PLAYGROUND SAFETY
SOLUTIONS
Part 1
By Scott Burton
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COPYRIGHT, SAFETY PLAY, INC. 2011
WHY ARE PLAYGROUNDS NEEDED?
We have known for a long time how important it is to provide playgrounds for
children. Socrates (400 B.C.) was quoted as saying that children need to have
the opportunity to play in order to become effective adults. We also know that
playgrounds are vital to children's physical, emotional, social, and
psychological growth as well. Therefore, if we tore out these structures
because we feel they are too much of a liability risk, the children would find
something to play on that is much worse. At least with play structures, we can
have a level of control over them. Basically, there is a "duty" to
provide play equipment.
STATISTICS
Depending upon which statistics you look at, there are 150,000 to over 230,000
children admitted to hospitals every year! We tend to see only numbers, but
these are real kids and real pain. What goes unnoticed is the realization that
this amount accounts only for the injuries severe enough to warrant a hospital
visit, and not all of the others that are NOT reported!
ASTM STANDARDS & CPSC GUIDELINES
Just as a matter of housekeeping, let's identify the rules (adopted as laws in
some states) that apply to playgrounds. Keep in mind that NOT ALL of these are
taught in any formal class!
ASTM stands for the American Society for Testing and
Materials which is located in Conshohocken, PA. You can purchase standards from
them at http://www.astm.org. In a nutshell,
the applicable "public use" playground standards are #F1487 for
Public Use Playgrounds, #F1292 for Surfacing, #F2373 for Children Under Two,
#F2075 for Engineered Wood Fiber (surfacing), #F2049 Playground Fence Standard,
#F1951 for determining Wheelchair Accessibility, and #F1918 for Soft Contained
Play Equipment.
CPSC stands for Consumer Products Safety Commission which is
located in Washington, DC. You can obtain the Handbook for Public Playground
Safety (#325) from them for free at http://www.cpsc.gov/cpscpub/pubs/playpubs.html.
They also have a checklist for Soft Contained Play Equipment and other
playground related documents as well.
You can get the ADAAG (wheelchair accessibility) documents at
http://www.access-board.gov.
The ASTM published a set of technical Standards (#F1487) for public use
playground equipment in 1993 and revised it in 1995, 1998, 2001, 2005, 2007 and
2011.
The Consumer Products Safety Commission (CPSC) published a
set of Guidelines in 1981 and revised them in 1991, 1994, 1997, 2008 and 2010.
Both ASTM and CPSC have been working on the next revisions for reasons such as
better clarification and to address problems and products not addressed in the
past. We keep revising them because in the beginning we looked at the most
serious hazards first and wanted to get the publications out as opposed to
waiting much longer to cover it all. There are new equipment styles that come
out, and as we refine the accident reporting data, we discover how kids become
injured in different ways and make adjustments that way as well. The changes
are needed, but can be frustrating for owners to keep up with. To compound the
problem, ASTM and CPSC conflict in some areas, one has critical information not
found in the other, and both have many sections that are easily misinterpreted!
The chances are good that you will find out about your misinterpretations after
an injury occurs and a lawsuit has been served. That is usually when I get
called in, but barn doors are already open. Although I am on numerous ASTM
committees, and have consulted with the CPSC on their revisions, it would not
be prudent of me to reveal specific changes that are coming prior to them being
published. However, those of us who are intimately involved in the creation of
these publications can take these changes into consideration when making
recommendations through audit, design, planning and bid evaluation services.
More importantly, knowing the various rationales for the rules (which are
usually not written in the Standards or the Guidelines) helps immensely with
proper interpretations in the field. Some items addressed by CPSC but NOT by
ASTM are:
In CPSC Sect. 5.3.4, Merry-Go-Rounds (whirls) can have no
openings greater than 5/16".
In CPSC Sections 2.5.3 & 5.3.6, it says metal slides should be placed in a shaded
area to prevent burns. It is no longer acceptable to simply place slides facing
North like it stated in previous versions.
In CPSC Sect. 5.3.2.6, it does not allow sliding poles for 2-5 year olds.
In CPSC Sect. 5.3.2.1.5 and Figure 9, it addresses the 18" maximum fall
distance for interiors of climbers (some of which are still being made).
There are many issues that I have presented to ASTM to address. ASTM addresses
many other issues that CPSC does not, and perhaps could not, address.
LITIGATION
I once had a case where a child incurred a 1" scar on his elbow after
another boy pulled him off of a chin-up bar. The equipment and surfacing passed
inspection. There were no broken bones, just a scar. They settled out of court
for $50,000! There's another case where a child fell off of an overhead ladder
onto dirt, broke his arm, and the jury awarded him $700,000. If you are an
owner (parks department, public OR private school, child care center, or even a
staff member of any of these) and have not been sued yet, I hope I'm getting
through. This is no longer an area that you can treat lightly. Consider the
liability implications of designing, installing, and inspecting playground
equipment yourself. Governmental Immunity will cover an employee's legal expenses,
and the employee is (typically) off the hook if their actions are found as
"simple negligence". But if they are personally named in a lawsuit
they may be held financially responsible if the jury finds "gross"
negligent for that employee. There's a huge gap between "simple
negligence" and "gross negligence". Such was the case in a
popular lawsuit in Louisiana regarding misinterpretations, and another in St.
Louis involving a parks department maintenance man!
SUPERVISION and BEHAVIOR.
The leading cause of public playground injuries is the lack of supervision and
improper behavior, totaling 44% of all injuries. What can be done about this?
Plenty. But no one expects those two human factors to be 100% perfect at all
times either. If you normally supply supervision, say from 2:00 - 6:00, be
aware that when you do not supply it during those same hours, and someone gets
injured, it may be a liability. Playground supervisors should be well trained
on proper use of the equipment so that they can enforce proper behavioral rules
to the children. There are a few ways that this can be accomplished. First of
all, assess your equipment and it's use patterns to establish where supervisors
are to stand, guide, and walk by the users. It would be unreasonable to expect
them to be everywhere like a safety net, so set some priorities. These can be
written into a pamphlet for you to use at your facility. Of course, be
cognizant of applicable supervisor/child ratios. If you have a problem child
who cannot follow the rules, he or she could be putting the others at risk.
Consider time out for him or her. You can also post informational signs or
labels that show how to use the equipment correctly in order to avoid misuse,
although these are rare to find. Even though some kids may not read them and
some adults might ignore them, you will find that informational and warning
signs and labels are a great aid to those who DO pay attention to them. They
are a benefit in any lawsuit to help avoid a "failure to warn"
accusation. Signs or labels should also identify what age group the equipment
is intended for. The requirement to do so is in the ASTM Standards as is the
requirement to post a notice about Adult Supervision (see #F1487, section 14).
Ideally, you should separate the children (and equipment) into user age groups
of 2-5 year olds, and 5-12 year olds. These two age groups play differently and
have different anthropometric sizes and abilities that the equipment should
accommodate. However, this may not always be possible to do, which is why you
have some equipment that is for 2- 12's. There will be more on signs and labels
in this article.
INSPECTING YOUR OWN or HIRE IT OUT?
Not long ago, my dentist told me that I had two cavities, which I was not aware
of, nor did they hurt at the time. I still had them filled because I knew I
would have a much more serious problem later, he was more qualified than I to
diagnose it, plus it would hurt later on! The same goes for identifying your
playground hazards. You may not know you have a problem until someone more
qualified identifies the hazards or someone gets hurt. There is not much
dispute as to the importance of getting hazards identified on the playground,
the question is, who should do it?
The initial "audit" is performed only once, unless the equipment or
surfacing becomes modified, relocated, damaged, or you've added more equipment.
The "audit" is much more detailed than routine inspections. An
"inspection" is usually considered to be performed on a periodic
basis, depending upon the level of use, maintenance, environmental factors and
materials used. Free "Frequency of Inspection" forms are available.
Please call me. I have audited thousands of sites, with as many as 50 pieces of
equipment at a site. I have yet to find a site, with "brand new" or
old equipment, that passes on the first audit. Usually it is due to one of the
following; improper installation, design, layout, construction, or even simple
lack of proper signage or labels. I've heard that the ASTM & CPSC rules are
"gray areas" and a "matter of interpretation". The reality
is that yes, some circumstances DO fall into those categories, but the vast
majority do not. So, the audit will reveal hazards not found during routine
inspections. Audits must be performed by a Certified Playground Safety
Inspector (CPSI). Your most important consideration is who will do a more
efficient job, not miss hazards, and have correct interpretations of the
standards and guidelines?
QUALIFICATIONS OF A PLAYGROUND AUDITOR
It is ideal that your auditor is;
1) experienced for over 5 years in auditing (vs. inspecting)
various equipment.
2) a participating member of ASTM to understand the rationale of the standards
since misinterpretations and conflicts abound.
3) someone who will make an excellent expert witness for you in court.
4) experienced in playground construction to have a knowledge of inexpensive
remedies that won't create other hazards.
5) a Certified Playground Safety Inspector that is not complacent with existing
problems.
6) insured for "Errors & Omissions" in case they miss something
that causes an injury later.
7) not bias and is without conflict of interest, especially on the INITIAL
audit.
There are many solutions to eliminate your liability and increase safety, but
they are not cure-alls by themselves. For example, having your own CPSI so you
can retain the level of safety after a third party audits your sites is the
best method, but is not the only thing you should do. You must repair &
replace equipment, have the required signs or labels, train your staff, etc.,
but each one by itself is not the single cure-all.
IDENTIFY THOSE HAZARDS BEING MISSED!
Having conflicts and misinterpretations? You're not alone! From certified
inspectors to sales people to playground staff, all seem to be very concerned
with this problem.
POPULAR INSPECTION FALLACIES CLEARED UP;
1) Sites previously thought not eligible for playground equipment due to being
too close to traffic/railroads/bodies of water, can have equipment there if the
play area is properly fenced in per the ASTM Standard #F2049 for playground
fencing. If any of the listed hazards are within 200 feet of the equipment or
Use Zones, a specific type of non-climbable fence is required, and if vehicular
access is that close, the fence (or barriers in front of it) has to pass an
impact test. Gate latches are also addressed for access/egress issues as well
as seeing if they are protrusion hazards. Do not take playground fencing
lightly. Lack of fencing has a history of being what could have caused numerous
fatalities and injuries.
2) Most slides with a slow-down curve at the exit region
won't fail if the rest of the bedway has a slope that is somewhat over 30
degrees. The tricky part is that slides must have a slope no greater than an
AVERAGE of 30 degrees, that is, ALL of the slopes on the bedway cannot total
more than 30 degrees. Example; measure the vertical height from the entry point
at the platform to the top of the exit region (bottom end of slide). Measure
the horizontal length from the end of the exit region to the platform entry
point. Divide the height by the length for a ratio no greater than 0.577, which
is the tangent of 30 degrees, (so, 0.577 is the same as 30 degrees), which is
the "average" slope. However, no part of any slide bedway can exceed
50 degrees.
3) Gaps between a slide and platform are a hazard not so much
because it may pinch a finger, but that it may catch the knot or toggle of a
drawstring, or loose clothing, necklace, etc., and strangle a child!
4) Head entrapments occur not so much when users place their
head in a gap first, but when they go feet first, allowing their body to pass
through an opening but not the head, entrapping or hanging a child. The size to
avoid is NOT 3-1/2" to 9"! It is (3-1/2" x 6.2") up to
9" in diameter. For example, this means that 5" diameter holes in a
panel that failed before actually pass because the torso probe will not actually
fit through it.
5) Both the standards and guidelines say to
"rotate" the torso probe to it's most adverse position. This does not
mean that if it is incapable of "rotating" inside the opening that it
passes or fails. It means to move the probe around to try to fit it into the
opening while both planes are parallel.
6) "S" hooks opened >.04" may not only
cause the seat or chain to disconnect while in use, but may entangle a
drawstring and strangle the child when they leap off. Also, closing
"S" hooks after they have opened reduces the tensile strength and
will open easier later on. Do yourself a favor and get rid of the "S"
hooks. Replace them with clevises (upside down "U"-shaped with a
horizontal bolt) or split-links (a "C" that snaps onto a backwards
"C" which then forms the appearance of a link) that won't open up.
7) The 50 lbf. (pounds of force) test should be performed
with a test gauge. Measure flexible openings including tot seats, nets, pipes
that may have slight flex, etc. Again, these are just a handful of issues to be
aware of.
IDENTIFY THE USER AGE GROUP!
This is one of the most important and very first things to do in an audit. You
can ask the owner what age range of users are intended and allowed, look for
signs or labels that display the intended user ages, and/or measure components
(stair heights, etc.) or check for age specific components (sliding poles for
5-12's, etc.). You might discover conflicts among the intended ages and the
components. Once you have identified the age group you can proceed with
inspecting for the correct measurements. Install a small self-stick sign or
label that displays the intended user ages as required in ASTM & CPSC. Some
reasons for separating kids into 2-5 and 5-12 year old groups is because they
play differently, have different capabilities, and their sizes vary greatly.
Therefore, sometimes the equipment is made for those two groups, or else the
2-12 age group when users must be combined due to lack of space, etc. The
center of gravity on 5-12's is higher than on 2-5's, so guardrails and barriers
are different, etc. The younger ones are not yet developed or large enough to
handle certain pieces of equipment such as sliding poles (fire poles), high
spiral slides, narrower steps, higher horizontal ladders, and flexible climbers
that do not allow their feet to be on the same level before ascending. The play
value and challenges should be there for each group.
COMMON INSPECTION TOOLS ARE NOT ENOUGH!
Keep one thing in mind. Like a Doctor, your auditor/inspector not only needs
the right tools, but more importantly, the right know-how to use them properly,
have the correct interpretations, and draw the correct conclusions! Most
auditors purchase inspection kits that include the torso and head probes, "fish"
template, and the protrusion gauges. They can do a good job with these tools,
but a thorough job takes more tools than that. Some of the other tools may be
available at hardware stores, but others are not. Some of the missing tools are
described below.
1) One critical test that is often overlooked is the 50 lbf. (pounds of force)
test. This test takes into account compression of skin to allow a child to
squeeze through an opening and become entrapped or hung. Most guesses of what
50 lbs. of force feels like have missed the mark substantially. Get the right
pull gauge or hire someone who knows how to do the test.
2) The articulated probe detects crush and shear points in
areas that are not detectable with standard neoprene (rubber) rods.
3) Other tools are the test template ("fish") for partially-bounded
openings (complicated to use), micrometer or "handgrip template" to
measure handgrip diameters, 30" radius gauge, angle finder, gap gauge that
is exactly .04", neoprene (rubber) rods (for crush & shear points)
that have a 50 durometer hardness reading (using wooden dowels or bolts are not
what is being cited to use), tape measure, line level (for surfacing).
COMMON HAZARD IDENTIFICATION;
The most common hazards identified are entrapments, entanglements, protrusions,
use zones, fencing requirements, signs/labels, etc. See "Inspection
Fallacies" above. Fencing rules are not covered in standard courses.
ADVANCED HAZARD IDENTIFICATION;
The best advice here is that it simply takes time, and lots of it, mixed with
auditing different types of equipment, to identify ALL hazards. This may
require visiting sites other than your own. This will cause you to change your
interpretations of the Standards and Guidelines and now fail some equipment you
passed before, or vice versa. A few advanced tips are as follows;
1) Pits are common at the ends of slides. Don't adjust the slide until you have
first leveled any loose-fill surfacing for a correct point of measurement. You
may just need an impact absorbent tile pad installed.
2) Are swing pivot points at least 7' away from overhead obstructions like
branches, power lines, etc.? Are Use Zones not just the minimum distance from
equipment, but also at least 7' "above" the surfacing and the
"designated play surfaces"?
3) Are the proper signs & labels installed? Do they CONFLICT with the
equipment (age ranges posted do not match design and intent of age ranges for
the components. VERY COMMON)? Do they have proper letter height, age groups,
coloring, etc.? Signs and labels should address; drawstring warning, age range
of users (2-5, 5-12, 2-12, and tot seats for under 4), adult supervision,
surfacing warning, surfacing line level marker (loose fill only). More on signs
& labels later.
4) Are you placing the thin 1/8" gauge over the vertical protrusion? You
can, but it is meant only as a 1/8" depth measurement tool, not to see if
the protrusion will fit "inside" the gauge (like it used to be
illustrated in F1487) and like the other gauges are meant to be used!
5) Do your slides have a platform with a minimum depth of 14" by the width
of the slide? Even on triangular platforms? If not, the user lacks the area
required for a stable transition from standing to sitting and can fall off.
6) Can the torso or head probe fit through a gap in a barrier (wall)? They
should not, since barrier walls are meant to contain the users. Do the 50 lbf.
test since even rigid pipes will flex!
7) Is your Poured In Place surfacing REALLY the proper depth? Time and again I
find even brand new surfacing poured way too thin. If you pay for 2-1/2"
of it, make sure it is at least 2-1/2" deep all around! Also, be sure the
perimeter tapers down OUTSIDE of the Use Zone (not within it, or it is less
impact absorbent).
8) Do you inspect playground fencing according to ASTM Standard #F2049? I sure
hope so. It protects kids from getting hit by vehicular traffic going into the
playground ("I hit the gas instead of the brakes"), kids running into
traffic, kids getting abducted, eyes/face injured by gate latches, etc. I have
not passed a playground fence yet according to that standard... after 2,737
sites (at the time of this writing)! KEEP IN MIND THAT A FENCE IS NOT ALWAYS
REQUIRED.
9) Are you checking for special Spiral Slide Clearance Zones, 50 lbf. tests,
use zone overlaps for adjacent equipment over 30" high, etc.? These are
only a fraction of the things commonly missed on audits/inspections. As you can
see, there is a lot more to an advanced audit, but if you don't have it done
correctly, you may find out by "accident" (translate
"lawsuit")!
HAZARDS ARE IDENTIFIED. NOW WHAT?
Contact the manufacturer to find out what their solutions and involvement might
be. Proper classification of hazards is important! If you are not familiar with
the rationale behind ASTM or CPSC you might see a hazard as insignificant. You
might call it a CLASS 3 (least hazardous) and get to it later, when it should
be a CLASS 1 (life- threatening) and needs immediate attention! A converse
example is if the torso probe passes through an opening near the ground and the
head probe does not, but just barely gets stuck. It is likely to be a CLASS 3,
not a CLASS 1 due to the likelihood of the horizontal position that the head
would have to be in to become entrapped and it's close to the ground. Ask
yourself "What are the chances of this injury occurring?" when you
have to prioritize. MAJOR TIPS AND SOLUTION are in "PART 2" of this
article. Read on!
This online article courtesy of The World Playground, Park & Recreation Products and Services Web Directory
Back to the "HOME Page" of Largest Web Site pertaining to the Playground Industry.
SAFETY PLAY, INC.
c/o SCOTT BURTON
Toll-free; 888-878-0244
Florida Office;
10460 ROOSEVELT BLVD., #295
ST. PETERSBURG, FL. 33716
California address;
7095 HOLLYWOOD BLVD., #1308
LOS ANGELES, CA. 90028 safetyplay@mindspring.com
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