Archive for January, 2018

December 7, 2017 Meeting Report from November 22 & 23, 2017 Bilateral Americas Conference for ISO TC83/WG8 Playgrounds Opportunities toward Harmonization of Standards in Playgrounds

Sunday, January 14th, 2018

Bilateral Americas Conference for ISO TC83/WG8 Playgrounds
Opportunities toward Harmonization of Standards in Playgrounds
Meeting Report

Opening Remarks
The meeting began with the introduction of the attendees including those on the telephone and Webex followed by an introduction by Rolf Huber to the discussion for the next two days. The list of attendees is attached. The discussion included the history of the proposal by Germany to produce an ISO playground standard and the resolution of TC83 to establish a Working Group (WG) to investigate the need for a global ISO playground standard, within a provisional work item. We shared the conversation that this will be a multi-year effort, providing the opportunity to review the original need for playground injury prevention standards, a discussion on whether the current standards have met the original goals and what might be the options for harmonization. We further explained there is not a mandate to write an international standard, but to give a sincere effort to investigate what can be harmonized potentially to an ISO standard and what might remain in the national prevue.

Rolf Huber brought the gathering up to date on the discussions that took place in Berlin at the first meeting of WG8. That meeting agreed that there shall be the prevention of serious harm within the context of provision of challenging playground equipment and playspaces. At this meeting there was a two pronged approach, the first being proposed by the German delegation to compare existing, En1176, ASTM F1487, CSA Z614, Australia, Japan and others, while the second is setting the priorities for the injury prevention that is to be provided in Standards. These are prevention of injuries related to death with the need to prevent serious injury such as entrapments and entanglements, fall prevention and impact attenuation of surfacing, and sharp and rough edges. The strategies to achieve these include, but not limited to improved inspection, maintenance and impact attenuating surfacing.

Ken Kutska provided an in-depth history of the need for injury prevention in playgrounds in the United States. The highlights of the presentation are that for the prevention of injuries the main causes were the design and construction of play equipment, falls to the surface, inspection and maintenance and reasonable foreseeable use. The development and implementation of standards around the world went a long way to resolve the design and structural issues related to injury prevention. What remains are issues with impact from falls, maintenance and inspections.

Ken went through the history of the development of standards, starting in 1974 to the present day chronicling the CSPC and ASTM process and related issues such as the American with Disabilities Act (ADA). Key to his presentation was that “not every child should be able to do 100% of the play events on any given day. Child’s ability to experience failure in a reasonably safe environment is very important to their development.” This was coupled with the new initiative in ASTM F1487 to have designers document a hazard identification and risk assessment under the relatively new addition listed in section 1.6.1.

Vic Hergott provided an overview of the development of the CSA Z614 during the 1980’s and publishing of a Guideline initially in 1990. This led to an awareness program he presented for many years “It’s Time to Stop Playing Around” to raise the issues of playground injuries and point out the serious need for injury prevention. This program eventually also became a video that went a long way to raise the awareness of issues in the playground. The 1990’s brought positive change moving to a more prescriptive “standard”, but he wonders if being prescriptive has limited creativity and opened the door to more litigation. He expressed a concern that there is a problem with inactivity, obesity and other negative factors associated with the lack of challenging playgrounds. There is a need to engage children in challenging play that they direct and allows creativity within a level of injury prevention.

Dr. Leticia Ryan was asked to speak to the injury threshold that would be acceptable with the medical community, and society. She also gave insight to the mechanisms of injuries in playgrounds and focused the discussion primarily on head injury and bone fracture. To this she provided the following;
 We discussed the impression of some that injures are a rite of passage during childhood and the general challenges in defining a threshold of acceptable injury? Fatal injury is a rare consequence of playground play, but broken bones (usually from falls) are a relatively common occurrence.
 Of children hospitalized with playground injuries, published data show that fracture of the upper extremities accounts for 68%, concussion accounts for 8.5% (usually sent home but extreme cases admitted), and fractures of the lower extremity account for 9.1%. There are approximately 9000 cases/year hospitalized – National Electronic Injury & Surveillance System (NEISS) data base.
 When is a child’s injury ‘serious’? One measure is the Abbreviated Injury Score (AIS), with an AIS of greater than or equal to 3 consider “serious”. AIS is assigned by coders who have been trained to assess the data. Another measure to consider is hospitalization; injuries resulting in hospitalization are likely more serious and associated with risk of mortality and morbidity. We can distinguish complicated fractures (fracture needing a reduction of misaligned bones or “open” fractures that break through the skin) from simple fractures. Complicated fractures are associated with more risk. For instance, if a child needs to be sedated to set a bone, this introduces a new risk from the anesthetic. Similarly, open fractures have an increased risk of infection. Head injuries can also be distinguished based on the presence of bleeding within the brain although concussions, despite not having such intracranial bleeding, may have long-term cognitive repercussions.
 Concussion/Traumatic Brain Injury (TBI) – There are a variety of definitions. The Centers for Disease Control and Injury Prevention (CDC) defines concussions as “a type of traumatic brain injury – or TBI – caused by a bump, blow or jolt to the head or by a hit to the body that causes the head and brain to move rapidly back and forth”. There is increased awareness of concussion and parents are concerned and asking about concussions when they bring their child to get checked after a fall. CDC guidance for parents on how to identify concussion/TBI. Concussion, depending upon severity is most commonly considered mild TBI, but every concussion is a brain injury requiring assessment and treatment. Treatment might just be removal from play and brain rest. There is a particular concern for children who sustain “concussion on concussion” – i.e. a second concussion before the brain has healed from an initial concussion, and can result in impairment. This can be challenging with children where symptoms such as behaviour changes might not be as readily observable. Kids need brain rest to heal the brain for a period of at least 2 weeks.
 Moderate to severe TBI – may have bleeding on the brain. Other consequence of head injuries include exposure to radiation if CT scans are obtained. Studies are now concerned about kids getting CAT scans due to a potential for increased cancer risk. Consequently, clinicians may rely on physical exam findings and observation in the emergency department – based on a research-informed decision tree – and then educate the parent that the scan is not required if it is deemed to be mild concussion.

Tom Norquist spoke of the need for challenging play equipment to ensure we keep play in the playground and potentially focus the location of play and the resulting potential for injuries to a location that is within public sight and they can be responded to. This could be in a park, school ground or child care, with the latter having a degree of supervision that would respond to an injury. He pointed out that children do not play within a set of rules and play is not a learned skill, but a complex development of knowledge of one’s abilities, physically, mentally, socially and emotionally. Success and failure is a consequence of the playful learning experience. He also pointed out that children may develop skills where they apply their own experience and culture to use that structure in reasonably foreseeable and sometimes unintended ways. He had numerous pictorial examples of play not as intended. This led to a discussion that owners and designers must look at both their intended design and consider what occurs when the child stretches the design to other uses. How does that affect the recommendations of the manufacturer for how the play structure is situated in the playground or playspace as related to other play structures or the performance of surfacing? He pointed out the very real concern for manufacturers of playground equipment that injuries do not only have a potential financial cost through litigation, but a manufacturer may run afoul of the US CPSC with a product recall that can have large financial consequences, based solely on the CPSC’s own investigation and definition for serious injury.

Another aspect with Tom’s presentation was what is acceptable and not acceptable from the point of view of use. This is a critical facet of any hazard identification and risk assessment. He also touched on how the age of users of the playground has changed over the years and where there might once have been a trend to graduate from the playground to sports, there is now an older and bolder group using the playground in the manner they see fit. This is likely more to do with the aspect of climbing and socializing within the play environment. The discussion around this discussion was that we cannot overlook the impact for those countries that require access to all regardless of ability. The consequence of the need for barrier free design has unintended consequences by placing some of the youngest and most vulnerable user’s at risk of unreasonable injury.

Doug Nix has become involved directly within the sport, play and recreation side of hazard identification and risk assessment through an invitation of the CSA Z614, ASTM F1487 and ISO TC83, WG6. His extensive experience in the machinery sector has made him a unique asset to this group. Doug spoke both about the need to consider international developments and the need to find balance between the aspects that can be harmonized and those that reflect and remain in the national interest.
Doug spoke of the need for;
 Development of a suitable risk assessment scoring tool for play equipment and playgrounds. The severity scale will need to be aligned to injury criteria that can be accepted by all stakeholders. Use of existing HIC and AIS categorizations is a starting point.
 Risk assessment/risk management outline. Many regulations are becoming less prescriptive and more risk management/assessment.
 Manufacturers need to design out as many hazards as possible following inherently safe design practices that are outlines in a Hierarchy of Control (see ISO 12100.2010). Integration of equipment during the design, and construction stages or playgrounds, and the installation of play equipment is key to reducing risk to playground users. Errors that introduce uncontrolled or poorly controlled risk in site designs may create hazards that equipment manufacturers could not be expected to reasonably foresee.
 Risk assessment documentation is key to showing due diligence, i.e. documentation providing details. Risk assessment should be part of every stage in the design and development process. Stakeholders should be involved, especially in the concept and design phases to identify the level of risk tolerance they have, as well as the degree of risk and challenge they want, want given the space available and user group(s).
 Level of risk tolerance – if different between North America (NA) and European Union (EU) might be considered a barrier of trade – if NA wants to prevent serious injury vs EU who don’t want to kill kids. Canadian European Trade Agreement (CETA) – need to eliminate technical barriers of trade, – not increase them. Harmonization of conformity assessment techniques is also mandated (See CETA Chapters 4 and 21).
 Inspectors should have recognized credentials, Recognizing what those credentials are and how they are certified and by whom needs to be identified and put into a standard. Standard Council of Canada operates an accreditation program that could be the basis for accreditation of inspectors and certification bodies in the playground sector. Any accreditation program for inspectors would need to conform to ISO 17024 for certification of persons, but could be designed to focus on the key aspects of playground safety deemed relevant by sector stakeholders. Certification bodies could also be accredited to ISO 17020. Also laboratories performing testing and inspections could also be certified to ISO 17025. EN1177 requires compliance to ISO 17025.

Following Doug and appropriate to the hazard and risk discussion was the presentation by Milton Chapple, general counsel to IPEMA (International Playground Equipment Manufacturers’ Association).

His presentation covered;
 Everyone involved in the stream of creating a playground all carry some level of liability for the standard of care – designer, manufacturer, constructor, inspector, and owner.
 What is standard and duty of care or failure to exercise duty and must show that there is actual damage – plaintiff must prove failure. Foreseeability is also a legal obligation. Negligence (failure in duty of care) reasonable person would expect or not expect to occur. There are different legal environments EU/CA and US and this needs to be fully fleshed out.
 In US the juries may not always follow the law but are sympathetic to plaintiff and make big awards. Very litigious. Different legal systems and different burden within the law and whether there is a jury or not.
 Settling – gives you certainty and a definite cost. Risk of going to final lawsuit is unpredictable even when you have compliant product. Plus the cost of legal work going to trial. Judges don’t reign in the juries when they should in many cases. Going to trial it becomes a sympathy thing and most lawyers recommend to settle the case early on.
 EU law – requirement in liability directive – manufacturer puts the CE mark which shows that the product is safe. Plaintiff then has to prove cause and effect linkage, i.e. defect in the product. Therefore a lot fewer lawsuits in EU.

These presentations led to a very stimulating discussion and day ended at 5pm and much of the discussion continued into the dinner that was attended by most participants.

Day two began with a presentation by Lloyd Reese with regard to the anthropometrics being used in playground design. Designers must understand the dimensions that allow children to function within their physical abilities in the playground. It is important to understand that the dimensions that are used today are more than 50 years old and the world has changed since them. New studies in Europe might bring new information for future designs. One item that is problematic for an international playground standard is that countries like Japan recognize a different size for head and neck entrapment. Since ISO standards do not allow for deviations as the CEN standards do, this could be problematic for an international standard. It would be incumbent upon those reviewing the standards to determine if there are other national or ethnic groups that have similar issues. Since this related to life-threatening safety of the child, this cannot be ignored. Finally, anthropometrics do not go to any understanding of how a child uses a playground and reliance on anthropometrics does not go very far beyond the physical structures in prevention of injury once the child enters an appropriately designed playground. Anthropometrics also do not help in understanding the nature of the body to resist injury and therefore compliance with anthropometrics does not help with injury prevention such as falls.

The presentation by Christine Simpson on age groups and age appropriate design stimulated significant discussion that generally provided consensus that current age grouping of 95th percentile 18 months or 5th percentile 2 year old to 5 year old and 5 year old to 12 year old are likely not appropriate today. At a very young age children have needs that require specific types of play, but shortly after 3 years, ability will drive play. As a result play structures might be better defined by ability. The barriers to ability within the playground and play structures is generally achieved through the provision of physical barriers. In a time when playgrounds must provide greater accessibility, the erection of physical barriers is in conflict with placing access barriers based on ability.

The siting of a playground, whether it be a school or park, age or ability will have a different approach. In the school there are concentrated clusters of children that are directed to a segregated playground that has been designed with the input of school personnel to be most appropriate for the school grade of the user, rather than the age. Another advantage of a school system is that play is supervised. This supervision is not to direct play, but to ensure that children of certain abilities based on school grade use playground equipment that generally meets their abilities in relation to injury prevention. Schools have a significant stake in the prevention of injury that is related to function of the equipment and provision of supervision.

Parks and other open public settings, including school sites that are accessible during off hours do not have the advantage of supervision and therefore designing to the ability of the child is most important. Although parental supervision might assist in identifying vandalism and prevent hazardous behaviour, parents are often a problem in the playground by providing assistance and placing the child in hazardous situations that can result in an unreasonable injury that would have been prevent if the child was left to their own abilities. It is important that owners work closely with designers to provide playgrounds that are appropriate to the needs of the children. It was pointed out that children over the age of 3 often find the 2-5 year structures as boring and are drawn to the 5-12 structures. Tom Norquist stated that as a designer he has observed children 5-8 taking challenges on equipment that requires upper body strength such as overhead events and failure may results in broken bones that are often unacceptable, being serious to severe. There is a balance between the need to elevate the body and the impact attenuation of the surfacing as determined by g and HIC values. Lowering the height of equipment and modifying landing areas, while still providing function is important; however in these areas where there is a higher probability of falls, the impact attenuation values must be as low as possible to prevent fractures, possibly a g value below 100.
A suggestion was to consider that the lower end of the age group for public playspaces and equipment be 3 years and the upper send may well be up to through 14 years of age as per the CEN Guide 14 “Child Safety Guidance for its inclusion in Standards or beyond. This recognizes that older children are remaining in the playspace as an unstructured setting rather than moving on to rule based games and sports. For some of the older groups they are involved in other unstructured activities such as skateboarding and cycling where there is an understanding and expectation of injury and therefore do not attract the same degree of litigation as does the playground.

Accessibility plays a positive role in the playground, bringing children of different abilities to the playground or allowing caregivers with diminished abilities to participate in their children’s play. Most playgrounds use transfer systems along with low rises and wide stairs and step platforms along with ramping. While these structure components provide greater access they also provide access by very young toddlers and encourage unsafe play by older children using skateboards and bicycles. Most disabilities (over 50%) are cognitive and not physical and the provision of accessible playground focuses on the physical barriers. The requirement in the United States is that the Department of Justice and the 2010 ADA Standards for Accessible Design focus and mandate ambulatory solutions. Accessibility is also mandated by CEN Guide 14 Child Safety Guidance for its inclusion in Standards as related to children under 14 years of age. This often does not allow for the balance of designs that are to limit access to parts of the play structures that are injury driven.

The range of abilities found within the playground are likely one of the biggest considerations in the renewal or rewriting of standards. This goes back to the “scoping statement of the first meeting of ISO TC83 WG8”, that playgrounds must prevent serious harm, while keeping in mind the need for challenging play and play structures. This balance will be a major challenge for standards writers into the future.

The afternoon discussion began to focus on the areas that the experts felt harmonization could potentially be international. This also included a discussion on factors that should remain with a national domain. This may lead to a need for two tiers to playground standards. The group used flip charts and “brainstorming” to develop ideas. The result was;
Develop an ISO “toolbox” for determining measurements.
 Probes and devices that are used for measuring aspects of the playground could likely be a first ISO document. The probes that are used to measure issues of safety could to a large extent be universal. Consideration must be given to probes that might be different based on ethnicity or country. Currently most test probes are not significantly different, but care must be taken to clearly state that new probes are to be used on play structures designed and installed after they are published as these are based on determined dimensions and older playgrounds that meet the requirements of the probes to which they were installed are not to be declared “unsafe” as a result of a minor dimensional change.
 At the present time the test device, including methods of calibration, assurance of being in compliance and the need for a support, for testing of impact attenuating surface as represented by ASTM F1292 and ASTM F355 and EN1177 are virtually identical. This device could also be part of the tool box.
 It must be remembered that the development of the tool box might still require how the probes and devices are used specifically within a region may well be driven by a national standard within the region.

Stories of rather recent playground installations collapsing prior to manufacturer’s warranty expiration have raised concerns of how to evaluate “Structural Integrity” requirements prior to or after purchase. Structural Integrity requirements could be reviewed and requirements for methods of determining structural integrity might be able to be harmonized provided this development does not reduce the functional longevity of the play equipment. This must also take into consideration the use of manufactured and naturally sourced materials, such as dimensional sized lumber, tree branches, rocks and boulders. One important aspect of structural integrity that is not currently universal is the calculation of static and dynamic loading. There will also be a need to determine where physical loading is required and where engineering calculations will be allowed to determine structural integrity.

Injury threshold should be a relatively easy item to harmonize since playground standards have their original need based in the prevention of certain injuries and reduction of the severity of others. Although prevention of death is absolute, knowledge and materials have advanced to the point where there is a better understanding of mechanisms of injury to allow for a new focus on prevention of serious injury. It is common that Product Directives, Consumer Product Safety Regulations, society and the courts have come to recognize that serious injuries or harm shall be prevented. This would generally be an injury that would fall within the AIS>3. Canada and the United States do have injury statistics that can be used as a source of information, while Europe and other parts of the world will have to develop and bring their sourced injury data. For those stating that they have no injuries and do not have the injury data to support it must be remembered that the “Absence of evidence is not evidence of absence.”

Performance of Hazard Identification and Risk Assessment specific to the play equipment, the assembly within the playspace and the inclusion of injury prevention mechanisms such as; head entrapment, protrusion/impalement hazards, crush hazards, sharp points/edges, suspended component impact hazards and impact hazards due to poor performing impact attenuating surfacing could be harmonized. At the present time ISO TC83 WG6 is working on the development of a tool related to the entire scope of TC83, but there is no reason that once this general tool is developed that something specific to play and children could be provided. This would be used by designers, manufacturers, owners, inspectors and maintainers in their work to ensure a level of injury below the stated scope of prevention of serious injury (AIS>3).

The group echoed the sentiment of the 1st meeting of WG8 that failures of playgrounds can often be associated with age of the playground, structures and surfacing, and this is associated with the lack of thorough quality inspections and maintenance. As inspection is a function of human activity and not related to the specific playground, there should be the opportunity to develop a standard for the credentials of a qualified person (inspector) and work output that would be expected of a person performing inspections for compliance to an ISO or National Standard equally. All stake holders should be involved in the development process of such a standard. This will be coupled with a parallel Standard Guides for the performance of playspace maintenance based on the manufacturer’s requirements, materials utilized, the exposure to environmental degradation, etc. that will keep the play space compliant with current industry best practice, functioning as intended, and clean/sanitary withinIt must be remembered that the development of the tool box might still require how the probes and devices are used specifically within a region may well be driven by a national standard within the region.

Stories of rather recent playground installations collapsing prior to manufacturer’s warranty expiration have raised concerns of how to evaluate “Structural Integrity” requirements prior to or after purchase. Structural Integrity requirements could be reviewed and requirements for methods of determining structural integrity might be able to be harmonized provided this development does not reduce the functional longevity of the play equipment. This must also take into consideration the use of manufactured and naturally sourced materials, such as dimensional sized lumber, tree branches, rocks and boulders. One important aspect of structural integrity that is not currently universal is the calculation of static and dynamic loading. There will also be a need to determine where physical loading is required and where engineering calculations will be allowed to determine structural integrity.

Injury threshold should be a relatively easy item to harmonize since playground standards have their original need based in the prevention of certain injuries and reduction of the severity of others. Although prevention of death is absolute, knowledge and materials have advanced to the point where there is a better understanding of mechanisms of injury to allow for a new focus on prevention of serious injury. It is common that Product Directives, Consumer Product Safety Regulations, society and the courts have come to recognize that serious injuries or harm shall be prevented. This would generally be an injury that would fall within the AIS>3. Canada and the United States do have injury statistics that can be used as a source of information, while Europe and other parts of the world will have to develop and bring their sourced injury data. For those stating that they have no injuries and do not have the injury data to support it must be remembered that the “Absence of evidence is not evidence of absence.”

Performance of Hazard Identification and Risk Assessment specific to the play equipment, the assembly within the playspace and the inclusion of injury prevention mechanisms such as; head entrapment, protrusion/impalement hazards, crush hazards, sharp points/edges, suspended component impact hazards and impact hazards due to poor performing impact attenuating surfacing could be harmonized. At the present time ISO TC83 WG6 is working on the development of a tool related to the entire scope of TC83, but there is no reason that once this general tool is developed that something specific to play and children could be provided. This would be used by designers, manufacturers, owners, inspectors and maintainers in their work to ensure a level of injury below the stated scope of prevention of serious injury (AIS>3).

The group echoed the sentiment of the 1st meeting of WG8 that failures of playgrounds can often be associated with age of the playground, structures and surfacing, and this is associated with the lack of thorough quality inspections and maintenance. As inspection is a function of human activity and not related to the specific playground, there should be the opportunity to develop a standard for the credentials of a qualified person (inspector) and work output that would be expected of a person performing inspections for compliance to an ISO or National Standard equally. All stake holders should be involved in the development process of such a standard. This will be coupled with a parallel Standard Guides for the performance of playspace maintenance based on the manufacturer’s requirements, materials utilized, the exposure to environmental degradation, etc. that will keep the play space compliant with current industry best practice, functioning as intended, and clean/sanitary within the original parameters of the designers and manufactures that built the space. This may well include a statement such as found in the Canadian CSA Z614 that budgets for maintenance of playgrounds must be established and be in place at the time of development and installation of the playspace.

The meeting also determined a list of items that they do not see as being harmonized on the international basis. These would likely have implications on the design of structures as well as the layout of the playspace. This is one reason for the consideration of a two tier system that recognizes harmonized or ISO standards and National standards for implementation.
Accessibility is a Federal requirement in the United States for public accommodation and although not fully mandated in Canada, it is generally finding its way into playspaces throughout Canada and the World. Accessibility has been addressed in Guide 14 related to children 14 and under as noted earlier and is also found in section 4.6 of ISOIEC JWG 01 Revision of Guide 51 N49 along with it reference is ISO/IEC Guide71 which address the needs of persons with disabilities in broad terms, but does not specifically cover guidance relating to children with disabilities. This has implications for the design of play structures and the layout of the space. It will also affect the types of surfacing and maintenance that is required for the surfacing. There has been a trend to move away from the “post and platform” type of structure for creativity, but this also appears to potentially defeat the need for access of play events within a climber. Prevention of access will not be acceptable. As a result factors that relate to accessibility are difficult to harmonize unless there is a concerted effort to harmonize around the requirements of the US DOJ ADA. The current US model law for accessibility eliminates barriers but it does not necessarily provide for inclusion of all regardless of needs or limitations.

Fall height and protective surfacing performance is significantly different around the world. In North America all play structures that are above grade and not designed to be used with feet on the ground require an impact attenuating surface. There also is no limit as to the height of the equipment and therefore the potential for a child to climb and fall can increase the severity outcome of a related injury. As a result surfacing performance must address the impact from the height it is anticipated a child will fall. This does echo the sentiment of the first meeting the WG8 that surfacing performance shall be based on where the child can fall from, but at the present time the CEN standards limit the requirement for surfacing to 10’ or 3 meters. This is not acceptable in North America, within the limits of litigation and regulations. There are also differences as to how fall height is determined as in the case of swings. As a result the need for surfacing will remain national. This is not a barrier to trade as manufacturers from around the world can ship their goods around the world, but it will be incumbent upon the manufacturer/designer to inform the owner of the surfacing use zone and impact attenuation requirements within the country it is sold and equally important is the owner’s responsibility to provide surfacing that meets national requirements.
The performance of the impact attenuating surface is related directly to fall height of the play equipment. There is another issue related to determining play equipment fall height that must be considered. There needs to be a measurable performance standard and test method to determine what is accessible to climb versus what is considered non-climbable while considering reasonable foreseeable use/misuse of intended and unintended users. This is the type of assessment that needs to occur as discussed in ISO/IEC PDGUIDE 51.2 Safety aspects – Guidelines for their inclusion in Standards. Since this is related to injury prevention, regulation and litigation, this will have to remain an issue left within the domain of a national standards writing body. Again this in not a barrier to trade as the obligation for performance at the time of installation and during the functional life will be required by the owner of the playground as stated in their standards and therefore a national matter.
Delineation of user groups also appears to be a problem for harmonization. It could be argued that children of any age around the world have the same ability to play; however the circumstances of the playground, whether it be in a park, school, early childhood care facility, museum, pay to play facility, adventure playground or an open unsecured, unsupervised public setting, the owner might choose to change the design based on their understanding of use of the playground. Removing this freedom from the owner and person responsible directly of the care of the children using the playground would be detrimental to the building of playgrounds.

Another potential problem associated with international harmonization of standards will be the process upon which harmonization decisions are based. One approach is the review the existing standards and create a standard that finds commonality and where they are not identical, the most stringent performance will be the accepted and promulgated to the world. We doubt this approach would be widely acceptable throughout the world. The other approach is to go back to the beginning and look at the reasons the existing standards were written. They all have a scope of prevention of harm and statistics indicate that injuries are increasing rather than decreasing. It might be time for another approach rather than take a group of mediocre standards and create a blend of mediocre standards. There is a lot of good performance requirements in the existing standards, but it might be time to begin with an ISO universal injury prevention statement based on serious harm and work through an open process that finally achieves that.

During the meeting in Toronto, the participants were asked to write down thoughts that came to them during the proceedings. These were either ideas that they found important within a presentation or ideas that they had that were stimulated by the discussion. They are interesting as they tend to stimulate additional thought and conversation. Consideration was given to provide a summary, but this would not do justice to the ideas. As a result they have been included as they were written. Please note that they are listed according to the time they were written and can be read sequentially in conjunction with this report as many were stimulated by the discussions reported herein. It is the hope of our participants that these “sticky notes” will prompt the reader to understand that play and playground standards are very complex and before we rush off to create a single ISO standard we seriously consider two questions that were expressed by the UK delegation at the First meeting. First, “Is there an overarching benefit to an ISO (international) standard?” and secondly, “Is there the potential for unintended consequences that cannot be reversed with the implementation of an ISO standard?”

Nothing in the meeting is to be construed as an agreement to move forward with standards writing at this time, but rather the need for more discussion and investigation of the opportunities and obstacles.

I would like to personally thank the people who took the time to attend and participate in the Toronto conference. We recognize that we all have many demands on our time and these meetings although being two days in length take a lot of preparation time to plan in advance for travel. Our American colleagues worked around their Thanksgiving holiday which is a special family time. The energetic group with diverse backgrounds and expertise covering owners, designers of equipment, designers of playspaces, manufacturers of equipment and surfacing, inspectors, maintainers, educators bringing many years of experience which was freely provided and benefited each and every participant, while not pushing any personal or business agendas.

Specifically I would like to thank Tom Norquist, Christine Simpson and Ken Kutska for their support in helping with organizing the conference and seeing that we made it a success.
Special thanks to CSA for the facility and allowing us to have the freedom to discuss ideas of general interest to play and standards. Also thanks to Jens Bauch for keeping us connected to WG8.
Respectfully submitted.

Rolf Huber, Head of Delegation to ISO TC83 and Chair of the Mirror Committee for Canada.

The next meeting for the Asian Region will be held in Sydney Australia February 26 and 27, 2018.

Proverb: The Road to Hell is Paved with Good Intentions

Sunday, January 14th, 2018

Proverb: The Road to Hell is Paved with Good Intentions
Kenneth S. Kutska, IPSI Executive Director 2008 to Present
International Playground Safety Institute, LLC

On September 8, 2004, international playground safety consultant Monty L. Christiansen (today retired Professor Emeritus, Penn State University), presented the keynote address to the Japan Playground Facilities Association (JPFA) National Playground Safety Conference entitled “International Playground Safety Standards ― An ASTM International Case Study: The American Experience in Retrospect: Best Intentions Gone Awry”. The conclusions presented by Professor Christiansen thirteen years ago are still very relevant today to all playground standards writing organizations. This paper revisits these points and enlarges them in perspective of the international situation today. Public playground safety standard stakeholders convening in Canada on November 20 – 22, 2017 will be discussing the possibility and need for a worldwide safety standard for public playgrounds.

I had the pleasure of working with Professor Christiansen (hereafter “Monty”) on many projects related to the care and feeding of public playgrounds primarily in North America, but also in Asia and Europe. Monty and I, along with Dr. Fran Wallach, created the National Playground Safety Institute (NPSI) in 1989 under the umbrella of the National Recreation and Park Association (NRPA). Monty was never satisfied with the limited scope of the NPSI and eventually founded the International Playground Safety Institute (IPSI) in 2005. He had a vision to bring playground management and public playground safety issues to other like-minded parts of the world who shared in his passion for safe yet challenging play spaces for all children. The formation of IPSI came about as a result of very successful 1995 and 1999 International Conferences on Playground Safety held at the Penn Stater Conference Center, University Park, Pennsylvania, both conferences chaired by Monty. Selected portions of the proceedings of these conferences are being reprinted and distributed to prepare participants for the November 2017 Toronto Conference: Harmonizing Opportunities Towards a World Playground Standard. While Monty is unable to participate in the Toronto Conference, his past words and efforts will help to define the task at hand as we wrestle with the future direction of playground safety standards.

I have taken the liberty, with his approval, to re-emphasize his concerns and challenges to all stakeholders while bringing a bit more focus to where the playground safety standards movement is today thirteen years after his invited keynote presentation in Japan.

There are many organizations actively involved in promoting best practices for public playground management. Each has the children’s best interest in mind however, their approach to the myriad of issues involved are often at opposite ends of the continuum between what a risk is and when the level of risk of harm becomes a hazard. I see a fine line between what is considered acceptable risk and where the risk of harm exceeds what society considers acceptable. Regardless of what side of this line you find yourself I think we can all agree there is a need for challenging play experiences for children of all abilities. We also can agree that challenge should not pose a risk of harm which exceeds the balance of the benefits of risky play versus the determent of an increase in debilitating and life-threatening injuries.

In North America there are several documents that influence public playground management decisions when it comes to playground safety issues. One is a guideline published by a federal agency, the United States Consumer Product Safety Commission (CPSC). Another is a voluntary performance standard established by the American Society for Testing and Materials International (ASTM), the world’s largest non-government standards development organization. Over the past 25 years ASTM has published many more playground equipment and impact attenuating surfacing standards. In Canada there is the CSA Z614 which is a very comprehensive standard related to the many aspects of the public playground environment. The application of this safety criteria has had some diametrically polarized results, which can serve as examples of issues to be considered by all standards writing organizations when it comes to children’s consumer products.

Need for playground safety standards
The need for playground safety standards in the United States arose as a result of several serious injuries and fatalities that occurred during a relatively short time period in the last 30 to 40 years. These injuries were sensationalized through local and national print and broadcast media. It was a perfect storm brought about by the need for more public playgrounds, the media’s interest in some of the more serious injuries, and rising number of litigations filed demanding compensation for recovery of injury costs and punitive damages. Several huge financial awards consequently led to a strong public demand for increased safety. Many well minded individuals and organizations believed the problem of playground injuries was “solvable.” They believed the problem of rising frequency of serious playground injuries could be resolved through the development and compliance to safety standards based upon facts learned through the collection and analysis of injury data.

Impact of safety standards on playgrounds: Linking Cause and Effect
The initial result of these safety recommendations has been;
• More multi-play composite structures and fewer freestanding single event play components
• More single-surface areas to reduce costs associated with the required protective surfacing under and around all play components
• Fewer to almost no forced motion equipment resulting more often in less challenging stationary equipment
• Less opportunities to stimulate imagination, more specificity in design leading to very similar cookie cutter type designs
• More repetitive climbing events as a result of the very popular post and deck composite structures leading to less variety of use
• Environmental stimuli (wind, sun/shade, sound, movement, natural plat materials, dirt/sand and water) are now seldom taken into account in playgrounds
• Too many new playgrounds consist of only a single multi-play composite structure with one type of surfacing material which is selected primarily on cost and the manufacture’s claim their materials meet the minimum standard requirements for impact attenuation and accessibility, where applicable. This is sort of a Swiss Army Knife approach to multi-use.
• Playgrounds are no longer a spacious play space with separation of various equipment and structures, with space to run, jump, roll, etc. on the surface when off the equipment.

These outcomes are based on,
• Fear of litigation and associated costs
• Cost of compliance to today’s safety recommendations
• Need to comply with accessibility legislation.
• Lack of open space

Safety criteria are a result of identifying hazards through accident data analysis, sharing past industry experience, known litigation, applying requirements based on anthropometrics and an understanding of how children will use the structures in unintended ways. Anthropometrics is better known as the application of body measurements by ages of the intended users to make the man-made environment more user friendly. As a result of these actions more playgrounds are being designed for a limited age group which can prevent multi-age interaction found in a reasonably safe public space intended for use by all people.

Change of U.S. accident data after 35+ years of safety standards
In the U.S., there has been a decrease in the percent of strike-impact fatalities and almost a total elimination of head and neck entrapment deaths. There has been an increase in strangulation fatality percentages however it seems many of these are more about how the child is dressed and what they bring with them to the playground than the equipment entanglement hazards created by the equipment configuration or improper or inadequate inspection and maintenance practices. There has been an increase of fall-related percentages primarily an increase of long-bone injuries and concussions. Many speculate this statistic is more about the use of unitary surface systems that do not disperse and cause more direct stress and less user lateral movement after initial impact, but this may also be attributed to a surface systems being installed at or near the maximum impact threshold limits allowed. There is a growing international recognition that all the playground safety surfacing performance standards are based upon the reducing the likelihood of a serious head injury, specifically brain concussion as a result of a vertical fall and the sudden resulting impact onto the falling child’s head. A vertical fall with the child landing directly on their head is a rather uncommon occurrence, but concussions can occur other than in this scenario. In the Zurich 2008, International Conference on concussion the mechanism of a concussion was defined as an impact to the head or upper body that transfer energy to the head and brain. The gold standard when developing today’s standards for fall impact related injuries might well be to consider all mechanisms of serious injuries. We know that standards and their rationale were first developed on information based on research available over 50 years ago with the goal to prevent death. We also know there is new research and data available today but standards writing organizations have been slow to see the need for and embrace any new approach to injury reduction in impact injuries resulting from falls to the surface. If reduction in serious injuries is an international health mandate for children why aren’t we looking beyond just critical and severe head injuries and consider all types of serious fall related injuries? Some have argued the rationale for such change is based on the automotive industry and not on research related to the actual playground. This is a true statement but have we forgotten that all the research used to get the playground industry to where it is today on fall related injuries and other impact injuries comes from the automotive industry?

Impact of safety standards on play value
In Monty’s words, “When you give a child a new hammer, he believes everything must be hammered.” In the 1990’s new safety standards (“New Design Hammer”) became the number one selling point for anyone wanting to build a new playground or for any manufacturer’s sales associate trying to sell more of their product. After all who does not want to provide a safe place to play for a child? In the 2000’s the ADA requirements became the new selling point for playground owners and manufacturers. Many said these playground safety and accessibility standards would be the end of public playground. Many predicted the rise of playground safety and accessibility standards would result in fewer playgrounds and therefore fewer play opportunities for children. This has not been the case. Unfortunately, many playground equipment manufacturers, designers, and owners in the North America, after adoption of playground safety standards and accessible guidelines, designed new play equipment and overall playground area designs primarily with safety and accessibility in mind, and as a result play value may have suffered. New playgrounds became predictable and offered fewer challenges and little stimulation. Fewer challenges lead to boredom and with boredom can come unintended misuse and the consequences that come with this sort of unintended use. New playground designs offered fewer challenges and little stimulation. Playground owners and designers alike need to understand that with repetition comes mastery; but what happens after mastery? After mastery repetition becomes redundant and boring. Play must be based upon children’s physical, social, emotional, and intellectual levels and must include opportunities for increasing ability, challenge, and competencies as well as opportunities for interactive play with others.

There needs to be a better method to measure impact of the new standards. The U.S., has a fairly good system of correlating the application of the standards to injuries. While this system is certainly not perfect and is in need of some updating to reflect today’s industry practices, it does meet the original need. On the other hand it may not be prudent to encourage much more sophistication in playground accident documentation because it may actually put too much emphasis upon the safety aspect of the playground thereby having the exact opposite effect of stunting play value, increasing boredom and injuries resulting in eliminating playgrounds altogether.

These facts have started a new discussion on the need to take one of two approaches to standards development. Option 1, we must better define today’s play components (Types) and the many variations of each so those responsible for assessing the compliance of these play components can make a definitive assessment on whether something meets the minimum requirements of the standard. Option 2, we must adopt a new approach to standards writing which focuses less on assessing compliance of play component types based on past definitions or perceptions of how something was previously designed and used and start looking at how something might be used and what potential hazards a child might encounter during reasonable foreseeable misuse. The complexity of trying to identify “what free spontaneous play is and where it occurs” coupled with the ability of designers of children’s playgrounds to “predict how children interact with things in their play environment” makes the first option a futile waste of time, energy, and cost. The time has come for a new approach to play area safety standards starting with a solid consensus of our current standard scoping statements followed by a thorough review of all existing playground equipment and surfacing performance requirements. The opportunity for such a new approach is now.

Obstacles and Opportunities to Free Active Play
There has been a dramatic increase in obesity in children in the U.S. over the past twenty years or so. There are several known causes, including high consumption of a high fat, high sugar, and high carbohydrate diet at home, at fast-food restaurants, and at school. Another possible cause: loss of or shortened recess and physical education in primary and secondary education schools. Another possible cause: less emphasis upon outdoor experiences, play and sport participation, more participation with passive recreation interests such as watching television, personal computer, gaming systems and cell phones; making online social networking easier and more addicting. It may be that children are finding their playgrounds boring and do not return to these areas to use. While overly safe, sometimes referred to as boring, playgrounds cannot be assigned full responsibility for the increased obesity of children, there does need to be a better, quantifiable means to determine the impact of playground provisions to not just safety, but also to fitness and health of children.

We need to distinguish between “risk” and “hazards” on playgrounds
We need to provide a variety of risk or challenge opportunities (tolerable or managed risk), but minimize exposure to hazards known to cause debilitating and life-threatening injuries. We need to recognize that “safety” is relative. Nothing is completely safe. Children do need to learn the consequence of activity, of experimentation, of play. Sometimes the consequence is unpleasant, whether the result is disappointment, embarrassment, or physical pain. Low-level pain is not bad and should not be designed out of the possibility of consequence. In other words, too much safety is not necessarily good. The child’s ability to experience failure in a reasonably safe environment is very important to their development. No child should be able to succeed each and every time they try something new. Experiencing failure on the playground is not a bad thing. Lessons learned on the playground are much easier to overcome and learn from than making bad decisions years later when mistakes and poor judgment can be devastating and much harder to overcome.

Almost 20 years ago there was a call for an open public discussion and debate on the best approach to establishing a proper balance between risk and safety. Today that same need exists but I suggest we reframe the question. We need to have an open public discussion and debate on the best approach to establishing a proper balance between challenge and injury prevention for our children’s sake and for the sake of society as a whole when our children become adults. We need to identify and consider all the variables that impact a child’s ability to access free play opportunities that stimulate and inspire their imagination.

Monty’s Conclusions (2004)
“Compliance with playground safety criteria is not a guarantee that injuries will be eliminated. Safety criteria should not be design-restrictive. There should be some safety absolutes but there should also be some safety principles that have more flexibility in application. Just as there is variety in food safety and preparation, so too should there be variety in playground safety and development. In the U.S. we do distinguish between home-based playgrounds, soft contained play systems, and public playgrounds. These few distinctions may be too limited. The setting and function of playgrounds may eventually have a larger part in the application of design and safety of playgrounds in public settings. Children have different play needs at pre-school care centers, at schools, at housing estates, at shopping malls or restaurants, and at holiday venues. In some settings, provisions for periodic change may be needed as novelty and challenge diminishes over time. Playgrounds may eventually be considered to be multi-generational, where children are not segregated from adults and older or younger children into “age-appropriate” play areas; but where parents, grandparents, and siblings may interact with each other while engaging in play. The application of anthropometrics will have to take this into consideration. But playgrounds are not “safe” because they are designed for specific child sizes and task-skill capabilities; they are “safe” because the children using them receive confidence, perceptions of stimulation and gratification, and simple pleasure from playing there.”

Ken’s Conclusions (2017)
Much of what Monty said still has relevance, however a number of things have occurred since 2004. There is a need to add a bit more emphasis on some factors that primarily impact playground owners but still have an impact on designers and manufacturers alike. We live in a different world today. Many things have changed over the past 30 to 40 years when the playground safety movement was born and there have been many significant changes since Monty’s 2004 overview of the situation. There are many more playground related standards to consider. We now have standards for when and where public playground fencing is required. This requirement is based upon its proximity to a hazard which by definition makes it a vulnerable play area. These fences must be designed to restrict exit of the child but also must keep safety hazards outside the playground. These hazards might be a body of water, unauthorized persons, or motor vehicles. Special gates and locking mechanisms are required. Fences must be hazard free, of a specified minimum height, and non-climbable. Where does this stop? There are so many variables that a one solution approach does not seem practical. How do owners manage such a responsibility when most have unrestricted public access and are not supervised? Supervision or the lack thereof has always been a major concern when it comes to injury prevention. The U.S. Consumer Product Safety Commission first acknowledged this in writing in documents leading up to the first 1981 Handbook. This is one of the injury prevention factors being considered when the CPSC decided it was in everyone’s best interest to not develop a Federal playground safety law. CPSC decided it was more appropriate to develop a playground safety guide consisting of various recommendations that would assist in developing safe public play spaces for children. Beside supervision the CPSC considered age appropriateness, anthropometrics, site selection and layout, and of course protective surfacing performance. Today supervision seems to be even more important issue to the owner depending on the type of playground and the intended user group. There are very distinct differences in the public’s perception of supervision when you consider an unsupervised and uncontrolled public park to a public school. A school playground will obviously be used and monitored during school hours by supervisory staff but it may also be used by the general tax paying public when school is not in session and the playground is not being supervised. Compare these types of play areas to a licensed childcare operator’s facility. These facilities require a whole different level of supervision. Supervision is implied and expected by the parent. The cookie cutter approach to public playgrounds is not always the best approach to safety standards or guidelines. Today standards writing organizations have come to realize that prescriptive use standards for the design of playgrounds and playground equipment is a waste of time and effort. These organizations are no more able to keep up with innovation in play apparatus design than they are able to limit its usage to intended design use.

Yesterday’s standards were based on injuries sustained over a period of time on the existing types of conventional equipment. The era of the composite post and desk continuous play system is still alive. This type of system serves large numbers of users on one structure and utilizes much less open space than the old fashion free standing equipment. Today many designers are now going the way of what has been coined “deck-less play systems.” They are creating more challenging play events and for less money. There is also a trend at destination playgrounds for the “mega tube-slide towers” to create the “Wow Factor” with their great vistas. This concept is being coupled with the technology for manufacturing huge seamless stainless steel slides. This has created very high and long sliding experiences through contained access by what is described as “non-climbable structures” where user access is created within the structure. It is also becoming more and more common to see manufacturers and designers combining both similar and/or different equipment types on top of one another. This has made the application of some playground standards difficult to apply in any consistent fashion. The creation of man-made topography or utilizing existing topography is creating and additional play experience commonly referred to as “play mounds.” These play mounds are replacing the flat play surface in an effort to add imagination and challenge to the playground environment while also reducing fall heights and the related surfacing costs. When these slopes are created they can create other challenges. They may pose potential trip or fall safety concerns to the general public just be being within the play area. Should the surface on or around these mounds be constructed of something other than hard surface? What are the considerations when play components are placed on or adjacent to the base of these mounds? The desire to increase challenge for all playground users introduces a new dimension of management and responsibility for the manufacturer, designer and owner who continue to push the playground design envelope. There is also a push for local designers, such as Landscape Architects, to be more involved in the design of play environments and the location of play components. What considerations should be given to their responsibilities and obligations in the overall safety component of the final design?

Public playground design and management are entering the era of the risk/challenge and hazard assessment. More consideration needs to be applied to not just the intended design use and how it complies with today’s safety standards but the need to consider reasonable foreseeable use/misuse must also be considered especially for the youngest and most vulnerable users.

“Children all over the world need and want to take risks when they play. For children taking a risk is a choice, while hazard assessment is not within their realm of experience or expertise. Play provision aims to respond to these needs and wishes by offering children stimulation, challenging environments for exploring and developing their abilities. In doing this, play provision aims to manage the level of risk so that children are not exposed to unacceptable risks of death or serious injury.” (Play Safety Forum, 2002)

“Providing challenge for all children, including those with impairments, is important in good play environments. When developing an open access play space, the widest possible range of abilities needs to be considered, as it is vital to retain different levels of challenge for all.”
(British Standards Institutions, 2013)

There are many issues that must be considered if the manufacturer, designer, installer, and owner/operator are doing their job. A one size fits all approach is not going to meet the needs of every user. Likewise one playground standard is not likely to be able to address each and every need. There will always need to be some compromise made along the way. If we are going to be successful in developing a harmonized international playground safety standard the path to be taken will undoubtedly require commitment from all involved, patience and understanding, and yes, compromise.

“During play, children are often driven by the challenge to do things that takes them to their limits, which in turn, leads to a better knowledge of themselves through experience. This challenge often corresponds to a sense of risk as there are changes for success or failure, even when the probability of an injury is minimal.” (British Standards Institution, 2013)

“…… safety must be considered at all stages of play provision but, inevitably, there will be a risk of injury when children play as there is a risk of injury in life generally. We must not lose sight of the important developmental role of play for children in pursuit of the unachievable goal of absolute safety.”
Health and Safety Executive in Play Safety Forum, 2002