Kutska comments on U.S. Consumer Product Safety Commission’s 2-16 -2012 Release #12-109 Children’s Slides Recalled by Landscape Structures due to Fall Hazard

February 18th, 2012

2-16-12 RECALL NEWS from CPSC on LSI Glide
The February 16th U.S. CPSC recall on the LSI Slalom Glider is an interesting development and it is worth another look. How many children need to sustain an injury allegedly due to some product before it is determined to be unsafe? What type and how many injuries must be sustained to warrant a government recall? At what point should government intervene to protect us from ourselves? Who determines when something is unsafe? The CPSC has made a decision to require a manufacturer to voluntarily recall one of its products. While we can applaud any action in response to a known hazard but I cannot help but wonder what was their basis for this decision? If 14 reported injuries (fractures), one bruised spleen, and one fractured collar bone over five years on thousands of these types of climbers are enough to require removal when will we hear about a recall on bicycles, soccer balls, skateboards, roller skates, and just about everything else we can think of that results in thousands of cuts and scrapes, numerous broken bones and yes, even death. The children who were reported injured on this equipment were under the age of eight. What has our judicial system determined to be the age of reason; a child older than 7? Obviously these children were probably not experienced in using such a piece of play equipment. They were also probably lacking in physical development, balance, maybe even slightly overweight or lacking in cognitive development. This recall labeled the play component as not compliant with the slide requirements of the CPSC Public Playground Safety Handbook. They are correct in their analysis for all the reasons stated in the recall however the component was not designed or labeled as a slide. It is a GLIDE. I understand that if it looks like a duck and quacks like a duck then it must be a duck. I can see for myself that children can slide down the component or climb up it just like other compliant slide. Just because someone names something does not mean that is how children will use it during play. Does anyone remember the banister slides we have seen on some public playgrounds? Manufacturers even labeled these incline double or triple rails as a type of slide. The user would have to straddle the bars with their legs or arms to go up or down the event safely. I am sure there were children that probably fell through the bars to the surface and I am sure some even broke a bone or two. I am sure some even used this equipment in unintended ways but that is just being a kid playing and experimenting with their own bodies. Do you think children have gone down these on their skateboard? Where am I going with all this? I am not exactly sure but one thing for certain is that until we as a society can accept the results of our own actions and take responsibility for our lack of supervision and most importantly accept broken bones as a part of growing up we will continue to see the loss of play experiences children so desperately need to develop to their full potential. I cannot help but ask myself where this all will end. Is there something to learn from this CPSC action? I think it is time to have a public discussion on Risk and Hazards. What is the definition of an Acceptable Risk? When does something become an Unacceptable Hazard? What level of injury are we trying to protect a child from? Is it all falls? Why not? We know falls are the number one cause of injuries to all people. In this instance we do not even know if the surface the children fell on was compliant to the impact attenuating surface requirements of the CPSC. Does anyone realize the ramifications of this recall? There are several other U.S. manufacturers and some international companies selling very similar play components to this Slalom Glider. While they look very similar and are used in the same way there are distinct differences not easily recognized by the general public. Some may not be as high off the surface. They may be at a different slope. None of them have any side rails and none of them are called slides or even glider.
So what is next? How much litigation might take place as a result of this recall? When is there enough information available to the general public and its government regulatory authority to make some unilateral decision that will have severe financial impact on any industry? I come back to the question of when does something warrant the label, hazard or unsafe? How does something get recalled when such a small number of children have suffered a less than permanently debilitating injury or death? There may be more information related to the decision but I have not seen it. I would like to see it. More importantly I would like to know when we will have an adult discussion on the value of and need for challenging play in children’s development? This discussion is desperately needed so we might agree on some defensible criteria for risk assessment based on the type and severity of injury we can all work towards eliminating. Equally important is the need to agree on what types of injuries we can accept while we attempt to provide physically challenging environments for our children? I fear for children’s free play opportunities based on this governmental course of action. It always seems that avoidance of potential losses through public playground owners elimination of the potential cause is becoming more and more their first course of action. It is easy to implement. That being said I fear for what might become the next playground equipment recall? What play event will be next to be eliminated, the swing set? Why not upper body equipment such as overhead ladder (horizontal ladder)? More broken bones occur on this component than any other piece of play equipment as a result of use by children with limited upper body strength, especially those less than 8 years of age. Why not? After all upper body strength isn’t important in today’s high tech world.
In my opinion, a more reasonable course of action might have been to label this equipment for children above some age greater than 5, 6 or even 7, but I would leave that decision to the designers and the child development community. SEE RECALL BELOW
NEWS from CPSC
U.S. Consumer Product Safety Commission
Office of Communications Washington, D.C.
________________________________________

FOR IMMEDIATE RELEASEFebruary 16, 2012
Release #12-109 Firm’s Recall Hotline: (888) 438-6574
CPSC Recall Hotline: (800) 638-2772
CPSC Media Contact: (301) 504-7908
Children’s Slides Recalled by Landscape Structures due to Fall HazardWASHINGTON, D.C. – The U.S. Consumer Product Safety Commission, in cooperation with the firm named below, today announced a voluntary recall of the following consumer product. Consumers should stop using recalled products immediately unless otherwise instructed. It is illegal to resell or attempt to resell a recalled consumer product.
Name of Product: Slalom Glider
Units: About 900Manufacturer: Landscape Structures Inc., of Delano, Minn.

Hazard: The Slalom Glider is a playground slide that lacks a transition platform on the top and sides of the chute. Children can fall when moving from the ladder to the slide and when descending the chute.
Incidents/Injuries: CPSC and the firm have received 16 reports of injuries to children under 8-years old, including one bruised arm, 14 fractures to arms and legs, one fractured collar bone and one bruised spleen.
Description: The Slalom Glider is a distinctive 6-foot high playground slide that is curved in shape and made from molded plastic. It includes an arched, tubular steel access ladder. The recalled product comes as a stand-alone slide or as an attachment to other playground equipment. The recalled products have model numbers 156456 and 172627 and were sold in combinations of colors, including red, blue, tan, green, granite and white.
Sold: To schools and other facilities with playground equipment nationwide between January 2006 and December 2011 for about $2300.
Manufactured in: United StatesRemedy: Consumers should immediately stop children from using the recalled gliders and owners will be contacted by Landscape Structures regarding removal instructions. Customers will be given the option of replacing the Slalom Glider with another piece of playground equipment, receiving a refund, or receiving credit towards a future purchase.
Consumer Contact: For additional information, contact Landscape Structures toll-free at (888) 438-6574 Monday through Friday between 9 a.m. and 4 p.m. CT, or visit the firm’s website at www.playlsi.comThe U.S. Consumer Product Safety Commission (CPSC) is still interested in receiving incident or injury reports that are either directly related to this product recall or involve a different hazard with the same product. Please tell us about your experience with the product on www.saferproducts.gov
CPSC is charged with protecting the public from unreasonable risks of injury or death associated with the use of the thousands of consumer products under the agency’s jurisdiction. Deaths, injuries, and property damage from consumer product incidents cost the nation more than $900 billion annually. CPSC is committed to protecting consumers and families from products that pose a fire, electrical, chemical, or mechanical hazard. CPSC’s work to ensure the safety of consumer products – such as toys, cribs, power tools, cigarette lighters, and household chemicals – contributed to a decline in the rate of deaths and injuries associated with consumer products over the past 30 years.
Under federal law, it is illegal to attempt to sell or resell this or any other recalled product.
To report a dangerous product or a product-related injury, go online to: www.saferproducts.gov, call CPSC’s Hotline at (800) 638-2772 or teletypewriter at (800) 638-8270 for the hearing impaired. Consumers can obtain this news release and product safety information at www.cpsc.gov. To join a free e-mail subscription list, please go to https://www.cpsc.gov/cpsclist.aspx.

Are the Current Thresholds Adequate in the ASTM F1292 Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment?

January 24th, 2012

by Kenneth S. Kutska, CPSI
Executive Director, International Playground Safety Institute, LLC
January 28, 2009

Since the very beginning of tracking and analyzing playground injuries to children it has been know that “Falls to the Surface” has been the number one most common cause of serious injuries to children. Knowing who falls to the surface, how they fall, where they fall from, what part of the body first impacts the surface have a profound impact on the type and severity of impact injuries to children. This information coupled with a myriad of variables related to the surface material one falls upon makes for a never ending discussion on whether performance requirements are adequate in today’s litigious society. The playground industry performance standard commonly used is the ASTM F1292 Standard. The scope of this standard is to reduce serious head injuries. Any surface system installed within the use zone of a public playground must have a maintained critical height which exceeds the fall height of the equipment. The critical height of a surfacing system is the height in full feet below which a life-threatening head injury would not be expected to occur on the surfacing system. The critical height of a surface system is the fall height when tested in accordance with ASTM F1292 which results in a peak deceleration to the head during impact of 200 g’s or less and/or peak deceleration of the head during impact related to the duration of deceleration of 1000 HIC or less.

In recent years there has been a large increase in the use of unitary surface systems as a means of complying with the ADA/ABA Accessibility Guidelines. Regardless of all the improvements to impact attenuating surface systems since 1991 there has been an increase in fall related injuries primarily in arm and leg injuries. Why is this? Is it a lack of maintenance? Is it a lack of sufficient depth of loose-fill materials? Is it environmental factors or loss of impact attenuation properties as a result of an aging surface material coupled with some of these environmental factors?

It is probably a combination of all of these factors. The major increase in injury data seems to be directly related to the type of surface system. More arm and leg fractures are occurring on unitary surface systems versus loose-fill surface systems. Is this because of ADA/ABA accessibility requirements? Do loose-fill surface systems allow for displacement of surface materials or is it the ability of the surface to disperse this energy at initial impact?

Advocates for injury prevention on children’s playgrounds have been questioning the effectiveness of the current industry safety standards and challenging the scope of the ASTM F1292 standard and the compliance thresholds established to reduce serious head injuries to children.

I recently participated in a in-depth educational session that focused on understanding the various factors that determine a public playground owner/operator’s compliance to the industry’s minimum performance standards related to ADA accessible public playground impact attenuating surfacing systems within the use zones of playground equipment. It is imperative owner/operators understand their responsibility to purchase, install, maintain, inspect, and document compliance of their playground surfacing systems throughout the life of the playground.

Challenges to this compliance will be made in the event of a serious injury to a user even if the injury is not a life-threatening head injury. If the surface system is found to not be compliant to all the standards it will be argued the injury may not have occurred. While the scope of the F1487 standard is the reduction of life threatening and permanently debilitating injuries; many have been arguing long bone and growth plate fractures are permanently debilitating even though the ASTM F15.29 Subcommittee has repeated stated that long bone fractures of any type were not within the current scope of the standards.

Arguably, advocates for injury prevention would like to see a decrease in public playground injuries requiring emergency room treatment. The reality of this goal would be to lower heights of equipment, reduce motion in equipment, and all but eliminate the element of risk and challenge within children’s environment. The elimination of challenge and risk in play environments is known by child development experts to significantly reduce the value of the play experience and the developmental benefits of play.

Before we go any further with the analysis of playground safety surfacing systems there should be a thorough search, documentation, and review of research studies completed prior to and after 1990. The last thorough search and analysis I am aware of was conducted for the United States Consumer Product Safety Commission by the COMSIS Corporation of Silver Springs, Maryland. This was completed in March of 1990. The conclusion of this study as it relates to safety surfacing systems focused on the criterion for determining impact attenuation thresholds for the reduction of life threatening permanently debilitating head injuries to children. The study recommended the following:

“5.1.3.6 Recommendations for the peak g criterion

Further research is needed to determine the appropriateness of the current 200 peak g criterion in the CPSC guidelines. Furthermore limitations and uncertainties associated with the peak g model for head injury and with the 200 peak criterion include the following:

• The peak g model does not take into account the effects of impact duration, angular acceleration, impact locations other than frontal head impact, and directions of impact other than the anterior-posterior direction associated with frontal head impact.

• The peak g model has not been correlated with the risk of structural or functional brain damage, particularly for children.

• The 200 peak g tolerance limit is based on linear skull fracture data, yet functional and structural brain damage can occur at impact levels well below those produced by skull fracture.

• The 200 peak g tolerance limit is based primarily on adult data, but there are important differences in the skull characteristics and head impact responses of children and adults.”

The study also questioned the 200 g-Max and 1000 Head Injury Criterion (HIC) and its ability to reduce most serious head injuries.

In lieu of the increase in long bone fractures to children ages 5 through 12 the question has been raised as to whether a lower g-Max and HIC threshold would significantly eliminate serious temporary and long term head injuries and concussions as well has reduce the number of long bone fractures. What reductions in these current impact thresholds need to occur to demonstrate a quantifiable decrease in these types of injuries? In 1990 the conventional wisdom within the industry was that most available loose-fill compacted surface systems at a minimum depth of 12 inches would result in a fall impact that would well bellow the current thresholds at a fall of 10 feet or less. With ADA/ABA requirements and increased popularity of unitary surface systems there was a concern with the industry’s ability to deliver compliant surface system solutions that were within the budget realities of most public playground owner/operators.

The last major revision to ASTM F1292 allowed for the development of the first field test instrument whose use would soon begin to challenge manufacturer’s product warranty, installation compliance, and allow the owner/operator to verify their maintenance and surface system compliance throughout the life of the playground. This has led to some initial studies of various surface systems by government granting agencies and an increase in requirements for procurement of surfacing systems to assure standard compliance and protect the owner, designer, manufacturer, and installer prior to the opening of the playground.

There are international standards development organizations and various advocacy groups who have conducted more recent studies that unfortunately are providing inconclusive data that lead to recommendations and conclusions that can only muddy the waters for the industry as a whole. Studies in Great Britain and Australia have stated there appears to be no conclusive evidence that surfacing systems reduce the frequency and severity of injuries from falls to the surface. Some have concluded because of incomplete data or incomplete gathering of pertinent information related to this analysis that only by reducing the fall height can there be any significant reduction of injuries from falls.

I for one do not subscribe to this notion and believe that a well thought out research study that analyzes all the factors related to the cause and effect of falls injuries will show:

• Non-compliant surfacing systems result in serious head injuries and life threatening permanently debilitating injuries.

• Environmental factors outside the scope of the current standard have a negative impact on impact attenuation and will render some surface systems non-compliant

• Compliant surface systems, i.e. 200 g-Max or less and 1000 HIC or less will still result in some statistically verifiable percentage of serious head injuries and permanently debilitating injuries.

• Verifying where the fall occurred and the fall height of equipment from where the injury occurred is consistent with the Standard’s stated fall height of the equipment involved in the injury.

• Reducing the current threshold for establishing the critical height of a surfacing system to 150 g-Max or less and 800 HIC or less will significantly reduce the frequency and severity of both serious head injury and long bone fractures.

Call for Further Research

Only when we can document this information can we begin to address any reduction in serious head injuries and life threatening permanently debilitating injuries plus some reduction in long bone fractures while maintaining a quality educational playground environment without significantly reducing challenge or risk.

How the industry goes about formalizing and developing the scope of this research project will be the next challenge but the largest obstacle to date is who should take the lead and who should fund this project. This should be a multi-disciplined effort capitalizing on research that has just been completed and is currently underway throughout the world. This will take several years to complete if and when research funds can be secured. Children cannot afford for us to procrastinate any longer.

New ASTM F1487-11 Standard released November 2011

January 7th, 2012

New ASTM F1487-11 Standard released November 2011
By Kenneth S Kutska, CPSI
Executive Director, International Playground Safety Institute, LLC
Chair of ASTM F15.29 Subcommittee responsible for the ASTM F1487 Standard
November 18, 2011

As Chair of the American Society for Testing and Materials Subcommittee responsible for ASTM F1487 Standard for performance requirements for public playground equipment I am pleased to announce the latest revision of this standard. This revision is over four years in the making and there are several significant additions. You can order this standard online through the ASTM web site (www.astm.org). I might suggest you look into the cost of joining the ASTM and compare the cost of membership to the cost of purchasing this one standard. As a member of the ASTM you are entitled to one volume of the ASTM standards in either a paper or CD version at no charge. The playground standards are located in one of two volumes. The standard would be in either F15.07 or F15.11. Check with ASTM membership services or do a ASTM web site search for ASTM F1487-11 Standard or any other playground related standards to determine which volume is most important to address your needs.

Major Swings Section Revisions

There is a new definition for a swing that should be of particular interest to all of us. A swing is now defined as an element or seat suspended from an elevated support structure, allowing users to move freely in one or more planes, possessing a pivot point greater than 24 in. (610 mm) when measured vertically from the top of the suspended element to the pivot point. This clarifies when a suspended element should comply with all the other performance requirements of swings based on a hazard based analysis. When we think of swings, we envision traditional to-fro belt or bench type swings or a tire swing. We have seen many new products from around the world attempt to enter the market place. While they may be compliant to another international standard, they did not meet the ASTM Standard. Now however, there is some hope. Up until now, we could not clearly and totally evaluate these new swinging products by using the ASTM F1487 Standard. The ASTM F15.29 Subcommittee Working Group responsible for swings took an in-depth look at what the real hazards were regarding swinging components. The new performance requirements are based upon the analysis of injury data related to swinging components. They concluded that swing related hazards were attributable to; falls to the surface, impact with stationary structural components, and impact with the suspended swinging components. Our goal is to eliminate known hazards with the understanding we cannot control how the users may attempt to interact with the play equipment in unintended ways. The Standard now identifies three possible types of swing configurations. They are; single axis (to-fro), multiple axis (rotating), or swings with multiple motions consisting of a combination of single axis and multiple axis (combination swings). Fall related injuries are already addressed in the F1487 Standard by requiring compliance to the ASTM F1292 Standard from the highest pivot point. The next major impact type injury regardless the swing type is from suspended components impacting the user. The new standard addresses this impact hazard through a new “Dynamic Impact Test” procedure that measures impact forces created by the swinging component. This test is intended to be administered by a commercial laboratory. The application of existing clearance zones requirements to any suspended swinging component reduces the likelihood of impact injuries sustained when the user and swinging component comes in contact with the structural members or the adjacent to-fro swing. More on this test method later.

Another concern was the CPSC’s recommendation that multiple occupancy swings not be used on public playgrounds. This recommendation has been around for more than 20 years. There were legitimate concerns based on the injury data gathered over the years but times have changed and the marketplace has introduced many new products. Some argue for multi-occupancy swing seats based on new products introduced in other countries. There does not appear to be any recorded impact injury history from these new products. The dilemma is that the ASTM Standard and the CPSC Handbook allow for multi-axis swings such, as tire swings, and not a multi-occupancy to-fro swing? These multi-occupancy multi-axis swing components (tire swing) move in all directions unlike the predictable to-fro action of traditional single occupancy to-fro swings. Why one and not the other? The explanation might be the fact the swinging component was a tire and somewhat flexible and impact attenuating. The CPSC Handbook even limited the swinging component weight to 35 pounds. This happened to be the average weight of an automobile tire. The real hazard and injury in question is Traumatic Brain Injury (TBI) through impact to the child’s head or body. But what really causes the injury and at what point does Traumatic Brain Injury (TBI) occur? During the October 2011 ASTM F8.63 Subcommittee meeting in Tampa Florida, Rolf Huber, Canadian Playground Advisory Group reported the results of a ten year injury analysis conducted by the NHTSA. The study showed a 10% reduction in TBI and death after a implementing a reduction in automobile industry impact thresholds. This study demonstrates real injury reduction related to a measureable reduction in industry impact threshold used to design automobiles. This study supports our new threshold for the “Dynamic Impact Test” on swinging components and therefore addresses the impact injury to the head and for the most part other body parts. The primary cause of serious impact injuries has always been heavy solid swinging components such as; metal animal swings, bench swings, and the two person glider swings. By implementing the new “Dynamic Impact Test” for suspended swinging components, we can mitigate the impact hazard for any swing component. The logic of this recommendation was of major concern to our group. Head impact injuries resulting from falls to a hard surface should have been addressed through compliance with ASTM F1292 thresholds for impact attenuation of less than 200g and 1000 HIC. These thresholds were not intended to address fractures, but the risk of death from serious head injury. It was unknown at what impact threshold we can achieve a significant reduction in broken bones. Based on the new research related to Traumatic Brain Injury (TBI) we are seeing significant reduction in TBI in automobile accidents. The new swing impact test thresholds more closely follow the National Highway Traffic Safety Administration (NHTSA) automobile safety standards as related to our scope of intended users, especially the pre-school age group, and the results of studies of concussed NFL players during the late 1990s. The standard requires test compliance of all swing seats and swing components located less than 84 inches from the surface during its full range of motion. The test method requires the suspended elements be brought back to a point, 60 degrees from its position at rest, and released to strike an instrumented head form imparting a force less 100 g and 500 HIC.. Mr. Huber’s research of studies on the subject of TBI and bone fractures supports this conclusion for a significant reduction in these types of playground injuries when these new impact thresholds are not exceeded.

The same impact performance requirements for clearance and use zones apply to a traditional single user to-fro single-axis swing-set, with no more than two swings per bay, however multi-occupancy and multi-axis swings have some different performance requirements. Both multi-occupancy and multi-axis swings are limited to one swinging component per bay and have specific clearance requirements related to their designed path of travel. These requirements eliminate impact by adjacent swing elements and their structural components.

The combination swing is a new type of product being introduced around the world. It represents a combination of to-fro and multi-axis swings and is used by more than one person. Taking the same hazard based approach; the Working Group came up with some similar, yet quite different, performance requirements. The clearance and use zone requirements combine the side and overhead clearance zones and use zone requirements for each type of moving (swinging) component. These requirements are too difficult to address in this article without including many illustrations. I suggest that you acquire the new ASTM F1487-11 standard and study that section in detail.

Signs and Labels

The Subcommittee also dedicated a significant amount of time on signs and labels section of the standard based upon recent injury data and requirements for warnings found within the 2010 U. S. CPSC Public Playground Safety Handbook.

The Sign and Label Section of the new standard entails significant changes that should be read very carefully. The new standard states the owner/operator of the play equipment shall be responsible for the content and location of all signs. What does this mean? The information regarding the intended ages of the users shall be provided by the manufacturer, designer, or consultant. The final location of these signs and warnings shall be placed where the manufacturer, designer, or consultant states, however, for lack of any guidance on location for posting these signs, the owner/operator shall place them so they are readily visible to the intended viewer and alert the viewer to the potential hazard in time to take appropriate action. The message may be put on either a sign or a label and be located on the equipment or be freestanding. Freestanding signs must be located outside the use zone. The question for all of us is, “Where do we locate the warnings so the viewer has time to act prior to coming in contact with the hazard?” Currently there is no specific wording for many of the warnings now required. Information communicated on the sign or label, or both, shall address, but not be limited to, the following messages:
• Information message communicating age appropriateness as determined by the manufacturer/designer.
• Information message communicating, at a minimum, supervision recommendation.
• Warning message communicating the removal of helmets, drawstrings or accessories around the neck which are all known to create head entrapment or entanglement hazards.
• Warning message communicating hot play surfaces and/or ground level protective surfacing, when applicable. These surfaces are known to reach temperatures high enough to cause serious burns to children generally less than four years of age but because of the many variables effecting how and when a surface becomes a safety concern it was not possible to find a one size fits all approach that the subcommittee could agree upon.
• Warning message communicating the hazard of play equipment located over hard surfaces, when applicable. This warning message is no longer required to be plastered on each and every piece of free standing equipment.

Specification for all warning signs or labels, or both, should conform to ANSI Z535.1 and either ANSI Z535.2 or ANSI Z535.4 in the following areas: legibility, type of lettering, clarity of message and symbol, color specifications, and word message and visibility. The labels or signs should be durable and conform to UL 969. It has been and continues to be the responsibility of the owner/operator to replace signs or labels, or both, should they become illegible, destroyed, or removed.

The Subcommittee has agreed to continue to work on the Sign and Label Section to seek better solutions, if any can be found. Anybody who is interested in working on this subject may contact me; however membership in ASTM is a prerequisite to be on a Subcommittee’s Working Group. I can forward your suggestions to the appropriate Working Group.

Two New Reference Documents

The Standard has added two reference documents that must be followed by the manufacturer, designer, consultant, and owner/operator. Regardless of the material or the treatment process, the manufacturer/designer/fabricator shall ensure that the users of the playground equipment cannot ingest, inhale, or absorb any potentially hazardous amounts of substances through body surfaces as a result of contact with the equipment. All materials content shall comply with the Consumer Product Safety Improvement Act of 2008 (CPSIA). This Act pertains to, but is not limited to, coatings and substrate of the materials used within the play environment.

As with previous versions of this Standard, this specification does not address accessibility, except as it pertains to safety issues not covered in the United States Department of Justice (DOJ) 2010 Standard for Accessible Design: Title II (28 CFR 35) and Title III (28 CFR 36). This document is available free at: http://www.ada.gov/regs2010/ADAregs2010.htm. This document is now the law and will be enforceable early 2012. While this document gives us guidance for what constitutes the minimum requirements for accessible design it cannot guarantee we might not have to face a complaint raised by one or more of our constituents. Then and only then will the Department of Justice rule on what, if anything, may need to done to bring a public playground or any public facility into compliance.

In closing, I would like to encourage everyone to get a copy of this new document and read it carefully. That being said I have just three more changes to highlight from the 2007 version. First, for many years we have stated there should be no gaps at the transition of a slide and the slide surface should smooth and continuous. This has been open to unlimited translations by many inspectors. The manufacturers are very aware of the safety concern with entanglements on slides. To take some of this guesswork out of the application of this old requirement we have changed the wording to, “Slides shall be constructed in such a manner as to provide a continuous sliding surface (roller slides exempted) and shall minimize the likelihood of entanglements.” This leaves a lot of the compliance interpretation to the manufacturer/designer so long as the slide is installed and maintained as intended.

Second, we now have a performance test method to determine when a projection increasing in diameter from its initial surface is truly an entanglement hazard. When the projection fits within any of the protrusion test gauges and the increase in size extends greater than 0.12 in. (3.0 mm) from the initial surface with a depth greater than 0.12 in. (3.0 mm) it is an entanglement hazard.

Third, on stairways, all steps greater than 48 in. (1220 mm) above the protective surfacing shall be required to have protective barriers. The height of the protective barrier on a step shall be the vertical distance between the top front edge of a step and the top surface of the protective barrier and appropriate for the ages of the intended users.

Hot playground equipment needs a cool down

November 6th, 2011

Kutska Responds 10-12-10 to The Kansas City Star, Newsroom, 1729 Grand Blvd., Kansas City, MO 64108 Article

Hot playground equipment needs a cool down

As Chair of the ASTM Subcommittee responsible for performance requirements for public play equipment intended for public use, I can report that our group is currently balloting the wording for a consumer warning for hot surfaces in public playground environments. Our Committee’s research indicates that there have been very few reported burn injuries to children on public play equipment yet we all appreciate the potential for these injuries in public places in general. The issue is not limited to metal play equipment. Even plastic play components can create the same problem for children, especially to toddlers under age 3 whose skin is most susceptible to these types of injuries. Within the last two years there have also been reported burn injuries to this user group due to hot rubber safety surfacing.
Metal play equipment has been around since the very beginning of the manufacturer of play components. This is nothing new and should not be a surprise to parents if they only reflect back on their own personal experiences as a child. Think back to a trip to the beach on a hot summer day. We kicked off our shoes and made a beeline for the water without even thinking. Within seconds the pain became excruciating. That happened to me as my feet began to scream HOT! What did I or anyone else who had the same experience do? We may have stopped and screamed out loud for help since we had no idea or experience to intuitively tell us what to do. As adults or even adolescents we knew from our life’s experiences that we must find shade or get to the water for relief.
Unfortunately our youngest children are most at risk and there is nothing we can do to protect them against every possible scenario. Parental supervision and guidance is truly the real answer to this problem. When it is sunny and hot, even walkways and concrete sidewalks become too hot for these youngsters. Are we to expect to sign these areas as well? Are we to coat them with a more user friendly protective surface? Even these kinds of surfaces can become a solar mass capable of reaching critical temperatures when the outside temperature is very comfortable. There are far too many variables to find a simple answer to these concerns.
I can assure you we will soon have a warning sign/label to explain the potential for injury but nothing will do more for eliminating these injuries in the future than educating the general public about the injury potential for our children when we do not dress them appropriately or supervise their actions as responsible parents or guardians. The media can do a lot to help inform the general public of the potential for injury to their children. This becomes another classic example of people taking responsibility for their own actions. We can never totally protect one from each and every possible risk found in the outdoor environment. Common sense must prevail.
KEN KUTSKA, Executive Director
International Playground Safety Institute, LLC
www.internationalplaygroundsafetyinstitute.com

The Watchdog | Hot playground equipment needs a cool down

The problem Heat can hurt. Just ask Carolyn Kisler of Kansas City, North, who took her 14-month-old son to Penguin Park on Sept. 13.
“He climbed onto a metal merry-go-round and immediately started screaming,” she said. “He ended up with a second-degree burn on his left leg.”
Kisler says she asked the parks department to move the equipment into the shade or paint it with sun-reflective paint.
Her doctor told her about a Consumer Reports article last July that said temperatures can rise to 140 degrees on playground equipment surfaces and that equipment became quite hot in the sun even when the temperature outside was only 80.
“And, toddlers not having efficient footing can’t get up as fast as older children can,” Kisler said.
The answer
The Kansas City Department of Parks and Recreation sent a certified playground safety inspector to investigate the merry-go-round.
“It was determined that instead of removing it, because it is such a popular play experience, we would try and use heat resistant/reflective paint to solve the problem,” said David Burke, an area superintendent with the department.
The painting will by done by the end of the week, he said.
“The department, as a practice now, stays away from installing any new pieces of equipment that would have a metal play surface,” Burke added.
The Consumer Reports article, written by Jason Harary, advises parents to make sure their children wear shoes on the playground and choose shaded equipment when possible. Parents also should test the equipment with the backs of their hands.
“If it’s too hot for you, it’s definitely too hot for the little ones,” Harary wrote.
The Watchdog says paws, too, can get burned on hot pavement.
Do you have a comment or question about a public issue? Write to The Watchdog, The Kansas City Star, Newsroom, 1729 Grand Blvd., Kansas City, MO 64108, or send e-mail to watchdog@kcstar.com. Include your name, telephone number and city of residence.

Read more: http://www.kansascity.com/2010/10/12/2306471/watchdog-hot-playground-equipment.html?story_link=email_msg#ixzz12FYwjSOd

Playground Area Standards Update and the Need to Improve Our Oversight of These Spaces

November 6th, 2011

Playground Area Standards Update and the Need to Improve Our Oversight of These Spaces
By Kenneth S Kutska, CPSI
Executive Director, International Playground Safety Institute, LLC
May 14, 2011
A public play area’s life and the joy it brings to the children who will visit can only be realized after a thorough planning process. It begins with the selection of an appropriate site and some planning meetings with all the intended stakeholders. Once their needs and desires are processed the planning process continues as the owner begins discussion with their local play equipment sales representatives. Here is where the owner and the sales representatives evaluate your specific play area needs. This process usually results in developing your procurement documents for the playground equipment, site amenities, and the necessary compliant impact attenuating surfacing system. This process can be overwhelming for the inexperienced and uninformed as the playground industry and its vast array of product options seem to change dramatically from year to year. Current economic conditions, global competition for industry market share, and different and ever evolving international standards for all aspects of your play area design; are adding many new challenges and opportunities to the typical governmental agency’s purchasing process. We all strive to develop the perfect play area containing something new and unique while meeting everyone’s expectations expressed during the planning process. Many of us do not have the luxury of in-house planning staff to help guide us through this process so we challenge our sales representatives to come up with new and creative designs. We desire equipment and safety surfacing systems of the highest quality that comply with or exceed; current industry safety standards, local building codes, and still remain within our shrinking budgets. Many Requests for Proposals require qualified bidders to address specified items such as; unique installation challenges, materials durability issues for the local environment, and assuring different levels of challenge for the developmental needs of the intended user group. On top of meeting these objectives the owner must first and foremost meet the minimum industry equipment safety requirements and address ease of access for people of all abilities. This process is more of an art form than an exact science. My worldwide observations over the past ten years demonstrate some understand these concepts. I have witnessed the constant improvement in the hundreds of play areas. These areas all look relatively new, attractive and very inviting to all who pass by the area. At first glance it appears everybody understands a very important objective of facility management, “Keep your facility in good repair and properly functioning.” This should be our first objective based on all the current emphasis on, “The Green Movement.” Maximizing the life expectancy of the area is the best use of resources and minimizes the consumption of raw materials used in the manufacturing process of the play equipment. I will comment on my closer observations of these areas later in this article since a drive-by inspection cannot possible do justice to the owner’s responsibility for the safety of the public.
First, I would like to share some of the issues bringing about changes within the children’s play area industry. It can be a real challenge to keep current with all of the changes occurring within the various government regulatory agencies whose actions impact the play equipment and safety surfacing industry. How do you stay current?
Staying Current with Industry “Best Practices” is Imperative
Becoming a Certified Playground Safety Inspector (CPSI) through the National Park and Recreation Association (NRPA) is a step in the right direction. For the past twenty (20) plus years more than 45,000 people worldwide have attended a CPSI Course and many have attained certification status. The current network of approximately 8,000 CPSIs in-good-standing have been introduced to the many organizations which help them stay current with the rapidly changing children’s play industry. All CPSIs receive a complimentary subscription to Playground Magazine (www.playgroundmag.com) and their online magazine and newsletter. While this is an excellent resource a CPSI needs to frequently check many other industry related web sites to stay current with the latest industry developments. Some of these webistes include the National Park and Recreation Association (www.nrpa.org), the International Playground Safety Institute, LLC (www.internationalplaygroundsafetyinstitute.com), the United States Consumer Product Safety Commission’s web site (www.cpsc.gov), the International Playground Equipment Manufacturers Association’s web site (www.ipema.org), and the National Program for Playground Safety (www.uni.edu/playground). Some have even joined the American Society for Testing Materials International (ASTM) (www.astm.org) and thereby get prompted electronically to visit the web site and participate in the standards development process by voting on the many play industry related standards that impact us all. In case you have not had the opportunity to visit these web sites I would like to share some of the most current developments and issues facing our industry.
New Standards and Guidelines Impacting the Play Area Industry
In November 2010 the US CPSC came out with another revision to their 2008 Draft, Handbook for Public Playgrounds, Publication, Number 325. This revision is a major step in harmonizing with the ASTM F1487 Standard Performance Requirements for Play Equipment for Public Use. This Standard is developed through the activities of ASTM Subcommittee F15.29. I, as Chair of this ASTM Subcommittee, invite you to join ASTM and participate online in this subcommittee’s activities. ASTM F15 Committee addresses all consumer products and I am sure there are many other Subcommittees whose activities relate to many other products you deal within your job responsibilities. There is a new revision to the ASTM F1487-07ae1 which should be published some time in 2011. The revision will include a major rewrite of the specific equipment requirements for swings. The new section will include a swing impact test method and performance requirements. Section 14 and 15 have been substantially revised to address five of the most common safety concerns impacting owner/operators. The most significant change is the elimination of the mandatory surfacing warning message as is currently stated in the 2007 version of F1487. The exact warning message for this and other safety related concerns such as supervision, intended user age group, and hot surface warnings; will be left up to the owner/operator and/or manufacturer. This will cause many of us some angst as we attempt to determine what message is most important to convey to the users and their caregivers. During the ASTM standard development ballot process, it became apparent to our Subcommittee that we could not come up with one simple mandatory hot surface warning message that addressed all the safety concern variables related to every possible geographic location, equipment or surface type, material or color.
New ASTM Task Group for Performance Requirements for Outdoor Fitness Equipment for Public Use formed May 2011
During the May ASTM Committee Week in Anaheim California the Subcommittee for Fitness Equipment F8.30, upon formal request to the ASTM from a Chinese Standards organization revising their current 2003 standard for outdoor fitness equipment, established a Task Group to develop a performance requirement standard for outdoor fitness equipment for public use. The initial meeting was an evening, two hour, virtual meeting with members of F8.30, F15.29 and our Chinese counterparts and the assistance ASTM Staff and a translator. This Task Group includes members of the ASTM F15.29 Subcommittee for public play equipment since we are most interested in the potential impact of unsupervised fitness equipment in public settings and have a lot of injury data related to children. The scope of this new standard appears to intended for users thirteen (13) years of age or older in unsupervised public settings. During the Anaheim meeting it was suggested the initial injury prevention discussions address equipment performance requirements addressing unintended users. The Chinese manufacturers of outdoor fitness equipment appear to have injury data supporting our current scoping recommendation to address safety and injury prevention related to the unintended user identified as the same user group in the scope of the ASTM F1487 performance standards for play equipment for public use. It was for this reason F8.30 invited the ASTM F15.29 Subcommittee to join this task group. Most of the work on this standard development process will take place through the ASTM web site and their virtual meeting capabilities. If anyone is interested in joining this effort they should contact ASTM or Harvey Voris, Chair of ASTM F8.30.
In late 2010 the ASTM F2049 Standard Safety Performance Specification for Fences/Barriers for Public, Commercial, and Multi-Family Residential Use Outdoor Play Areas became a performance standard in lieu of a standard guide. While this may appear to be a subtle change, it may have significant design implications to anyone who must follow all ASTM Standards related to public play areas. There are now special performance requirements defining when fencing may become a recommended requirement for a public play area. There are ASTM Subcommittee ballots currently being voted on that address requirements for the type and number of emergency access/egress gates. This standard is under the jurisdiction of the ASTM F14.10 Subcommittee which is part of the ASTM F14 Committee that addresses many other fencing standards for other recreation and park facilities such as; aquatic facilities, ballfields, tennis courts, and so on.
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Play Area Safety Surfacing Requirements Impacting Owner’s Operating Decisions
The ASTM F8.63 Subcommittee has several projects under consideration under the ASTM F8 Committee which addresses all types of surfaces and manufactured surfacing. There are many ASTM Standards which fall within this Subcommittee’s scope of responsibility that impact the public play area industry. The ASTM F2223 Standard Guide for ASTM Standards on Playground Surfacing gives a brief explanation of the many standards currently in effect that impact the different types of impact attenuating surfacing systems for public play areas. Did you realize there are several standards that should impact your purchasing decisions for the many types of play area surfacing systems you own or will soon own?
ASTM F1292 Specification for Impact Attenuation of Surface Under and Around Playground Equipment impacts every play area surface system requiring a use zone.
ASTM F1951 Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment impacts every new or altered play area for its accessible route to each and every accessible play activity.
ASTM F2075 Specification for the Manufacture of Engineered Wood Fiber (EWF) Surfacing for Public Playgrounds. If someone is selling you EWF they should be able to provide you an assurance certificate to that effect.
ASTM F 2479 Standard Guide for Specification, Purchase, Installation and Maintenance of Poured-In-Place (PIP) Playground Surfacing. If you are installing PIP in your playgrounds do you even have a clue of the various issues and processes the installer must content with in order to provide you a quality product. It may behoove you to get a copy of this standard and read it to understand what is involved in the installation process and improve your purchasing documents.

All ASTM standards are under constant review and revision. In many instances, new standards are developed to better clarify or even expand the minimum acceptable performance requirements of the existing types of surfaces already being used within the play area industry. There is currently a new ASTM F8.63 Subcommittee standard under development for loose rubber surface systems to determine acceptable levels of specific contaminants and foreign materials such as tramp metal.

How to Verify Compliance to Minimum Play Area Safety Surface Standards
Did you know that the ASTM F2223 Standard recommends several factors for consideration in selecting an impact attenuating surface for under and around your public play area? The surface system should conform to both ASTM F1487 for your use zones and ASTM F1292 for impact attenuation for the fall height of your equipment. In the USA, they must also conform to the minimum performance requirements of the ASTM F1951-99 to meet the minimum requirements of the Americas with Disabilities Act ADA/ABA Accessibility Standards. Now that there is a final standard enforceable by the Department of Justice (DOJ 2010 Standard – 28 CFR 35.1510 and 28 CFR 36.406; Sections 240 & 1008 Play Areas) things could change with regards to what is or is not considered to meet the minimum requirements of the ADA.

Since every surface system is unique in material, formulation, composition, and source of raw materials it should be tested to confirm conformance with the appropriate ASTM specifications identified in ASTM F2223, specifically F1487, F1292, F1951, F2479, and F2075.
Safety Surface Field Testing Will Document Compliance to Minimum Safety Standards
ASTM F1292 recognizes children play in climates with diverse temperature ranges. Regardless of the materials used in the manufacture of the surface system under and around the play equipment surface samples are required to be tested in a laboratory at three temperatures, 30 degrees F (-1 degree C), 72 degrees F (23 degrees C), and 120 degrees F (49 degrees C) to determine the height from which the g-max does not exceed 200 or the Head Injury Criterion (HIC) does not exceed 1000. Once either threshold is exceeded; the next lowest series of drop tests measured in full feet becomes the Critical Fall Height of that surface. The owner/operator of the play area should ensure the Critical Height of their selected surfacing system exceeds the Fall Height of their equipment. Did you know the pass/fail recommendations for the specification are minimum requirements? How do we know for sure what the exact temperature fluctuations might be under extreme heat or cold on any given day? How do we know when these extreme environmental conditions might render the surface system non-compliant to the minimum recommendations? How can we determine when this point of non-compliance might occur? The only real answer is known through field testing. The ASTM F1292 standard gives a detailed explanation of how to conduct the test in the field in addition to the laboratory testing requirements including a comprehensive list of items that must be included in the final test report. The basic difference between these two types of tests is the field test is conducted at the ambient temperature on the date and time of the test and at locations selected by the test operator that appear to be the most likely to fail. These locations might be areas of noticeable heavy use, visible wear, edges of tiles, and/or seams. There are many more requirements for information required within the actual drop test report including the recording of each of the three drops, at each of the three separate locations, within the use zone of each free standing piece of equipment and/or composite structure. This process is required and repeated for each different surface system within the use zone of each free standing or composite piece of equipment. In addition, digital photos are required to document each area tested. Weather conditions must be recorded, including the surface temperature and the temperature between one and two inches into the surface system at the time of the drop test. The surface system fails the compliance test if any of the drop test results (average of the second and third drop test results for each location tested) exceed the thresholds of 200-gs or 1000 HIC for the fall height of the equipment or the height specified by the owner/operator in their purchasing documents or contract, whichever is greater.
Did you know the ASTM F1292 and the ASTM F1487 require the owner/operator document this compliance and retain these records? This documentation includes verification the installation complied with the manufacturer’s specifications and the surface is maintained within the use zone for each play structure in accordance with the standard.
Providing Access For All and New Standard Put Focus on Maintenance Issues
September 2010 the US Department of Justice adopted the Americans With Disabilities Standard (referenced above) that establishes compliance requirements for the installation, maintenance, inspection, and documentation of the accessible route, up to and through, the playground area to every accessible play component. It is now imperative these standards be understood and adhered to in the USA. We are only beginning to realize and understand the ramifications of this landmark legislation. What are the minimum performance requirements of the accessible route? We have known the U.S. Access Board’s recommendations for this route for many years. The acceptable minimum slope of the route outside and to the play area should have a minimum width of 60 inches (1520 mm), a maximum running slope of 1:20 (5%), a maximum cross slope of 1:50 (2%), and a minimum overhead clearance, free of any and all man-made or natural obstacles, of 80 inches (2028 mm). In areas of rapidly growing vegetation this can present a unique set of inspection and maintenance requirements to maintain this clear space and firm, level, and stable surface along the accessible route including areas this route encroaches upon the accessible equipment use zones. Inside the play area the running slope my not exceed 1:16 with a cross slope no greater than 1:48 and it must maintain the 80 inch (2028 mm) overhead clearance. The accessible route within the use zone must comply with impact attenuation requirements of the ASTM F1292 Standard. How we measure these requirements in the field will become a challenge for most of us that utilize loose fill surface systems. It also presents unique challenges for those who use rubber tiles or even Poured-in-Place unitary surface systems. Expansion and contraction of almost any surface and ultraviolet radiation (UV) and thermal degradation (excessively high temperatures) can cause shrinkage, buckling and adhesive breakdown, resulting in raised edges and gaps. If any surface, within the 60 inch (1520 mm) wide accessible route, has gaps, depressions, or vertical raised edges of greater than ½ inch, the route is considered to be non-compliant. This will be the most common compliance issue facing public play area owner/operators. Only recently have most operators and manufacturers of surfacing systems come to realize the impact these accessible route requirements of the Accessibility Standard for public play areas. For more information visit www.access-board.gov.us.
New US Consumer Product Safety Improvement Act has Worldwide Impact
Did you know the U.S. Legislature passed a new safety law in 2010 governing all children’s products? It is the Consumer Product Safety Improvement Act (CPSIA) and it impacts all manufacturers and distributors of any child product sold in the USA. In short, it sets new threshold limits for toxic substances such as lead paint and toxic substances found in plastics. This will also impact the play equipment industry and the exact impacts are not yet fully known or understood. For the large number of playground equipment manufacturers selling products throughout the world, including here in the U.S., this can create some interesting challenges for many distributors of children’s products sold here and manufactured throughout the world. This Act does not just impact the final product. It impacts each individual component used to assemble the play equipment and includes all manufactured play area surfacing systems. Lead paint content of dyes used to color artificial turf top mats has raised concerns in the sports turf industry over the past several years. The CPSIA will continue to evolve as new information and research on the subject becomes known. One thing the ASTM F15.29 Subcommittee has learned as we attempt to deal with issues, such as; burns from hot surfaces and exposure to toxic substances within the play environment, is that children under the age of three (3) are most at risk to experience the negative impacts from exposure to these conditions.
All of this information is important to manufacturers, designers, installer/contractors, and those of us who inspect, maintain, and repair these public areas for children’s safety and enjoyment. This information is not just “nice to know” it is “need to know” information. All of this information comes into consideration as an owner/operator starts a planning process for a new facility. It is all very important in the analysis and final decision process of selecting equipment and safety surfacing systems for your project. It is time we allocate some of our limited and precious time to become more engaged students of these types of changes within our industry.
Green Objectives for Play Area Owner/Operators
In spite of all these changes the one thing that has not changed that has remained a major concern within the play area industry, is the lack of or improper maintenance being performed on our public play areas. In the USA, it appears that more than 40% of all public playground related injuries requiring emergency room or hospital treatment are alleged to may have been caused by this lack of proper maintenance. Proper maintenance requires knowledge and experience of the basic play area components from the equipment, below grade footings, to the structural components, fasteners, connectors, and fastening connectors, regardless of the materials used to create the components. Play area safety inspections must be routinely conducted by trained personnel authorized to take appropriate action to complete regular custodial type maintenance, conduct manufacturer recommended preventative maintenance at recommended intervals, and to make the repairs necessary to prevent equipment or component failure. Thus, when the inspector identifies a piece of equipment or a component that has failed or is near failure, they must be adequately trained and prepared to take appropriate action. Their actions will range from; immediately replacing a defective part or taking the play event out of service, to properly shutting down the entire play area in order to avert a serious, possibly life threatening, or permanently debilitating injury. The Certified Playground Safety Inspector Course defines this type of injury as; death, brain damage, loss of vision, loss of speech, loss of limb, and loss of internal organ. Long bone fracture and broken bones of any type, while serious, are not considered to fit this definition of permanently debilitating.
The Green Solution
I would like to go back to my earlier comment about the drive-by appearance or first impression of many public amenities. Over the past twenty years I have had the privilege of visiting most States and several countries throughout the world. To me, there appears to be one important, almost constant, issue throughout the world. What the general public and I see from a distance appears to be a very modern looking, well maintained, functional public play areas. Upon closer inspection, by a trained CPSI, they will discover the need for more maintenance and repair of play components and the safety surfacing. Many components and surfacing, regardless of the manufacturer, will show moderate to extreme wear, parts will be missing or broken, and many moving parts show excessive wear and should be replaced immediately. If repairs cannot be made immediately, steps should be taken to remove the broken play component or render it unusable so it does not injure a child or create another safety hazard when a child comes in contact with the temporary repair.
My observation, if correct, can only be addressed with a commitment of resources to hire and develop better informed, knowledgeable, more experienced staff or independent contractors who are charged with the responsibility to inspect, maintain and repair children’s play areas. Our industry safety standards and guidelines and the children who use the playgrounds require us all to do nothing less. Researchers have demonstrated the developmental benefits of play in a child’s development. Over the years, examples of healthy playful community planning have demonstrated these areas, and other similar public spaces, are a necessary amenity which add value to any vibrant city, school, park, childcare facility, or residential development. If play spaces are such a necessary component of quality living spaces then they should receive the necessary attention and resources to preserve the quality, safety, function and aesthetics of the original design concept.
How we move forward to enhance the quality of life for all people can be summed up in how we value and address the needs of our very young and the elderly. Public safety should not be compromised. We need make sure there is a life-cycle cost of maintenance and repair of our public spaces incorporated into the planning process and then we need to ensure adequate resources are allocated to life-cycle maintenance and repair costs associated with any and all public spaces. As I stated earlier in this article, ensuring the safety of the public, maintaining the function of the facility, and reaching or surpassing the intended life-cycle of the capital investment are some of the most basic GREEN objectives for the owner/operator. I suggest we make sure we allocate approximately 10% of the cost of the project to the annual inspection, maintenance, and repair of the area. In addition, I suggest we provide the necessary training to those responsible for the day to day management of these areas Over time we will be able evaluate the outcome and adjust our efforts accordingly.