Part 2 of 4 – Playground Surfacing Requirements and Injury Reduction: How much of either is enough?

February 7th, 2016

Part 2 of 4 – Playground Surfacing Requirements and Injury Reduction: How much of either is enough?
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC

August 1, 2015

The new starting point for debate on this very complicated Issue

Let’s recap the status of the ASTM ballot process on the issue of lowering the F1292 impact threshold from 1000 to 700 HIC. No change has been approved through the ASTM standards development process. The appeal ruling by the ASTM Council on Standards (COS) was never about the content of the issue or whether the change in HIC was warranted. The appeal was taken up by COS to determine if the ASTM balloting process was strictly followed. There was another concern raised on whether or not it was appropriate to go out to ballot on the same subject matter that was once voted down. This has always been within the authority of the Chair of the Subcommittee.

The outcome of this COS appeal resulted in another ballot a few months later on exactly the same motion. This time the ballot had many more negative votes with basically the same rationale given on the previous ballot. Negative voters wanted proof for the change based on playground research not research conducted by the automotive industry. People wanted empirical not anecdotal data related to serious head injuries. What is a serious head injury? Some only wanted to look at serious head injuries and not consider a possible reduction in long bone fractures since fractures are not specifically mentioned in the scope of the F1292. Some wanted definitive number of injuries that occur on non-compliant versus compliant surfaces. Some wanted to know the cost benefit factors for improving surfacing performance requirements versus the societal cost of these injuries. Some wanted comparisons of playground fall related injury costs versus those other more frequent and severe injuries sustained in other activities and locations. This information is currently not available and I doubt it will be any time soon. Research takes time and cost money. Thus far nobody is willing to foot the bill or volunteer to take on the research.

Derogatory comments about the ASTM and the efforts of volunteer members of the ASTM F8.63 Subcommittee is troubling to me and are not warranted. I would like to think the comments were a result of a lack of knowledge and understanding about the ASTM and the ASTM standards development process. ASTM, as an institution that has been around for over 100 years, does not provide technical data or research to support the rationale of their actions. The voluntary members of each Subcommittee provide the technical and subject matter experts who volunteer their time and money to develop thousands of industry standards for materials and test methods which benefit society as a whole. All Chairs volunteer to manage the efforts of their Subcommittee. The Chair of ASTM F8.63 Subcommittee is responsible for the current ASTM F1292 Standard and many other playground surfacing standards. The Chair is responsible to ensure the ASTM standards development process is followed throughout each step of voting process. There has been, and will continue to be, open and robust discussions and debate on all aspects of this ballot item and other ASTM Standards ballots. The ASTM organization, its process, and membership rules are the most transparent of any standards development organization in the world. Where else can anyone become a member of such a committee responsible for developing international voluntary industry standards for the small fee of $75 USD? Membership does not require attendance at each and every Subcommittee meeting. However, membership does require active ongoing participation in voting process for any and all Subcommittee ballots. Members have access to all Subcommittee meeting minutes, ballots, including supporting rationale for each ballot item, as well as other pertinent documents such as research papers related to the current topics being discussed by the Subcommittee. Unfortunately not every member, has the time or resources to attend Subcommittee meetings whether they be a virtual online meetings or regularly scheduled ASTM Committee Week meetings held around the US and Canada. It takes a commitment of time to read through all the information available so members can educate themselves make informed decisions.

The Need for Safety versus Need for Risky Play: Benefits versus Unintended Consequences
I venture to say that each and every country that has added something to this debate has a similar government mandate when it comes to local government and private industry’s’ responsibility for the safety of children. Public safety and injury prevention continues to be the primary focus of most standards developing organizations but it appears injury avoidance is fast becoming the most expedient means of addressing the safety and the potential liability facing the designer, manufacturer, owner, operator, installer, and inspector of public playgrounds. Manufacturers that do not sell product in the USA do not face the same public liability issues as those who do. If they chose to sell their products in the USA they will be under the scrutiny of the US CPSC and the 2008 Consumer Product Safety Improvement Act. As a result of these liability issues, real or perceived; our willingness and enthusiasm to provide risky challenging playground equipment with high play value is diminished based on how much risk public agencies and product manufacturers are willing to accept. Those who care deeply about children’s developmental are strong advocates for the benefits of more risky play opportunities in a child’s play environment. Unfortunately we cannot ignore the potential consequence of our actions when choosing play equipment appropriate for a particular location. These decisions are most often made by governmental authorities who, for the most part, are not well versed in all aspects of the long term management responsibilities that come with any playground.

The one question nobody has been willing or capable of answering is, how many deaths, debilitating, and/or life-threatening injuries is society and our judicial system willing to accept? These are cultural issues that must be answered by each individual country and in the USA it may vary by state. While play is a universal need in a child’s development, it is each country’s local customs and beliefs that will determine what emphasis they will place on child’s right and need to play.
All items brought forth, whether pro or con, on lowering the current impact attenuation performance thresholds have been discussed and debated over and over by the F8.63 Subcommittee members. Some requests for additional study and research are not much more than wishful thinking and far above the reach of this Committee. Are these requests truly warranted or are they nothing more than stall tactics or a means of adding unrelated issues to the mix to add confusion to the discussion?
Part 3 of this discussion will look at what got us to the current surfacing performance threshold. I will discuss how one other impact threshold requirement came about and how we have historically rationalized these numbers using whatever research data was available to support our rationale for the particular standard requirement.

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Part 1 of 4 – Playground Surfacing Requirements and Injury Reduction: Too much or too little?

February 6th, 2016

Part 1 of 4 – Playground Surfacing Requirements and Injury Reduction: Too much or too little?
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 10, 2015

Since 2013 I have discussed the international definitions for terms used in safety standards related to children’s products, such as; hazard, risk, harm, intended design use, reasonable foreseeable misuse, and risk assessment. I also discussed the terms and definitions for severity levels of injuries using the Abbreviated Injury Scale (AIS). I see a need to define the scope of international playground standards by using these terms and definitions that balance the developmental needs of children with unreasonable risk of harm. It is a somewhat of a delicate balancing act between providing enough safety requirements to keep children from being seriously harmed while not tipping the scale away from our ability to provide more challenging risky play opportunities. In reviewing the scoping statements of various international playground equipment and surfacing standards it appears this line is blurred. How much regulation is needed to meet the needs of children as they seek the thrill of challenge versus the unintended consequences when their developmental abilities are inadequate to assess their risk of harm? What level of consequence (severity of injury) is a fare trade-off for the developmental benefits of risky challenging play opportunities? I have posed these questions to before to those involved in creation and management of playgrounds.

Falls to Surface – Number one cause of injury and one of four top causes of death on playgrounds
We have known since the early 1970s the number one cause of serious playground injuries requiring medical attention is FALLS TO THE SURFACE. What frequency and severity of fall related injuries can we live with? Most of these fall injuries result in long bone fractures which occurs far more frequently than a serious head injury. Which injury is more severe? It depends on the level of severity which is determined by trained medical professionals using the AIS rating system. The causes of these fall related injuries are many. Sometimes the child lacks the physical and cognitive abilities necessary to successfully use the equipment as intended or the child decides to use the equipment in unintended ways. Maybe the equipment had some design issues or it was not properly installed. Often the owner/operator does not maintain the equipment or surfacing in accordance with the manufacturer’s instructions and the equipment brakes or the surfacing no longer provide the minimum protection required by the standards. What about those serious injuries that occur on playgrounds that are well maintain within the minimum requirements of the standards? Should they all be accepted as a part of everyday life or should there be some change in our approach to the cause and effect of FALLS TO THE SURFACE?

The effort to reduce the current ASTM F1292 impact attenuation thresholds has been going on for a long time. Parties on both sides of the issue have done their best to bring the most current information to the attention of the F8.63 Subcommittee members. Before I get into the real issue of surfacing performance and injury reduction I would like to address a little issue related to accusations made against the ASTM International organization and its members. I believe ASTM and the ASTM F8.63 Subcommittee are due an apology for some of the comments that have been made and/or implied on how the ASTM and their volunteer members conduct the business of developing voluntary industry standards.

The following statement was written by one of the interested parties against the threshold reduction to 700 HIC and is true, to some extent.
“This is a complex issue with strongly-held views. I will continue to foster reasoned, constructive debate and share news and views, here and elsewhere, to the best of my ability – though there are challenges, not least the lack of transparency in ASTM’s decision-making. To repeat: there is no doubt that the extent of debate and opposition to ASTM’s proposal has helped to get this result.”

Determining what is the appropriate impact attenuation threshold is a complex issue but to imply the ASTM process is underhanded and non-transparent or flawed could not be further from the truth. The question still remains whether the outcome of the last ballot and the successful appeal was the correct result. Let’s start with some background information to the issue at hand.

Here are the facts on the ASTM Process
There are many Committees within the ASTM organization. There are 36 Subcommittees within F8 Committee. The F8.63 Subcommittee is responsible for all playground related surfacing standards and guides. This Subcommittee currently has about 160 voting members. Once a Subcommittee ballot item has gone through Subcommittee approval process it must then be upheld by the Main Committee ballot. The point is there are many opportunities for the dissenting opinions on any issues to have their negative vote and rationale heard.

In this instance the ASTM International voting process was followed. A 90% affirmative vote is required to continue to move the ballot issue forward to the next step in the approval process. The results in this first ballot was overwhelmingly in favor of the change (+9 to 1). The next step in the voting process is to address any negative votes. The few negative votes received were then reviewed by the task group. Written rationale was provided to find the negative votes non-persuasive. The rationale for finding the negatives non-persuasive was put in the form of a motion and a ballot was voted on by the entire F8 Main Committee. The results of this ballot was again overwhelmingly in favor of the change (+8 to 1) to reduce the HIC to 700. This step requires a super majority (+2/3rds) affirmative vote. All ballots are then approved by the ASTM Committee on Standards before they can get published.

The ASTM Committee on Standards (COS) appeal findings had nothing to do with the merits of the change to the HIC. The issue was whether or not the Subcommittee properly handled the negative vote process. The primary issue, as I understand the appeal, had to do with the timeline in which supplemental information related to the ballot item was sent to the Chair and distributed electronically to all F8.63 Subcommittee members. This information was believed, by some, to support those members who voted in opposition to the proposed HIC reduction. Distribution of these materials occurred after the ballot was posted for the vote to find the negative voter’s rationale non-persuasive. By the time the documents were distributed some ASTM members had cast their vote. Regardless of the timeline issue, the documents were sent to everyone and the voting deadline was extended. Anyone who wished to change their vote would be allowed to do so. The voting results were as stated above. Should these voting results have been upheld by the COS, the reduction of the HIC from 1000 to 700 would have occurred. The COS heard and upheld the appeal based on the timeline for how this new information was handled in relationship to the ballot posting and closing dates. COS thought there should have been more time allowed prior to the ballot closing date or the ballot should have been delayed. The COS ruling on this appeal required this ballot item go out to a vote once again.

Did new documents in question support no change to the 1000 HIC?

So you might ask what was so compelling about this new information in support of the status quo of 1000 HIC. Prior to the appeal hearing and action by the ASTM COS, the information in question was presented and discussed at the ASTM F8.63 Subcommittee meeting. I was at that meeting. It was a very lively discussion. These papers were determined to be of no consequence to the matter being balloted as they did not support either lowering or leaving the HIC at 1000.

Some of the so called supporting documents were National Electronic Injury Surveillance System (NEISS) reports on fall injury reports and serious head injury reports from 2001-2008. What these reports do not represent is the real number of fall related injuries and how many of these falls result in serious head injuries. NEISS report analysis is a statistical sampling of a small number of pre-selected hospitals that would be representative of the demographic distribution of all Americans. So NEISS numbers are a statistical projection of injuries based on the information gathered by the NEISS participating member hospitals. The information gathered from these reported fall injuries do not give us enough detailed information about the accident to assist us in this surface performance debate. Some just state, person fell to surface. We do not know anything about the characteristics of the surface or if it was compliant. The report states the person was transported to hospital by ambulance, treated, and released. We do not know the extent of the injury or if there was any negative impact to the injured party after that initial treatment. Very few people stay in hospitals overnight if they can be, observed, cared for, and treated at home. Are these injuries serious or not? Can anyone tell me how many serious head injuries are too many? Do we really need a number? There seems to be more questions than answers.

The other research document was a research paper titled, School Playground Surfacing and Arm Fractures in Children: A Cluster Randomized Trial Comparing Sand to Wood Chip Surfaces (Howard, 2009). This study was based on the Toronto Public School’s experience with injury reduction. This study appeared to have too many unanswered questions to provide concrete evidence the 1000 HIC was adequate or the benefits of a reduction to 700 HIC were measureable and substantial enough to be worth the cost.

Two Points of View – What can we learn from the Howard Study?

Since the initial discussion on the Howard Study and after the COS appeal decision, there were two presentations made by Subcommittee members at the following May ASTM meeting in Anaheim. These presentations were based on the findings of the Howard Study. This research paper was about injury reduction in Toronto Public Schools. The focus was on which of 2 types of loose-fill surfacing material was most effective in injury reduction, primarily fractures; wood chips or granitic sand. The study concluded a higher reduction in fractures on this special granitic sand than with wood chips. The study’s conclusion that 12 compressed inches of this sand is superior to 12 compressed inches of wood chips raises some additional questions about surfacing recommendation in the U.S. CPSC Handbook since it still shows a 4 foot critical height for 9 inches of compacted sand. This study proves to me that not all sand is the same or performs equally. While depth of surface material can have an effect on performance there is no guarantee more depth will result in better impact attenuating results. What the study does not discuss are the changes the school district made to their playground design guidelines prior to the study. Before the study and new school guidelines there were many very tall wooden structures that did not conform to the Canadian Standard requirements. New policies were put in place that in effect brought all equipment and surfacing into compliance with current CSA Standards. This resulted in a lower fall height for most play equipment. These guidelines also requiring a minimum depth of at least 12 inches for granitic sand or wood chip products be installed and maintained. Again it is important to point out these conditions did not exist prior to the study. The study conducted after the equipment and surface improvements did show a significant injury reduction but nobody took into consideration the performance of the preexisting surfaces in the Toronto Schools or the fall height of the old play equipment that contributed to all the baseline injury data. So what is the reason or reasons for the lower incidence in fractures and other serious injuries?

One Anaheim presenter secured copies of actual field drop test reports from the Toronto Public Schools. He concluded that the field test results showed excellent impact attenuation of less than 500 HIC and 100g was reason for fewer injuries. The other presenter concluded that surfaces which are in compliance with the existing standard thresholds of 200g and 1000 HIC resulted in fewer injuries. Which conclusion is more compelling? The results of actual field drop test reports for the Toronto Public Schools demonstrate impact attenuation results that perform over 50% better than current threshold and far better than the 700 HIC proposal. There are other variables not taken into consideration in the Howard Study that would help us in this discussion but that horse has already left the barn. So what else, if anything, does the study tell us?

When you take into consideration the actual surfacing field test reports the injury reduction results are based on a lower equipment fall height and a minimum 12 inch depth of surface materials, conditions that did not exist prior to the study. Regardless, I would argue the Howard study demonstrates a lower HIC threshold will have a measurable reduction in frequency and severity of all fall related injuries. The study also points out not all sand performs equally. This granitic sand, which as far as I know is only found in Ontario Canada, has superior impact attenuating properties primarily because it is very uniform in particle size and does compact.

We might begin to see the real correlation between surface performance and severity of injury if actual field drop test results were taken immediately after every serious fall related playground injury. Some are requesting this kind of data before voting to reduce HIC thresholds. For many legal reasons I do not see anyone willing to try and make this happen. What we can do is use the best information available. The automotive industry has 50 years of experience in the area of impact injury research. Why not start with that?

In conclusion, the ASTM Council on Standards Appeal was over nothing more than the timing of the release of the information I just discussed. The appeal argued the late distribution of the supporting documents in support negative voter’s position effected the voting results. These documents were discussed at two Subcommittee meetings. The discussion did little to persuade any voters one way or the other. Using the Howard Study along with the actual surfacing drop test results presented after all the ASTM voting, a pretty good argument can be made that fewer fall related fractures and head injuries will occur on surfaces with impact thresholds, even lower than the proposed 700 HIC. These results can only be realized one of two ways; lower fall heights or improve the performance of surface systems. The surfacing must also must be managed by conscientious and knowledgeable staff that implement a consistent inspection and maintenance program.

But what about the potential impact of a lower threshold on risk and challenge? Stay tuned for Part 2 of the story.

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

Part 3 of 3 – Hazard Based Approach to Standards Development: The time is now.

January 6th, 2016

Part 3 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

How does the hazard-based approach work? Our Objective

“Playground safety performance requirements shall be developed and applied to focus on the hazards posed by equipment’s design, movement, and layout, whether free-standing or in combination with other components, and should address the issues of intended and reasonable foreseeable use rather than exempting that equipment from all but the most basic requirements of the past.” Kutska, Part 2 of 3, Hazard Based Approach to Standards Development

Last September I wrote about this concept of hazard based standards development. In this article I referenced a post I made on the NRPA Connect social media page created for CPSIs. I walked him through the assessment process I might use in evaluating this design. The person was challenging the layout and spacing for a stand up spinner that was attached to the support post of an overhead ladder that was connected to a much larger composite structure. This is maybe too much for one to analyze without a picture but basically it was all one big composite structure. My assessment process went like this;

“What is your citation for your findings? Remember use zones may overlap for composite structures. Rather than use zone issues there may be more clearance related issues. I do not discount your concern but right now IPEMA Certification Program would consider this compliant. It may not be best design but now is not the best time to bring up this concern. Planning stages is when owner should evaluate risk and make recommendations. You could still move spinner and make it a free standing play event if you have money and space but the owner will be footing bill. We are working on this very subject at ASTM as we see rotating equipment and composite structures requiring a second look. Ask yourself, what are the hazards? Falls to surface. Impact by spinning equipment. Impact from limited clearance. Loss of balance from rotating equipment leading to lateral discharge from inadequate upper body strength and lack of gripping or grasping surfaces. Is there sufficient circulation area around adjacent play events? All reasonable concerns. Now ask what the standard allows at a minimum and then ask what a reasonable person would allow given your specific end user and owner’s philosophy for free play.”

I stated that for the hazard based approach to move forward we cannot continue to evaluate playground equipment during a post injury investigation in the same manner, with the same objectives, as if the injury occurred in a workplace environment. We have to look at what the safety issues are during reasonable and foreseeable use. Assuming the standard has established society’s acceptable threshold for severity of injury, the designer and manufacturer of the playground equipment should be conducting their own risk assessment of their equipment to determine whether or not it is appropriate for the intended user during both intended and reasonable foreseeable use. Equipment designer/manufacturers shall make recommendations on age appropriateness and should recommend minimum use and clearance zones based on intended design use and reasonable foreseeable misuse. Also the playground area designer and owner need to consider all these things and more during the design process. Other than the age range of intended users and age appropriateness of specific pieces of equipment, all other special requirements within the standard are stated as minimums. These minimums may not meet the owner’s needs for the scope of their project. The owner and designer need to work together and conduct their own project assessment and answer the following questions; define the intended users, what if any supervision will be present, intended user load, level of accessibility, access to and from the playground, environmental concerns, border safety concerns, and most importantly what level of impact attenuation their surfacing system shall provide based on the fall height of the equipment. Remember the surface system needs to perform to these minimum standards throughout the life of the playground. Therefore the owner may want to consider specifying surfacing to perform well under the minimum impact requirements for the fall height of the equipment or even specify a surfacing performance threshold less than minimum required to provide more fall protection under and around the more challenging pieces of motion and upper body equipment. When it comes to protective surfacing, use zones, and clearance zones these requirements are stated as minimums. Therefore it is ultimately up to the owner’s risk assessment during the conceptual playground design to establish their own balance between how safe is safe enough and how much risk and challenge is too much.

Children will continue to be injured while enjoying the thrill of the challenge as the test their skills. We also know the primary causes of debilitating and life-threatening injuries in children ages 2-12. Falls have always been the number one cause of injuries on playgrounds and one of the major causes of playground deaths. We also know that impact by moving and even stationary equipment is another major factor. We know entanglements caused by projections or specific dimensions along with how we dress our children to play on the playground are the number one cause of playground related deaths. We know that projections of specific sizes and shapes can impale a falling or moving child causing many different types of injuries. We know that sharp points or edges cause lacerations. We know that heavy suspended moving components that come in contact with the user’s body, especially their head, can cause serious brain injury.
How we approach these known causes of serious injuries which fit within the medical profession’s measureable definition of debilitating or life-threatening is our challenge. We cannot look into a crystal ball and predict with any certainty the future but we have learned from the past and must act responsibly. Now is not the time to go back to some of the design practices of the past for the sake of new product design, especially when the past has shown time and time again the unintended consequence of an unsupervised child’s reasonable foreseeable behavior. That is the real challenge to play equipment designers, manufacturers, and playground standards writers.
Do you have the ability to assess the play environment and the equipment within this environment during the play area design process and ultimately come to a reasonable balance between safety considerations and the need for challenge and risk in a child’s play environment? That should be our main objective. If we do not get this right, children will find what they are looking for in places with far more hidden dangers and risk of harm than should exist in any well designed playground.

For these reasons the ASTM F15.29 Subcommittee is working towards a hazard based approach to reduction of those injuries deemed unacceptable to society as a whole. Julian Richter, founder of the German playground equipment company Richter Spielgerate GmbH, said it best, “We should have as much play value as we can possibly afford, but only as much safety as is necessary.”
More on the status of this approach to standards writing in future columns.

Posted in Certified Playground Safety Inspector Course, Hazard versus Risk, Kenneth S Kutska, Playground injuries, Playground Maintenance Technician, Playground Maintenance Training, playground safety, Playground Safety Training, Value of Free Play | No Comments »

Part 2 of 3 – Hazard Based Approach to Standards Development: The time is now.

December 31st, 2015

Part 2 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

Food for Thought from the US Consumer Product Safety Commission Staff

“Playgrounds should allow children to develop physical and social skills, and part of that development includes testing the limits of their skills. Innovation is important for this, as children need new challenges. Staff believes it is important that new, innovative playground components should still follow the safety recommendations and standards that both CPSC staff and ASTM have worked to refine over the past several decades.” CPSC Staff May 20, 2013

“CPSC staff believes that focusing on the hazards posed by the equipment’s design or movement would address the issues of nontraditional equipment more appropriately than exempting that equipment from all but the most basic requirements.” CPSC Staff May 10, 2012

“CPSC staff believes that rather than exempting nontraditional equipment from most aspects of the standard, a more appropriate method of dealing with any issues of nontraditional equipment would be to focus on the hazards posed by the equipment.” CPSC Staff May 10, 2012

The May 20th CPSC staff letter requests ASTM create definitions for each different type of play equipment. CPSC points out neither the ASTM playground-related standards nor the current version of the CPSC Public Playground Safety Handbook (Handbook) currently define a “slide”. ASTM currently believes a definition for a slide that addresses each and every possible variation would become design restrictive and stifle innovation. Any definition that does not address each possible variation for a type of play event should not mean the equipment need only be required to meet the performance standards based on what name the product is called by the manufacture. I would rather propose conducting a risk assessment that goes beyond the merits of the product’s intended function and consider the reasonable foreseeable misuse of the product by the intended user group.

Intended Design Use of a Slide

Historically, the 1986 printing of the CPSC’s A Handbook for Public Playground Safety, Volume II, defined a “slide” as an “apparatus having an inclined surface used for sliding.” They have since stated the working definition for a slide used by the CPSC technical staff is,

” a flat or concave, inclined surface where children are likely to sit on their buttocks and slide down with their feet in front of them.”

This sounds like a reasonable definition for a slide and its intended use. I also think the use of the words, “likely to sit on the buttocks and slide down with their feet in front of them,” is a bit too narrow a description for how it has been used by children for more than 100 years. Where we start to get ourselves in trouble is when we try to create one-size-fits-all performance requirements for each inclined surface where children are likely to sit on the buttocks. Currently there are many specific performance requirements for a slide. Slide side rails currently have a performance requirement of a minimum of four inches. Why four? Why not three or six? Why any at all? This requirement came about based on the CPSC staff injury analysis going back more than 30 years. The CPSC said slide side rails would not always prevent a child from falling off the slide bedway. The primary function of the side rails were to provide an edge guide for the user’s feet or heals which would minimize lateral discharge as well as provide something for the user to hold onto for balance, if so desired.

Reasonable Foreseeable Use of a Slide

How did you use your old school playground slide? Did you every run up the bedway? Did you go down lying on your belly headfirst? Did you hook your legs around the person in front of you to create a kind of human centipede? Is this typical use or misuse. The new ISO definition for reasonable foreseeable use states the word “use” is synonymous with word “misuse.” This seems reasonable especially in the context of consumer products intended for use by children.

To make my point I would like to share a personal schoolyard experience as I remember it. I use to enjoy a very physical game of tag on our schoolyard. Understand this was in the late 1950s before there were any standards or guidelines. Our school had a 10 foot high free standing slide. I first started using this slide as defined and intended by the CPSC 1986 definition. This slide became so much more to us around the age of 9 or 10. We had mastered the sliding experience as intended and were now beginning to experiment and see what else we might be able to do with this traditional slide. It seemed so huge. It had two different types of diverging bedways. It had a double wide, open riser, step ladder up to a fairly large slide transition platform supported by metal support posts angling outwards to the ground. The platform had a guardrail to keep us from pushing someone off the platform. The slide had evolved into the arena for my friends and I to play tag. We seemed to be able to play on this one piece of equipment for hours on end or until someone got hurt. The latter was our signal to stop playing however it never stopped us from coming back another day and play the same game. This game had only a few rules we made up. Basically if you were tagged you were “IT”, until you could tag one of the other players. We moved at warp speed. We ran up the bedways. We went down the stepladder. Sometimes we went under the guardrail and down any one of the platform’s support posts to escape. I wonder if anyone considered some of these uses for this equipment. We did whatever it took to avoid getting tagged. I remember watching my friend use the stepladder handrails as a very steep banister slide. We did not see this as misusing the slide. We were just playing. It was exciting and great fun. Not everyone had the skills to do some of the things the stronger more experienced kids could do. This made them appear almost super human and impossible to catch. We learned a lot about our individual abilities and used that knowledge and skill to our advantage as part of the game. To us that double slide was so much more than just a slide. What started out as just a slide years earlier became a challenging super structure perfect for our game of tag. I wonder if designers ever considered observing how a bunch of 4th, 5th or 6th graders might actually play if they thought they were being left alone with no rules? This game of tag and the unintended, yet foreseeable, behavior it generated never occurred during school recess. Teachers would never stand for such careless and dangerous activity under their watchful eye. Guess what happened after school when all teaches left the building or on evenings and weekends when the area was unsupervised?

Unintended consequences of Reasonable Foreseeable Misuse of a Slide

The unintended consequences of the reasonable foreseeable misuse of any piece of playground equipment may result in something more than society is willing to accept. There is not much the owner and manufacturer can do about the lack of or improper supervision or inappropriate user behavior. The best defense against unintended consequences is for the manufacturer to provide and the owner to follow all inspection and maintenance recommendations to keep the area in compliance with best practices for public playground management.

The manufacturer has, at a minimum, specific information they must provide to the owner about the equipment intended users, installation, inspection and maintenance of their equipment. The owner must post at least the minimum required information and warnings. Since children most likely will not read or head the warnings and the caregivers often ignore them, what more should either party provide to their respective consumers beyond these minimum requirements to address the unintended consequence of reasonable foreseeable misuse?

Prescriptive vs Hazard-Based Performance Standards

CPSC staff has asked the F15.29 Subcommittee to recognize the recommendations in their Handbook and the requirements in the ASTM F1487 standard which are designed with respect to the hazards posed by the type of equipment. These requirements are based on a long history of injury statistics and analysis of injury patterns based on until now a very limited number of play equipment types that existed at the beginning of the playground safety standards movement. Times have changed and so has playground equipment. CPSC staff has recommended the F15.29 Subcommittee develop definitions for the equipment types listed in Section 8 based on the likely use patterns of children. Does this include just intended design use or does it include reasonable foreseeable misuse?

We both agree that definitions should ensure all new innovations meet the appropriate safety requirements yet foster continuing innovation in playground design. Broadly written or vague definitions leave too much open to subjective interpretation by parties with conflicting interests and objectives. The ASTM F15.29 Subcommittee has realized they cannot in a timely fashion, keep pace, with innovation within the playground equipment industry. Play equipment types and the multitude of variations for each type do not fit neatly into the basic playground equipment types that were available when the first playground standards were first being considered.
Regardless of what something is labeled we should consider taking the path as suggested by the CPSC but reword a bit to say, “playground safety performance requirements shall be developed and applied to focus on the hazards posed by equipment’s design, movement, and layout, whether free-standing or in combination with other components, and should address the issues of intended and reasonable foreseeable use rather than exempting that equipment from all but the most basic requirements.”

In Part 3 I will discuss how the hazard based process is applied.

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

Part 1 of 3 – Hazard Based Approach to Standards Development: The time is now.

December 30th, 2015

Part 1 of 3 – Hazard Based Approach to Standards Development: The time is now.
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
July 18, 2015

Background Information on Developments within the ASTM F1487 Standard
On May 20, 2013 the ASTM F15.29 Subcommittee responsible for the content of the ASTM F1487 standard received a letter from the staff of the U. S. Consumer Product Safety Commission. CPSC staff noted that the specific types of playground equipment in Section 8 of the Standard (balance beams, climbers, upper body equipment, sliding poles, slides, swings, swinging gates, merry-go-rounds/whirls, roller slides, seesaws, spring rockers, log rolls, track rides, roofs, and stepping forms) were not defined in the terminology section of the standard. CPSC acknowledged the difficulty in defining these items but felt the lack of definitions may lead to differences in interpretations and application of the standard, resulting in some products not meeting the appropriate specific equipment performance requirements.

In May of 2012, the CPSC staff submitted a written comment on a ballot item that proposed to add a new Section 8.0 to ASTM F1487 to address new equipment designs not currently being addressed in specific performance requirements in the current Standard Section 8-Equipment and Section 9-Layout.

The proposed ballot item was to address all equipment does not fit neatly into the existing equipment categories or types. CPSC and ASTM agree, all non-traditional equipment not specifically identified in Section 8 still need to be evaluated using this standard. Everyone currently involved in writing playground performance standards understands industry innovation is moving at break neck speed. This is a good thing for children. The ASTM F15.29 Subcommittee wanted to minimize the likelihood of life-threatening or debilitating injuries from innovative non-traditional equipment by directing designers and manufacturers to apply all general performance requirements in all the Sections leading up to Section 8 of the standard and evaluate the equipment for any potential hazards.

CPSC staff has serious concerns about the implication of exempting all equipment, not of a specific type, from all of the equipment performance requirements currently contained in Section 8 and 9. CPSC staff believed this ballot item did not provide the guidance required to adequately eliminate or reduce the potential risk of injury from “non-traditional” equipment. CPSC staff believed this proposal provides a loophole that may allow potentially hazardous products to enter the marketplace. The basis for their concerns were spelled out in 3 points within the CPSC staff’s written comment to ASTM F15.29 Ballot F15 (12-03), Item 6, dated May 10, 2012:

“1. Section 8, Equipment, contains performance requirements for the following specific types of playground equipment: balance beams, climbers, upper body equipment, sliding poles, slides, swings, swinging gates, merry-go-rounds/whirls, roller slides, seesaws, spring rockers, log rolls, track rides, roofs, and stepping forms. The equipment types, however, are not defined in Section 3, Definitions. This leaves their definition open to interpretation and could allow equipment to be considered to pass the standard by a manufacturer, test lab, or consumer who asserts that the equipment was not mentioned specifically. For example, there is no definition for “balance beam.” If someone were to place a long, flat beam between two posts, 20 inches from the ground, could that person then claim it was not a balance beam because it is more than 16 inches from the ground, and therefore, covered by the proposed exemption? If the answer is “yes,” then CPSC staff strongly disagrees and feels this exemption would seriously undermine the spirit of the voluntary standard.

2. The “Climber” and “Upper Body Equipment” sections have generally served as the
“catch-all” categories for equipment that does not fit elsewhere. This exemption will allow equipment to avoid even those requirements.

3. This ballot item states that nontraditional equipment need only meet the “general performance requirements.” There is no section for “general performance requirements; however, Section 5, “General Requirements,” contains only three specific requirements limited to age grouping, anchoring, and small parts (15 CFR 1501); and Section 6 “Performance Requirements,” contains a limited number of performance requirements. As written, it is unclear how Sections 5 and 6 apply and whether Sections 9–15 apply at all.

CPSC staff believes that rather than exempting nontraditional equipment from most aspects of the standard, a more appropriate method of dealing with any issues of nontraditional equipment would be to focus on the hazards posed by the equipment. For example, one of the newer types of playground equipment, perhaps one considered by the subcommittee while discussing this ballot item, is an overhead spinner that children hold while spinning. The 1990 COMSIS report suggests that merry-go-rounds should be speed limited and that “the maximum allowable magnitude of centrifugal force must be less than or equal to the magnitude of force that the user is capable of supporting with his/her arms…”; and section 8.8.6.2 of the voluntary standard requires a maximum velocity for a merry-go-round. Section 8.3.1.1 of the voluntary standard requires that handgrip devices have a certain diameter to maximize grip strength of children. CPSC staff believes that these overhead spinning devices should combine these two requirements for overhead spinners, rather than exempting them from all but “general performance” requirements. In this example, staff believes it would make sense to have a section that applies to “upper body equipment” and “spinning equipment”; the overhead spinner would then be subject to both, while the merry-go-round would be subject to “spinning equipment” and perhaps a new section for “moving platforms.” CPSC staff believes that focusing on the hazards posed by the equipment’s design or movement would address the issues of nontraditional equipment more appropriately than exempting that equipment from all but the most basic requirements.”

The CPSC staff acknowledged over the past few years the design of playground equipment has undergone some radical innovations. They are in favor of innovations in playgrounds and believe playgrounds serve an important function in childhood development. They state in the letter,

“Playgrounds should allow children to develop physical and social skills, and part of that development includes testing the limits of their skills. Innovation is important for this, as children need new challenges. Staff believes it is important that new, innovative playground components should still follow the safety recommendations and standards that both CPSC staff and ASTM have worked to refine over the past several decades.”

The CPSC staff stated their concern with new innovations that are labeled as “climbers” and yet these climbers appear to be used by children as a sliding surface. Their initial concern with this type of equipment was the lack of time between when the product is released in the marketplace and the time required to create any kind of reliable injury statistics specifically pertaining to what may be considered by some as slides and labeled as climbers by a designer/manufacturer. Another issue they raised was how these new designs are identified, categorized, and finally entered into the National Electronic Injury Surveillance System (NEISS) database by someone with little or no experience in all the current types and variation of public play components. The NEISS system has been around a long time and this coding system may need to be looked at again for its relevance to today’s circumstances. The current coding system makes it difficult for the CPSC to differentiate data for these products from that of traditional slides. CPSC staff was made aware of incidents described as involving slides (such as “slid off side of slide,” “fell off slide while sliding down”), yet further investigation revealed the product involved was called or labeled as a “climber. Our major concern with trying to define these new types of play equipment is the definition needs to be very vague to not become design restrictive beyond the intended design use. The problems arise when the standards writing organizations begin to try to create performance specifications that are not design restrictive yet still address the injury patterns on a particular type of play event. It seems to me that what we call something is not the answer. The bigger issue seems to me to be how the users play and interact with it that is most important when it comes to the assessment of safety issues versus the need for challenge and risk in the play environment.
Many of us may remember a product labeled by almost everyone in the industry as a “banister slide.” They are still being sold today. Jay Beckwith recently pointed out in his Playground Professionals column that during the R and D on this component the designers/manufacturers asked, “How are the kids supposed to use this?” His response was something like don’t worry, they will figure it out. The point is, we cannot will a child to do anything the same way each and every time in an open free play environment. Once they figure out how they can use it, which may be the designer’s intended design use, they will master it. Then when boredom sets in they will begin to look for other ways to interact and use it the next time, and the next time after that, and so on. Usually this kind of process and experimentation evolves into more risky play behavior as the user’s desire to experience the thrill of the challenge. I challenge you to go out and play and try this little experiment. Go to a local playground that has a balance beam. Walk across a balance beam once or twice. Then try it again with your eyes closed. Which was easier? What were you thinking when you had your eyes closed? Could you do it? Did you peek? Were you scared? Did you feel your pulse rate increase? As we get older our desire for this kind of excitement unfortunately begins to dwindle but not in children. Most thrive on this kind of excitement and challenge. Imagine this same “balance beam” experience if the designer places a properly designed handrail on each side of the beam. It would be much safer and almost guarantee a successful outcome regardless of your balance skills or whether or not you had your eyes closed. Building codes and ordinances take this approach for the health and safety of the general public in residential, public institutions and commercial buildings. This is not the approach to be taken in the design of a public playground or the development of playground safety performance standards. We want as much safety factored into the design as necessary but as little as possible to address debilitating and life-threatening injuries. The concept for “not too much and not too little” causes the angst being felt by playground owners, designers, manufacturers and all who inspect, maintain and repair these facilities. Injury data has led to some play components requiring handrails and handgrips on access components and guardrails and barriers on platforms above a certain height. Have we gone too far? Does anyone think a child would find a balance beam with handrails challenging or fun? I think the child is more likely to climb up on the handrails and attempt to walk across them. I would call this “unintended design use” or “reasonable foreseeable misuse” with “unintended consequences.” Ultimately we come back to the point of determining how much safety or risk is enough and how much of either is too much.

Play equipment definitions versus its intended use and reasonable foreseeable misuse

Is a banister slide really a slide? Is an inclined board of say 20 degree slope constitute a slide in the traditional form? What slope is necessary before you truly can have any kind of meaningful sliding experience? If this board doesn’t have a point of reduced gradient or 4 inch side rails with proper slide exit heights and transition platform of at least 14 inches deep does it mean it is not a slide? This gets to the CPSC staff’s concern. How does an inspector evaluate a piece of equipment when it does not meet all the requirements for a specific piece of equipment based on what the designer calls it or what an inspector labels it? I would agree that a slide with only 20 degree slope would not be used for sliding as much as it might be used for climbing. What slope is required before a child will involuntary begin to slide down the surface because of gravity?
In Part 2 I we will look at the CPSC’s traditional definition of a slide and the reasonable foreseeable misuse of the slide from a child’s perspective. I will present some options to consider on how to evaluate a piece of equipment regardless of labels.

Posted in ASTM Standards, Certified Playground Safety Inspector Course, Hazard versus Risk, Kenneth S Kutska, National Recreation and Park Association, Playground injuries, Playground Maintenance Technician, playground safety, Playground Safety Training, US Play Coalition | No Comments »

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