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.

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

Summary:
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.

Posted in Uncategorized | No Comments »

Creating Conditions for Play: The Next Step in the USA

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.

Posted in ASTM Standards, Certified Playground Safety Inspector Course, Hazard versus Risk, Kenneth S Kutska, Playground injuries, playground safety | No Comments »

Clarifying Compliance to Playground Related Surfacing Standards

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?

Posted in ASTM Standards, Hazard versus Risk, Kenneth S Kutska, Playground injuries, playground safety, Playground Safety Training, Traumatic Brain Injury (TBI) | No Comments »

Reality Check – Where Are We Today versus Yesterday?

October 26th, 2014

Reality Check – Where Are We Today versus Yesterday?
By Kenneth S Kutska. CPSI
Executive Director, International Playground Safety Institute, LLC
March 15, 2014

Here I am at 37,000 feet on a Boeing 787 Dreamliner on route to Narita Tokyo International Airport. The Dreamliner is an impressive piece of modern technology that could not have even been imagined 40 or 50 years ago but that is another story. Today’s technology and what history has taught us is the story for today. I have to apologize for what I am probably going to say but my deadline is fast approaching and the level of oxygen at this elevation has brought about some weird thoughts. So back to my current state of affairs. It is five hours into my flight and I reflect back on my day thus far. My day started with a robo-call informing me the first of three flights commencing at 5:30 AM was cancelled. The reason I was later given was, “no crew availability.” The reason given is irrelevant but I bet it was weather related. The weather, regardless of where you live, has been a major story thus far in 2014. Regardless what the reality of the moment was the question remained, “What do I do now?” This notification came about 2 AM through my iPhone United Airlines App. This early morning call was not the first over the past two months. Disruptions to travel plans this winter seems to be a common but unappreciated reality for the regular air traveler. I am not taking my frustration out on the airlines. As a matter of fact I am applauding them for their ability to notify their customers when problems, often beyond their control, take over the situation. Yes, these kinds of calls are a huge inconvenience but think about our alternatives in the past. There was little or nothing we could do. We lived in the moment and relied on what our paper airline ticket said. Our parents and grandparents probably took the train or bus because air flight was not as predictable or affordable as it is today. Coast to coast or around the world travel was maybe a wanted extravagance but not an absolute necessity. Not so much today.

If we only accept yesterday’s technology and weather patterns as an absolute repeatable occurrence where would we be in the future? It did after all rain and snow in the past. I think even more than this winter of 2014. Most of us cannot even begin to appreciate many of the extreme weather events of the past unless we were actually there. I can remember a few Chicago winters of the 70s and 80s that were beyond what we have endured thus far in Chicagoland. Mayoral elections were lost over the incumbent’s inability to plow the streets and alleys of Chicago. It must have been the Mayor’s fault it snowed. I have to admit the winter of 2014 is not over so maybe this will go down as the worst Midwest winter of recent times but I cannot look into a crystal ball and say with certainty what will happen next. Technology and our ability to project the future continues to be a work in progress. We have not been able to predict, let alone manage Mother Nature, to any degree of certainty. I doubt we will ever be able to make weather predictions any better than we do now let alone be able to control her ability to wreak havoc on our day to day lives.

Looking back at my career I would have never imagined traveling to the other side of the world to conduct training on public playground management issues. In less than 48 hours I have arrived in Malaysia to do just that. In less than 12 hours I will have overcome the ravages of Mother Nature which put my plans in jeopardy. Thanks to today’s technology my travels have occurred rather smoothly, all things considered. Some of us yearn for the good ole days when we only worried about what was right in front of us at that moment. We went with the flow and dealt with whatever Mother Nature threw at us. We have to admit our inability to control the weather. All we can hope to do is use the technology of today and tomorrow to better cope with weather unpredictability and be prepared for the worse.
Each and every day we use technology to cope with the trials and tribulations of everyday life. Why are some still reluctant to accept the technological advances in society. While we cannot control the future we can learn from history and look for trends and assess our options to prepare for the future whatever it may bring. To change the subject from the probability and predictability of the weather to our ability to understand the probability and predictability of injuries on the playground we can agree on one universal truth. Weather and accidents will both happen with a certain probability of certainty. The extreme occurrences our outliers from the norm will continue to be the attention grabbers.

The National Oceanic and Atmospheric Administration (NOAA) and the US Consumer Product Safety Commission (CPSC), while different in their specific mission, have both been compiling a historic perspective related to their individual missions, weather and consumer protection. We think of NOAA being around from the early 1970s but its roots go back to the early 1800s. So how has their long history helped us predict the weather? Most would probably answer not very well but in fact it has helped us in our day to day lives in incredible ways. We seem to only dwell on those outliers I spoke of a moment ago. We cannot help but focus on the sensational. We in the US have been blessed with many organizations that help us live our lives in a more safe and predictable fashion. The US CPSC has more than a 40 year history of looking out after the consumer through gathering and analyzing injury data. When it comes to consumer protection no other country comes close to their record. As flawed as some believe this injury data gathering system is, the data and its analysis remains. I keep thinking of the saying, “The more we know, the more we know we don’t know.” It is time we use the technology of today and the historic reality from where we have come; to change for the benefit of society and specifically our children. What we chose to with regards to our consumer safety recommendations and industry standards will continue to have a ripple effect on other countries
The international community is beginning to speak the same universal language when it comes to children’s play spaces – Playgroundese. We are finding common ground that should benefit the development of all children. The element of risk and challenge experienced during children’s free play are fast becoming developmental imperatives for their future. While we may not all agree on how we put all the terms of Playgroundese into practice, we are at least beginning to understand each differing point of view. Understanding opposing points of view is important to eventual compromise.

I think the time is right for convening an international conference on children’s right for free play that addresses the conflicts between those who wish to mandate the safety of all children in all circumstances against those who wish to remove all rules and regulations which might restrict any child’s access to play opportunities based on an assumption of unreasonable risk. The ability of society to rationalize and accept the outcomes, good and bad, of a child’s reasonable foreseeable misuse versus the reality of possible outcomes, is fast becoming the question of the day. Many of us responsible for these free play opportunities consider unreasonable use or misuse coupled with the legal liability climate in the USA, the real “Elephant in the Room”. Generally speaking nobody really wants to talk about it. We seem to be more willing to allow whatever is going to happen, happen. Going back for a moment to my weather analogy it is sort of how our parents and grandparents lived their lives when it came to the weather. They more than likely just went to bed, woke up each and every morning, and see what they had to deal with.

Research and history continues to point out the importance of risk and challenge in child development. What this information cannot tell us is the unsettling, unpredictable and unknown. It is not if a child’s actions will result in an unfortunate serious injury, but when? Will it happen on my playground or yours?

Accepting the fact that children will be children, how do our public agencies responsible for creating and managing these unsupervised play opportunities rationalize the liability exposure their taxpayers face if and when a child goes beyond their abilities and is seriously injured. To put this in context to the uncertainty of our weather; what do you do when the Tornado or Tsunami warning system goes off? Sit in your home and look out the window waiting for what might happen or do you act rationally given what history has taught us and take appropriate evasive action. Measuring or adjusting the scale between risky play and safety regulation has proven to be a bit more complicated.

Children deserve our thoughtful consideration when it comes to their safety and developmental needs. Continuing this discussion on the benefits of risk versus safety regulation is a necessity. Those in charge of regulation and its enforcement have a duty that should not be taken lightly. Likewise parents and the children should not take lightly their own individual responsibility for the consequences of their actions.

Posted in ASTM Standards, Hazard versus Risk, Kenneth S Kutska, Playground injuries, playground safety, Traumatic Brain Injury (TBI), Value of Free Play | No Comments »

CAN WE ELIMINATE SERIOUS INJURIES THROUGH LEGISLATION? Part 2

October 26th, 2014

CAN WE ELIMINATE SERIOUS INJURIES THROUGH LEGISLATION? Part 2
Step 3 – 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
February 13, 2014

Two 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 definitions for different types of injuries and break down each type into various levels of severity.” As of end of 2013, the document has not been voted on. It is out for a vote and appears to be moving forward towards approval, based upon comments from various international voting members. As I am not sure when this column will run, I will proceed with my thoughts on terms and definitions within this document and how they may impact international standards for child injury prevention. My comments will be directed primarily towards fall related injuries and our current international impact attenuating surface standards.

I hope to put into perspective how playground related injuries and the different levels of injury severity relate to a currently compliant playground surface system. This is not going to be easy but I am going to give it a shot. If nothing else I hope to advance the discussion and provide some issues and facts to better understand how the current standards for evaluating surface systems. This part is easy. The more difficult concept to explain, understand, and accept is, “Does the scope of ASTM F1292 standard for playground surface systems adequately address the scope of the standard as well as ASTM F1487?”

The answer to this question depends on whether the current, and widely accepted impact attenuation thresholds adequately address the severity of injuries international playground standard’s performance safety requirements are attempting to address.

Let’s begin by defining an “injury,” and more importantly let’s understand the various levels of injury severity we are most concerned with and/or willing to address in our international playground related standards. We do not want a child to suffer a serious injury but 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. Recently I read a statement by Jay Beckwith, an old friend and playground industry colleague, who regularly contributes to this newsletter. He said something so very simple yet profound. Jay, I apologize in advance for not being able repeat your exact words. Your point was that a child must fall in order to learn. This statement rings true and is so basic to human development. Look back at your own childhood. That may be difficult since we have little memory of or most early and formative years but we can all look back at things our own children, grandchildren or even someone else’s children experienced early in life. How many stitches did you get as a child? Did you break an arm or leg? How many times did you say or hear from your spouse, “Should we take him to the hospital, is it broken?”

The research supporting the child development benefits of free play coupled with to Jay Beckwith’s comment on how we learn from our mistakes which allows us all to become all we can be. Unfortunately, but understandably, sometimes someone gets hurt. We all seem to know and willingly accept this fact. If true, then the issue should come down to what level of injury we willing to accept? In reality there will always be some obscure injury where a child is seriously hurt beyond what society seems willing to accept. Thank goodness these types of injuries are exceptions rather than the rule. So when does the frequency and severity of these types of injury warrant action from a government agency or industry standards organizations?

I do not believe this question has been adequately and fairly addressed by the special interests at the extreme ends of either point of view. The current practice lacks a collective consensus taking into consideration a balance between the user safety benefits and the developmental benefits from increasing challenging and risky play opportunities. The benefits from challenge and risk have been well documented throughout the world yet nobody can seem to articulate an acceptable reference point where the risk and statistical probability of serious injury outweighs the developmental benefits of the challenge. I think we can agree that learning to be self-reliant and personally accountable for our own actions are important and necessary life lessons yet we cannot seem to accept the consequences to our actions.

A scraped knee or cut finger is a minor injury. A laceration requiring stitches is more severe, but a sharp edge or crush hazard causing amputation of a toe or finger is serious and debilitating and probably beyond what society is willing to accept. If any of these minor injuries were to become infected, serious consequences could follow. But in this instance who should be held responsible for the consequences resulting from a lack of proper care after the fact. Children contribute to and should be held partially responsible for their own actions and resulting injuries when they play on equipment not intended for their developmental readiness. They should also be held accountable for their actions and outcomes beyond what a reasonable person would consider reasonably foreseeable. Is this fair to all concerned? Some equipment designs may be considered to be inappropriate for the generally unsupervised and unsecured public setting. Some caregivers fail in the supervision of those under their care, which can result in serious injury. Some international communities hold parents and caregivers legally accountable for their improper and unacceptable behavior. In this instance elected policy makers have determined what is best for the common good. How and where society-at-large seems to place blame and accountability are issues the legislative branches of government and the legal system need to seriously consider. Some fair and equitable solution is needed that addresses these concerns or we may lose free play opportunities as some units of government who provide these facilities take the quick and easiest solution available. Unfortunately this choice is to avoid these potential loss exposures by removing these play facilities. There are so many things at play here that when considering all the variables the task appears unmanageable. Avoidance is not the answer to the problem, it is another type of problem of kicking the can down the road thereby leaving everyone in the lurch who deserves a better outcome.

We continue to talk around all these variables from our differing points of view but when it comes to balancing risk and challenge with user safety nobody has come up with a workable solution to the question. There are many special interest groups weighing in on the subject but, thus far, there has been a lot of finger pointing and we do not appear to be any closer to a workable solution.

I would suggest the following as a possible solution. We could start by doing a better job of creating industry play area and equipment standards that meet the objectives of injury reduction if and when we define an acceptable and measurable level of injury outside of the occasional freakish incident. In order to accomplish this we need to agree on and define the injuries we will accept and which injuries we wish to reduce or eliminate. We may never eliminate all serious injuries, but we might be able to put measures in place to mitigate most of these injuries. We can do a better job of education the public and then we must work towards holding parents and caregivers, as well as the children more responsible for their own actions or inactions.

Many have criticized the various safety standards organizations for dumbing down our playgrounds or for reducing the number of play opportunities throughout the country. I disagree with this broad a general statement. ASTM F1487 is a performance based standard but in some ways it has become a bit design restrictive. That being said the ASTM F1487 standard and the US CPSC Handbook has contributed a lot to almost totally eliminate deaths and serious injuries related to head entrapment hazards. No one would argue this outcome cannot be attributed to the 1991 CPSC Handbook and 1993 ASTM F1487 standard recommendations nor can they say the result is not a good thing. The solution was not legislated by government but put out to the public and voluntary industry and consumer recommendations. The results of these recommendations are undeniable and yet, for the most part, unrecognized by the general public and most government officials. There is still much work to be done if we can trust the current injury statistics. The real question is how far should we go with this effort of voluntary or even mandatory safety performance requirements?

I will not go any further at this point to explain where I think we should go and how we might get there. I do not wish to jump the gun so to speak with embracing any further direction until we can agree on an approach to the problem and better define our mission and the scope as it relates to performance based safety recommendations that still embrace the importance of risk taking and increasing challenging play opportunities. Some reasonable balance must be struck between these two equally important opposing points of view. I will continue my discussion on this subject next month.

Until next month, play safe but play. I plan on playing a bit with my playful friends next week at the US Play Coalition Conference on the campus of Clemson University. I hope to have many things to share with you after the conference. The spring looks very busy and full of many play related education and training activities. Immediately following the conference I will be presenting a second playground maintenance technician course sponsored by Clemson University and Gwinnett County Georgia Park and Recreation District. If things keep up as they have weather wise we all might be able to build snowmen or have a snowball fight. This could make for some great pictures. March will include another trip to Malaysia to conduct the Certified Playground Safety Inspector Course and the Playground Maintenance Technician Course as they continue to work towards creating and implementing a playground safety policy for their country. They have created such a policy and requirements and I look forward to learning more of the details on the plan implementation during my visit.

On a final note I would like to congratulate the two CPSI classes I had the privilege of teaching earlier this year in Hong Kong and Singapore. Hong Kong had their best pass rate at 80% and Singapore likewise had their best results at 70%. I can tell you government employees and playground industry representatives from around the world take their responsibility for children’s safety seriously.

We all do are best as best we can. Keep up the good work.

Posted in ASTM Standards, Certified Playground Safety Inspector Course, Hazard versus Risk, Kenneth S Kutska, National Recreation and Park Association, Playground injuries, playground safety, Playground Safety Training, Traumatic Brain Injury (TBI) | No Comments »

« Older Entries
Newer Entries »