OSS draft response to SOWSA proposal

01st February, 2018

There is currently a proposal to create a Scottish Open Water Swimming Association (SOWSA). With free wild swimming an established constitutional right in Scotland, and the event and open water industry well established, what will SOWSA do and why? How will it impact swimmers? Is it a good thing or a bad thing? Who will it benefit – and who might it harm? 

Some swimmers in Scotland have published a proposal to create a Scottish Open Water Swimming Association (SOWSA) “to promote and grow safe open water swimming within Scotland through cooperation between relevant stakeholders and partners in the country.” The full SOWSA proposal is published on this website, together with a collective response from many Scottish wild swimming community groups. These are the Outdoor Swimming Society’s first thoughts on the proposal, on the day of reading it – these may evolve and change, so should be treated as a draft response. The OSS was not invited to comment as a stakeholder, but anyone can – see the SOWSA story.


The Outdoor Swimming Society (OSS) shares aims with the SOWSA proposers – we want to see opportunities for swimmers increase, to see safe events being delivered, and cooperation between all the different and constantly evolving groups that support swimmers. However we do not support the move to create SOWSA in Scotland for the following reasons:

  • we do not see the need of SOWSA or the benefit to swimmers. There are already multiple thriving channels that swimmers have created to support and further open water swimming, and there is no clear need to create a new one
  • we do not believe SOWSAs methods will increase event safety. Triangulating the relationship between event managers and their water safety plans/ risk assessments, and event managers and their landowners, by putting SOWSA in the middle could do the reverse: decrease safety and increase costs.
  • we believe the establishment of a self appointed regulatory body with power over all swimming events, venues and pilots in Scotland would create a commercial monopoly that would stifle, restrict and standardise the market, and restrict rather than improve swimming in Scotland. As a concept it does not respect the depth and ongoing development of safety knowledge in the open water world, or the huge variety of swimming competencies and tastes, all of which the open free market currently caters for.


SOWSA says it is aiming itself as the ‘sport’ rather than the recreation of swimming, but the two are so closely connected that what needs investigating is whether a body which does not consider the needs of recreational Scottish swimmers may harm their interests, limit their freedom and increase their costs.

“To promote and encourage new and existing participants to the sport of open water swimming in Scotland.”

There are already huge numbers of swimmers already working in different ways towards the proposed charities stated aim of ‘increasing safe participation in open water swimming in Scotland’ via different pathways: online communities (the Outdoor Swimming Society for example), local wild swimming groups (of which there are many, 15 of which have produced a collective response to this proposal also published here), open water venues, open water swims, open water coaches, and the crowd sourced map wildswim.com. Many of these groups have been working for years towards the aim of spreading the joy and love of swimming. It is highly likely there are other ways to support, strengthen, engage or use their expertise to help them carry on this mission, and that this may be more fruitful than creating another body.

“To grow open water swimming in Scotland through the promotion of current swim routes, and the development of new swim routes, especially routes connected with iconic Scottish historical, natural and built environments. To provide a comprehensive online information guide for swimmers interested in undertaking specific open water swims in Scotland such as, and not confined to, providing information on recognised routes, and affiliated pilots operating in these waters.”

These passages lead to red flags for the OSS here. We love swim routes, that is why we worked with Scottish agency STORM ID to recreate free crowd sourced wild swim map wildswim.com, and why we run regular stories on new routes that Scottish swimmers are swimming- eg last weeks story on swimming across Scotland, and stories like 58 miles between Scottish Isles.

In the case of individuals it is potentially dangerous to place an abstract body between that individual and their own responsibility to assess objective and subjective risk.  Any hint that a body such as SOWSA had somehow assessed or approved a venue, swim route or activity that might lead an individual into a false sense of safety in a wild swim situation is unacceptable.

The stories and collections on wildswim seek to share information between swimmers that enables routes to develop in an entirely noncommercial way, and champions individual understanding and moderation of risk. Some swimmers might want to employ a ‘pilot’ (boat cover), others might not. The worry about the SOWSA proposal is that a connection between route information and ratified pilots may exclude people from doing these routes on their own for free, restrict information to those with commercial interests (such as piloting) or discourage individual swim responsibility.

“To engage in open conversation with landowners and land and resource management bodies (such as conservation, nature protection, heritage and utility bodies) to ensure swimmers access open water venues in safe and environmentally responsible ways.”

The OSS Inland Access group note that there is generally no problem with inland access to rivers, lochs and reservoirs in Scotland due to the Land Reform (Scotland) Act 2003. This states that Access rights (which includes swimming subject to any local byelaws) extend to rivers, lochs and reservoirs.

“To provide a pathway for landowner and stakeholder engagement in the planning, organising and running of open water swimming events.”

We are not sure what the need is for this and can not anticipate it’s benefit. The Outdoor Swimming Society has been organising events since 2006. At no point during our 12 year run have we needed “a pathway” between us and landowners. We work with a huge variety of councils, farmers and local stakeholders and have a relationship with them – we talk, meet, discuss issues, shake hands, know each others names and phone numbers, share knowledge and experience and agree things. The idea of triangulating this relationship by putting SOWSA in between us and (for example) our farming friends or yacht clubs who use the same estuary would be detrimental to the relationships between swimmers and locals that successful events foster – it’s their land, we’re on it, and we bring swimmers with us by invitation and work together on the safe delivery of an event.

“To promote the undertaking of comprehensive risk assessments for all proposed open water swimming events to be held in Scotland, and maintain a database of individuals, charities and organisations who are able to carry these out.”

We all want swimmers who attend events to be kept safe. The SOWSA intention “to draw up best practice guidelines in running safe and environmentally sustainable open water swimming events in Scotland” could be helpful to new event organisers – many are on a steep learning curve when they begin, and don’t even know what questions they will need to answer. But we question the supposition that as a body SOWSA could make swims safer. At the start of every event idea there will be an information vacuum that needs filling: what are the risks? How are they addressed?

A successful safe event relies on the event organiser developing detailed knowledge of the locality, and getting to know their event and their swimmers inside out so they are in a position to identify and moderate each risk. If they lack the skills to do this there are consultants and experts they can employ who have those professional skills and experience. This is a commercial transaction, and there are already many good people working in the field who can be employed to do it. The market has already answered this need.

Event organisers make mistakes on swims, we have all seen that. They can arise, for example, out of non professional water safety, lack of open water knowledge (misreading tides or tidal flow, or not understanding cold) and lack of event experience (the complicating factors of large groups of people). This learning curve, and distinction between the best and worst events, exists for all events from village fetes to festivals, cycling sportives to local mud runs. These events do not have regulatory bodies. It is always regrettable when people have a bad time, and it is of serious concern when they have a dangerous time, and the results with a swim (like any other event) can lead to tragedy.

As event organisers we feel the only people who can make an event safe are the organisers themselves, it could not be outsourced to SOWSA.

We also note that event companies hold completely different views on best practise – the OSS, for instance, does NOT use towfloats at events. Others do. Look into any issue of event management from water purity to swimmer experience and weather conditions or water temperature and it will be impossible to find consensus. This would make the proposed SOWSA undertaking very very hard.

In all, we believe the expertise and IP of each event plan has to be held by the individual event teams. An outside body can only check paperwork, the most rudimentary tickwork, it’s how it matches conditions and how things are managed on the day that is pivotal.

In all of the above aims it is not clear to the OSS that events are in need or would benefit from a regulatory body, our fear is that the contrary would happen: the existence of a regulatory body would stifle, restrict, and standardise the open water event market. Understanding of open water, open water events, and best practise in safety is constantly developing. The open market that exists supports that development. There is more than one way to provide water safety for an event: every responsible water safety crew who works on an event builds their expertise and refines their plans year on year. It is not true that an outside body could do this better. 

“To work on open water swimmers’ behalf to improve safe and responsible access of open water venues in Scotland.”

It is not clear whether SOWSA talking about the establishment of inland beaches, for free community swimming, or commercial open water venues, and how they are going to represent swimmers to create more swimming? The OSS Inland Access Group created the OSS Inland Bathing Area Guide which clarifies the various models that councils and landowners can you when they open an inland beach. Can the proposers work with OSS Inland Access Group to help with the establishment of more inland beaches? Have they done this already? Or is their interest in commercial open water swimming venues?


“To maintain a list of recommended boat pilots and safety providers along with a detailed description of the open waters in which they have competencies.”

There is a concern that SOWSAs list of aims would have the result that they would become the self-appointed regulators of swimming in Scotland. All of the services it lists already exist as commercial services, but if SOWSA would want to work as a regulatory body with a monopoly on providing these services, and the ability to demand that events employ their services (“undertake risk assessments for all proposed swims”).

1st February