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, 2011A 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.