Part 1 of 4 – Playground Surfacing Requirements and Injury Reduction: Too much or too little?

February 6th, 2016

Part 1 of 4 – Playground Surfacing Requirements and Injury Reduction: Too much or too little?
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 10, 2015

Since 2013 I have discussed the international definitions for terms used in safety standards related to children’s products, such as; hazard, risk, harm, intended design use, reasonable foreseeable misuse, and risk assessment. I also discussed the terms and definitions for severity levels of injuries using the Abbreviated Injury Scale (AIS). I see a need to define the scope of international playground standards by using these terms and definitions that balance the developmental needs of children with unreasonable risk of harm. It is a somewhat of a delicate balancing act between providing enough safety requirements to keep children from being seriously harmed while not tipping the scale away from our ability to provide more challenging risky play opportunities. In reviewing the scoping statements of various international playground equipment and surfacing standards it appears this line is blurred. How much regulation is needed to meet the needs of children as they seek the thrill of challenge versus the unintended consequences when their developmental abilities are inadequate to assess their risk of harm? What level of consequence (severity of injury) is a fare trade-off for the developmental benefits of risky challenging play opportunities? I have posed these questions to before to those involved in creation and management of playgrounds.

Falls to Surface – Number one cause of injury and one of four top causes of death on playgrounds
We have known since the early 1970s the number one cause of serious playground injuries requiring medical attention is FALLS TO THE SURFACE. What frequency and severity of fall related injuries can we live with? Most of these fall injuries result in long bone fractures which occurs far more frequently than a serious head injury. Which injury is more severe? It depends on the level of severity which is determined by trained medical professionals using the AIS rating system. The causes of these fall related injuries are many. Sometimes the child lacks the physical and cognitive abilities necessary to successfully use the equipment as intended or the child decides to use the equipment in unintended ways. Maybe the equipment had some design issues or it was not properly installed. Often the owner/operator does not maintain the equipment or surfacing in accordance with the manufacturer’s instructions and the equipment brakes or the surfacing no longer provide the minimum protection required by the standards. What about those serious injuries that occur on playgrounds that are well maintain within the minimum requirements of the standards? Should they all be accepted as a part of everyday life or should there be some change in our approach to the cause and effect of FALLS TO THE SURFACE?

The effort to reduce the current ASTM F1292 impact attenuation thresholds has been going on for a long time. Parties on both sides of the issue have done their best to bring the most current information to the attention of the F8.63 Subcommittee members. Before I get into the real issue of surfacing performance and injury reduction I would like to address a little issue related to accusations made against the ASTM International organization and its members. I believe ASTM and the ASTM F8.63 Subcommittee are due an apology for some of the comments that have been made and/or implied on how the ASTM and their volunteer members conduct the business of developing voluntary industry standards.

The following statement was written by one of the interested parties against the threshold reduction to 700 HIC and is true, to some extent.
“This is a complex issue with strongly-held views. I will continue to foster reasoned, constructive debate and share news and views, here and elsewhere, to the best of my ability – though there are challenges, not least the lack of transparency in ASTM’s decision-making. To repeat: there is no doubt that the extent of debate and opposition to ASTM’s proposal has helped to get this result.”

Determining what is the appropriate impact attenuation threshold is a complex issue but to imply the ASTM process is underhanded and non-transparent or flawed could not be further from the truth. The question still remains whether the outcome of the last ballot and the successful appeal was the correct result. Let’s start with some background information to the issue at hand.

Here are the facts on the ASTM Process
There are many Committees within the ASTM organization. There are 36 Subcommittees within F8 Committee. The F8.63 Subcommittee is responsible for all playground related surfacing standards and guides. This Subcommittee currently has about 160 voting members. Once a Subcommittee ballot item has gone through Subcommittee approval process it must then be upheld by the Main Committee ballot. The point is there are many opportunities for the dissenting opinions on any issues to have their negative vote and rationale heard.

In this instance the ASTM International voting process was followed. A 90% affirmative vote is required to continue to move the ballot issue forward to the next step in the approval process. The results in this first ballot was overwhelmingly in favor of the change (+9 to 1). The next step in the voting process is to address any negative votes. The few negative votes received were then reviewed by the task group. Written rationale was provided to find the negative votes non-persuasive. The rationale for finding the negatives non-persuasive was put in the form of a motion and a ballot was voted on by the entire F8 Main Committee. The results of this ballot was again overwhelmingly in favor of the change (+8 to 1) to reduce the HIC to 700. This step requires a super majority (+2/3rds) affirmative vote. All ballots are then approved by the ASTM Committee on Standards before they can get published.

The ASTM Committee on Standards (COS) appeal findings had nothing to do with the merits of the change to the HIC. The issue was whether or not the Subcommittee properly handled the negative vote process. The primary issue, as I understand the appeal, had to do with the timeline in which supplemental information related to the ballot item was sent to the Chair and distributed electronically to all F8.63 Subcommittee members. This information was believed, by some, to support those members who voted in opposition to the proposed HIC reduction. Distribution of these materials occurred after the ballot was posted for the vote to find the negative voter’s rationale non-persuasive. By the time the documents were distributed some ASTM members had cast their vote. Regardless of the timeline issue, the documents were sent to everyone and the voting deadline was extended. Anyone who wished to change their vote would be allowed to do so. The voting results were as stated above. Should these voting results have been upheld by the COS, the reduction of the HIC from 1000 to 700 would have occurred. The COS heard and upheld the appeal based on the timeline for how this new information was handled in relationship to the ballot posting and closing dates. COS thought there should have been more time allowed prior to the ballot closing date or the ballot should have been delayed. The COS ruling on this appeal required this ballot item go out to a vote once again.

Did new documents in question support no change to the 1000 HIC?

So you might ask what was so compelling about this new information in support of the status quo of 1000 HIC. Prior to the appeal hearing and action by the ASTM COS, the information in question was presented and discussed at the ASTM F8.63 Subcommittee meeting. I was at that meeting. It was a very lively discussion. These papers were determined to be of no consequence to the matter being balloted as they did not support either lowering or leaving the HIC at 1000.

Some of the so called supporting documents were National Electronic Injury Surveillance System (NEISS) reports on fall injury reports and serious head injury reports from 2001-2008. What these reports do not represent is the real number of fall related injuries and how many of these falls result in serious head injuries. NEISS report analysis is a statistical sampling of a small number of pre-selected hospitals that would be representative of the demographic distribution of all Americans. So NEISS numbers are a statistical projection of injuries based on the information gathered by the NEISS participating member hospitals. The information gathered from these reported fall injuries do not give us enough detailed information about the accident to assist us in this surface performance debate. Some just state, person fell to surface. We do not know anything about the characteristics of the surface or if it was compliant. The report states the person was transported to hospital by ambulance, treated, and released. We do not know the extent of the injury or if there was any negative impact to the injured party after that initial treatment. Very few people stay in hospitals overnight if they can be, observed, cared for, and treated at home. Are these injuries serious or not? Can anyone tell me how many serious head injuries are too many? Do we really need a number? There seems to be more questions than answers.

The other research document was a research paper titled, School Playground Surfacing and Arm Fractures in Children: A Cluster Randomized Trial Comparing Sand to Wood Chip Surfaces (Howard, 2009). This study was based on the Toronto Public School’s experience with injury reduction. This study appeared to have too many unanswered questions to provide concrete evidence the 1000 HIC was adequate or the benefits of a reduction to 700 HIC were measureable and substantial enough to be worth the cost.

Two Points of View – What can we learn from the Howard Study?

Since the initial discussion on the Howard Study and after the COS appeal decision, there were two presentations made by Subcommittee members at the following May ASTM meeting in Anaheim. These presentations were based on the findings of the Howard Study. This research paper was about injury reduction in Toronto Public Schools. The focus was on which of 2 types of loose-fill surfacing material was most effective in injury reduction, primarily fractures; wood chips or granitic sand. The study concluded a higher reduction in fractures on this special granitic sand than with wood chips. The study’s conclusion that 12 compressed inches of this sand is superior to 12 compressed inches of wood chips raises some additional questions about surfacing recommendation in the U.S. CPSC Handbook since it still shows a 4 foot critical height for 9 inches of compacted sand. This study proves to me that not all sand is the same or performs equally. While depth of surface material can have an effect on performance there is no guarantee more depth will result in better impact attenuating results. What the study does not discuss are the changes the school district made to their playground design guidelines prior to the study. Before the study and new school guidelines there were many very tall wooden structures that did not conform to the Canadian Standard requirements. New policies were put in place that in effect brought all equipment and surfacing into compliance with current CSA Standards. This resulted in a lower fall height for most play equipment. These guidelines also requiring a minimum depth of at least 12 inches for granitic sand or wood chip products be installed and maintained. Again it is important to point out these conditions did not exist prior to the study. The study conducted after the equipment and surface improvements did show a significant injury reduction but nobody took into consideration the performance of the preexisting surfaces in the Toronto Schools or the fall height of the old play equipment that contributed to all the baseline injury data. So what is the reason or reasons for the lower incidence in fractures and other serious injuries?

One Anaheim presenter secured copies of actual field drop test reports from the Toronto Public Schools. He concluded that the field test results showed excellent impact attenuation of less than 500 HIC and 100g was reason for fewer injuries. The other presenter concluded that surfaces which are in compliance with the existing standard thresholds of 200g and 1000 HIC resulted in fewer injuries. Which conclusion is more compelling? The results of actual field drop test reports for the Toronto Public Schools demonstrate impact attenuation results that perform over 50% better than current threshold and far better than the 700 HIC proposal. There are other variables not taken into consideration in the Howard Study that would help us in this discussion but that horse has already left the barn. So what else, if anything, does the study tell us?

When you take into consideration the actual surfacing field test reports the injury reduction results are based on a lower equipment fall height and a minimum 12 inch depth of surface materials, conditions that did not exist prior to the study. Regardless, I would argue the Howard study demonstrates a lower HIC threshold will have a measurable reduction in frequency and severity of all fall related injuries. The study also points out not all sand performs equally. This granitic sand, which as far as I know is only found in Ontario Canada, has superior impact attenuating properties primarily because it is very uniform in particle size and does compact.

We might begin to see the real correlation between surface performance and severity of injury if actual field drop test results were taken immediately after every serious fall related playground injury. Some are requesting this kind of data before voting to reduce HIC thresholds. For many legal reasons I do not see anyone willing to try and make this happen. What we can do is use the best information available. The automotive industry has 50 years of experience in the area of impact injury research. Why not start with that?

In conclusion, the ASTM Council on Standards Appeal was over nothing more than the timing of the release of the information I just discussed. The appeal argued the late distribution of the supporting documents in support negative voter’s position effected the voting results. These documents were discussed at two Subcommittee meetings. The discussion did little to persuade any voters one way or the other. Using the Howard Study along with the actual surfacing drop test results presented after all the ASTM voting, a pretty good argument can be made that fewer fall related fractures and head injuries will occur on surfaces with impact thresholds, even lower than the proposed 700 HIC. These results can only be realized one of two ways; lower fall heights or improve the performance of surface systems. The surfacing must also must be managed by conscientious and knowledgeable staff that implement a consistent inspection and maintenance program.

But what about the potential impact of a lower threshold on risk and challenge? Stay tuned for Part 2 of the story.

Part 3 of 3 – Hazard Based Approach to Standards Development: The time is now.

January 6th, 2016

Part 3 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

How does the hazard-based approach work? Our Objective

“Playground safety performance requirements shall be developed and applied to focus on the hazards posed by equipment’s design, movement, and layout, whether free-standing or in combination with other components, and should address the issues of intended and reasonable foreseeable use rather than exempting that equipment from all but the most basic requirements of the past.” Kutska, Part 2 of 3, Hazard Based Approach to Standards Development

Last September I wrote about this concept of hazard based standards development. In this article I referenced a post I made on the NRPA Connect social media page created for CPSIs. I walked him through the assessment process I might use in evaluating this design. The person was challenging the layout and spacing for a stand up spinner that was attached to the support post of an overhead ladder that was connected to a much larger composite structure. This is maybe too much for one to analyze without a picture but basically it was all one big composite structure. My assessment process went like this;

“What is your citation for your findings? Remember use zones may overlap for composite structures. Rather than use zone issues there may be more clearance related issues. I do not discount your concern but right now IPEMA Certification Program would consider this compliant. It may not be best design but now is not the best time to bring up this concern. Planning stages is when owner should evaluate risk and make recommendations. You could still move spinner and make it a free standing play event if you have money and space but the owner will be footing bill. We are working on this very subject at ASTM as we see rotating equipment and composite structures requiring a second look. Ask yourself, what are the hazards? Falls to surface. Impact by spinning equipment. Impact from limited clearance. Loss of balance from rotating equipment leading to lateral discharge from inadequate upper body strength and lack of gripping or grasping surfaces. Is there sufficient circulation area around adjacent play events? All reasonable concerns. Now ask what the standard allows at a minimum and then ask what a reasonable person would allow given your specific end user and owner’s philosophy for free play.”

I stated that for the hazard based approach to move forward we cannot continue to evaluate playground equipment during a post injury investigation in the same manner, with the same objectives, as if the injury occurred in a workplace environment. We have to look at what the safety issues are during reasonable and foreseeable use. Assuming the standard has established society’s acceptable threshold for severity of injury, the designer and manufacturer of the playground equipment should be conducting their own risk assessment of their equipment to determine whether or not it is appropriate for the intended user during both intended and reasonable foreseeable use. Equipment designer/manufacturers shall make recommendations on age appropriateness and should recommend minimum use and clearance zones based on intended design use and reasonable foreseeable misuse. Also the playground area designer and owner need to consider all these things and more during the design process. Other than the age range of intended users and age appropriateness of specific pieces of equipment, all other special requirements within the standard are stated as minimums. These minimums may not meet the owner’s needs for the scope of their project. The owner and designer need to work together and conduct their own project assessment and answer the following questions; define the intended users, what if any supervision will be present, intended user load, level of accessibility, access to and from the playground, environmental concerns, border safety concerns, and most importantly what level of impact attenuation their surfacing system shall provide based on the fall height of the equipment. Remember the surface system needs to perform to these minimum standards throughout the life of the playground. Therefore the owner may want to consider specifying surfacing to perform well under the minimum impact requirements for the fall height of the equipment or even specify a surfacing performance threshold less than minimum required to provide more fall protection under and around the more challenging pieces of motion and upper body equipment. When it comes to protective surfacing, use zones, and clearance zones these requirements are stated as minimums. Therefore it is ultimately up to the owner’s risk assessment during the conceptual playground design to establish their own balance between how safe is safe enough and how much risk and challenge is too much.

Children will continue to be injured while enjoying the thrill of the challenge as the test their skills. We also know the primary causes of debilitating and life-threatening injuries in children ages 2-12. Falls have always been the number one cause of injuries on playgrounds and one of the major causes of playground deaths. We also know that impact by moving and even stationary equipment is another major factor. We know entanglements caused by projections or specific dimensions along with how we dress our children to play on the playground are the number one cause of playground related deaths. We know that projections of specific sizes and shapes can impale a falling or moving child causing many different types of injuries. We know that sharp points or edges cause lacerations. We know that heavy suspended moving components that come in contact with the user’s body, especially their head, can cause serious brain injury.
How we approach these known causes of serious injuries which fit within the medical profession’s measureable definition of debilitating or life-threatening is our challenge. We cannot look into a crystal ball and predict with any certainty the future but we have learned from the past and must act responsibly. Now is not the time to go back to some of the design practices of the past for the sake of new product design, especially when the past has shown time and time again the unintended consequence of an unsupervised child’s reasonable foreseeable behavior. That is the real challenge to play equipment designers, manufacturers, and playground standards writers.
Do you have the ability to assess the play environment and the equipment within this environment during the play area design process and ultimately come to a reasonable balance between safety considerations and the need for challenge and risk in a child’s play environment? That should be our main objective. If we do not get this right, children will find what they are looking for in places with far more hidden dangers and risk of harm than should exist in any well designed playground.

For these reasons the ASTM F15.29 Subcommittee is working towards a hazard based approach to reduction of those injuries deemed unacceptable to society as a whole. Julian Richter, founder of the German playground equipment company Richter Spielgerate GmbH, said it best, “We should have as much play value as we can possibly afford, but only as much safety as is necessary.”
More on the status of this approach to standards writing in future columns.

Part 2 of 3 – Hazard Based Approach to Standards Development: The time is now.

December 31st, 2015

Part 2 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

Food for Thought from the US Consumer Product Safety Commission Staff

“Playgrounds should allow children to develop physical and social skills, and part of that development includes testing the limits of their skills. Innovation is important for this, as children need new challenges. Staff believes it is important that new, innovative playground components should still follow the safety recommendations and standards that both CPSC staff and ASTM have worked to refine over the past several decades.” CPSC Staff May 20, 2013

“CPSC staff believes that focusing on the hazards posed by the equipment’s design or movement would address the issues of nontraditional equipment more appropriately than exempting that equipment from all but the most basic requirements.” CPSC Staff May 10, 2012

“CPSC staff believes that rather than exempting nontraditional equipment from most aspects of the standard, a more appropriate method of dealing with any issues of nontraditional equipment would be to focus on the hazards posed by the equipment.” CPSC Staff May 10, 2012

The May 20th CPSC staff letter requests ASTM create definitions for each different type of play equipment. CPSC points out neither the ASTM playground-related standards nor the current version of the CPSC Public Playground Safety Handbook (Handbook) currently define a “slide”. ASTM currently believes a definition for a slide that addresses each and every possible variation would become design restrictive and stifle innovation. Any definition that does not address each possible variation for a type of play event should not mean the equipment need only be required to meet the performance standards based on what name the product is called by the manufacture. I would rather propose conducting a risk assessment that goes beyond the merits of the product’s intended function and consider the reasonable foreseeable misuse of the product by the intended user group.

Intended Design Use of a Slide

Historically, the 1986 printing of the CPSC’s A Handbook for Public Playground Safety, Volume II, defined a “slide” as an “apparatus having an inclined surface used for sliding.” They have since stated the working definition for a slide used by the CPSC technical staff is,

” a flat or concave, inclined surface where children are likely to sit on their buttocks and slide down with their feet in front of them.”

This sounds like a reasonable definition for a slide and its intended use. I also think the use of the words, “likely to sit on the buttocks and slide down with their feet in front of them,” is a bit too narrow a description for how it has been used by children for more than 100 years. Where we start to get ourselves in trouble is when we try to create one-size-fits-all performance requirements for each inclined surface where children are likely to sit on the buttocks. Currently there are many specific performance requirements for a slide. Slide side rails currently have a performance requirement of a minimum of four inches. Why four? Why not three or six? Why any at all? This requirement came about based on the CPSC staff injury analysis going back more than 30 years. The CPSC said slide side rails would not always prevent a child from falling off the slide bedway. The primary function of the side rails were to provide an edge guide for the user’s feet or heals which would minimize lateral discharge as well as provide something for the user to hold onto for balance, if so desired.

Reasonable Foreseeable Use of a Slide

How did you use your old school playground slide? Did you every run up the bedway? Did you go down lying on your belly headfirst? Did you hook your legs around the person in front of you to create a kind of human centipede? Is this typical use or misuse. The new ISO definition for reasonable foreseeable use states the word “use” is synonymous with word “misuse.” This seems reasonable especially in the context of consumer products intended for use by children.

To make my point I would like to share a personal schoolyard experience as I remember it. I use to enjoy a very physical game of tag on our schoolyard. Understand this was in the late 1950s before there were any standards or guidelines. Our school had a 10 foot high free standing slide. I first started using this slide as defined and intended by the CPSC 1986 definition. This slide became so much more to us around the age of 9 or 10. We had mastered the sliding experience as intended and were now beginning to experiment and see what else we might be able to do with this traditional slide. It seemed so huge. It had two different types of diverging bedways. It had a double wide, open riser, step ladder up to a fairly large slide transition platform supported by metal support posts angling outwards to the ground. The platform had a guardrail to keep us from pushing someone off the platform. The slide had evolved into the arena for my friends and I to play tag. We seemed to be able to play on this one piece of equipment for hours on end or until someone got hurt. The latter was our signal to stop playing however it never stopped us from coming back another day and play the same game. This game had only a few rules we made up. Basically if you were tagged you were “IT”, until you could tag one of the other players. We moved at warp speed. We ran up the bedways. We went down the stepladder. Sometimes we went under the guardrail and down any one of the platform’s support posts to escape. I wonder if anyone considered some of these uses for this equipment. We did whatever it took to avoid getting tagged. I remember watching my friend use the stepladder handrails as a very steep banister slide. We did not see this as misusing the slide. We were just playing. It was exciting and great fun. Not everyone had the skills to do some of the things the stronger more experienced kids could do. This made them appear almost super human and impossible to catch. We learned a lot about our individual abilities and used that knowledge and skill to our advantage as part of the game. To us that double slide was so much more than just a slide. What started out as just a slide years earlier became a challenging super structure perfect for our game of tag. I wonder if designers ever considered observing how a bunch of 4th, 5th or 6th graders might actually play if they thought they were being left alone with no rules? This game of tag and the unintended, yet foreseeable, behavior it generated never occurred during school recess. Teachers would never stand for such careless and dangerous activity under their watchful eye. Guess what happened after school when all teaches left the building or on evenings and weekends when the area was unsupervised?

Unintended consequences of Reasonable Foreseeable Misuse of a Slide

The unintended consequences of the reasonable foreseeable misuse of any piece of playground equipment may result in something more than society is willing to accept. There is not much the owner and manufacturer can do about the lack of or improper supervision or inappropriate user behavior. The best defense against unintended consequences is for the manufacturer to provide and the owner to follow all inspection and maintenance recommendations to keep the area in compliance with best practices for public playground management.

The manufacturer has, at a minimum, specific information they must provide to the owner about the equipment intended users, installation, inspection and maintenance of their equipment. The owner must post at least the minimum required information and warnings. Since children most likely will not read or head the warnings and the caregivers often ignore them, what more should either party provide to their respective consumers beyond these minimum requirements to address the unintended consequence of reasonable foreseeable misuse?

Prescriptive vs Hazard-Based Performance Standards

CPSC staff has asked the F15.29 Subcommittee to recognize the recommendations in their Handbook and the requirements in the ASTM F1487 standard which are designed with respect to the hazards posed by the type of equipment. These requirements are based on a long history of injury statistics and analysis of injury patterns based on until now a very limited number of play equipment types that existed at the beginning of the playground safety standards movement. Times have changed and so has playground equipment. CPSC staff has recommended the F15.29 Subcommittee develop definitions for the equipment types listed in Section 8 based on the likely use patterns of children. Does this include just intended design use or does it include reasonable foreseeable misuse?

We both agree that definitions should ensure all new innovations meet the appropriate safety requirements yet foster continuing innovation in playground design. Broadly written or vague definitions leave too much open to subjective interpretation by parties with conflicting interests and objectives. The ASTM F15.29 Subcommittee has realized they cannot in a timely fashion, keep pace, with innovation within the playground equipment industry. Play equipment types and the multitude of variations for each type do not fit neatly into the basic playground equipment types that were available when the first playground standards were first being considered.
Regardless of what something is labeled we should consider taking the path as suggested by the CPSC but reword a bit to say, “playground safety performance requirements shall be developed and applied to focus on the hazards posed by equipment’s design, movement, and layout, whether free-standing or in combination with other components, and should address the issues of intended and reasonable foreseeable use rather than exempting that equipment from all but the most basic requirements.”

In Part 3 I will discuss how the hazard based process is applied.

Part 1 of 3 – Hazard Based Approach to Standards Development: The time is now.

December 30th, 2015

Part 1 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

Background Information on Developments within the ASTM F1487 Standard
On May 20, 2013 the ASTM F15.29 Subcommittee responsible for the content of the ASTM F1487 standard received a letter from the staff of the U. S. Consumer Product Safety Commission. CPSC staff noted that the specific types of playground equipment in Section 8 of the Standard (balance beams, climbers, upper body equipment, sliding poles, slides, swings, swinging gates, merry-go-rounds/whirls, roller slides, seesaws, spring rockers, log rolls, track rides, roofs, and stepping forms) were not defined in the terminology section of the standard. CPSC acknowledged the difficulty in defining these items but felt the lack of definitions may lead to differences in interpretations and application of the standard, resulting in some products not meeting the appropriate specific equipment performance requirements.

In May of 2012, the CPSC staff submitted a written comment on a ballot item that proposed to add a new Section 8.0 to ASTM F1487 to address new equipment designs not currently being addressed in specific performance requirements in the current Standard Section 8-Equipment and Section 9-Layout.

The proposed ballot item was to address all equipment does not fit neatly into the existing equipment categories or types. CPSC and ASTM agree, all non-traditional equipment not specifically identified in Section 8 still need to be evaluated using this standard. Everyone currently involved in writing playground performance standards understands industry innovation is moving at break neck speed. This is a good thing for children. The ASTM F15.29 Subcommittee wanted to minimize the likelihood of life-threatening or debilitating injuries from innovative non-traditional equipment by directing designers and manufacturers to apply all general performance requirements in all the Sections leading up to Section 8 of the standard and evaluate the equipment for any potential hazards.

CPSC staff has serious concerns about the implication of exempting all equipment, not of a specific type, from all of the equipment performance requirements currently contained in Section 8 and 9. CPSC staff believed this ballot item did not provide the guidance required to adequately eliminate or reduce the potential risk of injury from “non-traditional” equipment. CPSC staff believed this proposal provides a loophole that may allow potentially hazardous products to enter the marketplace. The basis for their concerns were spelled out in 3 points within the CPSC staff’s written comment to ASTM F15.29 Ballot F15 (12-03), Item 6, dated May 10, 2012:

“1. Section 8, Equipment, contains performance requirements for the following specific types of playground equipment: balance beams, climbers, upper body equipment, sliding poles, slides, swings, swinging gates, merry-go-rounds/whirls, roller slides, seesaws, spring rockers, log rolls, track rides, roofs, and stepping forms. The equipment types, however, are not defined in Section 3, Definitions. This leaves their definition open to interpretation and could allow equipment to be considered to pass the standard by a manufacturer, test lab, or consumer who asserts that the equipment was not mentioned specifically. For example, there is no definition for “balance beam.” If someone were to place a long, flat beam between two posts, 20 inches from the ground, could that person then claim it was not a balance beam because it is more than 16 inches from the ground, and therefore, covered by the proposed exemption? If the answer is “yes,” then CPSC staff strongly disagrees and feels this exemption would seriously undermine the spirit of the voluntary standard.

2. The “Climber” and “Upper Body Equipment” sections have generally served as the
“catch-all” categories for equipment that does not fit elsewhere. This exemption will allow equipment to avoid even those requirements.

3. This ballot item states that nontraditional equipment need only meet the “general performance requirements.” There is no section for “general performance requirements; however, Section 5, “General Requirements,” contains only three specific requirements limited to age grouping, anchoring, and small parts (15 CFR 1501); and Section 6 “Performance Requirements,” contains a limited number of performance requirements. As written, it is unclear how Sections 5 and 6 apply and whether Sections 9–15 apply at all.

CPSC staff believes that rather than exempting nontraditional equipment from most aspects of the standard, a more appropriate method of dealing with any issues of nontraditional equipment would be to focus on the hazards posed by the equipment. For example, one of the newer types of playground equipment, perhaps one considered by the subcommittee while discussing this ballot item, is an overhead spinner that children hold while spinning. The 1990 COMSIS report suggests that merry-go-rounds should be speed limited and that “the maximum allowable magnitude of centrifugal force must be less than or equal to the magnitude of force that the user is capable of supporting with his/her arms…”; and section of the voluntary standard requires a maximum velocity for a merry-go-round. Section of the voluntary standard requires that handgrip devices have a certain diameter to maximize grip strength of children. CPSC staff believes that these overhead spinning devices should combine these two requirements for overhead spinners, rather than exempting them from all but “general performance” requirements. In this example, staff believes it would make sense to have a section that applies to “upper body equipment” and “spinning equipment”; the overhead spinner would then be subject to both, while the merry-go-round would be subject to “spinning equipment” and perhaps a new section for “moving platforms.” CPSC staff believes that focusing on the hazards posed by the equipment’s design or movement would address the issues of nontraditional equipment more appropriately than exempting that equipment from all but the most basic requirements.”

The CPSC staff acknowledged over the past few years the design of playground equipment has undergone some radical innovations. They are in favor of innovations in playgrounds and believe playgrounds serve an important function in childhood development. They state in the letter,

“Playgrounds should allow children to develop physical and social skills, and part of that development includes testing the limits of their skills. Innovation is important for this, as children need new challenges. Staff believes it is important that new, innovative playground components should still follow the safety recommendations and standards that both CPSC staff and ASTM have worked to refine over the past several decades.”

The CPSC staff stated their concern with new innovations that are labeled as “climbers” and yet these climbers appear to be used by children as a sliding surface. Their initial concern with this type of equipment was the lack of time between when the product is released in the marketplace and the time required to create any kind of reliable injury statistics specifically pertaining to what may be considered by some as slides and labeled as climbers by a designer/manufacturer. Another issue they raised was how these new designs are identified, categorized, and finally entered into the National Electronic Injury Surveillance System (NEISS) database by someone with little or no experience in all the current types and variation of public play components. The NEISS system has been around a long time and this coding system may need to be looked at again for its relevance to today’s circumstances. The current coding system makes it difficult for the CPSC to differentiate data for these products from that of traditional slides. CPSC staff was made aware of incidents described as involving slides (such as “slid off side of slide,” “fell off slide while sliding down”), yet further investigation revealed the product involved was called or labeled as a “climber. Our major concern with trying to define these new types of play equipment is the definition needs to be very vague to not become design restrictive beyond the intended design use. The problems arise when the standards writing organizations begin to try to create performance specifications that are not design restrictive yet still address the injury patterns on a particular type of play event. It seems to me that what we call something is not the answer. The bigger issue seems to me to be how the users play and interact with it that is most important when it comes to the assessment of safety issues versus the need for challenge and risk in the play environment.
Many of us may remember a product labeled by almost everyone in the industry as a “banister slide.” They are still being sold today. Jay Beckwith recently pointed out in his Playground Professionals column that during the R and D on this component the designers/manufacturers asked, “How are the kids supposed to use this?” His response was something like don’t worry, they will figure it out. The point is, we cannot will a child to do anything the same way each and every time in an open free play environment. Once they figure out how they can use it, which may be the designer’s intended design use, they will master it. Then when boredom sets in they will begin to look for other ways to interact and use it the next time, and the next time after that, and so on. Usually this kind of process and experimentation evolves into more risky play behavior as the user’s desire to experience the thrill of the challenge. I challenge you to go out and play and try this little experiment. Go to a local playground that has a balance beam. Walk across a balance beam once or twice. Then try it again with your eyes closed. Which was easier? What were you thinking when you had your eyes closed? Could you do it? Did you peek? Were you scared? Did you feel your pulse rate increase? As we get older our desire for this kind of excitement unfortunately begins to dwindle but not in children. Most thrive on this kind of excitement and challenge. Imagine this same “balance beam” experience if the designer places a properly designed handrail on each side of the beam. It would be much safer and almost guarantee a successful outcome regardless of your balance skills or whether or not you had your eyes closed. Building codes and ordinances take this approach for the health and safety of the general public in residential, public institutions and commercial buildings. This is not the approach to be taken in the design of a public playground or the development of playground safety performance standards. We want as much safety factored into the design as necessary but as little as possible to address debilitating and life-threatening injuries. The concept for “not too much and not too little” causes the angst being felt by playground owners, designers, manufacturers and all who inspect, maintain and repair these facilities. Injury data has led to some play components requiring handrails and handgrips on access components and guardrails and barriers on platforms above a certain height. Have we gone too far? Does anyone think a child would find a balance beam with handrails challenging or fun? I think the child is more likely to climb up on the handrails and attempt to walk across them. I would call this “unintended design use” or “reasonable foreseeable misuse” with “unintended consequences.” Ultimately we come back to the point of determining how much safety or risk is enough and how much of either is too much.

Play equipment definitions versus its intended use and reasonable foreseeable misuse

Is a banister slide really a slide? Is an inclined board of say 20 degree slope constitute a slide in the traditional form? What slope is necessary before you truly can have any kind of meaningful sliding experience? If this board doesn’t have a point of reduced gradient or 4 inch side rails with proper slide exit heights and transition platform of at least 14 inches deep does it mean it is not a slide? This gets to the CPSC staff’s concern. How does an inspector evaluate a piece of equipment when it does not meet all the requirements for a specific piece of equipment based on what the designer calls it or what an inspector labels it? I would agree that a slide with only 20 degree slope would not be used for sliding as much as it might be used for climbing. What slope is required before a child will involuntary begin to slide down the surface because of gravity?
In Part 2 I we will look at the CPSC’s traditional definition of a slide and the reasonable foreseeable misuse of the slide from a child’s perspective. I will present some options to consider on how to evaluate a piece of equipment regardless of labels.

Access to Play for All 101

June 16th, 2015

Access to Play for All 101
by Kenneth Kutska, CPSI, Executive Director, IPSI, LLC
April 13, 2015

The following is part of a presentation made to groups in Hong Kong and Singapore who were interested in accessible and inclusive playground design. November 26, 2012.


Barrier Free Accessible Design Requirements + Inclusive Design Principles + Thorough Safety and Risk Assessment + Accurate Plan Implementation + Ongoing Compliance Management and Practice = Universal/Inclusive Access for All

This presentation will address more than the minimum requirements necessary for barrier removal as we start to investigate the impacts the principles of inclusion and universal design have on the usability of the play environment. These principles should be addressed through the planning process of any new play area. If the basic principles of inclusive design are adhered to from the very beginning of the planning process the end result should be greatly improved. One size fits all planning approach does not always work for everyone. We have learned that by involving the general public and other stakeholders in the design process it will not only improve access but it will provide help assure the basic principles of inclusion are addressed.

I follow this remark with my interpretation of the play area design process. I will explore some of the terminology that has evolved over time and is commonly used throughout the design process. The presentation will explore the practice of accessible design as found in the USA DOJ 2010 Standard for Accessible Design. We will then explore some of the more recent work and philosophy of the National Center on Accessibility at Indiana University and the Boundless Playground organization. Both organizations have embraced the principles of universal design established in 1997 by North Carolina State University School of Design and principles for inclusive design in their work throughout the USA.

In conclusion we will introduce an Inclusive Design Guide to help with the implementation process for inclusive design. This document was created in 2012 under the coordination and funding of Playworld Systems Inc., a play equipment manufacturer in Pennsylvania. The project team was comprised of Playworld staff and ADA advocates. Each participant brought their diverse skills, experiences, and knowledge in various disciplines such as; planning, child development, inclusion, accessibility, and barrier-free design.

If you have not already started to evaluate all your existing playgrounds for current compliance to the minimum requirements of the Department of Justice 2010 Standard for Accessible Design then there is no better time to start then today. Step 1 is to evaluate each and every playground to see if you have a compliant accessible route to each and every accessible play component to meet the minimum Standard requirements. Creating and maintaining the accessible route to and through the play area will be your biggest challenge. I have created a checklist to assist in this this initial task. I have used this checklist to conduct field assessments of play areas as part of my presentation. If anyone is in need of such a checklist they can contact me for more information.

Milestones to Access for All – Historical Perspective

Milestones such as the Architectural Barriers Act of 1968, Section 504 of the Rehabilitation Act as amended in 1978, and the Americans with Disabilities Act of 1990, and the combination of these documents to create the Americans With Disabilities Act Accessibility Guidelines (ADAAG) of 2004, have raised expectations across two or three generations of United States” consumers with disabilities seeking opportunities to improve healthy living through leisure pursuits. Now with the final rule becoming the law of the land in the USA the United States Department of Justice 2010 Standard for Accessible Design is the new measuring stick for evaluating compliance to this legislation. Understanding the law and being able to apply the requirements is a major concern of most people and organizations impacted by this wide reaching legislation. Once everyone understands what the law says they can begin to better implement the intent of the law. This was the vision accessibility advocates had for the implementation and enforcement of the law however it can be argued the results thus far may be less than envisioned. Access to and through the man-made environment has unquestionably been improved however the idea that there is equal access to all environments with equitable, flexible, simple, easy, safe use by all is not being achieved to everyone’s liking. The law, as with most legislation, must be black and white otherwise the words become nothing more than a government recommendation with no enforcement provisions if you do not comply. The law sets minimum requirements that must be met. Often these requirements are established through debate and compromise of all people invited to participate. The USA experience was a very open public process. Those who were not able to participate on the main committee had multiple opportunities to make public comment in writing or in person as all meetings were open to the public. Unfortunately for some advocates, with compromise comes a watered down version of what might have been envisioned. It is a perception that most regulations have financial consequences on commerce and therefore consideration should be given throughout the process so the regulations do not become financially burdensome to commerce.

The Evolution of the Access for All Movement

Barrier-free design has given way to accessible design which has embraced the concept of more inclusive design and/or a more universal design concept. Inclusive design and universal design are used synonymously however I believe there are significant differences. Both concepts attempt to address the civil rights of all people to have equal access to publicly funded things and programs including private enterprises that invite the general public into their facilities and programs. Examples might include a hotel, restaurant, amusement park, school or public library. The difference in the interpretation of these terms, although subtle, will become clearer through my interpretation and comparison of these terms. I am going to use a technology analogy to explain the difference. To me, the term “Universal Design” is a “Hardware Issue” and the term “Inclusive Design” is more of a “Software Issue”. Universal design is the application of barrier free design principles that foster individual independence to access all aspects of their day to day environment.

This idea or concept of Universal Design was more or less the beginning of the Americans With Disabilities Act (ADA) in 1990. The ADA took the Architectural Barriers Act (ABA) of 1968 to a new level as we began to look beyond barrier free access issues to and through the public indoor environment and take it to all outdoor environments and facilities. Accessibility advocates were empowered through the ADA legislation to look beyond barrier free design principles to address equal and independent access to programs and functions of our public facilities and institutions. I believe this began the “Inclusion Movement” that has fostered many architects, land planners, and ADA advocates looking beyond the “Hardware Component” and start to focus on the “Software Component”. The software or inclusion aspect of the ADA movement goes beyond barrier free access and design and begins to address the emotional heartfelt philosophy of not just equal access but integrating all people, regardless of their physical and cognitive abilities, into the mainstream of everyday independent living. Asking the users what they want and need is an important part of the design process. The inclusive movement has only been brought into practice over the past 10 to 15 years as we have evolved through individual experimentation and the sharing of ideas that works best.

Designers who practice the implementation of barrier free architectural design alongside inclusive mainstreaming program practices appear to be more successful in addressing the individual developmental needs of all people regardless of their challenges. Living your life as independently as possible and experiencing the simple day to day challenges in a dignified inclusive environment is best for all of society. The inclusive design concept is not an exact science rather it is an evolving art form. This heartfelt philosophy or “Software Component” of inclusive design is learned and will improve over time through continued practice, observation, experimentation, and multi-discipline training. This design concept continues to evolve as we learn more and more about the access challenges and day to day needs people face throughout their lives. Addressing day to day challenges people face is very important but all people face different developmental challenges and require and desire additional challenges and opportunities that stimulate further development and well-being. By applying inclusive design principles we add meaning and independence to their life. Landscape Structures Inc., another play equipment manufacturer in the State of Minnesota U.S.A., posted on their Web site,

“There are three components to a higher level of inclusive play: physical accessibility, age and developmental appropriateness, and sensory-stimulating activity. Combined, we will create an inclusive play environment that meets the needs of all children in the same place in a variety of ways. One group of children we must accommodate is the rapidly growing population of children with Sensory Processing Disorders as well. A higher level of inclusive playgrounds invite children of all abilities to play and imagine together – making them equal through play.”

This new and emerging philosophy is finally beginning to move the “play for all” discussion beyond the practice that minimum compliance to barrier free design is enough. Some question the cost to go beyond the minimum even though access and inclusiveness might be improved. This same reasoning is being applied to safety and performance requirements in play equipment design when designers consider impact attenuation surface system compliance. The myth and argument that accessibility and safety requirements add excessive cost to the project continues especially when an agency goes beyond the minimum design requirements. Some cost will be added but it does not always cost more and/or pose a financial hardship.

It is time to get beyond these perceived barriers of excessive regulatory compliance and cost? This discussion needs to continue and involve more stakeholders. The implementation of the inclusive design principles is the more heartfelt and passionate approach to play area design for all.


Like all good chefs, their secret to success is the thoughtful application of their acquired culinary knowledge and skills. A chef works hard over time to perfect their abilities and their recipes through their own experimentation or the knowledge gained from other chefs. They also learn and improve their craft from their own mistakes but hopefully a lot more successes. Top chefs are relentless in their search for something new and better than before. This too can be said for those of us who are practicing the art of inclusion as it applies to meeting the design objectives of a child’s play space. Since play is an important aspect of early childhood development it must be taken seriously. Play is the work of children and so is design for play the serious work of play area designer. Providing equal access to meaningful play for all while still meeting the developmental needs of each child can create both conflict and opportunity within the total play environment. Another concern resulting from the design for easy access throughout the entire play area is the safety of young children who now will have the access to equipment that is not age appropriate for their ability. This can be avoided with proper adult supervision but the safety concern is real. I believe the benefits of access for all outweigh the risk of unsupervised children in the play area. There are consequences all people face in their day to day life regardless of age. Children need to learn some of these important life lessons on a properly designed play space along with or without parental supervision. It is not fair to all concerned to deny access to play for people of all abilities because of the risk of injury due to a lack of or improper supervision. These safety issues cannot be ignored but they should not stifle the design process. Designing a truly inclusive play area requires knowledge and expertise in many disciplines and playground safety issues are just one part of the equal access for all equation.

In keeping with my previous analogy of top chefs and their recipes, I cannot help but use one more culinary reference to make another point. There is an old saying, “too many cooks spoil the broth.” The universal inclusive design process for public play areas serving all people should ignore this saying. In the inclusive design process the more chefs the better. Each chef (planning committee member) has their own set of skills and experiences that when blended together can result in something magical.

The recipe for equal access for all people requires a combination of different but similar concepts and processes. When properly executed in a fair and thoughtful manner the result is a better design solution. Good design starts with the planning process but there must be flawless execution and follow through. This includes the plan implementation and continues throughout the life expectancy of the project to truly be successful.

Public safety is one of the most important responsibilities of any government agency and it includes both the design process and the ongoing management of all public facilities and programs. Equal access for all people is just as important in all design considerations as public safety. The Chef’s (Designer’s) skillful combination of these two ingredients are required to make any good soup (Inclusive Play Area for All).

Combining best design principles and practices which address and eliminate known safety issues and architectural and program barriers should result in a safe, accessible, and inclusive facility for all.


START WITH: The Need for Accessible Play Opportunities for All

Known public playground safety standards, guidelines, and best practices (ASTM F1487, 1292, 1951, 2223, 2479 and U.S. Consumer Product Safety Commission Handbook).

THEN ADD – Barrier Free Accessible Design Requirements (ABA/ADA now DOJ 2010 Standard),

ADD – Inclusive Design Principles (NCA and Boundless Playgrounds),

COMBINE WITH – Universal Design Principles (NC State University) – MIX THOROUGHLY

ADD – Accurate Plan Implementation (Owner’s responsibility, good plans and specifications),

BAKE UNTIL DONE (Owner puts project out to bid to pre-qualified suppliers and contractors)


MUST CONTINUE Ongoing Compliance Management and Practice (CPSI Certification Course and Playground Maintenance Technician Course)


The planning effort should ultimately create an attractive functional public space that embraces universal design principles resulting in an inclusive children’s play space accessible to all.


ACCESSIBILITY: The design of the play space and surrounding environment as it relates to the users and caregivers getting into, around, and out of the play area.

ACCESSIBLE PLAYGROUND: As defined in ASTM F1487-11 Standard is a playground equipment area, that, when viewed in its entirety, may be approached, and entered and provides a range of play opportunities.

ACCESSIBLE ROUTE: An Americans With Disabilities Act (ADA) term referring to the pathway within the boundary of the site which provides access for individuals with disabilities including those using wheelchairs or mobility devices; from public transportation stops, accessible parking, accessible passenger loading zones, and public streets or sidewalks to the play activity. The accessible route shall, to the maximum extent feasible, coincide with the route for the general public.

ACCESSIBLE DESIGN: Accessible design means the design meets the minimum accessibility standards.

BARRIER FREE DESIGN: A design that has removed common obstacles limiting the use of an area based on some accepted accessible design principles and practices which create safe unobstructed access. Barrier Free Design is the precursor to universal design. Inclusive design has become interchangeable with universal design.

UNIVERSAL DESIGN: Universal design goes above and beyond the standards (Accessible Design) in a way to meet the widest spectrum of users, including those that may not necessarily meet the definition of disabled to benefit from the accessible design such as children and aging adults. Universal design was developed by a consortium of individuals with 7 guiding principles.

INCLUSIVE DESIGN: The ability to include all people – children, adults, and seniors, regardless of physical or psychological situation and provide everyone of all abilities access and the opportunity to move throughout and use the space safely and independently.

An inclusive playground addresses the safety and independent needs of all people including those who have autism, intellectual disabilities, hearing impairments, cerebral palsy, spinabifida and other disabilities. It also addresses the needs of children who are typically developing. An inclusive playground includes everyone and challenges them at their level.

PERSCRIPTIVE DESIGN: Prescriptive Design is the design of a piece of equipment or environment specific to a small user group or individual and based on a remedy to minimize or compensate for the group’s or individual’s functional limitation.

PERSCRIPTIVE PLAYGROUND DESIGN: Public playgrounds are designed for specific age groups, i.e. toddlers (6 through 23 months), per-school (2 through 5 years) and school age (5 through 12 years). Each play area is required to meet the developmental needs of a specified age group based on developmental abilities and needs of that target age group. One size does not fit all. If the designer incorporates universal design principles while applying accessibility standards the playground may be accessible but not necessarily usable by all for developmental reasons. In addition, there are safety compliance issues that must be addressed due to the needs and abilities of individuals within the intended user age group. Prescriptive use, accessibility standards, universal design principles and safety standards for public play areas are often counterproductive to one another. A risk assessment should become a part of the planning process to help balance accessibility, safety compliance, universal and inclusive use, while still providing multiple levels of challenge to address the developmental needs of the intended user age group.

INCLUSIVE PLAYGROUND DESIGN GOAL: Provide a rich, inclusive play space where children of all abilities can grow and learn through physical, emotional, sensory, and social experiences.

Accessible design and universal or inclusive design terms are NOT interchangeable. Here is a link that explains the difference between these two terms on the (NCA) National Center for Accessibility Web site.

“The public playground is, by far, one of the most important settings for child development. It is one of the few environments where a child has the freedom to run and jump, climb, swing and leap, yell, reign, conjure, create, dream or meditate. In this complicated world that we live in, the playground is a safe and common place for children to come together, to discover the value of play, to learn about each other, to recognize their similarities and differences, to meet physical and social challenges, to leave comfort zones and evolve into the little young people they are meant to be. It is a microcosm for life lessons, from challenge and risk to conflict resolution and cooperation. When we design for these purposes and apply the Principles of Universal Design, we design for inclusive play where every child, regardless of ability or disability, is welcomed and benefits physically, developmentally, emotionally and socially from the environment.” J. SKLULSKI, NCA, UNIVERSITY OF INDIANA


• Seven Principles of Universal Design by NC State University School of Design

Universal design was systematized in 1997 in the USA during the Civil Rights Era and represented a distillation of our communal demands for social inclusion. Legislative efforts in the USA have not been deemed adequate guidance to complete institutionalization of Universal Design.

Legislation and regulation must by their nature clarify the specifications of a final physical product. Universal design is rather a design approach and not some absolute one size fits all solution, measurement, or product.
These seven principles also serve to orient the entire project (concept, scope and specifications) around the observation that human beings occur with a wide range of ability sets that also change over time.

STEP 1 – Equitable Use: The design does not disadvantage or stigmatize any group of users.

STEP 2 – Flexibility in Use: The design accommodates a wide range of individual preferences and abilities.

STEP 3 – Simple, Intuitive Use: Use of the design is easy to understand, regardless of the users’ experience, knowledge, language skills, or current concentration level.

STEP 4 – Perceptible Information: The design communicates the necessary information effectively to the user, regardless of existing conditions or the user’s sensory abilities.

STEP 5 – Tolerance for Error: The design minimizes hazards and the adverse consequences of accidental or unintended actions.

STEP 6 – Low Physical Effort: The design can be used efficiently and comfortably, and with a minimum of fatigue.

STEP 7 – Size and Space for approach and Use: Appropriate size and space is provided for approach, reach, manipulation, and use, regardless of the user’s body size, posture, or mobility.

NOTE: These principles were compiled by advocates of Universal Design in 1997 and are copyrighted to the Center for Universal Design School of Design, School of Design, University of North Carolina at Raleigh, USA.

• Boundless Playgrounds –
The Boundless Playgrounds Inclusive Design Philosophy accounts for the physical site and the user needs like in Universal Design. At Boundless they looked at inclusive design as a combination of children’s play behaviors, removing the architectural barriers, and applying the universal design principles. Their design process applies the following eight performance criteria.

Eight Principles for Inclusive Design by Boundless Playgrounds

1. Absence of architectural barriers—a socially inviting, barrier-free environment

2. Developmentally distinct play areas supporting the predictable play behaviors of children

3. Diversity of movement sensations and experiences

4. Many loose manipulative parts and natural materials in the playground for children to use during each engaged play episode

5. Opportunities to play autonomously, alongside and with peers

6. Provision for experiencing height, being up high and viewing the world from an elevated vista

7. Addition of semi-enclosed spots

8. Rigorous and challenging places to play

• Inclusive Playground Design Guide – 2012 Playworld Systems, Inc.