What is new at IPSI, 6th Edition Playground Safety IS No Accident

July 20th, 2020

On behalf of the tens of thousands of playground owner/operators who have and will continue to use the contents of Playground Safety Is No Accident (PSINA) as a guide for training staff to inspect and maintain safer playgrounds, we are pleased to announce the new 6th Edition. It is almost a decade since this resource was last revised and much has transpired since the printing of the 5th Edition back in 2011.

Since 2011 there have been two new releases of the ASTM F1487 Standard and many revisions to the various impact attenuating surfacing standards under the jurisdiction of F08.63 Subcommittee. Likewise, other international playground standards from around the world have also been revised. The manufacture of playground equipment and various impact attenuating surfacing systems have become more of an international marketplace. Many play equipment manufacturers have expanded their supply chains to other parts of the world as new manufacturing techniques and new materials have become more readily available. This expansion has brought about more creative designs that focus more on play value and risk taking rather than on safety being the first and foremost objective. Many international companies have entered into the public playground equipment manufacturing world in hopes to secure a segment of the growing North American and world markets for both play equipment and protective surfacing. There are still several differences in the Asian versus European versus North American Playground Safety Standards. Standards writing organizations in North America such as ASTM and CSA have focused on many of these market driven changes. We have also recognized the need to apply a more hazard-based risk assessment approach to our performance standards development brought about by the inability of standards writing organizations to keep pace with all the new industry developments. We have found that we can no longer rely on the prescriptive performance standards writing approach for each and every iteration for every conceivable variation of our traditional playground equipment types. We have learned a great deal about our differences within each other’s national and international standards. While international standards are not likely to be harmonized any time soon, we can all agree that we should at least be speaking the same language related to our playground safety scoping statements and common performance requirements.

My involvement in the international community’s discussion on harmonization has provided useful and insightful information for improving and advancing our inspection and maintenance practices. This information will assist playground safety inspectors make playspaces safer by effectively and efficiently addressing identified deficiencies in the playground environment. We will never eliminate all injuries and deaths on playgrounds, but we can surely focus on eliminating and/or mitigating those things that contribute to the frequency and severity of all serious playground related injuries.

In response to the global playground safety movement, the 6th Edition includes an expanded glossary of terms to clarify and harmonize the language used by playground safety standards writing organizations. I refer to this international language as, “Playgroundese.”

This new edition includes upgraded inspection forms and worksheets with expanded explanations on how to use each form. An important change is the completely revised “Post Installation Compliance Inspection and Assessment” process and form. This form was formally referred to as the “Playground Safety Compliance Audit.” While the scope or purpose of the various types of playground safety inspection forms remain somewhat the same, there have been many revisions based on the redefining of some of the more basic equipment types as we move away from the prescriptive approach to a more hazard/risk assessment approach of performance standards writing. The content has been modified to reflect what has been occurring around the world with regards to industry performance standards and this includes our most recent efforts to harmonize terminology and their associated definitions related to playground design, manufacture, assembly, installation, inspection, maintenance and the overall management of these public facilities for the benefit of all people.  

Today’s playground safety needs have become more complex and inspectors require more information and tools to perform a more effective and efficient job. Over the years, many Certified Playground Safety Inspector’s (CPSI’s) have taken time to write and express their needs for additional resources. This new version includes many of these suggestions. There are  a few personal testimonials from people who have taken the time to put into their own words how previous editions of this book have provided the information and knowledge necessary to develop, implement, and improve a playground safety inspection and maintenance program.

As previously stated, one of the largest undertakings in this revision was the total rewrite of the “Playground Safety Compliance Audit Form.” The revised form reflects the most current recommendations found within ASTM F1487-20. This new Audit form is now referred to as the “Playground Safety Compliance Inspection and Assessment Form.” Its primary purpose continues to identify what is and is not in compliance with the best practices (Standards and Guidelines), Changes in the form and process will aid the user to focus more on the importance of each identified shortcoming to determine a priority for corrective action. This prioritizing or ranking in order of importance what actions are required and when they should occur are still based on the probability of a serious injury occurring because of frequent exposure to the non-compliant condition during normal use. There are many different risk assessment tools out there that an inspector can use during this process. This 6th Edition provides some additional materials to help the inspector establish their own assessment tool or process.

Most everyone agrees ASTM Standards are voluntary unless codified by some regulatory authority with jurisdiction over the owner/operator. However, these standards, along with the recommendations found in the current 2010 United States Consumer Product Safety Commission’s Handbook for Pubic Playground Safety provides everyone responsible for the safety of playground users a reasonably safe harbor for their defense should a serious injury occur. The new audit form, as with all other audit forms before, includes the new citation numbers relative to either the CPSC or ASTM document. These citations provide a reference to assist the user in preparing formal reports. They also provide a quick reference guide for less experienced inspectors who may need to refresh their interpretation of specific issues that may arise during the inspection process.

In September of 2010, the United States Department of Justice 2010 ADA Standard for Accessible Design (DOJ 2010 Standard) became law. While no one can be guarantee absolute compliance to this law, the 6th Edition includes a new section to assess compliance to the barrier free accessibility minimum requirements up to, into, and through the playground. This form is also provided as part of the comprehensive post installation “Playground Safety Compliance Inspection and Assessment.” This form and the process can be conducted outside of the post installation compliance inspection process as a stand-alone accessibility assessment process for those who have yet to complete a transition play for assessing every playground for compliance with the accessibility and barrier free requirements based on the enforceable minimum requirements of the DOJ 2010 Standard for Accessible Design. This assessment process does not attempt to qualify or guarantee a playground is ADA compliant because only the Department of Justice is the only authority for that final determination. There are many new additions under types of playground equipment that follow the new ASTM Standard.

The PSINA Book also includes a “Playground Safety Compliance Inspection and Assessment Short Form.” In 2002 with the 3rd Edition of PSINA there was a need for a revised “Audit Form.” Between 1995 and 2002 there were many changes to the ASTM F1487 Standard. Inspectors were looking for a current checklist that was up to date with changes in both ASTM and CPSC Handbook. While there was not much of a need to revise the remainder of the book the Audit Form was in definite need of revision. Antonio Malkusak now of Abundant Playscapes, previously worked as a landscape architect for the Wheaton Park District. Wheaton was a member of the Park District Risk Management Agency (PDRMA) who also requested an updated form for their member agencies. I was too busy at the time to undertake this project, so Tony volunteered to take this on which ultimately lead to the 2002 3rd Edition. Part of Tony’s work for PDRMA was to create what was referred to as an “Audit Short Form” which was a compilation of all the changes that had occurred within the ASTM Standards and CPSC Handbook since the last printing of the book. This provided an option for playground operators who had previously conducted a comprehensive post installation compliance inspection just before 1997. Using this new “Short Form” they could review all their playgrounds and focus on just the changes in performance requirements assuming that current inspections, maintenance, and repairs kept the playground in substantial compliance with those standards and guidelines in effect at the time the original compliance inspection was completed. There is another new short form to assist those who may not have done another comprehensive compliance inspection and assessment since the 4th Edition of PSINA in 2009 which addressed the most recent changes to ASTM F1487-07. This new short form will address changes in the 2010 CPSC Handbook for 2-12 playgrounds and the ASTM F1487 Standard versions from 2011, 2017, and 2020. There have been many changes to the content and layout of the new post installation compliance audit process so it might behoove all operators to complete the entire process from the very beginning but I will leave that up to you to decide. I have placed more emphasis on the assessment process for all identified non-compliant conditions including all the minimum accessibility and barrier free requirements. There now are more ASTM F1487 requirements for additional information that the owner needs to gather to verify in writing the playground equipment and the impact attenuating surfacing system was installed according to the manufacturer’s installation instructions.  While gathering this information is not necessarily the responsibility of the inspector this information should still be available for review by the inspector. This written verification should any special requirements as provided by the manufacturer for installation, inspection, maintenance, repairs, and performance are being followed and are part of the playground site history file. In addition, if inspectors are not required to perform surfacing compliance drop testing during their inspection, they should include a disclaimer to that effect in their contract or final report. Without written verification of surfacing performance compliance the job as a playground safety compliance inspector is incomplete. Surfacing performance is directly related to a playground’s overall safety compliance ranking and surfacing compliance verification to minimum requirements is directly related to the mechanism of injury outcome for both frequency and severity.  

PSINA 6th Edition includes all the inspection forms for each type along with other worksheets in an electronic format. The entire book and interactive adobe formatted forms can also be purchased separately in an electronic format. The electronic format will again include a PDF of the DOJ 2010) Standard, revised “Maintenance Needs Assessment Checklist” covering those inspection items that need to be assessed as part of any more comprehensive preventive inspection and maintenance process. This process would typically include the Low Frequency Inspection which is now being referred to as the “Operational Inspection.”  The “Maintenance Needs Assessment Checklist” will assist the inspector in developing their own customized inspection form for each individual playground location. This type of inspection covers the general playground environment for items such as site amenities, landscaping, walkways, signs and general impact attenuating surfacing requirements prior to moving into those items related to specific types of play equipment. This checklist will assist a novice inspector in conducting the more detailed operational inspection without having to memorize every item that may need to be inspected. It is highly recommended; however, the inspector creates a customized operational inspection form that also includes all the specific maintenance and repair recommendations of the manufacturer.

There is another type of inspection currently recommended in the European (EN1176), Australian (AS4685), Canadian (CSA Z614) standards. The Japanese (JPFA-SP-S) inspections has a somewhat similar types of inspections except for the frequency of each. That inspection type is referred to as the “Annual Main Inspection.” This type of inspection is performed annually and often by a third-party inspector. It is similar in scope to the “Operational Inspection” but includes a total site risk assessment. This same process can be used to develop and conduct the “Annual Main Inspection.” This type of inspection is somewhere between the operational less frequent safety inspection and the post installation compliance inspection. This inspection often includes surfacing compliance verification and a risk assessment analysis of the entire playspace on an annual basis.

Regardless of which of these international standards you might look to for guidance on installation, inspection and maintenance the most typical terminology used to describe the various types of safety inspections are “Routine Visual”, “Operational”, “Annual Main,” and “Post Installation.” “Routine Visual Inspection” is like what we traditionally refer to as “High Frequency Inspection.” They are done on a much more frequent basis even daily. The “Operational Inspection” is similar to the “Low Frequency Inspection” and done on a less frequent monthly or quarterly basis focusing on preventive and manufacturer recommended maintenance tasks. These include those routine custodial tasks that are also being performed during the “Routine Visual Inspection.”  

The International Playground Safety Institute, LLC recommends first time Certified Playground Safety Inspector (CPSI) Course participants purchase the Playground Safety Is No Accident, 6th Edition book before using the electronic inspection forms and worksheets. This is especially true for those individuals new to the playground safety inspection and risk management processes discussed in the CPSI Program. The book includes background information and detailed instructions on how to use the forms. It also includes new staff training materials to assist those with less knowledge, skill, and experience related to the use of these forms. This book is one of the recommended readings for anyone preparing to take the CPSI Certification Exam without first participating in the actual CPSI Course.

The contents of Playground Safety Is No Accident, 6th Edition provide practical information concerning various components of a comprehensive playground safety and inspection program. It has evolved from what was the Wheaton Park District’s Comprehensive Public Playground Safety Program I established back in 1989. The origins of the very first comprehensive compliance inspection or audit came from the State of Massachusetts Department of Public Health, Statewide Comprehensive Injury Prevention Program (SCIPP) Playground Safety Checklist. The 1st Edition which was widely circulated around the country was jointly published in 1992. It became part of the NRPA CPSI course materials and was distributed to all NRPA CPSI Candidates starting in the mid 1990’s. The 2nd Edition was jointly published by the NRPA, National Playground Safety Institute (NPSI), Park District Risk Management Agency (PDRMA), and its authors in 1998. The 3rd Edition was published by same way in 2002. The 4th Edition was published by the International Playground Safety Institute, LLC and its authors in 2009 as was the 5th Edition in 2011. This 6th Edition, as with all other preceding versions, is sold with the understanding that neither the IPSI, LLC, the publisher, author, contributing writers nor the agencies or organizations they may represent are rendering legal advice or other professional service. Both the law and professional standards and guidelines change regularly, and may vary from state to state and from one locality to another. You are advised to consult with a competent attorney in your state if you are in need of specific legal advice concerning any of the subjects addressed in this book.

Playground Safety Inspection Forms and Worksheets including the sample “Playground Safety Compliance Inspection”  and all other Inspection Forms are intended for voluntary use by anyone who has purchased a copy of Playground Safety Is No Accident to document playground equipment conditions at the time of inspection. Effort has been made to ensure the appropriateness of the forms in relation to best practices for inspecting playground equipment. However, Standards and Guidelines change from time to time and the final determination of the appropriate inspection practices and safety of playground equipment must be determined on a case-by-case basis. In addition, all manufacturer requirements must be strictly followed. Participants of the Certified Playground Safety Inspection Course who have attained CPSI status should, with practice and continued study, become skilled in applying their knowledge in conducting accurate and complete playground safety assessments according to their own frequency as determined by internal policy and procedures.  NRPA and IPSI, LLC and the book contributors do not endorse or enforce use of these forms. No certification or “seal of approval” is granted or may be inferred by the IPSI, LLC the authors, its officers, agents, or employees.

That being said, the materials contained in this new edition of Playground Safety Is No Accident are as current as the information available in the ASTM F1487-20 Standard, the November 2010 revision of the U. S. CPSC Public Playground Safety Handbook, and the Department of Justice 2010 Standard for Accessible Design.

For more information on how to acquire either the book with electronic versions of the forms and worksheets just go to;  www.internationalplaygroundsafetyinstitute.com or www.nrpa.org.

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

January 14th, 2018

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Proverb: The Road to Hell is Paved with Good Intentions

January 14th, 2018

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

American Society for Testing and Materials (ASTM) Releases New F1487-17 Standard

June 25th, 2017

American Society for Standards and Testing (ASTM) releases new ASTM F1487-17 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use
By Kenneth S Kutska, Executive Director, IPSI, LLC
Chair ASTM F15.29 Subcommittee
June 25, 2017

ASTM F15.29 Subcommittee has recently published a revised ASTM F1487 Standard. Our Subcommittee has been very busy since the last revision in 2011. Change does not occur over night and our work is not over. Our subcommittee consists of 226 members with 182 as voting members. The breakdown of voting class members; 126 general interest (which would be me and most of you), 95 producers, 2 users, and 3 consumers. By ASTM standards this is a rather large subcommittee. Most members do not attend our face-to-face, bi-annual meetings. These meetings are held during “ASTM Committee Week” allowing other playground related subcommittees to participate in the standard development process. Whether or not you attend these meetings in person, every member is able to join the F15.29 Subcommittee. Once a member has been assigned voting status, they are required to vote electronically on each and every ballot item related to the Committee’s standards. Joining as a “General Interest Voting Member” for only $75 annually is easy. To join online go to www.astm.org. Membership is quite a bargain. Each year you get to choose one free volume of ASTM Standards. All playground equipment and surfacing related standards are found in volumes F15.07 and F15.11. Each volume would cost a member approximately $300. If you purchase just the ASTM F1487 Standard it would cost $75. As a person responsible for children’s play areas, there is no reason to avoid joining and becoming an active participant in the ASTM standards development process. That is enough advertisement on the benefits of joining ASTM.

How the ASTM F1487 Standard changed since 2011.
The changes in playground equipment design and manufacturing techniques have brought about many innovative and creative play opportunities not even thought of a few years ago. Without stifling creativity the new performance requirements address safety issues brought about by advancements in design, materials, and manufacturing. New innovations in design and materials such as, fiber-reinforced-concrete and new and improved fasteners, connectors, and connecting fasteners are providing options to traditional post and deck systems while creating more challenging play opportunities. Designers and manufacturers have developed more inclusive play equipment and a lot of this equipment is not static. This is all good, however the thought of putting children in motion does raise safety concerns for many owner/operators. When we think of traditional motion equipment like swings, merry-go-rounds, track rides or equipment that put children in motion like a slide we have only our personal experience to as a frame of reference. Today’s designers continue to push the old paradigm of what the traditional equipment types can and should be.

Creativity is a wonderful and inspiring gift when effectively applied for the right reasons. Everyone involved in providing public play spaces has a responsibility to create spaces that embrace the many different types of play experiences. This is best accomplished when designers provide play opportunities with graduated levels of challenge offering various levels of risk. A well-designed play space provides an environment that facilitates a child’s development during self-directed free-play. This is a huge responsibility for all play area designers or managers. Equally as important is the responsibility for the safety of the child when they over estimate or miscalculate their ability.

Risk Assessment by Playground Designers and Manufacturers: The Missing Link
Many owner/operators do not have the knowledge and experience to conduct a play area risk and hazard assessment. Most choose to transfer the responsibility for design, installation, and inspection of playground equipment to outside consultants. However, even with this contractual transfer of risk, the owner still has the primary responsibility for the safety of the public.

Accidents will continue to occur within any public environment. Responsible and engaged supervision of children is the key to reducing serious injuries regardless of whether a playground is 100% compliant with industry best practices. Parents that encourage and/or contribute to behavior inappropriate for their child only add to the problem. A child will participate in a particular play experience when they feel ready to take on the challenge. Child development experts suggest these choices are made after the child conducts their own risk assessment. A parent or guardian, at most, should provide encouragement under a watchful eye and only intervene when absolutely necessary. As stewards of public facilities, we need to consider all aspects of managing this generally unsupervised and unsecured public environment. Many children will not be adequately supervised so the biggest challenge for playground designers, manufacturers, and owners throughout North America is the liability costs associated with almost any injury regardless of the severity. What needs to change is the general public’s belief that playground owners are responsible for every child’s broken arm or leg. Most of these minor injuries occur due to the miscalculation of the child’s abilities. In other words, they have insufficient physical and cognitive ability to assess the consequences of their actions. These very important skills can and will be learned over time on the playground. If children are not given the opportunity to develop these skills on a reasonably safe public playground they will seek out other spaces to play and explore which can present a far more dangerous environment with a greater chance for serious injury.

New Scoping Statement on Assessing Risk
The following information has been added in Section 1: Scope of the ASTM F1487-17 Standard. Section 1.6.1 now states,
“The requirements in this standard are designed to mitigate the hazards typically presented by various types of equipment. New equipment may not specifically fit into the designated types listed in the standard; however, the designer and /or manufacturer shall use professional judgment to perform & document a hazard analysis and follow appropriate requirements to mitigate the hazards.”

The following definition for “professional judgement” along with requirements for any person who claims the playground equipment is in compliance with this standard is directly related to this statement.

“Professional judgment” is defined as,
“the ability of an individual with current knowledge, skill or experience, or both, in the field of playgrounds/playground equipment design, use, or operations, which enables the person to form an opinion or make a decision, or both, concerning a matter within that field of expertise.”

Section 5: General Requirements states,
“Playground equipment represented as complying with this consumer safety performance specification shall meet all applicable requirements specified herein. Anyone representing compliance with this specification shall keep such essential records as are necessary to document any claim that the requirements within this specification have been met.”

Considering these three statements you can begin to understand the responsibilities of every party involved in creating a playground from concept through the day the playground is taken out of service. Owner/operators should not and cannot totally abdicate their responsibility for the public’s safety. They need to understand their responsibility and that of others involved in the design, manufacture, installation, inspection, maintenance, and repair of a playground

Addition to Specific Equipment Performance Requirements.
There are many more changes and additions than cannot be adequately covered in this article. I will attempt to address some of the more significant changes starting with two new definitions to help clarify some of the more technical aspects of each within the standard revisions. Terms and definitions are very important to understanding and applying this technical document. Words can have different meanings. Some of the more common terms used in this technical document conjure up a meaning in the mind’s eye that can lead to confusion. For example, the last revision of this Standard redefined what a swing was, as crazy as it sounds, and established the swing suspended component impact test which addressed several safety concerns. The result has been the development of many new types of swinging experiences. Let’s look at two new definitions and a few of the new performance requirements for “Embankment Slide” and “Rotating Equipment.”

New Embankment Slide Definition
Embankment slides have become more popular as designers attempt to minimize fall heights and the related surfacing requirements within the use zone. An embankment slide must follow the contour of the ground and at no point can the bottom of the slide chute be greater than 12 inches (305 mm) from the surrounding ground surface. The slide transition or entry platform may also be up to 12 inches (305 mm) above the surface and does not have use-zone requirements. Even though the slide is no more than a foot off the underlying surface and the slide exit height cannot be greater than 15 inches (380 mm) above the exit surface it still requires impact attenuating surfacing within the slide exit use zone. The fall height as it relates to protective surfacing requirements of an embankment slide has been an area of concern for some time. Why does a free-standing slide have a fall height based on the height of the top of the slide bedway vertically measured to the protective surfacing below the slide exit? It does not seem logical when the embankment slide bedway must not be more than 12 inches (305 mm) above the embankment. Since the vertical fall heights along the side of the embankment slide bedway are limited to 1 foot and the exit height cannot exceed 15 inches (380 mm) the need to calculate fall height using the existing criteria for a free-standing-slide did not make sense. The subcommittee agreed that the velocity of the user and subsequent impact at the exit required more consideration. The new requirement is based on the velocity and discharge forces at the exit. Other international playground standards recommend that the slide exit use zone for an embankment slide shall have a minimum of (1) meter or 40 inches fall height. The current critical height surfacing requirements of F1292 state the critical height rating of the surfacing must be in full feet measurements. Therefore, the critical height of the impact attenuating surfacing within the slide exit use-zone must be greater than or equal to 48 inches (1220 mm). The embankment slide exit must also end onto a protective surfacing use-zone that is not part of the embankment as well as meet the requirements of the slide exit clearance zone.

New Rotating Equipment Definition
Designs have changed drastically over the past few years. The safety concerns of the old “Giant Stride” or “Merry-Go-Round” were real and had to be addressed. Designers have pushed the envelope of creativity when it comes to the rotating equipment that I played on as a young boy, however, the hazards have not changed. New types of rotating equipment have emerged throughout the world that no longer fall within the old definition or performance requirements for rotating equipment. The ASTM F15.29 Subcommittee has identified the hazards associated with this type of equipment – ejection/falls to the surface, collisions with other users, impact with equipment, and impact with adjacent equipment/supports. Our ASTM Subcommittee looked at the many new and different types of rotating equipment, These new performance requirements are not meant to restrict new and innovative equipment designs rather than to clarify the critical requirements intended to address the above mentioned safety issues. These requirements make a distinction between rotating equipment intended to be sat on, stood on, or hung from by the user’s hands, and equipment that does not rotate freely and is intended to be manipulated by the user’s hands; such as, sand diggers and steering wheels.

Previously any rotating equipment with a diameter of less than or equal to 20 inches (508 mm) with designated play surfaces of less than or equal to 30 inches (760 mm) above the adjacent underlying surface can have an overlapping 72 inch (760 mm) use zone. Rotating equipment with a diameter greater than 20 inches, (508 mm) could not overlap any other use zone but composite structures were allowed to have overlapping use zones. Clearance requirements have not been specifically addressed within the standard other than for a few types of equipment such as swings and slides. Playground equipment designers and manufacturers have been responsible for controlling clearance dimensions that would address the probability of the user impacting another part of the playground equipment including adequate space for user circulation. The question was raised, “Why should rotating equipment attached to a composite structure be allowed without having to comply with the same clearance and use zone requirements for freestanding rotating equipment?” The following information highlights most of the new clearance and use zone requirements by type.

Rotating Equipment: Vertical versus Horizontal
Rotating equipment is defined as either vertical or horizontal rotating equipment and most of these new requirements are based on the overall outside diameter of the equipment and not just the diameter of the platform. Rotating equipment that revolves repeatedly about either a vertical axis (merry-go-round) or horizontal axis (logroll) can be at different angles provided certain clearance tolerances are met. It is the angle of the plane of rotation that differentiates the two types or rotating equipment. The deciding factor is the location of the fixed plane of rotation in relationship to a point 45 degrees from horizontal. This section also addresses rotating equipment which incorporates other climbing and/or rotating components on top of rotating equipment.

Vertical Rotating Equipment: Size Matters
Rotating equipment with a maximum dimension greater than 20 inches (508 mm) measured from the axis of rotation to the outmost perimeter is key in applying these new requirements. In other words the outermost diameter of the rotating equipment would be greater than 40 inches (1016 mm). Generally, it must have a perimeter that is approximately circular and within 2 inches (50 mm) between the minimum and maximum radii. Any component that extends beyond the outer perimeter shall be designed to minimize the likelihood of hazardous impact during use. Rotating equipment with a maximum dimension less than or equal to 20 inches (508 mm) measured from the axis of rotation to the outmost perimeter may be non-circular in shape. Rotating equipment designed for climbing shall also meet the requirements for climbers.

Clearance and Use Zone Issues with Vertical Rotating Equipment
Accessible barrier-free design has helped with the evolution of rotating play events. Historically rotating equipment had to have a minimum underside clearance of 9 inches (228.6 mm). Now rotating equipment platforms may be flush to the protective surfacing; however, there can be no gap greater than .312 inches (7.9 mm) measured in any direction between the platform and protective surfacing to eliminate crush and shear concerns. There are many other requirements related to the underside of any rigid rotating platform but these new requirement pertain primarily to the equipment designers and manufacturers. Unfortunately, some owners may have installed some of the first prototypes of these rather new types of rotating equipment that were not previously covered by the ASTM F1487-11 and may no longer be in compliance with these new requirements. Most of these requirements are also triggered by the diameter of the rotating equipment’s widest platform dimension.

The evolution of the newer types of rotating equipment did not relate technically to the old definition of rotating equipment and the interpretation and use of the term “platform.” Many types of rotating equipment did not require a platform as is already defined in the Standard and therefore many of the rotating platform requirements were thought to not apply. Impact by components outside the point of rotation or openings within the perimeter of the rotating equipment have long been thought of as a safety concern. In addition to potential for impact hazards from perimeter components there are other impact related concerns due to the user’s ability to contact the underlying playground protective surface while within the equipment’s perimeter, clearances between the equipment and the protective surface, and clearances to adjacent equipment. These discussions resulted in a complete revision of this part of the standard.

Clearance between the underside of the platform and the underlying playground surface has specific requirements based on the following clearance situations and dimensions:
• Rigid rotating platforms that are not flush to the protective surfacing must be free from abrupt changes that are rigid and hang below the overall thickness of the platform.
• Clearance between the rotating equipment that is not flush and therefore raised above protective surfacing has to be between 2.38 inches (60.5 mm) and 3.50 inches (88.9 mm) or greater than 9.0 inches (228.6 mm) above the underlying surface unless a protective skirt is provided.
• When a protective skirt is provided, it must be smooth and continuous, tapered towards the axis of rotation to a clearance between 2.38 inches (60.5 mm) and 3.50 inches (88.9 mm) or greater than 9.0 inches (228.6 mm) at the lowest point.
• Rotating equipment with a maximum radii dimension greater than 20 inches (508 mm) which also possess a 108 inches (2743 mm) use zone are exempt from speed limitation requirements and shall be designed and constructed to minimize the likelihood of hazardous impact by any rigid members and provide clearance to the protective surfacing material should the user fall or pass through the interior of the equipment during use.
• Rotating equipment with a fixed, but angled, plane of rotation, cannot oscillate and must maintain a minimum clearance of 9 inches (229 mm) at the lowest point of elevation from the underside of the equipment.
• Rotating equipment with a maximum radii dimension less than or equal to 20 inches (508) is exempt from several of the clearance requirements.
• Rotating equipment shall have a clear area free of rigid structural components of 72 inches (1829 mm).
• Rotating equipment within or upon rotating equipment shall have a 21 inches (533 mm) clear area free of rigid and non-rigid components such as cables, netting, and belting.

Rotating Equipment Use Zones
Historically rotating equipment has had a 72 inches (1829 mm) minimum non-overlapping use zone. Overlapping use zones were allowed if the rotating equipment the diameter was no greater than 20 inches (508 mm) and both adjacent pieces of equipment did not have a designated play surface greater than 30 inches (760 mm). Rotating equipment with a diameter greater than 20 inches (508 mm) could not overlap with any other use zones.

Vertical Rotating Equipment (Merry-Go-Round) Use Zones
The use zone for equipment with a maximum radii dimension less than or equal to 20 inches (508 mm) shall be no less than 72 inches (1829 mm) from the perimeter of the play structure. Overlapping use zones is permissible if the adjacent fall height of each structure is less than or equal to 30 inches (760 mm) above the protective surface. If the adjacent fall height on either structure exceed a height of 30 inches (760 mm), the minimum distance between structures shall be 108 inches (2740 mm). The use zone for equipment with a maximum radii dimension less than or equal to 20 in. (508 mm) shall be no less than 72 inches (1829 mm) from the perimeter of the play structure. Overlapping use zones is permissible if the adjacent fall height of each structure is less than or equal to 30 inches (760 mm) above the protective surface. If the adjacent fall height on either structure exceed a height of 30 inches (760 mm), the minimum distance between structures shall be 108 inches (2740 mm).

The use zone for equipment with a maximum radii dimension greater than 20 in. (508 mm) which do not exceed the speed limitation requirements shall be no less than 72 inches (1829 mm) from the perimeter of the play structure and shall not overlap any other use zone. Rotating upper body equipment with a maximum radii less than or equal to 20 inches (508 mm), is exempt from both the ground clearance and speed limitation requirements. The use zone for equipment with a maximum radii dimension greater than 20 inches (508 mm) and exceed the speed limitation requirements must also have a use zone of no less than 108 inches (2743 mm) from the perimeter of the play structure including a 72 inches (1829 mm) use zone that shall not overlap the use zone of other playstructures.

Single-user rotating equipment, such as sand diggers, which require the user to maintain contact with the ground during play, has no individual use zone requirements. However, sufficient space is needed between all adjacent structures and individual play equipment for the purposes of play and circulation.

Horizontal Rotating Equipment Use Zones (Example Log Rolls)
The use zone for equipment that rotates around a horizontal axis and has a designated play surface greater than 30 inches (760 mm) above the protective surface shall be no less than 72 inches (1829 mm) from the perimeter of the play structure. The use zone for equipment that rotates around a horizontal axis and has a fall height of 30 inches (760 mm) or less above the protective surface, such as a log roll, shall be considered stationary play equipment. No other play structure use zone shall overlap the use zone of equipment that rotates around a horizontal axis and has a fall height greater than 30 inches (760 mm) above the protective surface. The fall height of horizontal rotating equipment shall be measured from the highest designated play surface and the protective surface below. The horizontal rotating equipment surface that is intended to be stood upon shall have a designated playing surface less than or equal to 18 inches (460 mm) above the protective surfacing and provide hand gripping component(s), between 0.95 inches (24 mm) and 1.55 inches (39 mm) in diameter, to aid in mounting, dismounting, and maintaining balance while in use. Horizontal rotating equipment is not recommended for use by pre-school age children 2 through 5 years.

Suspended Components on Manipulative Play Components
There have been many new types of manipulative play components with attached suspended components particularly in the area of musical instruments. Existing performance requirements made compliance more difficult, especially for ground-level musical instruments. Pipe ends on chimes, tubes and other musical instruments no longer need to be capped so long as they pass the sharp edge test. Other suspended hazard requirements were modified to allow for longer connecting devices up to 24 inches (609 mm), such as a cable or chain, necessary to operate the equipment such as a small mallet but must not be attached any higher than 27 inches (686 mm) above the underlying surface. These manipulative parts are also exempt from meeting the projection criteria using the large 3-inche interior diameter projection gauge, since falling on or running into a larger projection that could damage internal organs in the child’s abdomen, are highly unlikely. The use of the smaller gauges still applies.

Flexible Climbing Components
There are more flexible climbing components in the play environment as either free standing or part of a composite play structures. These flexible climbers generally are comprised of a chain, cable or rope. The rigid components found on these play components are primarily intended for structural support and for the most part are not intended to be a climbing component. Almost none of these structural support components would fit the current handrail and hold requirements. Likewise, almost none of the flexible climbing components are made of materials that fit within the current handhold dimension of 0.95 to 1.55 inches (24.1 to 39.4 mm). Flexible hand gripping climbing components must be between 0.62 and 1.55 inches (12 and 39.4 mm). Flexible climbing components must be securely connected at both ends. When they are connected to the ground the anchoring device shall be beneath the base of the minimum required depth of the protective surfacing material or the anchoring device must be vertically shielded. When unitary surfacing material is used, a maintenance access opening is permissible, provided that the anchoring device is not accessible when tested with the 3.50 inches (88.9mm) projection gauge. Some cable nets are more susceptible to stretching over time and require some tension adjustment. Tensioning devices are not considered to be part of the anchoring device.

Falls from Adjacent Platforms
There was concern raised with adjacent platforms when the elevation between these platforms intended for access/egress required climbing components. The upper platform of adjacent platforms must have guardrails or protective barriers on the side adjacent to the lower platform depending on the height difference between adjacent platforms. The guardrails or barriers dimensions are required on the upper platform based on the age of the intended user. Obviously there will be an access/egress opening but the width of that opening needs to follow all the requirements for guardrails or barriers when there is not at least the top rail of a guardrail to limit the likelihood of an inadvertent fall.

Changes to Other Specific Equipment Type Requirements

The slope of the slide exit region can now be as much as minus 10° as measured from horizontal. This should help mitigate drainage and user exiting issues. The slides section now has a new figure to demonstrate how to measure a curved slide’s length to make it easier for compliance inspectors to calculate height/length ratio of the sliding surface on spiral slides.

In 2011 there was a complete rewrite of the swing section of the F1487 Standard. This section states only one multiple occupancy suspended element can be mounted within a swing bay. Traditionally the multi-occupancy swings that were considered to be impact concerns were more of a suspended “park bench” or a “2-person glider type” commonly found in residential playgrounds. Up until 2011 multi-axis-swings were considered to be similar to a tire swing. Only one such swing was allowed per swing bay. Starting in 2011 we allowed single axis (to-fro) multiple occupancy swings with only one per bay. This revised standard exempts single axis suspended elements intended for a maximum of two users from this requirement.

Does the Swing Pivot Point Height Effect Impact Forces?
A question was raised as to whether the impact forces of the suspended component (seat) was effected by the length of the connector to the pivot point. The manufacturer must now designate the maximum height of the pivot point at which the suspended element meets the impact threshold requirements as specified for the dynamic swing impact test. Those impact thresholds must be less than 500 HIC and 100g. If an owner, designer, and/or installer exceeds the manufacturer’s maximum pivot point requirement the impact thresholds may be exceeded.

Roofs and Other Shade Structures versus Overhead Obstructions
These structures are an integral part of a play structure yet they should not become a physical play event. They may be at any angle, provided that the roof line (lowest edge), excluding support members, is at least 84 inches (2130 mm) above the underlying designated play surface and the pivot point of a swing. The problem arises when the lowest edge of the roof or shade structure line is too close to a designated play surface. In the case of a swing it would include the area the user occupies when in the full range of motion. Therefore these structures must maintain a clearance above the protective surfacing within the use zone of a swing of X + 42 inches (1065 mm), where X is the distance from the pivot point of the swing to the underlying protective surface.

Roofs that are an integral part of a play structure and are less than 84 inches (2130mm) above the designated play surface shall contain no designated play surfaces and their support members shall be designed to discourage climbing. Roofs or shade structures that conform to these requirements do not have a fall height requirement.

All parties involved in the final design and plan approval of the playground should consider the intent of this section when designing and using roofs on play equipment.

Playground Layout as Related to “Play Functionally Linked”
The use of the term “Play Functionally Linked” has successfully been put into practice to create many interesting continuous play opportunities and playground designs. Unfortunately it has also been abused by some to get around equipment use zone requirements and site related spatial limitations. As I discussed earlier in this article, the new standard scoping statement requires the playground designer and manufacturer to conduct a hazard analysis for each individual piece of play equipment. This should include how any particular piece of equipment relates to all the other play opportunities that make up a composite piece of equipment and the entire play space. I strongly suggest the owner conduct their own such risk and hazard assessment. What may be considered compliant design may not always be considered good design. ASTM F1487 has previously addressed the acceptable distance between stepping forms based on child developmental factors and anthropometrics of the intended users but there are many other types of stepping surfaces and climbers with stepping surfaces that when placed adjacent to one another are being labeled “play functionally linked.” This revision requires two or more adjacent play components, intended to be considered play functionally linked, to not be greater than 12 inches (300 mm) apart for 2 through 5 year old children and 18 inches (460 mm) for 5 through 12 year old children. These dimensions are measured edge to edge between the adjacent stepping surfaces and address the stepping capabilities when there is a change in elevation between adjacent stepping surface elevations.

WARNING! ASTM F1487 does not specifically address or differentiate between stepping and climbing surfaces on adjacent play functionally linked play components. The designer, manufacturer, and owner should consider how the intended user group will use the climbing equipment in relationship to other adjacent functionally linked stepping or climbing equipment and assess where the user may fall if they fail to use the climbing equipment as intended.

Consider a scenerio where stepping forms or a balance beam is linked to a vertical-climbing-net. Where is the intended path of travel? How will the user use and interact with each piece of functionally linked component? Is access and path of intended travel from the side or will the user need to climb vertically up or across functionally linked component putting the user considerably higher than the adjacent linked stepping component? Will the fall height be far greater than 30 inches without consideration for a minimum use zone free of obstacles? Regardless, each stepping play surface that is adjacent to the climbing net or any other designated play surface must meet the spacing requirements of this new section. Owners, designers, and manufacturers need to consider how the user will interact with all the functionally-linked equipment and consider mitigation measures to address related safety concerns.

Playground Maintenance: It’s Your Duty
The standard requires the owner/operator to inspect, maintain and repair each play structure within the playground and the impact attenuating surfacing in accordance to the designer/manufacturer’s installation and maintenance instructions. Beyond maintaining the equipment’s function and surfacing impact attenuation it also will assure the playground remains compliant and, where applicable, continue to meet the intent of the DOJ 2010 Standard for Accessible Design. To that end the owner/operator shall make periodic inspections of each play structure and remove any extraneous materials from the equipment or impact attenuating surfacing that could cause injury, infection, or disease. This could include litter, blood borne pathogens, wildlife excrement, and ropes tied to play equipment.

The owner/operator must also establish and maintain detailed installation, assembly, inspection, maintenance, and repair records for each public-use playground equipment area. Section 11 of this Standard details who is responsible for providing most of the information necessary to fulfill the above documentation requirement.

Next to the lack of supervision or inappropriate unintended use of play equipment, the lack of adequate maintenance of play equipment and surfacing within the use zone, is the second leading cause of most serious playground related injuries. We have a lot of work ahead of us so let’s get to work.

This has been a general overview of most of the changes to the ASTM F1487-11 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use. You can acquire a copy of this new ASTM F1487-17 document by ordering online, www.astm.org.

July 13th, 2016

Research Supports NRPA’s Certified Playground Safety Inspectors Reduce Injuries:
Part 4 of 4: Closer Look at Research Process and Methods that Support Curtis’s Conclusions and Suggestions for Future CPSI Research

By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
April 27, 2016

The purpose of this study was to examine the effectiveness of the playground safety inspector certification programs on reducing reported injuries sustained on public playgrounds in the state of California. Utilizing themes from a review of the literature and the three elements of the working model (CPSI-CEWM), the study examined three hypotheses:

(a) A greater decrease in injuries will occur when cities utilize certified playground safety inspectors
(b) The degree to which supervisors value the playground safety inspector program will affect injury rates
(c) Playground safety inspectors’ beliefs about the system will also influence injury rates.

Based on predominant themes derived from the review of literature and the elements of the CPSI-CE Working Model, three hypotheses emerged, included:

(a) A decrease in injuries occurred when playground safety inspectors were hired.
(b) Playground safety inspectors’ beliefs in the system influenced injury rates.
(c) The value supervisors place on the playground safety inspector program affected injury rates.

Method – Design and Participants
Previous teacher certification effectiveness studies provided excellent guidelines for designing this study. A correlational framework was utilized to examine relationships among injuries sustained on public playgrounds among three different size municipalities in the state of California during a 10-year period and model components such as playground safety inspectors’ and their supervisors’ beliefs and attitudes about certification status, experience level, and available resources.

Three sets of participants from municipalities were sampled for this study, including
(a) active playground safety inspectors (n = 474),
(b) the ‘supervisors’ of the playground safety inspectors (n = 474),
(c) the risk managers from those same municipalities (n = 474).

A response rate of at least 40% for cities from each size category was targeted, but actual response rate was over 63% with 286 communities providing completed responses. Only one active playground safety inspector from each city was included in the study because the number of inspectors could vary from city-to-city, with larger cities having a number of active playground safety inspectors while smaller cities may have only one. Also, the second group of participants, the ‘supervisors’ of the inspectors, typically would have one supervisor overseeing all inspectors. The number of inspectors and supervisors was kept the same to allow perceptions of both groups equal weighting in analyses.

Cities were divided into three population sizes, including:

(a) small (500 – 9,999),
(b) medium (10,000 – 199,999),
(c) large (≥ 200,000) cities.

Cities of less than 500 were eliminated from the study because pilot study data suggested most did not or were not responsible for maintaining public playgrounds. Cities were categorized into three distinctive sizes enabled inferences to be drawn about each of these population-based subgroups that otherwise could be lost in a more generalized random sample. Stratified sampling by city size also afforded an opportunity to assess the variations of results, if any, based on city sizes (e.g., Did more medium-sized cities have CPSIs, and experienced a reduction in injuries as a result, compared to small or large cities?). Only one active CPSI from each city was included in the study because the number of inspectors could vary from city-to-city, with larger cities having a number of active CPSIs while smaller cities may have only one. The second group of participants is the inspectors’ ‘supervisors,’ and depending on the organizational structure of the city, one supervisor could oversee more than one inspector, which influenced their perception.

To examine the effectiveness of playground safety inspector certification on reducing reported injuries sustained on public playgrounds, it was necessary to develop three survey instruments to obtain data to test study hypotheses. These included;

(1) Playground Safety Inspector Assessment Survey (PSIAS),
(2) Playground Safety Inspector Supervisor Assessment Survey (PSISAS),
(3) Playground Safety Inspector Injury Data Survey (PSIIDS).

The instruments were developed specifically for this study and for specific positions within city organizational structures that could provide necessary data and perceptions.

The PSIAS and PSISAS were broken into the three primary dimensions of the CPSI-CE Working Model and were specifically related to the participants’ positions as playground safety inspectors and ‘supervisors’ of playground safety inspectors. The PSIIDS was an instrument designed to collect injury data and was administered to risk managers for each sample city.

(1) Playground Safety Inspector Assessment Survey (PSIAS).
The playground safety inspector was defined as a full-time employee with the responsibility to inspect playgrounds for safety issues and eliminate risks. The PSIAS was developed specifically for this study to gain perceptions and demographic data from playground safety ‘inspectors.’ The PSIAS was based on the elements of the CPSI-CE Working Model and consists of four sections including,
(a) certification,
(b) experience,
(c) resources,
(d) demographic and background information, including 32 perception items and 10 demographic questions.

The PSIAS employed three model-based subscales, including;

(a) 12-item training and current certification subscale to assess perceptions of playground safety inspectors towards training and certification issues,
(b) 10-item experience subscale to examine perceptions of playground safety inspectors toward experience based on the CPSI-CE Working Model,
(c) 10-item adequate resources subscale to assess playground safety inspectors’ perceptions toward available resources based on the CPSI-CE Working Model.

The PSIAS also was comprised of 10 demographic questions related to history as a playground safety inspector, certification status and source, age, and gender.

(2) Playground Safety Inspector Supervisors’ Assessment Survey (PSISAS).
The PSISAS was designed for this study to be completed by the supervisor of the playground safety inspector. Supervisors were defined as full-time employees or elected officials with the responsibility of supervising the city’s playground safety inspector(s). The supervisor completing the PSISAS was not required to be certified or trained as a playground safety inspector. However, each was to be responsible for supervising the playground safety inspector who completed the PSIAS. The PSISAS was developed for administration to the ‘supervisors’ of the playground safety inspectors, and was comprised of the same four assessment dimensions as the PSIAS. The PSISAS was developed to ascertain beliefs and attitudes about how supervisors of playground safety inspectors perceive the effectiveness of their employees’ certifications (or present training status) in reducing reported injuries in playgrounds they were responsible for inspecting, based on CPSI-CE Working Model elements. The three perception subscale items were identical to the PSIAS, except each obtained the perceptions of the supervisor.

(3) Playground Safety Inspector Injury Data Survey (PSIIDS).
The PSIIDS was developed specifically for administration to the risk managers of sample cities to identify the number of reported injuries for each municipality during the years 2000, 2005 and 2010. The risk manager was defined as the municipal employee, elected official or outsourced risk management agency with the responsibility of obtaining and maintaining records of reported injuries on respective city playgrounds. This data was most likely in the form of financial claims against the municipality for injuries sustained on its public playgrounds. Injuries sustained on public playgrounds not requiring medical attention were most likely not be reported. The three data collection years were selected because the dates were recent and would allow a measurable trend analysis. The information obtained from this instrument provided the injury data from which the three hypotheses were examined.

Survey Outcomes
The primary objective of these analyses was to examine the relationships between the certified playground inspector program and injury rates in California for 2000, 2005, and 2010. The second purpose was to investigate perceptions about how effectively the playground inspection program and certification were working, including:
(a) How much influence does employing a CPSI have on reduction of injury rates?
(b) How much do inspector beliefs in the CPSI system influence injury rates?
(c) How much do supervisors’ value and support of the program affect injury rates?

Additionally, more inductive analyses were conducted to identify whether meaningful profile groups could be distinguished based on;
(a) dimensions of perceived inspector effectiveness
(b) change in injury patterns, with differences between profile groups

Supervisors’ Perceptions Impact Injury Rates
The second hypothesis assessed how supervisors’ perceptions about certification impact injury rates in the state of California. These results support the role of supervisors’ certification perception on reducing injury rates. Survey results generated a four-factor solution accounting for 78% of the total variance among 21 supervisor perception items of the certification program. The high factor loadings throughout each of the four factors demonstrates strong supervisor dimensions which were used to examine the relationship between supervisors’ perceptions on the CPSI program and California’s injury trends across the decade from 2000 to 2010, thus providing support for Hypothesis 2. Less than adequate resources for inspectors’ results in fewer inspections and less frequent repair of equipment, perhaps contributing to increased injuries (Hudson et al., 2004; Kutska, 2009). Support of the CPSI program by the supervisor would then seem crucial to program success. Additionally, supervisor support for the CPSI would also seem to play a critical role in advocating for resources from the local government lawmakers (Iverson & Payne, 2008-2009; Kustka, 2008; Kutska, 2008-2009). Contributing additional support to Hypothesis 2, results revealed generally positive relationships between supervisors’ perceptions about the CPSI system and injury rates, indicating that supervisors’ subscales (i.e., supervisor experience, resources, CPSI value, and employee benefits) are positively related to the reported steady decline in playground injuries in the three assessment years of 2000, 2005, and 2010.

Influence of Inspectors’ Certification Perceptions on Injury Rates
Playground safety inspectors’ perceptions generated a five-factor solution accounting for 75% of the total variance among 20 inspector effectiveness items. The high factor loadings for each of the five factors indicate strong inspector perception dimensions thought to mediate injury rates, and thus provides support for Hypothesis 3.

The combined reduction in playground injury rates and the results on the perceptions of the inspectors were consistent with previous conceptual predictions and research. Peterson (2002) argued that being keenly aware of how to identify the hazards through CPSI training and experience is a priority risk management skill, but only 49% of employees have any interest in the CPSI certification (National Recreation and Parks Association, 2010).

It goes without saying that a significant challenge is to obtain and retain certified inspectors. Miller and Svara’s (2009) and Mulvaney’s (2010) concern with city operating budget shortfalls has the potential to create less than adequate resources that prompt fewer inspections and repair of equipment, increasing the likelihood of more injuries (Hudson, 2004; Kutska, 2009). A strong positive perception of the program by inspectors would then seem crucial. Results revealed a generally positive relationship between inspector beliefs in the CPSI inspection and maintenance program and injury rates. The results indicate that inspector perception dimensions are related to the reported steady decline in playground injuries in the past decade, providing additional support to the Hypothesis 3.

Supervisors’ and Inspectors’ Perceptions.
The analysis results for supervisor and inspector perceptions produced four significant correlations, all of which were significant. When inspector perceptions of resources, experience and the value of certification were low, their supervisors had corresponding low beliefs about these certification perceptions. Similarly, when inspectors perceived employee benefits, experience and supervisor resource beliefs positively, their supervisors demonstrated similar perceptions for these three variables, even though they reported a somewhat negative perception of the value of certification. These results parallel what Hudson et al. (2004), Kutska (2009), and Mulvaney (2010) suggested about playground maintenance, particularly that as maintenance suffers injury rates increase if resources and experience are lacking. In other words, if the resources and experience are limited, the perceptions of both inspectors and supervisors believe injury rates could increase.

Analysis among inspectors and supervisors had similar positive perceptions about the value and benefits of certification, although supervisors also perceived experience as moderately beneficial as well, and inspectors and their supervisors who valued experience highly also believed their resources were low. Kutska (2008/2009) asserted that maintenance staff really do care about the quality of their work, but require the means to do it. With only 49% of playground maintenance employees having any interest in the CPSI certification, it seems logical that there is a need by both inspectors and supervisors to have positive perceptions about the values associated with certification (National Recreation and Parks Association, 2010). The results of the analysis broaden support to this third hypothesis.

Results of this study found that strong positive CPSI’s perceptions of certification benefits promoted reduction of injuries. Additionally, these results suggest that helping prospective CPSIs understand the benefits of certification for both injury reduction and personal advancement needs to be made a more important part of the certification process.

Correlational analyses about the relationship between injuries and inspector perceptions and between inspector and supervisor perceptions, provided some support for Hypothesis 3.

Injuries and inspectors’ Perceptions.
The analysis found the relationship between injuries and inspector perceptions to be non-significant. Results produced three correlations but none were significant. This finding did not lend support to Hypothesis 3, but the lack of significant effects doesn’t necessarily indicate that certification has no impact (Jepsen, 2004).

Surprisingly, the relationship between injury and inspector perceptions demonstrating minimal relationships with injury rates. Because injury rates generally declined across the decade, it begs the question why 2005 correlation results were particularly low. This finding could be a reflection of the new CPSI requirements the state of California instituted in 1999 needed time for cities to adjust and demonstrate injury reductions from the implementation of the new program. Despite Kutska’s (2008) assertion that CPSI efforts should have a substantial bearing on decreasing injury rates, realistically it would take time to implement a Playground Safety and Inspection program and results would lag several years behind implementation, thus explaining this unexpected finding. Though the results for 2005 were low, the modest positive relationship further supports the Hypotheses 2 and 3.

Dwight Curtis’s Research Conclusions:

Curtis goes on to say the implementation of the California Playground Safety Regulations (R-39-97) in 1999 provided an excellent information base to examine the effectiveness of the playground safety inspector certification. While the reported national playground injury rates have been increasing, California’s have decreased over a ten-year period. The NPPS playground safety report card for both 2000 and 2004 gave California higher grades of B- than the nation overall.

Curtis went on to say his study did not include a statistical analysis comparing the downward trend of California’s reported injury rates, the timing of the law requiring certified inspectors for new playground installations, and the NPPSs’ Safety Report Card results. However, the three all point toward a positive relationship (i.e., a downward trend of injury rates from 2000 through 2010), and the enactment of the law in 1999, and California receiving above the mean NPPS playground safety grades (i.e., “B-” in 2000 and 2004 while the national average was a “C-” in 2000 and a “C+” in 2004; NPPS, 2004). Even though the results of this study for inspector perceptions were not as strong as might be desired, they do provide support for Hypothesis 1 that a decrease in injuries is likely if a Certified Playground Safety Inspectors are hired. These findings also provide support to all three critical elements of the Certified Playground Safety Inspector-Certification Effectiveness Working Model (CPSI-CEWM).

The data collected through this exploratory study sought to examine California’s playground safety inspectors’ certification status, its supervisory support, and if and how they have influenced injury rates in that state. The data analyses clearly support this study’s three hypotheses of;
(a) decreasing injuries if certified playground inspectors are on staff,
(b) the value supervisors place on the playground safety inspector program affects injury rates, and
(c) playground safety inspectors’ beliefs about the playground safety inspection program also influences injury rates, and delivers solid support for the Curtis Playground Safety Inspector Certification Effectiveness Working Model (CPSI-CEWM).

Dwight Curtis’s Implications for Future Research and Practice:

Curtis went on to say his study was exploratory and established an information base upon which future research can be built. Results revealed a host of implications for future research and practice. It would be interesting to know the under the demographics of the study;
• number of inspections conducted each year
• number of times inspectors find issues while inspecting
• number and types of issues addressed during a specific period of time
• reasons certain issues are not addressed.

What is the True Value of the California Law requiring CPSI designation by the NRPA.
Curtis went on to suggest that because California has the unusual circumstance of being the only state to require that certified playground inspectors approve the installation of playgrounds before they can be opened for public use (C. Smith, personal communication, May 27, 2012) it would be useful information to know whether this already is an inspirational goal nationwide.

Curtis suggests a national goal generated from the results of this study may enhance the playground certification movement, but other states need to better understand the benefits of California’s law on injury rates.

These questions would require knowing more fully what the costs versus the benefits of certification are. This study also shows that playground injury reduction in California is statistically significant, but is it practically significant? Knowing the costs versus the benefits would also assist in answering this ques