Archive for June, 2015

Access to Play for All 101

Tuesday, June 16th, 2015

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

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


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

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

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

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

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

Milestones to Access for All – Historical Perspective

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

The Evolution of the Access for All Movement

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

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

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

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

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

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


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

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

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

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

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


START WITH: The Need for Accessible Play Opportunities for All

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

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

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

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

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

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


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


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


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

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

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

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

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

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

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

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

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

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

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

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

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


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

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

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

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

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

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

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

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

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

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

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

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

Eight Principles for Inclusive Design by Boundless Playgrounds

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

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

3. Diversity of movement sensations and experiences

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

5. Opportunities to play autonomously, alongside and with peers

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

7. Addition of semi-enclosed spots

8. Rigorous and challenging places to play

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