PLAYGROUND SAFETY
SOLUTIONS
Part 2
By Scott Burton
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WHO'S RESPONSIBLE FOR THE HAZARD?
We said that 44% of injuries are due to a lack of supervision and improper
behavior. Lack of maintenance is responsible for 36% while improper equipment,
installation, and design cause the remaining 20% of injuries. Lack of
maintenance might be opened "S" hooks, unkempt surfacing leading to
exposed footings and lost impact absorption, etc. Although the Standards and
Guidelines change (for good reasons), the hazard(s) may have been present at
the time of installation. The fault could have been due to the manufacturer,
installer, owner, accidental, user abuse, or natural causes. The point is, be
open-minded when assessing hazards and not place the blame too quickly. Ask anyone
who claims to be certified (in anything) for the basis of their certification.
Be cautious of "self-certifications". Manufacturers and installers
are doing a much better job in complying. Even if you have new equipment
installed, are they aware of the Standards & Guidelines? If so, do they
promise compliance? If so, then they must comply in it's entirety, not just
certain areas. How do you know if the manufacturer and their installer comply
with both ASTM and CPSC and ADA? I strongly suggest that you have a third party
consultant review the plans and perform a site audit on your behalf to be on
the safe side. The only other way you might find out is by getting sued, which
is not the time to discover mistakes. Your auditor should be without bias or conflict
of interest.
WHAT TO DO ABOUT YOUR HAZARDS
Try to absorb as much of your consultants advice into your final decisions.
Your options are to fix the hazard, discard the piece (or whole unit), replace
the part(s), or defer the problems until later. First let's look at the latter.
DEFERRING the problems, due to lack of money, manpower, etc.,
is not an option if it is a CLASS 1 hazard. If, for some reason, you must defer
these, I suggest that you either safely close the site down or remove the
equipment until you can correct the problems. Deferring CLASS 2 and 3's will
depend upon their severity, complexity, etc. For example, if you have 8"
of mulch and need 9" it's probably a CLASS 3 and can wait if it has to.
Remember, the longer you wait the closer you get to injuries and lawsuits! I've
seen cases settle or win/lose due to loose fill surfacing being one inch short
of the minimum requirement!
REPLACING with new equipment or surfacing, of course, is the
most expensive solution. In some cases it's best to contact your equipment
sales rep. and replace a part. But consider whether the new item will correct
the problem, have the same problem, or present a different hazard! Will the new
piece fit the same as the one it replaces (molds and shop jigs may have changed)?
You may spend more time and money field rigging it than fixing it correctly in
the beginning. New equipment could have more drawbacks than just initial cost.
It is not always a guarantee that it will be safer than an old piece you
replace it with, but then new equipment may be your best option.
DISCARDING the problem equipment is always a last resort. You
would be surprised at how simple and inexpensive most solutions really are. If
you eliminated all of the playgrounds, you shirk the duty to provide recreation
and play areas. Kids will suffer injuries from some activity like climbing
trees, or even buildings (I have a picture), which you cannot have as much
control over as manufactured equipment. You should keep the playgrounds and
retain control by doing your best to comply with ASTM and CPSC by way of proper
designs, maintenance, audits, inspections, etc.
FIXING the hazard. A client of mine had a school that had
equipment with a broken lower rung on an arch climber attached to a large
composite structure. The manufacturer said that if they did not buy a
replacement arch and instead tried to weld on a new rung (or the old one), the
warranty would be void on the entire structure... slides, paint and all!
Obviously, this is not the policy of all manufacturers! The reality is that the
warranty should not cover the new rung, but should still remain in effect on
the rest of the unit. You might consider hiring a welding contractor to shift
the liability. There is a zinc rod that you can rub onto a hot clean weld that
will "galvanize" it. Matching paint does wonders, too.
It would be ideal if your auditor/consultant is experienced
enough to let you know what modifications to make and to help coordinate things
with the manufacturer's sales representative, who will normally be of great
assistance!
BUDGETING REPAIRS & REPLACEMENTS
If you have classified your hazards and decided on repairs and replacements,
you are ready for a timeline budget. Secure funding for parts and labor.
Consider sharing the costs with other departments, such as risk management,
maintenance, etc. Some costs will fall under capital improvements, repairs,
etc. First of all, plan on handling the CLASS 1 hazards right away. Then plan
for the CLASS 2 and 3 hazards. Keep in mind that some Class 2 or 3's can be
handled during corrections being made to Class 1's. It's important to realize
that you must make the effort. If you do the best that you possibly can, then
that is exactly what is "reasonably expected" of you. No one expects
you to discover hazards today and have them fixed by tomorrow. It's quite possible
to not be able to get to the next class of hazard until another budget year.
Don't forget to incorporate initial audits and routine inspections into your
budget!
MODIFICATION TECHNIQUES
Fixing one hazard can create another. Some examples are;
1) If you discover an entrapment gap between two platforms
and lower one of them, you could create another entrapment between it and a
third platform or its pipe wall. You could also cause the stepping distance to
be >12" apart (for 2-5's) or >18" apart (for 5-12's).
2) I saw that a pipe wall had been removed from a structure
and was replaced with a plywood panel complete with splinters, protrusions,
head & neck entrapments, and a height below the user's center of gravity. I
wondered how the old pipe wall could have been much worse. Whoever performs
your retrofitting, whether it is temporary or permanent, must clear any change
with an experienced and certified safety auditor.
INEXPENSIVE SOLUTIONS
If any of your problems have been determined to have existed at the time of
delivery and/or installation, contact the manufacturer or installer to see if
they can correct their portions of the problems. The key point is to make sure
you have the correct interpretations beforehand. I frequently hear "the
Standards and Guidelines have changed" which, although true, there are
times when the site was out of compliance the day it was installed by either
your own employees, the manufacturer's, or a sub-contractor.
Remember to always use the current ASTM Standards and CPSC
Guidelines when auditing, inspecting, designing, and correcting hazards. The
following are some examples of Problems ("P") and their Solutions
("S");
1) "S" hooks open more than .04" apart. S;
Replace with a locking link-style or clevis style if you can. They do not open
like "S" hooks, are hazard-free, and last much longer.
2) Pipe wall has entrapment gap (3-1/2" X 6.2" up
to 9" diameter). S; Depending on the location of the gap, either weld
another pipe in place or adjust the pipe wall over/up/down. Be careful so that
none of these create another gap, and do not lower the wall
3) Entrapment gap between platforms. S; Adjust the platform
or install a kickplate. It may require an access component and alternate
handgrips for access.
4) Partially-bounded openings between panel corners and
posts. S; Purchase and install a post clamp (which will be used ONLY to close
the gap), unless the manufacturer has another method to correct the problem. It
may look dumb, since the post clamp appears to serve no function, but if it closes
the gap then you're good to go.
5) Steel swing frame legs move up and out of the concrete
footings when in use. S; The legs are not secured inside of the concrete
footing due to either using the swing before the concrete hardened, or the legs
were not "flared" at the factory, or other methods were not taken to
secure the legs. Install a horizontal cross-bolt through the legs inside of the
footing to keep it down and then re-pour the footings.
6) Splinters found in wood. S; Remove/sand hazardous splinters.
To help lessen the severity of splinters, use a wood sealer every few months
after the initial purchase. "Checking" (cracking) of the wood is
normal up to about 1/4 inch wide.
7) Bolts protrude past gauges and/or are >2 threads past
the nut. S; Replace with shorter bolts, or cut and peen them smooth so they
pass all the tests.
8) Playground intended for 2-5 age group actually has
components designed for use by 5-12 age group only, such as a sliding pole or
an overhead ladder more than 60" high. S; If you are limited on funds yet
must provide a playground to all age groups, then exchange the sliding pole
with an activity panel as opposed to only allowing 5-12's here, and being
forced to purchase a new unit for each age group. Be careful of the other
measurements to make sure they pass for both groups, such as step distances,
guardrail and barrier heights, etc.
9) Rung between platforms can cause entrapment. S; If
platforms are less than or equal to 18" apart for 5-12's, or less than or
equal to 12" apart for 2-5's, then a rung is not required, so remove it
and keep the spare part! Otherwise, you might have to adjust the platform(s).
Avoid entrapment gaps (3-1/2" X 6.2" up to 9" diameter).
10) Swing hanger bolts are a vertical entanglement hazard when
a child gets on top of the beam (and they do). S; Install carriage bolts with
heads on top, nuts on the bottom, or simply flip the existing carriage bolts.
Check with the gauges for entanglements.
11) Swing hanger shackle is extremely loose. S; Before you
buy expensive new hangers, try replacing the .25-cent "sleeve"
bearings inside. Call a local bearing supplier.
12) Swing chain is worn 25% on the top and bottom links.
Instead of all new chain, try cutting off the bad end links, and installing new
connectors, keeping an eye on the rest of the links. Make certain that the seat
is not raised out of reach since seat heights are minimums, but there are no
maximum heights!
13) Slide has a gap between it and the platform. S; Try
adjusting the bolts to move it in to close the gap. I've seen a bondo filler
material used (such as LOCKTITE FIXMASTER, an epoxy putty) that seems to have
bonded well. Contact the equipment supplier as to which filler to use if they
do not have a custom piece to install or other options. Hazardous gaps can also
be found between sidewalls and posts! Consider possible entanglements. Check
Standard and Guidelines for more.
14) Slide chute is >30 degrees average slope -OR- wave
slide has a portion of slope over 50 degrees. S; Ask the installer to come back
if it is not a result of the manufacturer (mold), maintenance, environment, or
use. The installer should raise it if the exit region can stay 0-4 degrees
below horizontal. If not, contact the manufacturer.
15) Tube slide is >30 degrees average slope and exit
region is ABOVE horizontal. S; Since the exit region needs to be lowered and
the chute should be raised, one solution may be to have the installer adjust
and turn the curved section(s) and re-attach the bottom end (correcting the exit
region problem but correcting the slope). Keep the exit end the proper distance
from surfacing. Keep any extra section(s) as spare parts! No costs! -OR-
Contact the manufacturer. Remember, each problem has a solution. All that's
left is to figure it out!
SURFACING SOLUTIONS;
Falls account for 75% of all playground injuries. CPSC has a loose-fill
surfacing chart that shows tested depths (6" and 9") for specified
heights. Many folks assume that 12" of loose-fill is the minimum, which it
is not. CPSC has tested 6" depths as well. If 6" is actually the
minimum depth of surfacing for say, a balance beam, then you are spending twice
as much as you should by buying 12"! In this example, it is advised to buy
at least 9" so that it compresses
to 6" or so. The most critical thing to understand is how to determine the
fall height for your equipment. This is very easy to botch and could cost you a
lot of money in surfacing, as well as the possibility of not providing the
proper level of impact absorbency. So, have the correct fall height assessed
and then either check with the chart or have it field tested. ASTM has
identified Fall Heights for almost all playground equipment.
LOOSE-FILL SURFACING;
Loose-fill surfacing is the least expensive and most popular, but requires
maintenance and needs to be fluffed up or refilled. It gets kicked and blown
away, becomes compacted, or may not have been the proper depth in the beginning
due to compacting after use. However, unitary surfacing (Poured In Place,
rubber tiles) is not only expensive, but does not have the
"displacement" properties of loose-fill, which may be what it takes
to prevent some of those broken bones! CPSC suggests measuring loose fill
surfacing from a level point up to the fall height of the equipment in order to
determine the Use Zone. One common scenario is that although you may have
always had pits under your swing seats, you may not have noticed the
ramifications of the pits in an inspection frame of mind unless you audit an
unfamiliar site. This may trigger you to realize that you've measured from a
point BELOW where the surfacing should be level, up to the pivot point of the
swing hanger. This miscalculation creates greater distances required for use
zones and surfacing depths, and raises your costs as well. Level the surfacing
first, or run a string line level, and then measure it for a true reading. You
might just need tile pads installed under each seat, but be aware of trip
hazards while swinging. Tiles should be large enough to prevent this and should
have beveled edges as well. If you have loose-fill and must accommodate for
ADA, paths of tiles or Poured In Place surfacing would work, as opposed to
replacing all of it. You can have an ADA wheelchair accessible path AND loose
fill surfacing, keeping your costs to a minimum. There are some companies that
provide loose fill surfacing that is wheelchair accessible!
POURED IN PLACE and TILE SURFACING;
These are much more expensive, while reducing or almost eliminating maintenance
costs. Rely on the manufacturer's claim for impact efficiency of under 200 G's
and a 1000 H.I.C rating. These two types of surfacing are great for ADA
accessible play areas! Be absolutely certain that the correct depth &
perimeter (from the equipment) is laid down in the Use Zones.
SIGN & LABEL SOLUTIONS; Signs AND labels are important
but are frequently overlooked. I always hear comments such as "Kids won't
(or can't) read them", "Parents don't pay attention to them",
"You can never say enough or say it the right way to be effective",
and so on. Although these may sometimes be valid points, there are kids,
parents, and LAWYERS who will read signs. If you have not experienced it yet,
you may learn that a lawyer will say that the owner has a "duty to
warn", failed to do so, and add it to the list of complaints in their
lawsuit. It can be avoided for pocket change!
WHAT SHOULD SIGNS & LABELS SAY?
First, let's look at actual examples of what they should NOT say; "Warning
- use of this playground by children or other persons is prohibited"
(apparently for use by animals and aliens). "This playground is for use by
children 6 on up", which allows teenagers and adults but not kids 5 or
younger, when they had infant swing seats and equipment for ages 2-5(!?!?)
SURFACING WARNING LABEL;
This one is required by ASTM Section 14. It should be attached to ALL pieces of
equipment that require surfacing. It will inform, warn, and educate purchasers,
installers, and those supervising children who play on the equipment about the
ongoing danger of installing equipment over hard surfaces. It will serve as a
constant reminder to provide and maintain appropriate surfacing. Place these as
close to adult eye level as possible, facing the direction that they are able
to approach the equipment.
DRAWSTRING WARNING LABEL; It will warn about the ongoing
danger of a user being entangled, in an effort to prevent strangulation. See
CPSC Section 3.2.1 and ASTM Section 14. Place this at each entrance to the
playground, or on the equipment, in positions that can be seen as adults
approach the playground, always as close to eye level as possible.
AGE GROUP (INFORMATIONAL) SIGN / LABEL;
Keep the age groups separated by stating that one area is for ages 2-5, and the
other area is for ages 5-12. If that cannot be the case, then display one that
says the equipment is for 2-12's. The most ideal situation is to have an age
group label posted onto each piece of equipment. That way, if you happen to
have a piece that is a different age group, it is clear to the user and/or supervisor.
Place this at each entrance to the playground, or on the equipment, in
positions that can be seen as adults approach the playground, always as close
to adult eye level as possible. See CPSC Sections 2.2.3, 2.2.6, 2.2.7,
5.3.8.3.2, and ASTM Section 14.
TOT SEAT (INFORMATIONAL) SIGN / LABEL;
"Tot seats for use by children under 4 years of age, with adult
assistance" tells the users and supervisors the appropriate ages for tot
seats. This reduces wear, misuse, breakage and injuries. See CPSC Sections
2.2.3, 2.2.6, 2.2.7, 5.3.8.3.2, and ASTM Section 14. Place these on the swing
posts (both sides) nearest to the tot seats, at adult eye level.
SUPERVISION (INFORMATIONAL) SIGN / LABEL;
"Adult Supervision is Recommended" will tell children, supervisors,
and lawyers that the intent of the playground is a place for supervised play.
See CPSC Sections 1.6 and 2.2.7, and ASTM "Introduction" and Section
14. Place these at each entrance to the playground, or on the equipment, in
positions that can be seen as adults approach the playground, always as close
to adult eye level as possible. SURFACING LEVEL MARKER (INFORMATIONAL) LABEL;
This will allow maintenance people, supervisors, and users to be able to
quickly and easily check the support posts for the proper amount of loose-fill
surfacing depth. If the surfacing is below the marker it is time to add to, or
fluff up, the surfacing. See CPSC Sections 2.4.2.2(4) and 4.3. Place these at
the pre-determined position on each post at the minimum surfacing level height.
Signs and labels must have the proper letter size & type, coloring, etc.,
according to the ANSI Standards on signs and labels in order to hold up in
court. Compliance is a key consideration so that the users and adults will
notice them.
CONCLUSION
Some risks are acceptable, to a degree, but not the life-threatening ones! If
you are an owner concerned about being held personally liable in a lawsuit, you
are not alone. So be extremely careful if you decide to create your own
playground designs, specifications, or perform audits. If you cannot afford the
audits, signs, labels, etc., it is understandable, but realize how much more a
legal defense would cost. Also, don't make the assumption that new equipment
will automatically comply with CPSC and ASTM. It may or may not. Most
manufacturers and contracted installers sincerely put forth their best efforts
to comply. However, I've seen old equipment get replaced with new equipment
that had its own list of hazards. Just to be sure that you are safe, have a
third party that is on your side check it out for you. Some manufacturers have
independent laboratories check their equipment for load tests and other issues
covered by ASTM only, but are not being checked according to CPSC or ADA. Your
equipment still needs to be audited according to CPSC and ADA though since you
need to comply with CPSC, ADA and ASTM. It would be prudent to ask them for a
list of the tests that the unit went through to verify which phase of testing
was covered according to ASTM, ADA and CPSC. Keep in mind that a
"pass" designation cannot take into consideration the final outcome
of each different site due to unknown factors involved, such as the installer
putting a unit together differently, or a unit supplied with parts that may
vary in size or shape from shipment to shipment. I'm not saying that these
things always occur, but they have happened. It is something for the owner to
consider when looking at equipment marked "approved" or
"certified". It's best to get your own designer and auditor that can
recommend which manufacturer to select!
In the meantime, keep an open mind when a hazard is
discovered because it may turn out that the finger you are pointing just might
turn YOUR way! It is possible to have a playground that is fun, challenging,
and will pass inspections and audits. If you do the best that you, and a jury,
would think is reasonable, you've got a great start!
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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