Agreed on the observation penalties, not sure on things like 'touches course, racking, load' increasing to a 5 though, bearing in mind we have always had the facility to exclude for violent collision.
My main concern as previously stated, is that instructors will become so pre-occupied filling in forms correctly, that practical training will start to suffer.
I also cannot understand why every accrediting body has a separate registration system, surely if the ABA wants to do something useful it should create a centralised system?
For example I recently had to try and find proof of previous training for a new employee of a client of mine, he couldnt remember who had trained him or what accrediting body the training conpany belonged to, and his former employer wasnt prepared to co-operate, a familiar situation when people leave for another job and the previous employer gets the hump.
I was faced with days of chasing through the various organisations to find his registration, I was able to check two of databases as a registered user, but neither turned up anything, so then it was lots of emails and phone calls, a central database would make life so much easier.
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