Archive for December, 2013


Friday, December 13th, 2013

Step 2 – Whose Path of Action is Most Realistic and Reasonable to Measurably Reduce Serious Injury?

By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
November 30, 2013

Which came first? The chicken or the egg. Man has been pondering this question forever and now I feel like I am in the middle of the same conundrum with regards or performance requirements for play equipment versus performance requirements for impact attenuation surfaces within the play equipment use zone.

The answer from ASTM F15.29 Subcommittee’s perspective with regards to the future direction of the F1487 standard is not so easy. Our Subcommittee has never been able to identify and analyze each and every piece of play equipment prior to its entry into the marketplace. We continue to struggle with coming up with specific equipment requirements not addressed by the general performance requirements for each of these play components in a timely fashion. My simple answer to this question is, “Not in my lifetime.”

The staff of the U. S. Consumer Product Safety Commission (CPSC Commission) presented a letter addressed to me as Chair of the American Society for Testing and Materials (ASTM) F15.29 on May 20, 2013. This letter was a follow-up to a written comment dated May 10, 2012 from CPSC staff regarding the F15.29 (12-03) ballot item #6. In this letter, it was noted that the specific types of playground equipment in section 8 of the ASTM F1487 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) do not appear in the definition section of the standard. CPSC suggested we define these types of equipment in the terminology section of the standard.

The ASTM F15.29 Subcommittee discussed this letter during the May 20, 2013 meeting. The discussion continued into our Working Groups breakout sessions. The Subcommittee members in attendance concurred with the CPSC staff’s findings that it is difficult to keep up with the marketplace and define these new items in any timely fashion due to the speed at which the industry introduces new product into the marketplace from around the world. While the CPSC staff feels the lack of more definitions to address new variations of play equipment may lead to differences in interpretations of the standard resulting in some products not meet the appropriate performance requirements of the ASTM F1487 Standard. As a CPSI Course Instructor, I receive questions from CPSIs conducting compliance audits on how to evaluate these new products. The NRPA CPSI Course suggests a common sense approach to this dilemma as part of the course curriculum. The curriculum says we should not be claiming something is not compliant with the ASTM voluntary industry standard just because it does not fit into one of the existing types of specific equipment performance requirements. This approach does not appear to go far enough for everyone concerned. So what should we do? The purpose of the standard is to protect the children by eliminating known hazards and reduce or even eliminate serious debilitating injuries and death. I think we can all agree we have made significant contributions to this end however there will always be some serious injuries and even deaths and they may occur on a perfectly standard compliant playground. Can anyone protect everyone from every possible accident or a child’s own unreasonable actions?

Do you think it is reasonable and responsible to expect ASTM or CPSC to attempt to define each and every play component and/or variation of each type along with related additional specific equipment performance standards? The current playground equipment catalogs from around the world compared to those of just ten years ago demonstrate how many new play opportunities have been created. Many of these were never contemplated when the CPSC created their first handbook for public playground safety in 1981. The CPSC and the ASTM have been playing catch-up ever since the first standards and revisions of the 1990s. I have to ask if such a massive undertaking would do if anything for the prevention of serious playground injuries. I also have to ask whether the CPSC’s request would be considered a step towards improved equipment performance requirements or a step towards restricting or dictating design.

In a draft letter to all members of ASTM F15.29 Subcommittee I expressed my belief that any attempt to define each and every type or variation of play component is impossible if we are to stay within the scope of our performance based voluntary industry standard. ASTM F1487 is not a design standard even though we seem to arrive at this notion within the current standard on certain specific equipment types. During informal discussions and at our November ASTM F15.29 meeting some suggested our efforts to implement the CPSC Staff’s recommendation, while well intended, would become a time consuming and very expensive exercise in futility and an impossible process to strategically manage. This process will end up costing ASTM Subcommittee members an enormous amount of human and financial resources and we would never ever get to all the different types before new types of play components enter the marketplace. The ASTM democratic balloting process used in standards development is open and participative democratic process and therefore it is a lengthy process. It would take years of commitment and effort to accomplish such a task on the backs of volunteers, many of whom spend their own resources to participate in the standards development process. We have to ask what will have been accomplished in the short term, say two or three or even 5 years down the road, to reduce the frequency and severity of serious injuries? I first suggest we evaluate what measureable reduction in the frequency and severity of NEISS reported injuries has occurred over the past twenty years.

I predict that if we implement the course of action being suggested in the May 20th letter the ASTM F1487 standard and CPSC Handbook will become even more design restrictive while not addressing the existing hazards which result in truly serious injuries as defined in the ISO TC83 Committee’s technical paper on terminology. While this report has not been published I can see that it has gathered much international consensus and could give us something tangible to use as we attempt to focus on the big issues, such as life threatening and permanently debilitating injuries.

The ASTM F1487’s scope states,
“This consumer safety performance specification provides safety and performance standards for various types of public playground equipment. Its purpose is to reduce life-threatening and debilitating injuries.”

So where are we today in reducing these types of injuries? I believe we have made progress in reducing deaths and debilitating injuries in public playgrounds primarily in the area of head and neck entrapment and entanglement but I do not see a reduction in the frequency of injuries being tracked by the CPSC. Based on the fact that CPSC and the NEISS injury data reflect little or no reduction in public playground injuries it suggests we might be approaching the injury prevention issue from the wrong point of view. We seem to continue on the same path of trying to close the barn door after the horse as already left.

CPSC states that over the past few years the design of playground equipment has undergone some radical innovations. In general, we all need to make sure that known safety standards are being addressed. Both ASTM and CPSC support innovations in playground equipment and believe playgrounds serve an important function in childhood development. The CPSC Staff stated it so well in their May 20, 2013 letter,

“playgrounds should allow children to develop physical and social skills, and part of that development.”

We can both agree new, innovative playground components should still follow the safety performance recommendations that both CPSC staff and ASTM F15.29 Subcommittee have worked to refine over the past several decades. We both can agree with the CPSC statement,

“Staff asks that the subcommittee recognize that the recommendations in the Handbook and the requirements in the standard are designed with respect to the hazards posed by the type of equipment.”

We also agree with the statement in the CPSC Handbook, Section1.6,
“Because all playgrounds present some challenge and because children can be expected to use equipment in unintended and unanticipated ways, adult supervision is highly recommended. The handbook provides some guidance on supervisory practices that adults should follow. Appropriate equipment design, layout, and maintenance, as discussed in this handbook, are also essential for increasing public playground safety. A playground should allow children to develop gradually and test their skills by providing a series of graduated challenges.”

Section 1.7 Playground Injuries states,
“The recommendations in this handbook have been developed to address the hazards that resulted in playground related injuries and deaths. The recommendations include those that address:
• The potential for falls from and impact with equipment
• The need for impact attenuating protective surfacing under and around equipment
• Openings with the potential for head entrapment
• The scale of equipment and other design features related to user age and layout of equipment on a playground
• Installation and maintenance procedures
• General hazards presented by protrusions, sharp edges, and crush or shear points

Section 2.4 Surfacing states,
“The surfacing under and around playground equipment is one of the most important factors in reducing the likelihood of life-threatening head injuries. A fall onto a shock absorbing surface is less likely to cause a serious head injury than a fall onto a hard surface. However, some injuries from falls, including broken limbs, may occur no matter what playground surfacing material is used.”

All this being said I personally suggest the ASTM F15.29 Subcommittee, responsible for industry performance requirements for public playground equipment, spend its time promoting child development through innovative challenging play opportunities following best industry performance specifications and not focus on trying to identify and define each and every type of equipment including all the variations as CPSC recommends in their May 20 letter. I would suggest our time be best spent on continuing our efforts towards a hazard based approach to addressing a measureable level of injury reduction based on the current NEISS injury data analysis and the ISO definitions for hazard based risk assessment and the definition of serious injuries based on accepted medical analysis.

What would help with either of these recommended courses of action are universally accepted definitions and descriptions of a level of injury we can all agree on and relate efforts for reduction of these injuries back to our standard’s scoping statements. This would better define our mission and the types of injuries the standard performance requirements are attempting to address. I believe this course of action best supports child development and supports more innovative equipment that challenges children at all levels and advocates for healthy risk during free play. The course of action taken should also support those playground owner/operators who are attempting to create such creative challenging spaces while giving equipment manufacturers and designers the freedom to meet the markets expectations without restricting international free trade. Limiting liability to all for unreasonable misuse is something that needs to be addressed if we are going to successful in this endeavor. In Germany, parents have a legal obligation for the health and safety of their children and if their children are injured they will be held accountable. This sounds very reasonable to me and something North America needs to promote.

The standard development process the ASTM F15.29 Subcommittee has successfully embraced, over the past few years, is to address serious injuries through a thoughtful playground equipment safety performance based analysis following a strict hazard based approach to known hazards and current injury patterns. Risk assessments should be conducted by trained and experienced playground designer/manufacturer that looks at not just the intended design use but reasonable foreseeable misuse. We soon will have a set International Standards Organization (ISO TC 83) terms and definitions that will have been accepted by the international community. Many international standards organizations contributed to the development of this list and definitions and I hope to be able to release this list once approved. These terms will help guide the risk assessment process used by the designer, manufacturer, and perspective buyer of public consumer products developed for use by children under the age of 14. Play equipment is just one of these products. I hope these terms will be used by those involved in conducting safety compliance inspections of public playground equipment areas and organizations responsible for the creation of playground safety standards and guidelines.

The one missing link in reducing serious injuries on playgrounds might just be the impact, or lack thereof. ASTM F1292 Standard has had on the reduction of the frequency of falls related injuries. ASTM F15.29 follows ASTM F8.63 Subcommittee’s ASTM F1292 Standard as created and modified by this Subcommittee. This Subcommittee must be an integral partner in the future plan of action between ASTM and CPSC. Leaving out the impact attenuating playground surfacing requirements in future discussions will more than likely result in no meaningful reduction in serious injuries. The challenge is for all involved to come to some agreement on what the surfacing impact attenuating thresholds used in the ASTM F1292 standards should be. What need to understand what this outcome will be with some level of assurance that predictable falls from play equipment to the surface will provide enough energy absorption to address some predetermined level of injury likely to occur from the play equipment’s fall height.

Next month I will discuss the type and severity injury we can likely expect when falls occur to surface systems currently compliant with the ASTM F1292 Standard and how this relates to the level of injury ASTM F1487 performance requirements are attempting to address.

CAN WE ELIMINATE SERIOUS INJURIES THROUGH LEGISLATION? Part 2, Step 1 – International Standards Embracing Playground Surfacing Compliance Test Method

Friday, December 13th, 2013

Step 1 – International Standards Embracing Playground Surfacing Compliance Test Method
By Kenneth S Kutska, Executive Director
International Playground Safety Institute, LLC
October 23, 2013

In Part 2, I will discuss whether the laboratory test is even needed and should there be mandatory compliance field test requirement after installation and then consider follow-up testing at some reasonable interval thereafter.

I would like to go back to my participation in the TUV Austria Conference in Vienna October 23, 2013. Not every participant was of the same opinion on how the EN1177 standard should be revised. Some of the participants thought there was no improvement needed to the current playground surfacing standards. Some suggested there was no need to make impact attenuation requirements more restrictive. To paraphrase what I heard during the meeting was the existing requirements go too far in trying to protect children from themselves. The overall impact of well-intended adults recommending improvements to this existing surfacing standard are taking away a child’s opportunity to develop risk assessment and problem solving skills that evolve when children encounter challenging play events. This would be problematic for those following the CPSC Handbook and/or ASTM F1487 when considering requirements for a three dimensional net climber whose fall height might go far beyond the EN1177 – 3 meter (10 feet) maximum fall height. The individual went on to say the element of fear is important and brings about a different kind of play and learning experience.

While we might all see the importance of this point of view a compliant surface system which absorbs most of the energy of the falling child is a better approach rather than the child’s body absorbing most of the energy. I think we can all agree most children are very capable of using these kinds of play components without falling to the surface. In Europe, these large climbing nets have been around more than thirty years. These climbing net manufacturers state there is little or no injury data on falls from these climbing nets and this may very well be the result of the above discussion of how fear and risk assessment by children can change the way they play. We might also expect similar injury free results for most fit, agile, and athletic children, but what about those who may not possess those traits at this moment of their life. We are all unique individuals. We each develop at our own pace. Most of us were not fortunate enough to become the biggest, strongest, and smartest of our peers. Never the less, every one of us deserves the opportunity to experience the developmental benefits of play. So what would you do or say or do if your child was one, of the unfortunate few, who fell onto the playground surface and suffered some serious head injury?

Playground surface system performance can be compared to a seatbelt in your car. How many of us ever use them? We must buckle up whenever we drive but most of us never have an accident that would require the use of the safety belt or the car’s airbags. Both of these passive safety systems are there to protect us from the probability of suffering a life threatening or permanently debilitating injury if we are involved in an automobile accident. If we put this passive safety system concept into practice within the public playground environment the manufacturer and owner/operator should expect children to interact with challenging play equipment in unintended ways. Children continue to experiment outside their known; physical, emotional, social and cognitive capabilities and sometimes the child is not successful in completing a task. It is not reasonable to expect 100% success when a child undertakes a challenging activity. Some rate of failure is inevitable and some failure should be acceptable as part of child development as long as the resulting consequences remain within the limits of a societal norm. What is the acceptable severity of injury we are all willing to accept in our safety standards scoping statements? Once this question is answered we should be able to better evaluate the performance of the play equipment and the impact attenuating surface system under and around the play equipment where falls off the play equipment are likely to occur..

This seemed to be THE question of the entire week during the November ASTM Committee meetings in Jacksonville Florida. Falls continue to be the number one cause of injuries on public playgrounds and this fact has not changed ever since the CPSC began gathering and analyzing injury data.

If we are ever going to make some progress in reducing the frequency and severity of fall related injuries we need to define, to some measurable degree, the type and severity of these types of injuries. The ASTM standards groups are in the process of taking this next step. Regardless of where we are in ASTM F1487, changes to the surfacing F1292 performance requirements will potentially have the biggest impact on reducing frequency and severity of serious fall related injuries. Unfortunately the scope of the ASTM F1487 standard does not appear to address the severity of injuries currently identified within the scope of both ASTM F1487 and F1292 standards. More cooperation between these two ASTM Subcommittees and CPSC will be necessary if we can ever hope to make any substantial reduction in serious injury reduction.

Next month I will discuss some of the challenges facing our industry as we further evaluate the current level of performance the impact attenuating surface system standard provides and how these performance thresholds translate to a level of injury these standards currently address.

What is the future of Playground Surfacing Requirements?

Wednesday, December 4th, 2013

What is the future of Playground Surfacing Requirements?By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
September 2013

Where is the playground surfacing industry going in the near term? I wish I could give you a definitive answer. I will attempt to enlighten you but what I will not do is give you the answer you all need. It is time to roll up your sleeves and do some good old fashion homework. There is no excuse for not being informed on the many variables that impact your purchasing decisions. Yes it might make sense to hire a consultant however buyer beware. When it comes to listening to what you are being told or what you read in marketing literature always consider the information and source with an open and inquisitive mind. One bit of good advice I received from a friend as my son was starting to become a bit more social and wanted to go to a friend’s house for a sleepover was to, “trust but verify.”

I continue to get questions from CPSIs and others who want to know what surface system they should be specifying for their playgrounds. I appreciate the fact that we are all very busy and would appreciate some help from the industry experts. I too did the same when I was responsible for all of playground related tasks for my agency. I realized early on there was not an adequate comprehensive source of information in one place nor were there enough well informed people within the industry to get the quick answer we all desire. This was understandable for two reasons. Everyone is trying to sell their own surface system and private consultants want to be paid to do your homework and make an appropriate recommendation for a surface system that best fits your budget and performance requirements. Where do these consultants get their information? I realized back in the day they get most of their information from many of the same sources I was using. I, like many of you, was paying the cost to educate my consultant. A lot has changed over the past 30 years. There are many new products available in the marketplace and many more industry performance standards for play area surface systems. When I started out in the field of Park and Recreation Management there was no Google Search. There was no Internet or cell phone. Things were not as bad is it appears. We did have indoor plumbing, electricity and the telephone. We found answers to most of our problems through word of mouth and experimentation. This is not the way things are done today. Google it and you get all kinds of things to read most of which are put out by the surfacing companies and their marketing staff who are trying to sell you their products. Most of this information will point out all the positives of their surface systems. Unfortunately there is no consumer report on the subject. You will not find a complete report with a side by side comparison of all the positives and negatives of each system available in the marketplace. Regardless of all the good, and sometimes bad, information available through the Internet the question everyone should be asking is, “What performance requirements must be adhered to for my surface system to meet the current industry recommendations for a compliant system and how long should it last?”

It is time for everyone involved in managing public playgrounds to do their homework and become knowledgeable in everything necessary to select the appropriate impact attenuating surface system for their situation. This includes everything related to proper installation, maintenance and repair throughout the system’s life. There is no excuse for not knowing what resources are required to maintain a compliant impact attenuating surface within the play equipment use zone. Knowing this information is only half of the battle. Knowing what resources you have at your disposal to successfully manage the surfacing throughout its life will help you apply this knowledge to achieve the best outcome. This is where making good decisions becomes a bit more involved. Accessibility requirements for firmness and stability tend to steer our choices towards unitary systems. There are so many new unitary and composite hybrid surface systems it is becoming very difficult to keep up with the surfacing industry. Then how do you compare these new systems to one another when looking at initial cost versus long term maintenance and projected life expectancy. Most of these systems have not been in place for more than a few years at best. Loose fill systems like Engineered Wood Fiber (EWF) and loose rubber are still popular and provide excellent impact attenuation but issues related to accessibility and the ongoing frequency of maintenance of these systems pose the biggest challenge for most public play areas owners.
Still the number one consideration guiding our purchasing decision should be to provide the most impact attenuation possible while meeting all our other unique issues each play area presents. Too many owners and their consultants are focused on meeting the minimum industry performance requirements without understanding the future challenges of meeting these requirements throughout the life of the playground. What kind of warranty is available for each of these surface systems? Do these warranties have any limitations? I doubt most people have taken the time to read these warranty statements and what your responsibilities will be to remove and replace a system that fails within the warranty time limits. What is more troubling to me is how many people defer their decision to their consultant for what surfacing system to specify. Many owners give little or no guidance for what performance requirements you expect. I see this scenario repeating itself time and time again with very unpleasant outcomes 3 to 5 years down the road. Now it is too late. Everyone is upset and the owner is the one left to deal with the issues at hand. If this has happened to you I suggest you look in the mirror to find the person responsible. Nobody should relinquish their responsibility to someone else for choosing the best most appropriate surface system for their play areas. I would start with defining and specifying impact attenuation performance?

Social media groups, such as one I belong to in LinkedIn, have been debating the positive and negative impact of playground performance standards. Where we are headed in the near future is unknown but one fact remains. The number one cause of injuries on public playgrounds is falls to the playground surface within the use zone. The numbers have not changed over the past twenty years and if anything the may have even increased. One thing that has remained constant over the past twenty plus years is the impact attenuation performance requirements found in every international playground standard. The current debate going on is whether or not these performance thresholds meet the current scope of our standards which are looking for a reduction of serious injuries and death on our children’s play spaces. This discussion always seems to bring us back to my previous rants on the benefits of risk and challenge versus foreseeable misuse. Then you add the question of how much can society expend on our public playgrounds when it comes to providing a reasonable safe environment that still meets the developmental needs of children at play as compared to other causes of serious injuries and death to children. This discussion is for another day.

I am not going there again. Today I am suggesting something that hopefully will make the best use of our limited resources. I would like to see each of us responsible for selecting playground surfacing incorporate something that improves your purchasing decisions while extending the life of a compliant surface. This step should reduce the frequency and severity of playground injuries. My suggestion is to specify the fall height and performance requirements for HIC and Gmax at something less than the current ASTM F1292 thresholds. It is your responsibility and right, as owner, to specify your own minimum performance requirements to pre-qualify any surface systems for further purchase consideration.

I think the ongoing industry discussions on surfacing and performance requirements are beginning to get somewhere. These discussions allow all interested parties and each special interest to make their argument and challenge other points of view. This is not just a USA issue. Australia, various members of the European Union, and Canada all have been commenting on whether or not we need better surfacing standard performance requirements. There is a lot more to be learned as these discussions and debate play out in the ASTM, CSA, AZ, and EN standards groups.
Raising the bar for performance by lowering the impact attenuation thresholds below 100 HIC and 200g is part of the solution. The is another discussion going on as to whether there should be industry requirements for post installation compliance drop testing to certify compliance to whatever the requirements may be. I am starting to see government organizations and some more enlightened municipal entities moving the surface system industry towards compliance testing. This kind of compliance testing protects everyone’s interests including children’s safety and the taxpayer’s capital investment.
I am not sure this will occur on its own without some legislative action. Based on the current stated objectives for injury prevention of Health Canada and US CPSC I could see both making field testing a requirement for some government entities. Currently there is not the will for such a move. Many would dread the day this occurs but I would rather see this then ongoing recalls of equipment because of a few broken bones when children are just being children. Many of these broken bones result when a child falls and attempts to avoid hitting their head by breaking their fall with their hands and arms. Many occur solely by chance as a result of how a child happens to land while running across the playground surface or falling from a very low height of the surface.
Risk and challenge are most important to a successful play area. That being said I agree with those who think annual field drop testing might be a step in the right direction but this might be bit much in all situations. I believe there is room for some reasonable compromise for the frequency of such testing based on the previous drop test performance results. Maybe once a surface begins to reach the upper limits of acceptance it should require annual testing but when a surface performs at no more than 50% of the current threshold maximums it might only warrant testing every three years. I believe many broken bones are a result of falls to non-compliant surfaces but we will never know for sure without testing after the injury.
Rolf Huber, Canadian Playground Advisory, Inc., makes one of the most compelling twelve point arguments for a change from the status quo. Mr. Huber says,
“The need for Playground Surface Testing is very simple to understand.

1. Playground injuries are 60 to 75% falls to the surface worldwide and depending upon which study one looks at.

2. 200 Gmax was determined back in the 1950s, 60s, 70s and even today as being the 50% threshold for skull fracture and death in animal and cadaver studies.

3. 1000 SI (Gadd Severity Index) was determined in the 1970s as being the 50% survival threshold for head injuries in simulated automobile accidents.

4. The HIC (Head Injury Criteria) is generally 20% lower than the SI for the same data with a 10ms pulse and therefore 1000 HIC would set a threshold for HIC as 800 HIC.

5. Prasad and Mertz in the presentation of the USA to the ISO automobile standards in 1985 submitted data that 1000 HIC is a 15% risk of AIS (abbreviated injury score) >4 (life-threatening with survival probable, but a mortality rate of 10-12%

6. In 2000 the US National Highway Transportation Safety Administration and Transport Canada revised downward the HIC threshold for automobiles from 1000 to 700 for all person over the age of 6 and 570 children under 6. This is still a 5% risk of AIS>4.

7. NFL study provides of 30 concussions that took players out of the game showed Gmax values of 98 and HIC of 381 for what is considered to be a “serious head injury”.

8. 2008 Cen publishes En1176 to “prevent accidents with a disabling or fatal consequence” and sets swing impact for single users to 50g and 120g for multiple users

9. In 2011 CEN published the CEN/TR 16148, Head and neck impact, burn and noise criteria, which stated that 1000 HIC has a 10-15% probability of death.

10. In 2011 ASTM publishes ASTM F1487-11 and swing impact is set to a maximum of 100 Gmax and 500 HIC and injuries related to swings are less than 3% in the USA.

11. Since the thresholds for the testing in the laboratory or the field are above a 10% probability of death, all surfaces should be tested within 10-40 days following installation and no payments should be made until the testing is completed and confirmed. Testing should be a minimum of every 2 years provided the Gmax or HIC at the previous testing was less than half the required Gmax or HIC. Gmax or HIC greater than 50% would require annual testing.

12. Surfaces and primarily synthetic surfacing should have a warranty for the maintained surface for compliance to the relevant standard for minimum of 5-8 years.”

There are many weighing in on the argument for mandatory testing. Most cite testing as being too costly and therefore this additional cost will reduce play opportunities for children. One expert in the United Kingdom argued the cost is too much for the benefits to society as many more children are seriously injured as pedestrians. A better use of these injury prevention funds would be to spend them on improving pedestrian safety. It was estimated the cost to conduct annual drop testing on all 30,000 UK public school playgrounds could be as much as $30,000,000. One Canadian playground inspector who conducts annual mandatory inspections of all childcare facilities by law stated he was ready to move to the UK and start an inspection service. He explained he was getting only a fraction of the UK estimated drop test cost in Canada. His point being if testing became mandatory there would be more people doing the testing and costs would come down. Besides the initial cost of the testing equipment, travel and mobilization adds a great deal to the bottom line cost for surface testing. Supply and demand should have a significant impact on reducing costs to public playground owners to something more manageable.
There are also those who argue there are not significant numbers of serious injuries or deaths as a result of falls to the playground surface. They also make the point that there is no proof lowering impact thresholds in playground surface standards will result in a significant reduction of injury frequency or severity. There is research emerging that refutes this claim.

This debate continues to bring to light research and professional papers from various disciplines supporting the position for some form of mandatory compliance drop testing and/or a reduction in current playground surfacing standards minimum acceptable impact attenuation thresholds.
What path to injury prevention and compliance will the playground industry follow?

Status quo, lowering HIC and Gmax values by standards organizations or owner’s purchasing specifications, or mandatory post installation surface testing requirements for every playground coupled with some requirement for testing at some frequency throughout the life of the playground until the system fails. When failure occurs, industry standards require the owner take the playground out of service until the surface system is brought back into compliance.
What do you choose to do?

The Benefits of Risky Play

Wednesday, December 4th, 2013

The Benefits of Risky Play
By Kenneth S Kutska, Executive Director, International Playground Safety Institute, LLC
Chad Kennedy, Landscape Architect, ASLA, O’Dell Engineering, CA
July 22, 2013 (August Issue)

My last two columns came about as a result of some recent developments related to the ASTM Standards Subcommittee meetings in May. My intention was to start this discussion based on a couple or articles I read via my LinkedIn online discussion groups. Instead I decided to write about some ongoing discussions related to terminology being historically thrown around in our discussion groups. Recently terms such as risk and hazard started a lively dialog, not just at ASTM, but within other Standards Organizations around the world. On October 22, 2013 there will be a meeting sponsored by TUV Austria to discuss the EN 1177 surfacing standard and the compliance thresholds for impact attenuation as they relate to current research and standards scope. Immediately after this meeting the International Standards Organization Technical Committee 83 (ISO TC 83) will be holding their meeting to discuss many of the terms I spoke of in my last column.

I want to start with the premise that nobody wishes to minimize the importance of play, risk and challenge in a child’s routine development. Likewise nobody wishes to minimize the importance of rigorous safety inspections, maintenance and repair to keep our children from serious harm and our public play spaces in good condition. What I have learned over the past many years is we all have similar goals. I see more that the participants in this discussion have in common than things on which we disagree. It is the varied personal experiences and knowledge everyone involved adds to the discussion that clouds the waters. The diverse group of participants currently involved in these online discussion groups cannot seem to narrow the dialog to what is the most important versus what is of concern but not just as important to the mission at hand. Everyone involved thus far continue to raise valid points. So the question remains,” how do we narrow the focus of the discussion, or scope of the current standards, to what is of most concern?” I do not have the answer today but I intend on being a regular participant in these discussion. The language of play and the terminology used throughout the world to articulate one another’s standards and guidelines are becoming more and more important as we try and make sure we act responsibly and make sure our intentions are universally understood. One fact that affects all of us in North America is the reality of the impact enforcement and regulatory authority government organizations, like the US CPSC and Health Canada, have on anyone who owns, designs, manufactures, sells, installs, inspects, repairs, maintains, and a public playground. This does not appear to be the case in the United Kingdom and will be a topic for some future article.

Last month I shared some terminology and definitions for your consideration as we move the discussion forward. I defined RISK as a foreseen occurrence that combines the probability of occurrence of harm and the severity of that harm as perceived by the INTENDED USER. Remember we are talking about children in the context of user. I defined HAZARD as an UNFORESEEN SAFETY CONCERN that when identified and analyzed with a RISK ASSESSMENT PROCESS (based on a RISK ANALYSIS and RISK EVALUATION) is seen by a consensus of all stakeholders to exceed the level of TOLERABLE RISK during REASONABLE FORESEEABLE MISUSE by the INTENDED USER likely to result in a high probability of HARM defined as a LEVEL OF INJURY unacceptable to societal norms. Assuming you agree with these definitions we must begin to ask ourselves how we do a better job of providing risky play in a reasonable responsible fashion.

So let’s look ahead to the future and design of your next new playground.

I want to thank Chad Kennedy, Landscape Architect, ASLA, with O’Dell Engineering of Modesto , California for permission to reprint excerpts from two articles as published in his monthly LAND Connections online publication: June 2010, Playground Safety – What’s the Big Deal and July 2012, Inclusive Play Community Series: Risky Play. Each contained useful information pertinent to the ongoing discussion of how to responsibly create more play value, risk and challenge for all children. Mr. Kennedy provides good information to consider as we strive to improve the quality and developmental benefits of tomorrow’s play spaces and experiences.

Mr. Kennedy’s described a personal account when as a child he experienced risk and challenge. The story captured the essence of this discussion. He wrote, “After climbing through a weathered window and up onto the ledge of a wooden A-frame play structure in the backyard, I took a moment to adjusted my ingenious (but highly ineffective) grocery bag parachute snuggly against my shoulders. The mere 7′ drop was no different to my eight year old mind and eyes than that of a fifty foot drop. Noticeably cautious, a few encouraging shouts from below were necessary to help build sufficient courage to make the leap. The plastic grocery bag flapped loudly as the ground approached…much more rapidly than expected! After all, the parachute should have slowed me down right? I lived to tell the tale and vividly remember making that leap many more times. Unbeknownst to me at the time, these types of risks, and others, during my play time as a youth were the ultimate training for risk management as an adult. Modern research has revealed this to be the case in most situations along with many other benefits that risky play has on ALL children’s development. Risky play is universal and observed in all demographics of children filling an innate developmental need not met any other way. The essence of risky play is a child’s attempt to manage perceived danger in an environment with the reward of excitement, achievement and exhilaration. “

This is our challenge; How do we succeed in providing excitement, exhilaration and opportunities for personal achievement in a reasonable fashion without reverting to the unacceptable option of dumbing down public play areas and blaming it on safety standards and the fear of liability?

The Benefits of Risky Play: Risk in the playground is essential for children’s growth, creating challenges which allow children opportunities to succeed and/or fail based on individual reasoning and choices helping them to learn risk management. Hazards, on the other hand, are items or situations that a child is not expected to comprehend, see or foresee. Risky play has been shown to be beneficial to children’s development by helping them cope with stressful situations, learn how to follow-through, improve social interaction skills, increase creativity, learn about human mortality, assist in understanding their limitations, recognize areas for improvement and help form positive, pro-active attitudes.¹ Other benefits also include improved motor skills and cognitive understanding of the environment.³ The lack of risk in the play environment could lead to children who are “risk-averse”, never having learned how to effectively manage everyday situations, or children who seek out dangerous or hazardous locations to experience thrill. Mental health professionals also argue that the lack of risk in play can lead to a lack of resilience and ultimately mental health, resulting in the need for professional intervention.¹ Arguments by advocates for risky play are quite convincing, some even suggest that risky play is a product of evolution and natural selection, but this has no bearing on why the children themselves choose every day to engage in this form of play.

Risky Play from the Child’s Perspective: It is common to see risky play occur in scenarios where the children’s skills exceed the opportunities afforded to them in the play space.⁵ This can manifest itself in a child using equipment in ways that are not intended, jumping from high places, climbing structures or trees and mock-aggression. One study showed that the most common and preferred form of risky play by children was climbing. It didn’t really matter what was climbed, trees, poles, rocks, playground climbers, hills or anything else, as long as the opportunity to climb was there. Second to climbing, children also enjoyed and preferred jumping from elevated locations over other forms of play.⁵ The degree to which children are willing to take risks, however, varies greatly. Each child constantly manages their personal feelings of fear versus anticipated enjoyment and makes a choice. This assessment period range from seconds to minutes depending on the child, as some jump right into activities while others hesitate or eventually retreat. Ultimately children choose whether or not to engage in risky play based on if the reward is enough to outweigh the risk. It should be noted that children with disabilities are no different than other children in this regard. They benefit from risky play as well and should not be denied the opportunity by overly protective care givers. Socially inclusive play spaces in particular should provide opportunities for children to manage risk. Below are descriptions of how children outwardly express their emotions during risky play:

Fear: Much of a child’s time during play is spent managing the emotion of fear. This emotion can be recognized primarily by the avoidance of or retreat from an activity. Still, other expressions of fear can be observed when a child acts defiantly, freezes in place, becomes defensive or timid, or solicits help from an adult.³ This is a normal, healthy emotion which all children experience at some level and should learn to manage while they are young.

Exhilaration: Exhilaration is the reward the child feels after having accomplished a risky feat that they may have been unsure about in the beginning. Children’s experiences during risky play border on euphoric; hence they will tend to engage in the same action repetitively in order to re-experience the original pleasure and excitement.⁴ This emotion is commonly expressed through laughing, smiling, screaming, yelling, dancing and engaging in vestibular oriented play.³

Borderline Fear: Often during play, children will feel out of control or be involved in an unpredictable situation and will tend to be unsure, maybe even confused of the emotions they are feeling. Are they scared or exhilarated… or both?³ It is during these times that children may quickly experience fear followed by exhilaration and vice versa as noticeable when a child suddenly stalls or becomes hesitant during play.

Categories of Risky Play: Through interviews and studies of several children’s programs in Norway, risky play has been categorized (by the risk involved) into six main types of risk.² Each of these may not be found in every play environment. If they are not, children will instinctively attempt to find ways of experiencing them. A brief listing of them is as follows:

Great Heights – Climbing, jumping, balancing, hanging
High Speed – Swinging, sliding, running, bikes and skating
Dangerous Tools – Cutting, poking, whipping, sawing, lashing, tying
Dangerous Elements – Elevation change, water, fire
Mock-Aggression – Wrestling, fencing, play fighting, rough and tumble play
Disappearing / Getting Lost – Exploring, unknown environments

The research is quite clear on the benefits of risky play. The task we face as a society now is to determine how to avoid over sanitation of play environments, minimize regulations, and give children space to explore and experience, while providing for safe recreation free of hazards that could result in serious injury or death. The generations before us understood that accidents happen and that it wasn’t always a bad thing. My fearless leaps from roof tops, ledges and trees (with and without home-made parachutes) didn’t always end well.

I think we have all had our share of bumps, bruises and even broken arms. These experiences, or close calls, prepare us for life, whatever it may bring us during our early development, and continue to serve us well into adulthood and as parents and grandparents.

Designers must act responsibly and be reasonable in designing play spaces for children of all abilities. What may be routine for one may present a challenge beyond their ability. This can result in unforeseen consequences to those not yet ready to understand the risk and the harm that might result from their personal decision to give it a go. This is when reasonable choices by designers and owners’ become the main topic of discussion.

Below are listed some common hazards found within the play environments that should be assessed and addressed:

• Improper Surfacing Impact Attenuation and Use Zones
• Entanglement and Protrusion (Impalement) type Hazards
• Head and Neck Entrapment in Completely and Partially Bound Openings
• Crush and Shearing points
• Sharp points, Corners and Edges
• Suspended Overhead and other Impact Hazards
• Toxic Substances
• Improper Age Appropriateness of the Equipment and Layout of Equipment
• Tripping Hazards
• Lack of or Improper Information and Warning Signs

Playground accidents will happen regardless of any attempt made to eliminate danger in the playground environment. Playground safety measures are not designed to limit play activities, creativity, or to eliminate risk. A thorough assessment of your public play areas by a trained and experienced CPSI can identify known hazards and other significant safety concerns, which if addressed, can minimize the potential for serious injuries.

In the future I hope to begin a discussion on what is a serious injury. This definition has a significant impact on everything we are talking about. Society as a whole will and should impact the scope of injuries we should try and address however there is currently only a few involved in determining what is or is not acceptable when it comes to the unreasonable actions of some children and adults.
1-Gleave, Josie (2008): “Risk and Play: A Literature Review”. Playday:Give Us a Go. National Children’s Bureau.
2-Sandsetter, Ellen Beate Hansen and Leif Edward Ottesen Kennair (2011): “Children’s Risky Play from an Evolutionary Perspective: The Anti-Phobic Effects of Thrilling Experiences”. Evolutionary Psychology. 9:2, 257-284
3-Sandsetter, Ellen Beate Hansen (2009): “Children’s Expressions of Exhilaration and Fear in Risky Play”, Contemporary issues in Early
Childhood, Volume 10:2, 92-106.
4- Sandsetter, Ellen Beate Hansen (2009): “Characteristics of Risky Play”. Journal of Adventure Education & Outdoor Learning. 9:1, 3-21.
5- Sandsetter, Ellen Beate Hansen (2007): “Categorizing Risky Play – How can we identify risk-taking in children’s play?. European Early
Childhood Education Research Journal. 15:2, 237-252.