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 these are
structures that we can have a level of control over. 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!
The ASTM published a set of technical standards (F1487) for public use playground equipment in 1993 and revised it in 1995, 1998, 2001 and 2005. The Consumer Products Safety Commission (CPSC) published a set of guidelines in 1981 and revised them in 1991, 1994 and in 1997. 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 several ASTM committees and have consulted with CPSC on revisions, it would not be prudent of me to reveal specific changes that are coming prior to 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:
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.
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! 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 "negligent". 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 "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 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 now in the ASTM
Standards as is the requirement
to post "Adult Supervision is Recommended" (see #F1487, section 15).
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, or damaged, and is 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) Check for lateral discharge on slides. In ASTM Sect. 8.5.4.6, it
says to check for lateral discharge on spiral slides and slides with a
curved cross section, but does not
explain how. Hopefully ASTM or CPSC will include it in the next revisions.
The CPSC 1981 guidelines went into great detail on this, but was removed in
1991, yet must still be
performed.
2) Most slides with a slow-down curve at the exit region won't fail if the flat bedway slope is somewhat over 30 degrees. The tricky part is that slides must have a slope no greater than an AVERAGE of 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), and is the "average" slope. No part of any slide bedway can exceed 50 degrees.
3) There is controversy on use (fall) zones around components attached to composite structures (gym sets). Some say that the only use zone applicable to the entire unit is 6' on the boundary (perimeter) of the whole structure, with the exception of the possible extra length required for slide exit ends. Others believe that each attachment should have the side use zones the same as they are required to have as if they were free-standing units. Check ASTM Sect. 9.2 and 9.2.1, and CPSC Section 5 and 6 for your own interpretation.
4) 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!
5) 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.
6) 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.
7) "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. Clevises must have the round end on top.
8) 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 both the torso and head probes and the protrusion gauges, which
are great
kits! 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 50 lbs. of force have missed the mark substantially. Get the right gauges or hire someone who knows how to do this test.
2) The articulated probe detects crush and shear points in areas that are not detectable with standard rods.
3) Other tools are the (complicated to use) test template for partially-bounded openings, the surfacing sifters (determines which type of surfacing you have, i.e., fine vs. coarse sand), micrometer, 30" radius gauge, angle finder, gap gauge that is exactly .04", neoprene rods (for crush & shear points) that have a 50 durometer hardness reading, tape measure, line level (for surfacing per CPSC).
COMMON HAZARD IDENTIFICATION; The most common hazards identified are entrapments, entanglements, protrusions, some gaps, etc. See "Inspection Fallacies" above. These are covered in standard courses. Don't forget to identify and contact the manufacturer prior to modifications.
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 trajectories at least 7' away from 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) Do signs & labels have proper letter height, age groups, etc.? More on signs & labels later.
4) Are you placing the 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 and like the other gauges are meant to be used!
5) Do your slides have a platform with a minimum depth of 22" (CPSC rule) times 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. Note that ASTM says this platform size must be at least 14", but CPSC is more stringent on this.
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.
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, kids running into traffic, kids getting abducted, etc. I have not passed a playground fence yet according to that standard... after 2,503 sites at the time of this writing!
9) Are you checking for lateral discharge, 50 lbf. tests, 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 a pipe wall 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.
Ask
yourself "What are the chances of this injury occurring?" when you
have to prioritize.
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.
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