Archive for October, 2014

Hazard Based Approach to Equipment Performance vs Defining Specific Equipment Requirements

Sunday, October 26th, 2014

Hazard Based Approach to Equipment Performance vs Defining Specific Equipment Requirements
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
September 28, 2014

This month I will discuss an emerging trend in playground equipment standards development. The focus of the hazard based approach is to embrace reasonable foreseeable playground related injuries regardless of what the equipment might be called, what specific category it appears to fit into, or what the equipment looks like. The United Kingdom’s approach to this risk assessment and hazard based approach may sound quite familiar but one country’s interpretation of what constitutes a hazard or what is an unacceptable injury rests within the societal differences of each after all who is right hinges on who is in charge.

The American public playground equipment injury prevention movement was born more than 40 years ago as a result of many research projects of the United States Consumer Product Safety Commission (CPSC). The CPSC injury prevention and safety staff along with other child development and play advocates have been reacting to injury reports and statistics. Initially this approach to injury prevention has been very effective in many areas. Today we can no longer meet the change of pace in product development throughout the playground equipment industry. We continue to chase our tails expending a lot of human and financial resources only to find ourselves back in the same place we started or we are expending too much time changing what we already have done. We seem to be considering more exceptions to the rule than to modify the rule in the first place. Either way our actions seem focused on allowing for some new piece of equipment rather than requiring the new equipment meet the basic requirements for hazard mitigation. In essence, our current approach to creating and revising playground safety guidelines and recommendations could be compared to the farmer closing the barn door long after the livestock has left the barn. So how does the hazard based approach differ from the continual need to expand the specific equipment requirements? The answer to the first part of the question is easy. Sections 4, 5, 6 and 7 of ASTM F1487 and primarily Section 6, covers almost every hazard based performance requirement for any piece of play equipment no matter what it is called.

Once we get into Section 8 Equipment, the performance requirements start to become more design restrictive. When injury reports become more widely known by the general public and lawsuits get filed the injury prevention folks start to do their job. Is this necessary or is it a knee jerk over-reaction? Follow up investigation analysis after a serious injury seem to be done as if the injury occurred within a workplace environment. Unfortunately the public playground environment is starting to be compared to a place of employment which it is not. In the workplace, the employer is responsible for their employee’s safety. In the adult world, we are concerned with loss of productivity, lost income and medical and rehabilitation costs. Most workplace environments have very strict State and Federal Occupational Health and Safety Act (OSHA) requirements. Any shortcomings uncovered in OSHA inspections lead to corrective action and often fines to the owner of the workplace. Workplace injuries often lead to new performance requirements. Over time this has proven to be a good thing as improvements within the workplace have eliminated the cause of many future injuries. I am not saying we should take this approach in a hazard based analysis of playspaces. I have stated before that children’s playspaces are not to be treated as a workplace environment. There are obviously the medical and rehabilitation costs like with adults, but provided the injury does not exceed a societally acceptable threshold, the injury becomes an acceptable outcome to a failed learning experience. It is worth repeating, “Children’s playspace injuries should not be treated the same as workplace injuries.” Workplace injuries, for the most part, are not acceptable in today’s society, even when they are unforeseen. This is especially true when an employer could have taken action to eliminate the cause of the injury either by warning signage, employee training, additional safety equipment/tools, or new improved facility and equipment designs.

A public playspace’s purpose is much different than almost all places of employment where the primary purpose is to create a product or service while creating wealth for the company’s shareholders and its workers. A playspace is a place for young rather inexperienced children to explore their abilities, assess play opportunities, and take risks. A place to try things for the first time even when the outcome is unknown. It should be a requirement that each playspace be a place for less rules not more. It should be treated as a place to enjoy free time. It is a place to explore everyone’s individual capacity to grow and learn new things about themselves and the environment around them. Imagine what the adult workplace environment would be like if these ideas and principles were to be applied. Some would argue chaos would prevail. Many successful companies have what could be called an unstructured or chaotic environments, but invariably hazards to people or property are cleverly removed. Workplace rules are designed to protect the employee and to protect the company from the ever increasing onslaught of Worker’s Compensation claims and cover situations where the injured employee do not follow workplace procedures resulting in a preventable injury. Obviously children cannot be held to the same standard of behavior. I would argue the playground owners and equipment and surfacing manufacturers also should not be the scapegoat whenever obvious or blatant inappropriate personal behavior and lack of supervision lead to the unfortunate injury. I want to be clear that I am not looking to absolve anyone from a defective product, improper installation, lack of adult supervision, or a lack of inspections, maintenance, and corrective action. This is a whole different story. Hazard elimination must be unobtrusive and it results from ongoing adult assessment and review of the playspace.

For the hazard based approach to playground standards to move forward the playground equipment design and playspace post injury investigation cannot be measured in the same way as the workplace environment. Society must first set an acceptable threshold for injury. Today we are debating if this will be based solely on prevention of death or life-threatening as it was 40 years ago or be focused more on concussion and long-bone injury or those defined by the CPSC as a societal surrogate in the CPSIA. The goals and objectives are quite different for each environment. Regardless, the manufacturer and designer of the playground equipment and use zone surface system should be conducting their own risk assessment of the prototype piece of equipment or new surfacing system to determine whether or not it is appropriate for the intended user regardless of any reasonable foreseeable misuse by the child/user.

So how does this new hazard based approach get implemented?
A colleague of mine read my response in the “NRPA Connect” Playground Safety Forum on a question related to a stand-up spinner and its attachment to a composite structure. He thought my response was brilliant. How could I disagree? Just kidding. 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 response went as follows:

“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.”

Brilliant!? Well maybe not so but the point is that we at ASTM F15.29 Subcommittee have been working on a way to change our approach to evaluating playground environments and writing standards and guidelines. We see a desire to change from a prescriptive equipment performance/design approach to a hazard based approach when it comes to specific types of specialized equipment, taking into consideration function and what can go wrong. This approach focuses on the injuries that could occur rather than trying to keep up with ever-changing equipment configurations and reacting to injuries that become obvious years later.

My colleague said he was doing a lot of thinking about this new approach to safety standards development. He loves the potential paradigm shift, however he is concerned it may create a double edged sword. One side provides for the opportunity for more challenge in the playspace but the other side of implementing this hazard based approach could create a trickle down negative impact on the industry by adding a degree of responsibility and risk assessment they are not currently used to. This is of particular concern for the manufacture that copies and implements a design and without understanding all of the hazard mitigation in the original design. He was not concerned about the logistics of what the ASTM would have to go through to change the current standard. His concern was more centered on how it would applied in the field. He was concerned about the final result when the end user and/or their post installation compliance inspector applies these changes. He sent me the following four points.

1] Hazard based approach looks at a finite number of possibilities – We should all know what hazards are present in playground environments. We have injury data and there are a finite number of possibilities therefore there should be no need to try and keep up with manufacturer’s research and development.

2] Current CPSI training and certification – The hazard based approach would render the current CPSI Course training program obsolete. We might be able toss out a lot of the number memorizing but we would need to bring in more information to create a better understanding of child development and how children play. This would create another opportunity to develop a new training program. Maybe we all could agree to get rid of “inappropriate use” as a fall back response to a new rash of injuries. Maybe we could avoid some of the compliant yet potentially hazardous conditions by creating a universal understanding of child development, how they play, and understanding how to deliver an environment and range of activities that meets all children’s developmental needs.

I was reminded of a brainstorming session the old National Playground Safety Institute Executive Committee held during a NRPA Conference We were asked about potential new playground training opportunities as well as tweaking the “current” training. One of the suggestions was to change the current CPSI course outline from following the ASTM table of contents to using the “Dirty Dozen” as the new course outline. He thought this approach was more in line with how children play.

3] Does this hazard based approach open up the opportunity to consider something non-compliant because their thought process crossed over from just eliminating known hazards to eliminating risk and challenge and perceived safety issues? Would this become the easy way out for some who would like to eliminate playgrounds because it is easier to avoid more potential liability than to manage the public playground as it should be maintained in the first place? This brings us back to the need for all involved in public playground management to understand the difference between the terms, hazard and risk. Would an inspector justify removing some piece of equipment by misunderstanding this hazard based approach? The hazard based approach is not a risk avoidance approach? Would a hazard based approach set in motion an exponential increase in “professional judgment”? Would risk and loss control managers and attorneys rule the day (again)????

4] Connecting the Dots – The key to this hazard based approach may rest in our ability to train playground managers, designers and safety inspectors to connect the dots between the perceived potential hazards and how, when, and where to cite the new ASTM standard. Can we accomplish the objective while still allowing for graduated challenge play opportunities for all children? Understand that every challenge presented in a play environment may not be developmentally appropriate for everyone 100% of the time. Connect this reality to the fact that children will be seriously injured on even the most compliant playspace. This hazard based approach is a much needed concept that everyone including the users, policy makers, and legislators and our judicial system must embrace.

In conclusion, Playspaces that comply with this Standard will not prevent all injuries. There exists a shared responsibility among the design consultant, owner/operator, caregiver, equipment manufacturer, surface system provider and installer/assembler of the playspace when it comes to injury prevention. Well-designed and constructed playspaces in compliance with the requirements of this Standard create a foundation for play within the context of injury prevention. Regardless of how well the playspace is designed, adult caregiver supervision of children is still vital to injury prevention especially when an unsupervised child exercises unreasonable misuse or abuse of the playspace. Playspaces complying with this standard provide a formal environment focusing free play activity to a specific locations rather than an inappropriate location or activity of the child’s choosing because of boredom due to the lack of challenge at the local public playground. Although injuries will occur in any play environment, it is better they occur in a well-designed public playspace where appropriate injury response can be delivered in a timely fashion.

Risk versus Hazard or Graduated Challenge versus Equal Access for All
How we approach the implementation of the hazard based approach in a playspace with a good variety of graduated challenges for all users goes beyond the risk assessment of the play component and surface system. The level of challenge required and desired by children varies enormously with their age and physical, emotional, social and intellectual development. Therefore, it is almost impossible to design a piece of playground equipment that meets the needs of the individual child while meeting the needs of all children all the time. Playground equipment areas that children find attractive are generally those that present various levels of difficulty referred to as graduated challenge. Children can explore solutions to these challenges and practice their newly acquired abilities in carefully designed settings, where the hazards have been assessed and are managed by adopting supervisory and design techniques.

What I mean by supervisory and design techniques has to do with each owner/operator’s philosophy on free play. Does the owner/operator have an operational policy for their supervisors to follow? Does the policy and/or standard operational procedures come with a set of playground rules? Maybe there are no rules? I think the fewer rules the better. Another risk management approach by the owner/operator might be to select age appropriate equipment that fits the needs of the intended users and the space allocated to the playspace. Not all compliant or age appropriate piece equipment as determined by the manufacturer and playspace designer may be appropriate for every location. The owner/operators need to take the many things into consideration when approving a playspace plan based on their own operation guidelines and approach to free play and risk management.

Adult caregiver supervision of children is an important aspect of risk assessment management and intervention when a child is demonstrating unreasonable misuse or abuse of the play equipment. The value of supervising a young child’s behavior should not be underestimated. In the context of injury prevention it goes beyond just observation. Supervision includes the review of the playspace for objects and blatant failures through vandalism or severe environment forces such as; flood, ice storm, earthquake, ultraviolet and thermal radiation. Weather plays an uncontrolled factor in the play activity. Discouragement of an activity on the part of the child playing that would clearly expose them to a hazardous situation such as; climbing on a roof or wearing a bicycle helmet when on the playground equipment or playing without proper footwear should be mitigated through the strategic placement of information signs and warnings. Signage and warnings, although directed at everyone, are clear messages to the caregiver with regards to behavior modification aimed at injury prevention.

Beyond adult supervision precautions need to be taken by play owner/operators to reduce the severity of injuries if children make the wrong judgment however the possibility of harm cannot be completely removed. Like other physical activities, the use of public playground facilities involves the residual risk of injury. The manufacturer must take into consideration the behavior of children given reasonably foreseeable misuse and assess their designs and structures from the point of view of exposure to hazard or the intended user’s frequency of failing due to the challenge presented. The elimination of a hazard such as frequency of falling from a piece of manufactured play equipment might fall to another manufacturer’s product within the playspace, such as the surfacing supplier, but it is the responsibility of the equipment manufacturer to point out the risk of the fall. This risk assessment responsibility extends to the consultant, and owner/operator who along with the manufacturer should analyze the entire playspace and determine what residual risk may remain and design for a different outcome. The other possible solution might be to provide user information and warnings. The typical public playground performance specification recommends minimum requirements for playground equipment and the surface adjacent to the play equipment. In the USA these standards have evolved through the ASTM standards development process. This process is an open democratic consensus based process. Often injury prevention is the application of mitigating measures to remove, reduce, or guard against by the use of a protective device certain exposures to risk. For example, the risk of injury from falls may be mitigated thereby reducing a severe or life-threatening injury to a serious injury through better impact attenuation performance. In the risk assessment approach a reduction in the equipment fall height might be one item for consideration. Raising the minimum height for the barriers around the elevated platforms might be another consideration. Further risk analysis and discussion of the option to raise the barrier height from 38 inches to 60 or 72 inches might seem appropriate but in reality it would actually increase the equipment fall height when applying the assumption of reasonable foreseeable misuse. After a more detailed assessment it might be more appropriate to add some additional strategically located handholds at all elevated access egress points along with selecting a better surface system which performs in excess of existing minimum requirements. This could be the best solution for everyone including the children.

Another major mitigating factor to prevention of injuries is the provision of inspections and maintenance by the owner/operator or their representative. Post installation inspection of the structures and surfacing to standards and contractual requirements establishes compliance to the standards from the beginning. Once the first child plays in the playspace it belongs to the owner/operator and other than warranties, the manufacturer, supplier, and installer/assembler have moved on. The owner/operator shall maintain this compliance for the remainder of the playspace’s useful life. The owner/operator shall have established a budget, prior to purchase of the playground, for the ongoing inspection, maintenance, and repair of the play structures and surfaces taking into consideration the information that is provided by the manufacturer on maintenance and functional longevity. Timely inspection and maintenance is the ongoing key to long-term injury prevention. They also preserve the function of the equipment and surfacing while reducing more costly repairs and premature replacement.

Preventing life-threatening, long term debilitating injuries, and death are the current focus of this standard. While prevention of all injuries is not possible, prevention of one type of injury can lead to a reduction in severity of others which gets us all closer to today’s standard injury thresholds. We cannot reduce the frequency of “failure” if we are to provide playspaces and playground equipment that increase graduated challenges, but we can mitigate the severity of the injury when failure does occur.

Reasonably Playground Design – Risk and Challenge versus Safety Issues versus Hazard Prevention.

Sunday, October 26th, 2014

Reasonably Playground Design – Risk and Challenge versus Safety Issues versus Hazard Prevention
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute
August 24, 2014

Last month I shared my perspective on playground related injuries and how the severity of injuries do not necessary correlate with the notion a currently compliant playground will eliminate or substantially reduce the frequency or severity of injuries. The question which needs to be answered is whether or not our performance requirements for both equipment and impact attenuation surface systems are addressing the level of injury our standards purport to address. The various international playground performance standards (ASTM F1487, ASTM F1292, EN1176, EN1177, CSA Z614) and the CPSC Handbook state in very general terms the types of injuries they are attempting to address. Each standard introduction and scoping statement states the objective of injury reduction. Every standard and guideline I have read acknowledges there will continue to be many injuries sustained by children on even the most complaint play environment. Children’s play environments should not be inspected as if the inspector were an OSHA inspector in a workplace. Children are expected to challenge themselves beyond their current level of proficiency. This is all part of child development process. The challenge for playground designers, owners and manufacturers is to find balance between the safety issues and need for more challenging equipment. Challenging equipment presents a child with the opportunity and need to perform their own risk assessment. It is one thing for a child to take a risk but do they have enough experience to differentiate between challenges that introduce new elements of risk versus a hazardous condition. A young child cannot appreciate the probable consequential outcome when they come in contact with a truly hazardous condition.

Designers, manufacturers, owners and operators should not be in the business of eliminating risk. It can be done through the creating various levels of graduated challenge. We need to focus on assessing and managing risk while eliminating hazards and allow children to be children. Children face some forms of risk and hazards each and every day. Children need the opportunity to learn from these challenges and the personal choices they make and a well-designed somewhat controlled environment. The child’s decision on whether or not to undertake the challenge offered from the various graduated challenge opportunities within the play environment is part of that important personal development process.

I believe today’s playground standards and guidelines have provided much needed guidance to eliminate most of the hazards which existed decades ago. We have eliminated head entrapment, entanglements and protrusion hazards and the deaths associated with these know hazards but we still have children who are seriously hurt or even die as a result of some unfortunate accident. Over the past 25 years the NRPA, and its National Playground Safety Institute, have provided valuable training to better understand and eliminate the root causes of most severe playground injuries. Designers and manufacturers have taken these Federal recommendations and voluntary industry consensus based standards and in good faith have worked to provide more fun and challenge on the playground. The issue of what happens when a child fails to safely execute a skill necessary to complete some challenge on the playground still remains. Who will be held accountable and for what? The child? The parent? The owner of the playground? The manufacturer? The installer?

I ended last month’s column by outlining what I see as our next step. We must address the obstacles to meeting our current Standard’s scoping statements. These obstacles are;
• the need to reconcile the difference between the definitions for a “serious injury” according to the AIS System and the Consumer Product Safety Improvement Act and what our standard’s scope says.
• the playground industry’s agreement on the risk assessment process based on the possibility, probability, and level of injury likely from a fall to a surface just under 1000 HIC, which is a 16% risk of AIS >4.
• the need to accept the residual risk or harm after a risk assessment has been conducted by the designer, manufacturer and owner and reasonable risk reduction or protective measures have been implemented based on the intended use and reasonable foreseeable misuse of the equipment.

I believe we can do more to provide more challenging opportunities within the play environment while minimizing the liability exposure to designers, manufacturers and owners of public play areas if we can address these issues. Frivolous lawsuits need to end. Nobody wants a child to get hurt but we all know from experience we cannot protect each child from themselves when involved in free play. Children will fall and run into things and take risks they may not be developmentally ready to safely execute.

I would suggest a few action items. We need to come up with a better definition or concept of exactly what we are trying to create within a child’s play environment. This needs to be easy to understand by the general public, policy makers, and the entire playground industry. We need to identify and understand the hazards we wish to eliminate from the play environment. Finally, and as difficult as it sounds, we need to identify and agree upon what level of injury we, as a society, can accept. If we ever hope to be successful in accomplishing these items it will take a sustained major public awareness and education campaign directed towards all levels of all stakeholders.

Without some clarification to our playground standards scoping statements and performance objectives, the dark cloud of uncertainty will continue to inhibit our ability and desire to provide the types of age appropriate challenging and risky play opportunities our children need and deserve.

I left you last month with this question. Can you define what tolerable or acceptable risk of some level of injury severity should be generally accepted by society? In order to answer this question we all need to have a broader understanding of injury severity. We have all suffered a scrapped knee or elbow in our lifetime. Some scrapped knees are more severe than others as we can probably all relate to as well. We know when a scrape becomes a laceration requiring a few stitches it is more severe and also requires professional medical attention beyond what mom or dad can do for that skinned knee. When that laceration is so severe that it requires many more sutures at different layers of tissue we know more medical skill and attention is required for this severity of injury. Skin burns are another example of level of severity of injury. Who has not had a burn over the course of their life? Most of us have experienced a good sunburn at some time. It may not be healthy but it is not life-threatening. It could be. The sun is a leading cause of skin cancer and many people have died as a result of skin cancer. What I have just introduced is the concept of probability. Basically, what are the odds that I might end up with skin cancer? Are you or society will to accept those odds because the cost to eliminate any chance of skin cancer are either too great of the odds of getting skin cancer is so small everyone is willing to live with the consequences. So what is tolerable or acceptable when it comes to injury severity?

In my previous column I introduced a means of assessing injury severity through the use of the Abbreviated Injury Scale (AIS). If you look on Wikipedia for AIS you will find the following information.

About AIS
The Abbreviated Injury Scale (AIS) incorporates current medical terminology providing an internationally accepted tool for ranking injury severity. The AIS© is an anatomically based, consensus derived, global severity scoring system that classifies an individual injury by body region according to its relative severity on a 6 point scale.

What is the Abbreviated Injury Scale (AIS)?
The Abbreviated Injury Scale (AIS©) is an anatomically based, consensus derived, global severity scoring system that classifies each injury by body region according to its relative importance on a 6-point ordinal scale (1=minor and 6=maximal). AIS© is the basis for the Injury Severity Score (ISS) calculation of the multiply injured patient.

Injuries are ranked on a scale of 1 to 6, with 1 being minor, 4 severe and 6 an unsurvivable injury. This represents the ‘threat to life’ associated with an injury and is not meant to represent a comprehensive measure of severity. The AIS is not an injury scale, in that the difference between AIS1 and AIS2 is not the same as that between AIS4 and AIS5. There are many similarities between the AIS scale and the Organ Injury Scales of the American Association for the Surgery of Trauma.

AIS Score Injury
1 Minor
2 Moderate
3 Serious
4 Severe
5 Critical
6 Unsurvivable

There are nine AIS chapters corresponding to nine body regions:
1. Head
2. Face
3. Neck
4. Thorax
5. Abdomen
6. Spine
7. Upper Extremity
8. Lower Extremity
9. External and other.

The AIS provides standardized terminology to describe injuries and ranks injuries by severity. Current AIS users include, health organizations for clinical trauma management, outcome evaluation and for case mix adjustment purposes; motor vehicle crash investigators to identify mechanism of injury and improve vehicle design; and researchers for epidemiological studies and systems development, all of which may influence public policy (laws and regulations).

Some users are interested in its standardized injury descriptor capabilities; some are interested only in its injury severity assessment; and some in both. The AIS Uses and Techniques course allows people to learn how to correctly code injuries according to established rules and guidelines, which increases interpreter reliability worldwide.

Health and research records of all types may be coded in a prospective manner. AIS codes may be assigned using algorithms that map other commonly used disease and injury codes — such as the WHO-originated International Classification of Diseases. Some of these maps have been programmed into trauma registry and medical record software, and may be proprietary tools. Some others have been made available by the original developers.

History of the AIS
In 1973, the Association for the Advancement of Automotive Medicine (AAAM) assumed the lead role for continuing the development of a scale to classify injuries and their severity, originally begun by a joint committee of the American Medical Association (AMA), Society of Automotive Engineers and the AAAM in 1969. The first scale was published in 1971 in the Journal of the AMA, titled: “Rating the Severity of Tissue Damage – The Abbreviated Injury Scale”. Publication of the 1980 revision of the AIS was enthusiastically embraced by the trauma research community as a useful and reliable injury assessment tool. Today, the AIS is the global system of choice for injury data collection and has become the basis for a number of derivative scales in use (e.g., Injury Severity Score, TRISS, ASCOT). Over the years, the AIS has been translated into French, German, Italian, Chinese, Spanish, and Japanese.

The AIS has been continuously improved since its inception. The current edition, AIS© 2005 Update 2008, represents a five-year revision process involving hundreds of contributors in the USA, Canada, Australia, New Zealand and numerous European countries. The AIS© 2005 Update 2008 is significant in its total restructuring of injury classifications for both upper and lower extremities, and the pelvis, body regions that are significant in nonfatal long-term impairment and disability. The new classifications give in-depth researchers and investigators a tool to record injuries in these body regions with greater precision and detail.

Abbreviated Injury Score-Code is on a scale of one to six, one being a minor injury and six being maximal (currently untreatable). An AIS-Code of 6 is not the arbitrary code for a deceased patient or fatal injury, but the code for injuries specifically assigned an AIS 6 severity. An AIS-Code of 9 is used to describe injuries for which not enough information is available for more detailed coding, e.g. crush injury to the head.

The AIS scale is a measurement tool for single injuries. A universally accepted injury aggregation function has not yet been proposed, though the injury severity score and its derivatives are better aggregators for use in clinical settings.In other settings such as automotive design and occupant protection, MAIS is a useful tool for the comparison of specific injuries and their relative severity and the changes in those frequencies that may result from evolving motor vehicle design.

Abbreviated Injury Score
AIS-Code Injury Example AIS % prob. of death
1 Minor superficial laceration 0
2 Moderate fractured sternum 1 – 2
3 Serious open fracture of humerus 8 – 10
4 Severe perforated trachea 5 – 50
5 Critical ruptured liver & tissue loss 5 – 50
6 Maximum total severance of aorta 100
9 Not further specified (NFS)

What Level of Injury Severity is Acceptable Today?
The following information is summarized from web site where they combine the Abbreviated Injury Scale (AIS) and the Injury Severity Score (ISS) to assess patients involved in traffic accidents. This assessment process makes use of the Abbreviated Injury Scale (AIS) and its value correlates with the risk of mortality. Another way to look at this based on my early analogy to sun exposure is how much sun are you willing to expose yourself to in order to have a nice year round suntan based upon your own assessment and choice to worship the sun year round versus the probability you will die from skin cancer.

I looked over several types of injuries sustained in car accidents that somewhat related to injuries sustained on a playground. Most of these are direct result of impact from a body in motion to the surface or some other playground equipment surface. Generally the higher the impact the more severe the injury sustained.

Minor Injury (AIS 1)
• Aches all over
• Minor lacerations, contusion and abrasions (simple Closure)
• 1st degree burns
• Small 2nd and 3rd degree burns
• Cerebral injury with headache or dizziness but no loss of consciousness
• Whiplash complaint with no anatomical or radiological evidence
• Abrasions and contusions of ocular apparatus (lids, conjunctivae, cornea, uveal injuries)
• Vitreous or retinal hemorrhages
• Fractures and/or dislocation of teeth
• Chest muscle ache or chest wall stiffness
• Abdomen muscle ache
• Dislocation of digits

Moderate Injury (AIS 2)
• Extensive contusion or abrasion
• Large laceration
• Avulsion less than 3 inches wide
• 2nd or 3rd degree burn involving 10-20% Body Surface Area
• Cerebral injury with/without skull fracture, less than 15 minutes unconsciousness, no post-traumatic amnesia
• Undisplaced skull or facial bone fractures or compound fracture of nose
• Laceration of the eye and appendages
• Retinal detachment
• Disfiguring lacerations
• Whiplash severe complaints with anatomical and radiologic evidence
• Simple rib or sternal fracture
• Major contusion of chest wall without hemothorax or pneumothorax or respiratory embarrassment
• Major contusion of abdominal wall
• Minor sprains and fractures to extremities and pelvic girdle
• Compound fracture of digits
• Undisplaced long bone or pelvic fractures
• Major sprains of major joints

Serious Injury (AIS 3)
• Large lacerations involving more than 2 extremities
• Large avulsions, ≥ 3 inches wide
• 2nd or 3rd degree burn involving 20-30% of Body Surface Area
• Cerebral injury with or without skull fracture, with unconsciousness more than 15 minutes, without severe neurological signs, brief post-traumatic amnesia (less than 3 hours)
• Displaced closed skull fracture without unconsciousness or other signs of intracranial injury
• Loss of eye
• Avulsion of optic nerve
• Displaced facial bone fractures or those with antral or orbital involvement
• Cervical spine fractures without cord damage
• Multiple rib fractures without respiratory embarrassment
• Hemothorax (presence of blood in the pleural cavity (between lungs & inner chest wall)
• Pneumothorax (presence of air or gas in the pleural cavity)
• Rupture of diaphragm (the muscular wall separating the thoracic from the abdominal cavities)
• Lung contusion (bruised lung)
• Contusion of abdominal organs (bruised liver, spleen, pancreas or kidney)
• Extraperitoneal bladder rupture
• Retroperitoneal hemorrhage
• Avulsion of ureter (tearing off or away)
• Laceration of urethra
• Thoracic or lumbar spine fracture without neurological involvement
• Displaced simple long bone fractures
• Multiple hand and foot fractures
• Pelvic fracture with displacement
• Dislocation of major joints
• Multiple amputations of digits
• Laceration of the major nerves or vessels of extremities

Severe Injury (AIS 4)
• Severe lacerations and/or avulsion with dangerous hemorrhage
• 2nd or 3rd degree burns involving 30-50% of Body Surface Area
• Cerebral injury with or without skull fracture with unconsciousness of more than 15 minutes, with definite abnormal neurological signs; post-traumatic amnesia 3-12 hours
• Compound skull fracture
• Flail chest
• Pneumomediastinum
• Myocardial contusion without circulatory embarrassment (bruised heart muscle)
• Pericardial injuries (damage to the heart sac enclosing the heart)
• Minor laceration of intra-abdominal contents (to include ruptured spleen, kidney and injuries to tail of pancreas)
• Intraperitoneal bladder rupture
• Avulsion of genitals (tearing away or torn off)
• Thoracic and/or lumbar spine fracture with paraplegia
• Multiple closed long-bone fractures
• Amputation of limbs
• Multiple open limb fractures

Critical Injury (AIS 5)
• 2nd or 3rd degree burns involving >50% of Body Surface Area
• Cerebral injury with or without skull fracture with unconsciousness of more than 24 hours; post-traumatic amnesia more than 12 hours
• Intracranial hemorrhage
• Signs of increased intra-cranial pressure (decreasing state of consciousness, bradycardia under 60, progressive rise in blood pressure, or progressive pupil inequality)
• Cervical spine injury with quadriplegia
• Aortic laceration
• Rupture, avulsion or severe laceration of intra-abdominal vessels or organs, except kidney, spleen or ureter
• Major airway obstruction

I will make the assumption that injury severity diagnosis beyond an AIS 3 is unreasonable and therefore not acceptable. we are living in the acceptable boundaries of types of injuries that fall within the diagnosis or AIS 2 and 3. Can we accept with the injuries we have identified in the scope of an AIS 3? I think when we look at some of these injuries a bit closer, we might find some to be considered permanently debilitating with survival probable. Are you alright with that? If not, where would you draw the line? What are some of the % probability of death for these AIS 3 injuries? Survival is probable for AIS 3.

When we look at the list of AIS 3 injuries you will see that the ASTM F15.29 Subcommittee responsible for the content of ASTM F1487-11 has actually made many significant contributions towards eliminating hazards and severe injuries through general performance requirements. I stated earlier we have developed requirements to minimize the potential of skull fractures, lacerations, loss of an eye or damaging internal organs with our protrusion gauges and test methods. We have addressed the potential for head and neck entrapments and the potential for death because of anthropometrically designed torso and head probes and a test method. We have a swing impact or suspended component dynamic impact test to minimize impact injuries and recognize new products and materials that do not pose the same safety concerns of similar play events of 30 to 50 years ago. All this being said there will always be new challenges and opportunities when designing new innovative play component concepts and there will always be a number of serious and severe injuries and some deaths that will occur on even the most compliant playground.

We do need to agree on a vision for reasonable play equipment performance standards and then address the known hazards. At the same time, we must also understand children will continue to overestimate their abilities while testing their own limits. They will continue to learn and problem solve as they process the circumstances of a challenging situation. They are doing what each and every one of us did as a child and when these AIS 2 and 3 injuries occur they to will survive. Unfortunately some children will suffer some trauma, discomfort, and probably some temporary mobility challenges and the parents will also have to deal with some inconveniences. There will also be medical bills to pay but we all should have health insurance. We have to get over the notion every injury can be avoided or even should be. We cannot be held expected to protect every child from all injury. That is unreasonable if we are to hope for fun challenging free play opportunities our children all need and deserve.

CAN WE ELIMINATE SERIOUS INJURIES THROUGH LEGISLATION? The Next Step – The Path of Action Must be Based on Universal Terms and Definitions to Reasonably Reduce Playground Injuries.

Sunday, October 26th, 2014

CAN WE ELIMINATE SERIOUS INJURIES THROUGH LEGISLATION? The Next Step – The Path of Action Must be Based on Universal Terms and Definitions to Reasonably Reduce Playground Injuries.
By Kenneth S Kutska, CPSI
Executive Director
International Playground Safety Institute, LLC
July 4, 2014

Several months ago I ended my column with the following statement: “Assuming the ISO TC 83 terminology paper “Injury and Safety Definitions and Thresholds” is approved and published, I will discuss the terms and definitions for different types of injuries and break down each type into various levels of severity.” This document has been approved by the International Organization for Standards Technical Committee Technical Committee ISO/TC 83 for Sports and other recreational facilities and equipment, Subcommittee. I believe it is at their editor for printing where it will be given some sort of identification number similar to what ASTM does. I will share my thoughts on some of the terms and definitions within this document. I will try to relate how they may impact international standards related to child injury prevention in the future. My comments will primarily focus on fall related injuries and their relationship to the current international playground industry impact attenuating surface standards.

I begin with my perspective on how playground related injuries, and the different levels of injury severity, relate to a currently compliant playground surface systems. The question which needs to be answered is, “Do the current fall impact thresholds within these standards address the level of injury, specifically life-threatening and debilitating, these international performance standards (ASTM F1487, ASTM F1292, EN1176, EN1177, CSA Z614) and the CPSC Handbook recommendations are attempting to address. Each standard introduction and scope defines the objective of injury reduction while each one continues to admit there will continue to be many injuries sustained by children at play. Play environments are not, and should not, be inspected as if the inspector were an OSHA inspector in a workplace. Children are expected to challenge themselves beyond their current level of proficiency. This is all part of child development. We must find balance between safety versus risk versus hazard.

Some of these terms have been used synonymously and maybe after going this article you may change your mind on a few things. Let us first define an “injury,” but more importantly define the levels of injury severity we are most concerned with and want to address in our international playground related standards. Nobody wants a child to suffer a serious injury. What is a serious injury? It is easier to define than to accept when it is your child or grandchild on the receiving end of the pain and suffering.

Based on the new ISO TC 83 document; the terminology used to separate the severity of injury classes are defined as follows;

“Life-Threatening Injury: an injury to any part of the human body which are serious or resulting in permanent impairment, that would be categorized as AIS (abbreviated injury scale) of 4 (severe with survival probable) or greater.

Debilitating Injury: an injury that diminishes or weakens the human body and has a legacy of greater than 1 month and that could be categorized as AIS (abbreviated injury scale) of 3 (serious, but not life-threatening).
Note; debilitating injuries would include requiring surgery, concussions that require removal from play to medical attention.

Serious Injury: an acute physical injury requiring medical or surgical treatment or under the supervision of a qualified doctor or nurse, provided in a hospital or clinic and includes injuries such as burns, factures, lacerations, internal injury, injury to organ, concussion, internal bleeding, etc.”

While these definitions may give us some frame of reference, we still need more information to help guide the lay person and the medical profession. What does “removal from play to medical attention” mean? What constitutes “medical attention?” Are we talking about a physician or a school nurse? Both have a level of medical training. When we mention fractures under serious injuries, are we talking about any fracture or one that requires reduction through surgery? You will notice the categories, “life-threatening injury” and “debilitating injury” as it relates to the Abbreviated Injury Scale (AIS). The AIS system is a medical diagnostic and prognosis system. I foresee issues with the definition of serious injury and how it relates to the AIS. Additionally, there is some confusion between minor and moderate injuries AIS 1 and 2 and how the level of AIS defines the level of severity of a burn (as an example.) For burns the medical profession considers a 2nd and 3rd degree burn and then factors in the body part and the percentage of the body or part that is impacted. I see some subjectivity involved here, but the medical training of the evaluator, should address my concerns. This scale originated in the automotive industry, where the current surfacing thresholds come from, and has become recognized within the international medical profession and should serve us well as we move forward with the debate on what level of injury society is willing to accept. The risk of a fatality for each AIS is minor 0%, moderate 0.5%, serious 2.1%, severe 10.6%, critical 58.4%. This AIS diagnostic and prognosis system is defined as follows;

“The writing of standards and the elimination of hazards must have an evaluation system based on injuries. To this end a universal injury evaluation system both for injury reporting and scoping in standards will benefit all involved. The risk evaluation is based on scoring systems, which may vary by country. It may be considered whether those tools should be part of the Standards written by ISO TC 83. This threshold for injury would be acceptable in the scoping of national standards to ensure universality for elimination of hazards and risk evaluation. They may be mentioned in an informative annex or listed as reference.

Medical Thresholds and Diagnostic Tools
Abbreviated Injury Scale (AIS):
A numerical rating for quantifying the severity of injury to a human based on body region, anatomic structure, level of injury and injury severity that must be used in the scope of standards intended for safety or injury prevention. The range of severity is from 1-9.

Injury Severity Abbreviated Injury Score

Minor injury 1
Moderate injury 2
Serious, but not life-threatening 3
Severe Potentially life-threatening, survival likely 4
Critical with uncertain survival 5
Un-survivable injury (maximum possible) 6

The AIS system also considers
• different parts of the body
• the type of anatomic structure

Injury Prevention Thresholds for Scope of Standards
The scope of TC/83 calls for both product safety and promotion of trade and to this end the user of the products in the standards should be able to rely on credible standards to ensure them that claims of compliance to a standard will effectively protect them from hazards and harm within the context of acceptable risk. The scopes of standards must clearly state the harm and risk to which the consumer and user of a product is exposed.

The provision of definitions and thresholds are only valuable if they are used in the development of standards and used, particularly in the scope of standards intended to prevent injury. The prevention statement of the scope shall assist the manufacturers, test houses and legislators in understanding the intent of the standards writers and specify the limitations related to prevention of injury.

The definitions and a carefully defined scope must by extension focus the standards writers in their deliberations and development of those performance standards.

It must be noted that using thresholds, terms and definitions is not intended to reduce the challenge or enjoyment of a sport or recreation activity, but to raise the awareness of the need to accept risk, while working to avoid and limit risks in the context of reasonably foreseeable misuse.

This has and will continue to be a collaborative effort and should assist the sub-committees under ISO TC/83 and hopefully National and European Standard Bodies with similar scope as of ISO TC/83 to consider the need to harmonize terms and standards to assist ISO TC/83 in promoting international trade within the context of injury and risk prevention.”

Designers, manufacturers, owners and operators should not be in the business of eliminating risk but rather managing elimination of hazards and injury prevention to allow children to be children. There will always be some residual risk of harm in anything a child is doing within their immediate environment as they undertake the graduated challenge opportunities within the play environment.

How does this impact ASTM F1487 and ASTM F1292 standards now and in the future?

I am responsible for facilitating the discussion which determines the direction and content of ASTM F1487. I am also a voting member on the ASTM F1292 standard. F1487 requires compliance to ASTM F1292. The international standards industry has been using the maximum impact attenuating threshold of 1000 HIC (Head Injury Criteria) as the gold standard for a compliant playground surface system. Previously, I have discussed what this threshold means in terms of AIS in my previous column. Also, I have discussed what our standard scoping statements suggest we shall address. I am starting to believe that 1000 HIC does not address the level of injury we profess to address in our standard. We may be addressing the level of injury with regards to equipment performance, but the surfacing within our use zones is probably missing the mark, as the scope or the CPSIA are currently worded. It is time to say what we mean and mean what we say.

The obstacles to meeting or current scoping statements are;
• the need to reconcile the difference between the definitions for a “serious injury” according to the AIS System and the Consumer Product Safety Improvement Act and what our standard’s scope says.
• the playground industry’s agreement on the risk assessment process based on the possibility, probability, and level of injury likely from a fall to a surface just under 1000 HIC, which is a 16% risk of AIS >4.
• the need to accept the residual risk or harm after a risk assessment, which includes risk analysis and evaluation, has been conducted by the designer, manufacturer and owner and reasonable risk reduction or protective measures have been taken based on the intended use and reasonable foreseeable misuse of the equipment.

I believe we can make progress in providing more graduated challenge opportunities within the play environment while minimizing the liability exposure to designers, manufacturers and owners of public play areas if we can address these issues. Without some clarification to our playground standards scoping statements and performance objectives, the dark cloud of uncertainty will continue to inhibit our ability and desire to provide the types of age appropriate challenging and risky play opportunities for our children, the intended users, need and deserve. I will continue to work towards a solution and I urge everyone to get involved. You all have a dog in the hunt.

I leave you with this question. Can you define what tolerable or acceptable risk or to put it another way, injury threshold, is when it comes to your child? Are you willing to except a child’s accident resulting in a mild concussion or even momentary unconsciousness? Are you willing to accept a leg or arm fracture? If your answer is yes, are you also willing to accept the same consequences if the accident involves your child?

NOTE: You may have noticed some of the words were underlined. These words are just some of the terms defined in this new ISO Document.

Creating Conditions for Play: The Next Step in the USA

Sunday, October 26th, 2014

Creating Conditions for Play: The Next Step in the USA
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC

I recently read a great column by Jay Beckwith in the online Playground Magazine titled “Creating Conditions for Play.” His comments struck a nerve. After just finishing my last column related to some of the of the current playground surfacing issues and challenges we face in the USA I was finding myself pondering the current status of the public playground movement and where we seem to be headed in the future. I agree with everything he says in this article. He has laid out an interesting course of action for us all to consider. If you have not read his complete article I urge you to do so. There is however one thing I take some exception with and it is the reality of where we are today. We seem to have painted ourselves into a corner because of the constraints we have placed on ourselves or the limitations others seem to have put on our industry as unintentional as the outcomes of their well-intended actions may have been.
The USA has some unique challenges of which other countries around the world do not have to concern themselves. This is true so long as their manufacturers do not intend to sell their product here in the USA. We have some Federal requirements placed upon our child’s products industry that may be just considered “Best Practices” by others, but they are the law in the USA. The way play equipment and playgrounds are designed in many other countries reminds me of the playground industry back when I was a young school age boy. The industry did just about anything they wanted. They relied on their own common sense to guide their design and risk assessment of their product. They modified their products when they became aware of design problems and the resulting injuries. Those were the good old days. Litigation was not of major concern as parents and children took personal responsibility for their actions. All parties understood there was risk of injury during play. Parents did not always exercise proper supervision of their child because they could often go to the local park of schoolyard unsupervised. Children often made errors in judgment resulting in personal injury. Only in the last 30 or 40 years has the cloud of litigation cast a dark shadow over our children’s ability to experience their individual relationship with their environment during free play. Their environment was open and unstructured, even natural for the most part, with little or no rules to limit personal experimentation.

I would love to be able to turn the clock back to 1988 and start again with the ASTM process knowing what we know today and with the technology we have at our disposal. Unfortunately this is not the movie, “Back to the Future.” We did a good solid job over the past thirty years building a solid foundation for injury prevention. We did this from the ground up just as a good builder constructs a home it starts with a proper foundation. We gathered injury data and began to analyze the how, where, who and what was being injured. We created a sound database for the ergonomics of those most at risk of injury through the creation of a resource document for anthropometrics of the human body. This allowed us to design products that were user friendly and better designed for the intended user. We did a lot of research on child development. Maybe we should have placed more focus on understanding how play impacts human development throughout life? This earlier work, much of which was funded and developed by the U.S. Consumer Product Safety Commission (CPSC), set the solid foundation for the early standards work of the American Society of Testing and Materials (ASTM).

I draw the comparison of developing our current ASTM F1487 Standard and the playground standards development process to that of building a house. We must first have a solid foundation on which to build the house. Unfortunately we did not have a good set of plans for the long term future from which to start. We did however build a sturdy first floor of this structure with bricks and mortar provided by the CPSC. This solid foundation and first iterations of the ASTM F1487 and F1292 Standards thereby is making it more difficult to modify or mold into something more functional for the every changing needs of today. We did not have a clear vision and understanding for what this structure was going to look like and how it was going to assist with the developmental needs of all children when our initial work was finished. We also did not consider how we were going to maintain it or expand it if the need arose. Today as I look at the house we have built, I see many problems that were unanticipated 25 years ago. It has become difficult, if not impossible, to expand this house to meet the needs of children today? Continuing with the house building analogy, there does not seem to be enough property for future expansion to address the growing needs of our playground family. The weight of current addition after addition is creating concern for the structural integrity of the house and the foundation on which the couple of floors were built appears more and more obsolete for the future needs. The need to keep adding on and adding on is not going to stop and building codes are restricting our ability to remodel let alone expand much further and meet the needs of the family. This seems to be where we, the architects of the ASTM F1487 Standard, are today with the deliberations on future directions of the ASTM F15.29 Subcommittee. In a way our standards have become like some of the overly restrictive building codes of yesterday. In many jurisdictions it is very difficult to get any type of variance when some new product or technology comes along. That being said, some code requirements for fire prevention, electrical requirements and structural requirements are very important safety requirements that we would not wish to do without. Likewise eliminating sharp edges, crush points, head entrapments and protrusions that impale and damage internal organs are equally important. It is when overzealous building codes and the building inspectors go too far by requiring carpet over tile for flooring or white paint over beige on our walls that these code requirements go too far.

I have somewhat discussed this in my solid foundation and home building analogy above. Jay Beckwith talks about “Infrastructure” in his article. Jay writes,
“As the movement (Creating Conditions for Play) begins to gain momentum, there will be a need for supportive infrastructure. In the past safety and access movements, that infrastructure was provided by ASTM Standards as well as state and federal laws. While these addressed the issues, as they were perceived at the time, we now realize that this legalistic approach is less than ideal as it prevents the flexibility needed to adapt to new insights, innovations, and technologies. The new movement must learn from this past experience and find ways to implement best practices without writing them into law.

It is important to realize that for significant changes to occur on playgrounds, for them to look and function in new ways, the existing infrastructure will have to be addressed and updated. There have already been some movements in this direction. For example, in 2008 the European standard EN1176 was revised. Here’s a note I got from Mogen’s Tom Jensen regarding that change:

The 2008 revision of EN1176 seems to have created the platform for a significant shift of paradigm in that admissions to the necessity for being introduced to risk, the inherent risk in play, that accidents still exist and do happen, broken bones and the nonsense of comparing safety at work with safety at play, etc.

If you take a closer look at the European manufacturer’s web-sites, it’s clear that the standard itself is a lesser problem for designs and challenges provided, than the self-induced censorship by playground owners, “just to be on the safe side,” eagerly supported by playground inspectors without any idea about play but equipped with a measuring stick and a check list!

It would be very interesting to consider what would happen if public agencies here in the States would begin to accept the EN1176 as equivalent to ASTM. Not only would this allow for the importation of some very interesting new play apparatus, but it would also allow an escape hatch for US companies to create new equipment outside the straight jacket of the ASTM Standard. Such a change could provide a significant boost to this industry.”

This is where I have to take some issue with the Beckwith’s approach for the future. We need to address all the things he has suggested however there is the need for cooperation among many government and legislative bodies to undo some of regulations we have in place. I have often heard it said that to change something so engrained in our everyday life, such as the CPSC Handbook for Public Playground Safety, it may take an act of Congress. In this case, I am afraid it might, since Congress created the CPSC and the CPSC’s Consumer Product Safety Improvement Act (CPSIA) of 2008. The requirements of this Act apply to all children’s consumer products and therefore applies to all playground surfacing systems and playground equipment. I think this is where an “Act of Congress” might have to become reality if we are to ever put Beckwith’s suggestions into practice in today’s regulatory and litigious environment. I believe the Act has set the bar too low for what is considered a serious injury and what costs they might impose on the industry in an attempt to reduce or eliminate certain types of injuries.

If you have not read the CPSIA I suggest you go online and download it for your reading pleasure. It is impacting all of us and in ways we are just beginning to understand. It is ties our hands and stymie’s our creativity as decisions are being made based on the avoidance of potential liability. These decisions are for the most part business decisions which are easy to criticize by those who wish to push the creative envelop and yearn for the good old days before the proliferation of lawsuits and quick legal settlements. These decisions, for the most part, impact everyone’s bottom line and have become the easy answer for most entities. Unfortunately the children are the ones who lose because these decisions result in the elimination of many different and much needed innovative play opportunities being designed today.

Beckwith also discussed “Safety and Choice” when it comes to play areas of the future. He writes,
“We started this discussion talking about the role of safety and choice as being the fundamental conditions for play. More choice for kids will come more from educating parents and society about the need for play than by any new innovations in playground equipment and design. Improving safety can take many forms. For example, using mobile technology and social media to monitor children, can be both non-invasive and very effective thus allowing children more free roaming in their neighborhoods. A discussion of safety can also be part of the whole consciousness raising process whereby we take a critical look at our assumptions. For example, a sport-related injury is looked on as just a part of the game, but the same injury on the playground is to be somehow prevented by laws and standards.”
The goal of the new playground movement should be to increase children’s play choices and taking a broader, and more effective, approach to safety. The steps needed to achieve this are: 1) get the word out, 2) provide ready access to best practices and core information, and 3) leverage the existing successes and social media.”

Playground related injuries will continue to occur regardless of how diligent an effort our stewards of the public play environment put forth. We, as a society, have to learn to accept many of these injuries as a part of everyday life, especially when it comes to child development. Research more than suggests the developmental benefits of risky play are too important to ignore. I think we could actually attain Beckwith’s vision once everyone accepts a certain frequency and severity of injuries as a reasonable outcome of child’s play regardless of the environment as long as the court system understands and supports the benefits of risky play even when some play results in injury. When it comes to the public awareness aspect of Beckwith’s goals for the new movement we will need to rely on the various government entities best suited to educate all of society. We have to encourage them to take up this challenge to educate the masses. I suggest the CPSC, the Center for Disease Control (CDC), and the State Departments of Health along with the Departments of Education are best equipped to meet this challenge. The real question is are any of these groups willing to accept this challenge? The public education aspect of Beckwith’s vision is not within the scope of most playground safety standards organizations with the exception of maybe the CPSC. That being said there is still a lot we can do help the cause and promote the value of free play. Once the courts system and the general public accept the fact that many injuries are part of childhood development and growing up the various standards development organizations can focus on the true hazards within the public play environment. The key to the success of this vision for the future will require those responsible for managing these public areas to do their part in maintaining the areas free of know hazards.
Next month I will finally be able to discuss the International Standards Organization Technical Committee 83 (ISO TC83) on Sport and Recreation’s N312 Report on Definition/Thresholds to be utilized by National and International Standards bodies within the scope of TC83. Playgrounds are within the scope of the ISO TC83. I am optimistic this terminology and definitions will bring clarity to our mission as international standards organizations and the architect responsible for the future standards and best practices of children’s play spaces.

Clarifying Compliance to Playground Related Surfacing Standards

Sunday, October 26th, 2014

Clarifying Compliance to Playground Related Surfacing Standards
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
May 10, 2014

If you are a playground owner, it is important to understand how squarely behind the 8 ball you are when it comes to standards. I apologize for all the technical details to follow, but it is important.

While traveling home after the May 7 and 8 Toronto ASTM Committee meetings I started this column to try and capture my observations from all the meetings. One thing I observed was drop testing done by the F8.63 Subcommittee responsible for the ASTM F1292 Standard. There were 7 different Triax used to conduct a series of tests on the same test pad. This was a new pad made of a more dense materials that should result in a consistent and repeatable drop test result assuming all the Triax equipment was properly calibrated. The testing followed the ASTM F1292 field test protocol for consistency and relative accuracy to the real world. The premise of the test was to determine whether the test equipment has too large a variance in test results from one device to another or is the variance due to an inconsistent surfacing material used for conducting the laboratory test results versus the Triax field test results conducted on-site immediately after the same surfacing material has been installed. The results of the Toronto drop tests showed a 2% difference from the high to the low individual drop test results. This was based on 21 total drops on the same test pad. Bottom line is the differing values derived from field tests when compared to laboratory tests appears to be more related to how the installation of the surface system was done in the lab versus the actual on-site installation. Which test results are more important to the owner of the playground? After a serious injury which result will the judge and jury consider most important? There are many variables that can impact test results in the field and that is troubling since the owner has to maintain the system in compliance or remove it from use until it can be brought into compliance. What can we do about this from a standards based approach to assure compliance?

To put the remainder of my comments into perspective I will start with the following analogies to bring into perspective the current debate on injury prevention within the public play environment. We have heard many stories related to the successes of the automobile industry’s efforts to reduce death and severe injuries resulting from automobile accidents. Driving does not relate well to some when it comes to injury prevention in playgrounds and playground regulations. Never the less we do not remove our seatbelts or disconnect our airbag system just because we have not needed to use either. Today these passive safety features are in our cars because research demonstrated impact thresholds could consistently be reduced and thereby reduce the potential for the types of catastrophic injuries. So instead of the comparing the playground surfacing industry to the automobile industry let me try this comparison on you. I have been taking Statins for years as a preventive measure recommended by my Doctor to maintain my cholesterol at an acceptable. This risk assessment was recommended by my Doctor since I had a history of heart related issues in my family. In spite of all the running and exercising I use to do 70s and 80s my HDL and LDL numbers were elevated. Back then the recommended range for HDL and LDL levels were higher than what is recommended today. Even today the debate on what these numbers should be or whether or not these numbers are true markers for the likelihood of heart problems are still be challenged by some. Whatever was considered to be a good or bad numbers 30 years ago are not close to what is being recommended today? I did not try and rationalize not to take my Doctor’s recommendation that I should modify my lifestyle and start taking his prescribed drug treatment. I could have argued that I was grandfathered in 10 or 15 years earlier when my numbers were only slightly high. I did have a choice but I did not think it was a rationale one. We usually listen to our Doctor since they are the experts. Most of us change or lifestyle habits based on research results and recommendations from people who know far more than we do when it comes to the medical profession. Everything seems to change when information presents a good reason to do so and the heart association raised everyone’s awareness of healthy living and using drugs like Statins to reduce and control cholesterol levels. Just because your airbag has not been needed does not give reason to disconnect it or underestimate its value and to society as a whole who would not have to bear the cost of a lifetime of treatment should you become incapacitated. For the record my current HDL and LDL numbers are even within the new lower consensus numbers being recommended by the medical profession. I often wonder what might have happened if I had not taken my Doctor’s recommendation some 30 years ago? Let’s get to the subject related to public playgrounds.

For more than 40 years the U.S. Consumer Product Safety Commission (CPSC) and many other organizations have been gathering and analyzing playground injury data. Throughout this time, user impact with the surface has been the leading cause of playground injuries requiring medical attention and continues to be one of the four leading causes of death. This is not a new revelation. While the debate on whether the percentage of fall related injuries has increased or decreased the fact remains falls and impact with the surface are still the number one cause of injuries requiring medical attention.

Since the beginning of the playground standards and guidelines development, some 40 plus years ago, our industry has used the best research information available as the foundation of our final recommendations. When American Society for Testing and Materials (ASTM) F8.63 was given by the CPSC a test method and minimum acceptable performance threshold to minimize the likelihood of life-threatening head injury they took the recommendation from the CPSC for 200g and 1000 HIC. The rationale used to establish these first performance thresholds continues to be used by all international playground standards organizations. Unfortunately there has been no measureable reduction in the number or severity of fall related injuries.

Both the F8.63 Subcommittee, responsible for the ASTM F1292 Standard, and the F15.29 Subcommittee, responsible for the ASTM F1487 Standard, continue to debate and discuss what the acceptable performance requirements should be within their respective documents. Who controls this debate? Who should control the outcome of the debate? The answer is easy. The children impacting the surface should control the outcome through the ASTM voting process but that is not how things are done. This ongoing debate may have a significant impact on the outcomes of the ASTM F1292 and F1487 Standards but the few ASTM members who attend these meetings have the final say so. I would suggest that all Subcommittee members be allowed to vote electronically on whether or not negative votes are persuasive or not. This is a problem for the standard development process no matter which side of the vote an individual is on. Why should the deliberation of the few present at these meetings control the outcome? These meetings are rather expensive to attend when you factor in all the expenses with airfare, room, meals, and loss of income while at the meeting. I urge you to join ASTM and join these committees.

ASTM F15.29 is currently working on redefining its overall scope as it relates to the performance requirements. Our mission is to address known hazards that result in a level and frequency of injury identified in the ASTM F1487 Standard’s introduction and scoping statement. ASTM F15.29 has already addressed one form of impact hazard related to swings and other suspended components by reducing the impact threshold allowed in the surfacing impact attenuation standard 50% to maximum of 100g and 500 HIC. Since this revision applies to the performance of equipment it falls under the purview of ASTM F15.29. ASTM F08.63 Subcommittee which by its scope is to provide both a test and minimum performance requirements has had two attempts to reduce the impact threshold to 700 HIC which would reduce Gmax to approximately 115 – 125 but both attempts have failed. The most recent ballot was to reduce the HIC to 700 for both preschool and school age user groups. While there were enough affirmative votes cast by the Subcommittee ballot to begin to address the few negative ballots there was not the 2/3 affirmative vote cast at the recent meeting in Toronto to find the first negative vote non-persuasive. Therefore the ballot item is stalled as the result of the affirmative vote outcome being less than the 2/3 majority vote requirement. There were approximately 30 people in attendance who actually voted which is not an overwhelming number when you look at the total number of F8.63 Subcommittee voting members. The bottom line is the debate will continue but who should have the final say so as to the impact thresholds? The F1292 scope is to address a test method and threshold. The current threshold, from cadaver and primate studies in the automotive industry has proven to be woefully inadequate. Thankfully there is not a large number of deaths when you look at the total number of injuries requiring medical attention. One thing everyone needs to understand is that while we have not reduced the current impact threshold in ASTM F1292 there is one requirement in that standard that significantly effects each owner of a public playground and the manufacturer of the equipment within that playground. F1292 states it is the owner/operator’s responsibility to maintain the surface in compliance throughout the life of the playground and when tested in accordance with F1292 it is found to exceed the impact thresholds of 200g and/or 1000 HIC it be taken out-of-service until it can be repaired and brought into compliance. The requirement to know this on the accessible route is part of the 2010 ADA standards and F1487 requires that the surface be maintained to F1292. This can only be addressed with impact attenuation performance testing conducted in the field. Owners are sticking the heads in the sand, so to speak, if they do not already conduct this testing in the field to assure performance requirements whether it is prior to first opening the play area or at some interval of performance field testing throughout the life of the playground. F08.63 Subcommittee members understands this. After all they wrote it but when something goes awry who will be held accountable for less than acceptable impact attenuation performance?

The owner needs to understand the existing and future revisions to all the standards within the purview of these two ASTM Subcommittees continues to hold the owner/operator responsible for attaining and maintaining the minimum requirements of these standards after installation or they have the responsibility to take the playground out-of-service until the equipment or surface are brought into compliance. There appears to be some disconnect between the two ASTM Subcommittees which occurs immediately following a serious injury. When someone falls off a piece of playground equipment the question becomes what caused the injury? Was it the equipment designer/manufacturer’s fault for creating too challenging a design or was there some design or manufacturing flaw in the product? Either one of these scenarios might bring the Consumer Product Safety Improvement Act (CPSIA) of 2008 into play. Potentially the owner is at fault for selecting the specific piece of equipment in the first place however, maybe just maybe, it was a lack of adequate impact attenuating surface performance? Without a field testing compliance document there is no way to know for sure. I would like to suggest it might be the limiting capabilities of the current impact attenuation performance thresholds? It appears we have come full circle back to the age old question of which came first, “the chicken or the egg?” More important to these questions is who gets to answer these questions?

There is a general lack of knowledge by many owner/operators as to what these playground equipment and surfacing performance standards actual say? Do you know what these standards imply to each party involved in the management, design, layout, installation, inspection, maintenance, repair and ultimately replacement of each and every public playground?

Those responsible for producing playground equipment and playground surfacing systems must be required to provide all information necessary to maintain the playground in compliance with all the standards that apply to public playgrounds if the playground owner/operator is ultimately the one that is accountable for the safety of the users.

This information is important to the owner/operator and designer and it is needed in order to make an informed purchasing decision. These decisions should be based on the owner knowing how the surfacing and equipment is expected to perform and the requirements necessary to assure performance throughout the life of the playground and not just on cost. The owner needs much more than just the critical height of the surface system. The surface system manufacturer/installer must provide in writing all requirements and detailed instructions for proper installation, inspection, maintenance and repair of the system throughout the reasonable projected life of the playground. Field performance, compliance testing, and some reasonable performance based, multi-year warranty to comply with performance standards must also be provided to the owner, if not required by the owner.

If the ASTM F1292 Standard can state in Section 4.4.2, “When an installed playground surface is tested in accordance with this section, if the impact test scores at any tested location in the use zone of a play structure do not meet the performance criterion, bring the surface into compliance with the requirements of this specification or the play structure shall not be permitted to be used until the playground surface complies” then why should the ASTM F1487 Standard not be responsible for stating the who, how, what, and where requirements for surfacing compliance within this standard. There has been an long standing reluctance on the part of the F08.63 to make the field test a requirement for compliance to F1292. It is just an option available to the owner who must then follow the test method as described within the Standard. The reality of not performing compliance field testing does not say that the playground and/or surface cannot be used, just there is no written documentation for proof of compliance after installation as is required of the owner by the ASTM F1487 Standard.

The documents needed by the owner has to include information related to installation, safety performance, inspection frequency, routine and foreseeable maintenance requirements, and repairs; required to keep the system in compliance with the various playground surfacing standards.

ASTM F1292 also states in Section 4.4.3
“More Stringent Specifications—The specifier is permitted to specify additional impact attenuation performance requirements, providing that such additional performance requirements are more stringent than the performance requirements of this specification.”

ASTM F1487-11 Section 9 Play Structure Use Zone states,
“There shall be a use zone for each play structure which shall consist of obstacle-free surfacing that conforms to Specification F1292 appropriate for the fall height of the equipment. The dimensions and configuration of the use zone shall be dependent upon the type of play equipment, as specified in Section 9. Use zones of certain types of equipment may overlap unless otherwise specified”

ASTM F1487 Section 10.1 states.
“Playgrounds shall comply with the DOJ 2010 Standard for Accessible Design where applicable”

This means firm, stable, slip resistant and level within the requirements within the DOJ 2010 Standard.

ASTM F1487 Section 13 Maintenance states,
“13.2 Protective Surfacing:
13.2.1 The owner/operator shall maintain the protective surfacing within the use zone of each play structure in accordance with Specification F1292 appropriate for the fall height of each structure and Specification F1951 where applicable.
13.2.2 The owner/operator shall maintain the protective surfacing within the use zone of each play structure free from extraneous materials that could cause injury, infection, or disease.
13.3 Records—The owner/operator shall establish and maintain detailed installation, inspection, maintenance, and repair records for each public-use playground equipment area.”

CPSC Handbook states on page 8,
“Section 2.4 Surfacing – 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.

The most widely used test method for evaluating the shock absorbing properties of a playground surfacing material is to drop an instrumented metal headform onto a sample of the material and record the acceleration/time pulse during the impact. Field and laboratory test methods are described in ASTM F1292 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment.

Testing using the methods described in ASTM F1292 will provide a “critical height” rating of the surface. This height can be considered as an approximation of the fall height below which a life-threatening head injury would not be expected to occur. Manufacturers and installers of playground protective surfacing should provide the critical height rating of their materials.”

CPSC Handbook Section 4.1 Maintenance Inspections states,
“A comprehensive maintenance program should be developed for each playground. All playground areas and equipment should be inspected for excessive wear, deterioration, and any potential hazards, such as those shown in Table 3 (Specifically Problems with surfacing i.e. displaced loose-fill surfacing, holes, flakes, and/or buckling of unitary surfacing). One possible procedure is the use of checklists. Some manufacturers supply checklists for general or detailed inspections with their maintenance instructions. These can be used to ensure that inspections are in compliance with the manufacturers surfacing specifications.”

Based on the above information and the lack of continuity and consistent intent of these documents there needs to be effort to clarify specific responsibilities of the playground owner and the supplier of the play components and impact attenuating surfacing required within the use zones of the play area.

My final thought is if ASTM F1292-13 Standard Section 4.4.3 states, “More Stringent Specifications—The specifier is permitted to specify additional impact attenuation performance requirements, providing that such additional performance requirements are more stringent than the performance requirements of this specification.”

Then why should the specifier and/or owner, not be allowed to specify the performance threshold regardless of the recommended threshold in the ASTM F1292 Standard? More importantly, why should the ASTM F1487 Standard whose scope is to reduce all serious injuries be accountable for establishing an impact threshold that will address these injuries related to falls? The responsibility for establishing performance requirements for both surfacing within the use zones of public playgrounds as well as the playground equipment should be within the F1487 Standard’s scope as it relates to injury prevention.

The ASTM F08.63 Sub-committee must realize they have developed an extremely well scrutinized test and device that is used regularly in other ASTM Standards such as wall padding and pole vault and each have their own performance thresholds. This test device with its 4.6 kilogram hemispherical missile, or headform as we often refer to it, is migrating to the ASTM F355 test method and is may make ASTM F1292 less relevant. Many other ASTM Subcommittees related to sports surfacing and equipment have lowered or are considering lowering their Standard’s impact attenuation thresholds. As a result of these actions why should the F15.29 Subcommittee not undertake the responsibility for setting in the field playground surfacing performance thresholds for public playgrounds under the purview of F15.29 which is already responsible for establishing performance requirements for; materials used in the manufacturer of play structures, structural integrity loading requirements, equipment use zone requirements, specific equipment requirements and other requirements related to installation, maintenance, inspection, documentation, information and warning signs and other hazards potentially found within the playground use zone?

This will become the next debate. What do you think?