a reef day trip, Michaelmas Cay
A visitor left a guided snorkel group and drowned, against a background of cardiac conditions he did not know he had. The coroner found missed opportunities, including that the operator did not identify him as an at-risk snorkeller, and that its procedures needed extensive review. The coroner could not say the death would have been avoided. Lesson: the coroner recommended a review of procedures, training, supervision and auditing. Brief every guest on the conditions, and notice when someone leaves the group.
An overseas school expedition
A student with type 1 diabetes died after becoming ill on an expedition. The supervising adults were not trained to recognise the complication, and the diabetes management plan did not travel with the group. The Victorian school and the expedition company pleaded guilty to safety charges under Victorian law. Lesson: a trip that took place overseas still led to prosecutions in Victoria, and medical disclosures must reach the leader in the field.
A hands-on distilling experience, Rutherglen
A still exploded during a booked gin-making experience run by a winery at its own distillery, with no tour seller involved, injuring two staff and seven guests. A stand-in operator had only one of the two instruction documents. The company was fined $50,000 without conviction. Lesson: if guests take part in production at a venue you send them to, ask what written operating procedure exists and hold the venue's certificate of currency.
Fines and penalties are generally excluded from public liability on the tour operator policies we arrange. At least one specialist PI wording we place has a sub-limited statutory liability extension for some penalties that are insurable at law, and some WHS penalties cannot lawfully be insured. More cases, with the cover that may respond to each, are in tour operator claims and court cases.
Accreditation and permits. The Great Barrier Reef Marine Park Authority offers an extended 20-year permit term for tourism programs certified by Ecotourism Australia (Ecotourism or Advanced Ecotourism level) or EarthCheck. Tasmania's Parks and Wildlife Service requires a nature-based tourism licensee to gain accreditation with the Tourism Industry Council of Tasmania, or an equivalent industry body, within 12 months of the licence starting. See park and council permit insurance requirements.
Your insurance submission. We do not claim that risk management earns a discount. Published proposal forms ask about several of these controls, so have the answers and documents ready. On the case we placed, the underwriter wanted them before confirming cover. The underwriter may also review your website, so what it shows guests doing needs to match what you tell them.
Sources relied on for this page
- Work Health and Safety Act 2011 (Cth), ss 19, 35 to 39
- Safe Work Australia: notifiable incidents handbook (December 2025 update)
- Safe Work Australia: incident notification requirements under the model WHS Act
- Occupational Health and Safety Act 2004 (Vic)
- Safe Work Australia: Model Code of Practice, First aid in the workplace
- Safe Work Australia: remote and isolated work, WHS duties
- Outdoor Council of Australia: Australian Adventure Activity Standard
- Australian Tourism Industry Council: Sustainable Tourism Accreditation Standards
- business.gov.au: develop an emergency management plan
- Tourism Council WA: tourism insurance
- Australian Maritime Safety Authority: distress beacons
- NT Government: Watarrka National Park
- Tourism NT: Kings Canyon Rim Walk
- NT Coroner: inquest findings [2015] NTMC 025
- Australian Human Rights Commission: Child Safe Organisations
- NSW Office of the Children's Guardian: who needs a Check
- Victorian Government: the Working with Children Check explained
- Queensland Government: blue cards for the tourism industry
- WA Department of Communities: Working with Children Check application and renewal
- SA Government: expiring Working with Children Check
- Tasmanian Department of Justice: renew your RWVP
- Access Canberra: apply for or renew a WWVP registration
- NT Government: Working with Children Clearance, before you apply
- Disability Discrimination Act 1992 (Cth)
- Disability Standards for Accessible Public Transport 2002
- Austrade: accessible tourism
- Queensland State Coroner: findings on K'gari (Fraser Island) 4WD deaths, 23 April 2010
- Coroners Court of Queensland: findings, Michaelmas Cay snorkelling death, 27 November 2017
- AAP: school pleads guilty after death of student on trip
- The Nightly: report on the sentencing of the school and the expedition company
- The Border Mail: fine over a distillery still explosion at Rutherglen
- Great Barrier Reef Marine Park Authority: tourism industry
- Tasmania Parks and Wildlife Service: leases and licences
FREQUENTLY ASKED QUESTIONS
Tour Operator Risk Management FAQs
A sound starting point is the five controls an underwriter asked for on a case we placed: safety and emergency procedures, participant declarations where appropriate, pre-program briefings, checks on guides, suppliers and service providers, and incident, accident and complaint reporting. Add first aid, a way to call for help where there is no phone coverage, and working with children checks if you run tours for children.
A clear description of every tour, who supplies transport and venues, group sizes, and how you manage risk. Published Australian tour operator proposal forms ask about guide to participant ratios, leader qualifications, emergency communication on remote tours, alcohol and food, and whether guests sign a release. The underwriter may also look at your website, so it needs to match your answers.
We do not promise a discount. Published proposal forms ask about several of these controls, and on the case we placed the underwriter asked for the operator's risk controls before confirming cover. That is one past placement. Price still depends on your activities, destinations, revenue, limits and claims history.
Possibly. Under the model work health and safety laws, a death or a serious injury or illness of any person arising out of the conduct of the business must be notified to the regulator immediately. Serious injury includes one needing immediate treatment as a hospital in-patient. Victoria has its own Act with similar rules. Check with your state regulator, and tell your broker as well.
No single rule fits every tour. The Safe Work Australia first aid code says CPR should be refreshed every year and first aid qualifications renewed every three years, and that more advanced first aid should be considered where emergency services cannot arrive quickly. As a control, look for a current first aid qualification from a registered training organisation, and remote first aid training where you operate away from help.
There is no single ratio for guided tours, and we will not quote one. It depends on the activity, the terrain, the guests and what your permit says. The Australian Adventure Activity Standard and its Good Practice Guides are the published reference for led outdoor activities, and at least one published tour operator proposal form asks for your ratio. Decide it, write it down and keep to it.
It depends on the work. The state schemes are triggered by child-related work in listed categories, such as transport services for children and overnight camps for children. Queensland's blue card page lists guided tours for children and youth tours with overnight stays. If you run school or youth tours, check with the screening agency in each state you operate in. A school may also ask to see the checks.
In some places. The Great Barrier Reef Marine Park Authority offers a 20-year permit term to operators certified by Ecotourism Australia or EarthCheck at the accepted levels. Tasmania's Parks and Wildlife Service requires nature-based tourism licensees to gain accreditation with the state tourism industry council, or an equivalent body, within 12 months of the licence starting.
RELATED GUIDES
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National park and council permit insurance requirements
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Educational tour insurance
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Accessible tour insurance
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Multi-day tour insurance
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