A week on, questions are now being raised about liability following the White Island eruption.
Is anyone legally responsible for this disaster, and should tourists in New Zealand be better informed about the risks they're taking?
Bill Hodge, a professor of law at the University of Auckland, says due to ACC no one in New Zealand can sue for compensation for personal injury - "full stop".
But it's a double-edged sword.
"I believe in people seeing justice being done, and ACC is an administrative, bureaucratic procedure - you don't get a feeling that those responsible were ever held to account," says Prof Hodge.
The only way anyone would be held to account and reparation paid is if a successful criminal case were brought against the adventure tourism operator.
"By bringing a health and safety prosecution, we are in a sense, getting around ACC," says Prof Hodge.
Overseas, lawsuits are much more likely.
Many of the victims were on board the cruise ship the Ovation of the Seas, operated by American company Royal Caribbean.
A maritime lawyer in Miami is already accusing it of being "exceedingly reckless", by failing to communicate the risks of the tour.
"I believe yes, we do need to inform tourists a bit more carefully," says Michael Lueck, a professor of tourism at AUT university.
Prof Lueck says the disaster should be a wake-up call for tourism operators.
"Even if you have a waiver form, who's reading it? Who's going through pages and pages of fine print? I think we need to be honest and fair about what the potential risks are," he says.
Whether the potential risks at Whakaari / White Island were communicated is now being investigated.