Access to Play for All 101

June 16th, 2015

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

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

PREMISE
EQUATION FOR ACCESS FOR ALL

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

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

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

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

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

Milestones to Access for All – Historical Perspective

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

The Evolution of the Access for All Movement

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

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

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

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

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

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

IPSI, LLC’s EQUATION FOR EQUAL ACCESS

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

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

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

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

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

IPSIs RECIPE FOR EQUAL ACCESS PLAYGROUNDS FOR ALL

START WITH: The Need for Accessible Play Opportunities for All

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

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

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

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

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

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

WHEN COMPLETE, DO NOT IGNOR CONTENTS OR THEY WILL SPOIL AND COULD CAUSE ILLNESS, BODILY HARM, OR DEATH

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

OR CONTENTS WILL GO BAD AND YOU WILL NEED TO START PROCESS ALL OVER.

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

TERMONOLGY RELATED TO THE CONTINUM OF EQUAL ACCESS

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

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

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

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

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

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

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

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

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

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

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

Accessible design and universal or inclusive design terms are NOT interchangeable. Here is a link that explains the difference between these two terms on the (NCA) National Center for Accessibility Web site. http://www.ncaonline.org/education/index.shtml

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

RESOURCES

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

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

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

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

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

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

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

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

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

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

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

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

Eight Principles for Inclusive Design by Boundless Playgrounds

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

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

3. Diversity of movement sensations and experiences

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

5. Opportunities to play autonomously, alongside and with peers

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

7. Addition of semi-enclosed spots

8. Rigorous and challenging places to play

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

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CPSI Certification and Recertification Issues: Why do CPSIs have to retest every 3 years?

February 28th, 2015

CPSI Certification and Recertification Issues: Why do CPSIs have to retest every 3 years?
By Kenneth S. Kutska, CPSI, Executive Director, International Playground Safety Institute, LLC
April 1, 2015

Over the past few weeks a series of comments and questions related to the CPSI examination process have surfaced on one of the National Recreation and Park Association’s (NRPA) social/professional networks appropriately named, NRPA Connect. The group network or community is named, “CPSI & Playground Safety Community.” This online community is open to any CPSI Course participant regardless if they pass the CPSI examination. For more information on how to join contact Karen Snyder, NRPA Playground Safety Coordinator at ksnyder@nrpa.org. As I reviewed the questions and comments the primary concern or issue is the requirement to re-certify by taking the examination every three years. The second issue was the CPSI Candidate’s desire to know what questions they got wrong and have the opportunity to discuss the correct answer with NRPA or their course instructor. Here are some excerpts from the comments made on the NRPA Connect: CPSI & Playground Safety Community.

Why do I need to keep re-certifying to maintain my CPSI?

“I, too, agree that taking the test to recertify is a waste. My pesticide recertification only requires a one day class. I am all for the class for updates.”

“I agree with you, did the online exam three years ago and plan the same for my recertification in March. This will be for the 5th time I have taken the test. All my other certifications require educational and work experiences but not testing.”

“I liked the in-class course. I learned a lot however, to have to recertify every three years by passing the basic exam is a money grab plain and simple. It’s like in school, we all cram for the test and when the test is over, that’s it. Nobody can possibly remember all these requirements. That’s what they have reference materials for. It is my opinion that recertification should be performance based similar to the Certified Safety Profession (CSP) or the Certified Hazardous Materials Manager (CHMM). We are required to show proof of continued education, proof that you are actually working in the field, etc. The application for recertification has a cost to it, but not an exam! Why doesn’t a lawyer have to retake the BAR exam every three years? By-the-way, the online refresher is Xcellent!”

“I did my last recertification using the online prep and it work great for me. It helped me pass my re-cert exam locally. My only issue is having to re-cert every three years. I have numerous professional certifications in the professional safety and environmental engineering field and they do not require taking a recertification test. You do have to show proof of continued education and be working in the field but no testing.”

“I would not consider the online tutorial and exam for the 1st or 2nd time. I have taken it 6 times. Regardless of who pays for it (and I hope it’s your employer) it is worth it to network with others about all the other things. I knew one guy that was unemployed at the time and got a job from one of the other attendees. He still complains about the 3 day interview.”

“I took the online course last year and was able to pass the test with a good margin. If I had to do it over again, I would take the class in person as I did quite a bit of outside studying of the ASTM and CPSC standards. It seems very beneficial to have the interaction with others to talk through situations. The pros and cons of the online program are as follows;
Pros:
4 modules with questions peppered throughout and a practice exam.
Can work at your own pace at your workstation.
Great for folks who are good at taking standardized tests.

Cons:
No collaborative feedback.
Still need to study outside of the materials presented in the modules.”

Here is my initial response to the group.

“Any national certification program worth its salt requires a consistent approach to maintain the integrity of the exam. These requirements are not just established by NRPA. They are created and maintained by organizations whose responsibility and livelihood are based on the integrity and reliability of the examination results. It assures ongoing credibility based on the body of knowledge and exam questions which have passed the test of time. Over time each exam and question is analyzed for its validity from year to year. National certification exams have a specified number of repeat questions used in each exam from one year to the next. These questions are known as “equators”. Without these equator questions the exam company cannot effectively evaluate and compare the year to year results of each and every exam and establish a passing rate that reflects consistency in the passing rate from one year to the next. NRPA could stop the current practice any time they choose but they could no longer defend the CPSI as a national or international certification program. Knowing what questions one gets incorrect on the exam would rapidly negate any exam security and the credibility of the CPSI Certification designation. Many of these questions have been asked time and time again. Nobody is requiring anyone to attain this CPSI designation. Having the CPSI designation does not make one an expert or a good inspector. Hopefully it makes one a better inspector. I am currently writing my column for Professional Playground’s electronic newsletter. It will be a bit of a historic account of how the CPSI Certification came about and some of the options for attaining and maintaining this certification if one chooses or is required to do so. A CPSI is just one of approximately 6 to 7 thousand certified individuals whose primary responsibility is to identify safety concerns which could severely injure a child. Take pride in your achievement and do not rest on your past exam results. Until you get 100% on an exam there is always room for improvement and the opportunity to learn new things. Only with continuing education can you attain this goal. And, only by passing a rigorous examination can one prove they have gained the knowledge necessary to use the CPSI designation”.

In order to better understand how the CPSI Certification program and examination got to where it is today we need to understand from where it evolved.

A bit of history on the CPSI Certification designation and CPSI examination.

A Certified Playground Safety Inspector (CPSI) designation is something that is earned. It is something to be proud of attaining. It does not come easy and not everyone is capable of passing the rigorous requirements of the CPSI Certification Examination. Why doesn’t everyone pass the CPSI exam the first time, if ever? We are talking about information and requirements that can make the difference between life and death of a child. Playground safety requirements may not be rocket science but there is a lot of important information that needs to be processed and understood so the CPSI can apply this knowledge to their day to day job responsibilities. Today a CPSI is one of approximately 6,000 to 7,000 individuals internationally who have passed this examination and become part of this very important group. The reason I cannot give an exact number of CPSIs is because the number fluctuates daily. Every three years the CPSI is required to re-certify. The certification exam dates fluctuate from month to month and year to year. Now with the availability of online testing the CPSI Candidate can go almost anywhere in the USA to a local NRPA approved testing lab and take the examination without ever attending one of the over 50 CPSI Courses offered annually throughout the USA. In any week during March or April it is not unusual to have more than 8 to 10 courses. This amounts to approximately 300 to 600 CPSI Candidates. While CPSI designation does not make anyone an expert it is proof of some level of understanding of the information necessary for the care and feeding of a public play area. Only by practicing their trade through the thoughtful and appropriate application of this knowledge will a CPSI gain the necessary experience to someday be considered an expert in public playground inspections, operations and management.

It is true that lawyers and doctors get certified by their respective professional organizations and once they pass their bar exam or boards they begin their practice as lawyers and physicians. I cannot speak to these programs as I am not well versed in the inner workings of their type of certification. They can do what they need to do to maintain the integrity of their profession and NRPA will continue to do what they think is best to maintain the integrity of their four different national certification programs; Aquatic Facility Operators, Certified Park and Recreation Professional, Certified Park and Recreation Executive, and Certified Playground Safety Inspector.

How did the CPSI Certification designation come about?

The NRPA has been offering the Certified Playground Safety Inspector Course and Exam since 1994. The first National Playground Safety Institute (NPSI) was held in Baltimore, Maryland as a NRPA pre-conference education program in 1991. The NPSI fast became the premier source for comprehensive playground and playground safety education. The playground industry market sought some form of acknowledgement for attaining some level of proficiency in public playground management due to the many issues that began to surface just prior to the release of the revised 1991 US Consumer Product Safety Commission’s (CPSC) Handbook for Public Playground Safety. It was not until after the 1992 NPSI Program the NPSI Executive Committee decided to apply for national certification recognition by the National Certification Board (NCB) of the NRPA. It took almost three years of work and resubmittal to get all the necessary documentation to the NCB to authorize a conditional certification designation with the agreement that there would be an examination created based on a multi-disciplined written justification of need for such a training program and acceptance of nationally recognized body of knowledge. The course curriculum outline and course content outline for the national certification examination would be based on this body of knowledge. Fran Wallach was instrumental in developing the first course content outline with a course outline of competencies to be learned by each and every participant.

Body of Knowledge Exam selected in lieu of Job Performance or Description form of Certification.
I think we can all acknowledge the fact that the national audience for public playground management is very diverse. If we were to attempt to create CPSI certification based solely on one’s job description a one-size-fits-all approach would be difficult to create and defend for each discipline involved in the planning, design, manufacture, installation, inspection, and maintenance of a play area. The care and feeding of a public play area is like a team sport. If one or more of its starting players does not fulfill their job responsibility the team’s chances of winning the game are greatly diminished. It was during my discussions with Fran Wallach, Monty Christiansen and others that I realized the path to national certification would be best served through a “Body of Knowledge” based certification exam versus “Job Description” type of certification. Another major factor behind our decision to move forward with certification was that the scope of our audience who would benefit from this basic body of knowledge which crosses over into the many disciplines involved in the playground industry. This broad based body of knowledge would be of great value to all involved. I think those of us who have participated in one or more of the CPSI courses would agree not everyone may utilize each and every part of the course curriculum. The overall goal was to make sure each person better understood their role in the big picture of playground management and design while striving to do their part to assure the safety of the users and the proper function of the equipment even though each CPSI Candidate may not use all the information in their current job.

As Chair of the NPSI during its formative years it became my role to shepherd the CPSI Program through the national certification application process. It took us a few attempts to get all the required documentation in place. The CPSI designation was finally recognized and approved by the independent National Certification Board of the NRPA after administering the first CPSI certification examination and presenting those examination results including the required process of examination analysis and validation.

Soon after the CPSI Course achieved national certification status the NRPA hired an independent contractor to oversee and manage the certification exam process, including its ongoing development, implementation, exam scoring, and test administrations. This removed all potential conflicts of interest when it comes to the integrity of the exam and the certification process. The independent contractor works with NRPA staff to secure exam content experts and also works closely with the NRPA CPSI Certification Committee who is responsible for the ongoing review and management of the CPSI course content outline. This course content outline represents the formula for the national CPSI Certification Exam.

Once a year the CPSI Exam Committee meets to write new questions, review proposed test questions, and approve the final testing instruments for the coming year. During this process the course content experts take the exam numerous times and establish a degree of difficulty for each and every one of the three styles of questions found in any exam. These three types of questions are; recall, application and analysis. Recall questions are the easiest type of question and analysis the most difficult. The ongoing maintenance of the complete pool of questions are continually reviewed for their relevance to the body of knowledge and new questions are added to the pool while some are removed.

Over the past twenty years there have been many formal requests made by both CPSI candidates and CPSIs challenging the need re-certify and take the CPSI Exam every three years. Some people make the case that other national certifications only require proof of continuing education to maintain their certification. Some claim their test is an open book exam. Some state that once they pass the exam the first time their certifications are good for life. While some, if not all of these suggestions, seem reasonable the CPSI Program has adhered to the standards established by international organizations responsible for accrediting national certification programs. This is the only way independent testing companies who oversee and administer national certification programs and the NRPA are able to defend their certification program and the integrity of the examination against challenges from the outside.

What are the Body of Knowledge components used in the CPSI Course?

The Body of Knowledge used to establish the CPSI Certification is identified in the CPSI Candidate Handbook which is available free online at www.nrpa.org. It includes all the pertinent information on the CPSI Certification program including the CPSI Course Content Outline for the 100 question exam. A major component of the course is hazard identification and impact attenuating surfacing requirements based on industry accepted standards and recommendations. This is approximately 60% of the exam content. The ASTM standards are a major component of the program and they must be reviewed, modified or reaffirmed at least every five years by the standards writing organization. Since the ASTM F1487 Standard was first published in 1993 it has been revised and re-published in 1995, 98, 01, 05, 07, 11 and will again be revised by early 2016 so shall the course content need to change. Each year, some years more than others, the exam questions change to reflect the current standards and best practices while still following the course exam content outline. This course content outline is modified from time to time when standards change. NRPA has conducted surveys with the assistance of qualified independent contractors to gain input from the playground related industry partners and CPSIs. The objective of these surveys is to affirm what is necessary for a CPSI to complete their duties as a playground safety inspector. Currently the 100 question CPSI exam is based on these most current documents; ASTM F1487 Standard, ASTM F2223 Standard, US CPSC Handbook for Public Playground Safety, and the book, Playground Safety Is No Accident, 5th Edition.

Re-certify without attending a CPSI Course and Exam in person.

Participation in the CPSI Course is a major commitment from the candidate and their place of employment. The cost to attend, in person, the CPSI course and examination can be anywhere from $450 to $650 for the two day training. Costs do vary as local hosts establish their program cost based on the host organization’s continuing education policy. Some hosts have increased registration costs to cover extra training room rental fees, audio visual equipment rental, and associated food costs, especially when conducted in hotels. In addition to the CPSI candidate’s registration fee the candidate must be gone from their job for at least four days.
NRPA continues to look for new ways to increase the passing rate of the examination and soften the financial impact to the individual and agency who pays to attend the program. Over the past few years the NRPA has offered several new items to assist a CPSI Candidate in prepare to sit for their first certification exam or prepare to recertify. A CPSI can even take the exam online at approved local testing laboratories. All these options can be found on the www.nrpa.org Website. The CPSI Candidate Handbook is covers all requirements of the program and how to go about preparing for the course and exam. The CPSI Course Tutorial is available online in four course modules that can all be acquired as a package or purchased individually. The materials come right from the current CPSI course PowerPoint presentation. Each module asks questions that must be answered to continue through the module. There is also a practice exam that will help prepare the candidate for the types of questions to be expected on the examination whether it is the online version or the paper exam as offered when a candidate attends the course in person. A candidate can retake the examination as many times as they chose until they successfully attain a passing score. Sometime exam anxiety can effect one’s performance even when they believe they are knowledgeable and well prepared for the exam. The CPSI Certification Committee allows retesting once a month which is about as quick as one can reapply and get approval to take and exam at some preapproved location and time.

Why do CPSIs have to re-certify by taking the exam?

To answer the question I would respond by asking another question. Do you think it reasonable to expect a CPSI who barely passes the exam with a 70+ out of 100 score to get re-tested at some time in the future?

Or

Ask yourself, when you are selecting a doctor to perform a very serious surgical procedure on yourself do you shop price or select one who barely finished medical school? I look for a doctor who finished first in their class and has successfully performed the procedure thousands of times with living references to attest to the doctor’s knowledge and surgical skill?

Since the CPSI is responsible for the safety and well-being of children, how better to assure those responsible for this important task are kept current with the requirements necessary to operate their public play spaces? Should they be able to demonstrate improvement in their knowledge and skill to apply that knowledge? Is three years a reasonable period of time before re-testing is required? How else can a CPSI demonstrate their improved knowledge of the standards and the application of these standards in the field? There is no continuing education program that can measure one’s grasp of this body of knowledge therefore the only reasonable and manageable way to accomplish this end is by demonstrating a marked improvement in their passing exam score? NRPA could not substantiate these outcomes without an exam score based on a test instrument that has been created and maintained with strict adherence to policies and procedures established by international certification exam requirements. National certification programs are best created and managed by organizations whose reputation and very existence is based on the integrity of each and every certification program they manage.

Having a CPSI to implement an agency’s playground safety inspection and maintenance program can be a very important defense tool for the playground owner when it comes to protecting our children at play from unreasonable and preventable injuries. A CPSI can be the first line of defense in protecting the playground owner from costly claims of negligence. In addition, the CPSI has the responsibility to preserve and protect the function and capital investment made by the owners, usually local taxpayers. A CPSI has a big responsibility therefore I suggest that until a CPSI Candidate scores 100 on their next CPSI exam they need to keep working towards that goal. There is always room for improvement. If and when you do attain that 100% mark please give us a call. We could use your talents!

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

The Latest Challenge to Free Play – Today’s Headlines

February 28th, 2015

The Latest Challenge to Free Play – Today’s Headlines
By Kenneth S Kutska, Executive Director
International Playground Safety Institute, LLC
November 22, 2014

I signed up for Google Alerts on various topics of interest to me such as; Playground Safety, Playground Injuries and Playground Legislation It is amazing how many email notices I receive on just these three topics. It is a great way to stay in touch with what is going on around the country and within the media when it comes to playground issues. Just a view weeks ago I received an email alert about a 7 year old girl’s death on a playground in the State of Washington. This recent death of a young girl has once again placed our public playgrounds under the microscope of media scrutiny. I have a concern with how the media and public playground owners are reacting to this story. Some public agency governing boards and administrators have already taken action even though the facts of the case are still under investigation. Here is what we know based on the media stories to date.

Recent Newspaper Headlines
The KOIN 6 News Staff of Seattle Washington published the following story October 3, 2014 at 4:03 pm and it was updated October 3, 2014 at 11:19 pm.

October 1st a Seven Year old girl dies from traumatic brain injury from a fall of a swing at a Vancouver Washington Elementary School.

A student at Fisher’s Landing Elementary School died Friday morning at an area hospital, following an incident on the playground that may have precipitated the child’s brain injury.

According to Evergreen Public Schools, the student, who was later identified only as a 7-year-old girl, was taken to a hospital Wednesday evening after telling her family about an incident on the playground earlier in the day. However, the district said no one at the school witnessed the incident nor did the student report it to anyone at the school.

Jennifer Allen, a parent of another student who attends the elementary school, said she was devastated when her daughter told her the news.

“My daughter told me that her friend came to her upset that one of her friends was swinging on the swing set and that she swung back a little bit too hard and fell of the swing set and hit her head,” explained Allen.
Evergreen Public Schools released a statement on the matter, saying they immediately began an investigation that included calling in a third party investigator. The investigation will include a review of the weekly playground inspection reports and interviews with staff.

A letter informing school families of the student’s death was sent home Friday.

“It’s just something you don’t really expect, but how do you take a precaution? I mean, at some point, kids playing at any manner, you know, somebody is going to get hurt at some point,” said parent Rolf Vellek.
The district said they continue to support the family, students and staff at Fisher’s Landing. The district’s grief counselors are on site and will be in place for as long as needed.

A teddy bear sits outside the chained-link fence at Fisher’s Landing Elementary School in Vancouver, Oct. 3, 2014. (KOIN 6)

The story was updated 5:32 AM – Girl, 7, who died following Fisher’s Landing playground accident identified and the following story was reported by Emily Gillespie, Columbian breaking news reporter and published October 6, 2014 at 7:49 AM

The 7-year-old girl who died Friday, two days after she reportedly sustained a head injury on the Fisher’s Landing Elementary School playground, has been identified.

Stormy Solis died of a closed head injury, according to the Multnomah County Medical Examiner’s Office.
A family member of Solis told KATU-TV that the girl walked home from school Wednesday and told them there had been an accident on a swing set and that she felt dizzy.

When her brother went to check on her later, the TV station reported, he found her sick in her bedroom. The family called an ambulance, and the girl was transported to a PeaceHealth Southwest Medical Center, where she was diagnosed with a traumatic brain injury, according to KATU. She was eventually transported to Doernbecher Children’s Hospital in Portland, and doctors took her off life support Friday morning.
Grief counselors were at the school on Friday and Monday and will return again as needed, Evergreen Public Schools spokeswoman Gail Spolar said.

The school district said Friday that no one at the east Vancouver school saw the incident and that the student didn’t tell anyone about it. It said the district and a third-party investigator are in the process of an investigation that includes interviews with staff and a review of the weekly playground inspection reports
So what went wrong? Who was watching the children on the playground? Was the playground in good condition? Was the playground surface compliant with the current safety recommendations?

The authorities are going through the investigative process answering these questions and many more. It may take months to gather and analyze all the information. In the meantime, stories continue to come out in the media. There is enough finger pointing going on with each of the involved parties that will make this investigative process take even longer. This incident is truly a tragedy for all concerned however maybe, just maybe, this tragedy was just an unfortunate tragic accident which cannot be easily put aside.

What is next?
Only time will tell but the process is well underway. One thing is certain. Children’s play and free play opportunities are once again under attack. Once this incident became public the press was all over this story. Obviously this was how I heard about it through my Google Alert notifications. The first press release I read that was not about the details of the incident was;

School District Phasing Out Swings On Playgrounds Due To Liability Issue October 7, 2014 9:07 AM

“RICHLAND, Wash. –Many playgrounds have replaced cement with cedar or rubber surfacing. The cement was just too dangerous. Now, swings are in the line of fire.”

Swings are being phased out of Richland schools. The district says pressure from insurance companies over the liability is part of the issue. Swings are blamed for the most injuries of any play equipment. Richland School District already removed them from some campuses and will phase them out of the rest.

“As schools get modernized or renovated or as we’re doing work on the playground equipment, we’ll take out the swings, it’s just really a safety issue, swings have been determined to be the most unsafe of all the playground equipment on a playground,” said Richland School District’s Steve Aagard.

Each year, about 200,000 children go to the emergency room for injuries that happened on a playground.

Muge Kaineoz’s daughter will be starting school next year. She’s in favor of the decision to remove swings.

“When she starts elementary school, those swings can get crazy!”

While there are many ways that children can get hurt on a swing set, sitting on the actual swing isn’t the most dangerous thing. More injuries come from walking in front of or behind a swing.

“I actually witnessed an accident with my own eyes one time,” said Muge.

Muge saw a toddler walk right in front of a swing.

“By the time you could do something about it she was knocked out,” said Muge.

Other parents see swings as a regular part of being a kid, danger or not.

“They were our great joy and we all played on them, I truly can’t remember anyone being hurt,” said Richland resident Gail Thorricellas.

Richland doesn’t plan to take that risk as the swing sets are removed from elementary schools. We tried to check with the city of Richland to see if this is a citywide decision that could result in swings being removed from city parks and we never heard back.”

This is not what the statistics show in the 2003 School Playground Safety Guidelines for Vancouver Washington Educational Service District 112 when it comes to playground injuries.

The National Injury Foundation statistics show playgrounds as the most injury-intensive activity in primary schools. Up to 80% of all primary school injuries occurred on the playground.

Accidents on and around the playground account for a statistically significant percentage (around 15% in many districts in Washington State) of injuries to all children in school. Six years of school injury data (from a northwest Washington State school cooperative) show that the top five causes of injury on the playgrounds are as follows:
• Falls from equipment 25%
• Athletic participation (in a game) 17%
• Slip, trip, or fall 16%
• Struck against object 13%
• Struck by object 11%
• All others 18%

In almost half of the playground injuries, equipment was involved. The types of equipment most frequently involved in school playground injuries are as follows:
• Bars 29%
• Balls, bats, racquets 23%
• (tetherballs, baseball bats)
• Composite structures 14%
• Climbing apparatus 10%
• Non-play equipment 8%
• (such as poles & posts)
• Swings (including tire swings) 7%
• Slides 5%
• Other play equipment 3%
• Tires & tire climbers 1%

The most severe school playground claims involve falls from equipment and being hit with balls.

The fact that 25% of all school injuries involve falls from equipment and almost half of those injuries sustained on the playground involve equipment with swing related injuries, including tire swings, accounting for 7% of those playground injuries; one would wonder why bars at 29%, composite structures at 14%, climbers at 10% and even slides at 5% should also be removed from the school playground.

Have we forgot what it was like to be a child? I fear we are going too far in the direction of injury avoidance when we look at public policy related to free play related injury prevention.

What can we do to curtail or fend off this knee jerk reaction and public relations nightmare?
There is a need for a comprehensive public awareness and education campaign on the benefits of play on a child’s development versus the risk of harm to that very same child. This type of media campaign and ensuing public discussion is the missing link to educating and training both the general public, policy makers, and public play area managers.

We need an open discussion with legislators and policy makers on the harm of over-reacting to injuries that create sensational headlines to these tragic events. Accidents do happen regardless of how compliant a play area is to current public playground equipment and protective surfacing safety recommendations. We all know a child can suffer a very serious permanent debilitating injury or even die anywhere and anytime during the course of their day. Yes, these tragedies do occur in the most secure safety compliant environment. Why does the injured party and their family feel victimized? Why do we always have to find someone responsible for the incident? Fortunately very few children die while playing in their neighborhood school or park playground. Nobody wants to see a child seriously injured or die. That being said Society cannot protect each and every person from their own actions. Everyone agrees these types of injuries are shocking. They each have profound impacts to the injured party and their family. Thousands of people die needlessly from common every day occurrences. While nobody wants to see a child seriously injured we all cannot lose sight of the function and purpose of the play area. Playgrounds provide a child critical developmental benefits derived from these free play experiences. The intended playground users learn and experience very important life lessons within these challenging fun environments. The goal of the owner/operator and designer of these play environments is to provide new stimulating and challenging experiences and learning opportunities for every user based on their developmental needs. Such a play environment will provide opportunities for the user to conduct their own personal risk assessment and learn from this experience. This assessment process requires the user to consider their perceived readiness to take the risk of their own actions based upon their physical abilities, current life experiences and cognitive readiness. Someone once told me a child cannot learn to walk without falling down. Likewise a child cannot learn and grow without trying many different thing and experiencing failure in the process. By trying new and different things we begin to solve our own problems from different approaches. Do kids always slide down a slide sitting face forward? Do kids ever run up the slide? To we ever swing the seat standing up? We are all different? We all develop at our own pace. We learn to walk and talk at different times. There is no set date when we utter our first word however there are several developmental milestone or points of reference that child development experts consider within the normal range. It for this reason we must embrace our differences and understand there is no right or wrong answer here but there remains the need to allow for this individuality and understand that children will make mistakes in judgment. Even though children need to fall to learn to walk do we always hold their hand? We realize sometimes the consequences of a fall may be severe. What we cannot do is protect a child from all the consequences of falling. My son did not learn that the stove was hot because I said so. He first needed to understand what the word “hot” meant. Once he experienced what hot was he had a frame of reference which allowed him to move on and learn why he should have listened to me and not placed his hand on the frying pan. This learning experience was carried through into other circumstances he encountered in other indoor and outdoor environments.

What role does the media have in this public debate?

We struggle to make the kinds of significant improvements in both quality and quantity of our public playspaces when it comes to giving children the kinds of environments they desire and need. Funding Issues have always been a major issue however we continue to fight the windmills of public opinion making play some kind of four letter word. Beyond the issue of funding there is the Liability Issue or the perceived fear of liability. We have to stop making settlement payments for every child that breaks an arm or leg while doing what children do at play. More of these types of tragic injuries occur in and around the home than in public school grounds and public parks. For every headline about some tragic incident on the playground I wish the press would give equal time to stories about the lack of play opportunities. What about the resulting negative outcomes on our children because of fewer play opportunities and the looming cost to society from generations of play deficient childhoods? What if our children never get a chance to swing? What if they never experienced that inner ear vestibular stimulation? Do these experiences help develop and even improve one’s balance? Would this limit their future growth in some way which in turn could limit their ultimate potential to succeed? There are too many questions which I cannot answer but from the things I have heard and read from people far smarter than I, it certainly appears the lack of play has had some very negative impacts on human development. So in conclusion the resulting Lack of Equitable Play Opportunity Issue poses a largest threat to our children’s development. What is really holding us back is the lack of the general public’s understanding of the whole of the Importance of Play Issue and how all the parts fit together.

The Lack of Funding Issue

Many Foundations and organizations who are promoting the benefits of free play and nature play continue to find money to fund these projects. Most of these projects impact public agencies that lack equal quality play opportunities in many of our major urban centers. I agree these facilities are much needed but as history has shown; they too will soon become underused because of improper or lack of maintenance. Facilities no longer functioning as intended pose conditions likely to cause serious injury. The current focus is to build more new facilities. While this is an easier sell when it comes to the Funding Issue and fundraising I would argue the focus should be towards maintaining what we already have. If we can learn to maintain these facilities as intended, throughout their intended life, we would make the best use of our limited financial resources. While well intended, this process of funding worthy causes ends up a bit short of its goal. Shortly after the initial positive community spirit and excitement generated during the construction of the new project the public support begins to wane. Without public support and enthusiasm for the playspace the general public’s enthusiasm will quickly wane. They will become apathetic about the place they created and the need to maintain a safe place for our children. Once the community becomes apathetic toward the playspce the condition of the play environment can quickly become less than desirable making the area unsafe for our children and a liability for the community and the people who are charged with its upkeep.

Do these words sound harsh? Yes they are. If the grantors and grantees of these much needed playspaces cannot commit the funds and manpower required to maintain and repair the playspace throughout their intended lifecycle we should stop funding and building the playspace until we can commit to the need for training those responsible for inspection, maintenance and repair of these very important playspaces. Failure to maintain our playspaces with trained professional staff can result in serious liability to the playground owner and worse yet result in a severe injury or even death.

Possible Solution

The well-intended grantors should build into the grant guidelines the requirement every grant recipient must demonstrate they already have or will secure the necessary knowledge and tools required to manage, inspect, maintain and repair their existing public playspaces and the proposed new playground as best practices for operating playground spaces already suggests.

What has the playground Industry done on behalf of minimizing potentially hazardous conditions – the Liability Issue?

The ASTM Standards for public playground equipment has created performance requirements for designers and manufacturers which have eliminated many of the causes of severe injuries and death on the public playground. Head entrapments, protrusions, crush/shear, and entanglement strangulation hazards have been effectively been addressed. Safety concerns related to impact of the playground user with various surfaces within the playground equipment use and clearance zones has been the leading cause of serious to severe playground injuries and a leading cause of death on the playground.

Just last week the F8.63 Subcommittee on playground surfacing systems upheld a vote to reduce the impact attenuation performance requirements from 1000 to 700 HIC however there is a challenge to this item being brought forward to the ASTM Committee on Standards. The hearing and results of this challenge should be known before the first of the year.

This is a big step towards reducing both Traumatic Brain Injury (TBI or concussion). It also has the potential for a lower incidence of long bone fractures. A reduction of the impact threshold to 700 HIC is likely to reduce the Gmax relationship from 200 to approximately 125g. Only over time and with good timely injury investigation and reporting system will we have the facts to support my assumptions. Who will step to the plate to assure these things are done?

This is where the media has the opportunity and responsibility do something positive on behalf of the benefits of play and child development even in the face of the loss of a child’s life.

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

Hazard Based Approach to Equipment Performance vs Defining Specific Equipment Requirements

October 26th, 2014

Hazard Based Approach to Equipment Performance vs Defining Specific Equipment Requirements
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute, LLC
September 28, 2014

This month I will discuss an emerging trend in playground equipment standards development. The focus of the hazard based approach is to embrace reasonable foreseeable playground related injuries regardless of what the equipment might be called, what specific category it appears to fit into, or what the equipment looks like. The United Kingdom’s approach to this risk assessment and hazard based approach may sound quite familiar but one country’s interpretation of what constitutes a hazard or what is an unacceptable injury rests within the societal differences of each after all who is right hinges on who is in charge.

Background
The American public playground equipment injury prevention movement was born more than 40 years ago as a result of many research projects of the United States Consumer Product Safety Commission (CPSC). The CPSC injury prevention and safety staff along with other child development and play advocates have been reacting to injury reports and statistics. Initially this approach to injury prevention has been very effective in many areas. Today we can no longer meet the change of pace in product development throughout the playground equipment industry. We continue to chase our tails expending a lot of human and financial resources only to find ourselves back in the same place we started or we are expending too much time changing what we already have done. We seem to be considering more exceptions to the rule than to modify the rule in the first place. Either way our actions seem focused on allowing for some new piece of equipment rather than requiring the new equipment meet the basic requirements for hazard mitigation. In essence, our current approach to creating and revising playground safety guidelines and recommendations could be compared to the farmer closing the barn door long after the livestock has left the barn. So how does the hazard based approach differ from the continual need to expand the specific equipment requirements? The answer to the first part of the question is easy. Sections 4, 5, 6 and 7 of ASTM F1487 and primarily Section 6, covers almost every hazard based performance requirement for any piece of play equipment no matter what it is called.

Once we get into Section 8 Equipment, the performance requirements start to become more design restrictive. When injury reports become more widely known by the general public and lawsuits get filed the injury prevention folks start to do their job. Is this necessary or is it a knee jerk over-reaction? Follow up investigation analysis after a serious injury seem to be done as if the injury occurred within a workplace environment. Unfortunately the public playground environment is starting to be compared to a place of employment which it is not. In the workplace, the employer is responsible for their employee’s safety. In the adult world, we are concerned with loss of productivity, lost income and medical and rehabilitation costs. Most workplace environments have very strict State and Federal Occupational Health and Safety Act (OSHA) requirements. Any shortcomings uncovered in OSHA inspections lead to corrective action and often fines to the owner of the workplace. Workplace injuries often lead to new performance requirements. Over time this has proven to be a good thing as improvements within the workplace have eliminated the cause of many future injuries. I am not saying we should take this approach in a hazard based analysis of playspaces. I have stated before that children’s playspaces are not to be treated as a workplace environment. There are obviously the medical and rehabilitation costs like with adults, but provided the injury does not exceed a societally acceptable threshold, the injury becomes an acceptable outcome to a failed learning experience. It is worth repeating, “Children’s playspace injuries should not be treated the same as workplace injuries.” Workplace injuries, for the most part, are not acceptable in today’s society, even when they are unforeseen. This is especially true when an employer could have taken action to eliminate the cause of the injury either by warning signage, employee training, additional safety equipment/tools, or new improved facility and equipment designs.

A public playspace’s purpose is much different than almost all places of employment where the primary purpose is to create a product or service while creating wealth for the company’s shareholders and its workers. A playspace is a place for young rather inexperienced children to explore their abilities, assess play opportunities, and take risks. A place to try things for the first time even when the outcome is unknown. It should be a requirement that each playspace be a place for less rules not more. It should be treated as a place to enjoy free time. It is a place to explore everyone’s individual capacity to grow and learn new things about themselves and the environment around them. Imagine what the adult workplace environment would be like if these ideas and principles were to be applied. Some would argue chaos would prevail. Many successful companies have what could be called an unstructured or chaotic environments, but invariably hazards to people or property are cleverly removed. Workplace rules are designed to protect the employee and to protect the company from the ever increasing onslaught of Worker’s Compensation claims and cover situations where the injured employee do not follow workplace procedures resulting in a preventable injury. Obviously children cannot be held to the same standard of behavior. I would argue the playground owners and equipment and surfacing manufacturers also should not be the scapegoat whenever obvious or blatant inappropriate personal behavior and lack of supervision lead to the unfortunate injury. I want to be clear that I am not looking to absolve anyone from a defective product, improper installation, lack of adult supervision, or a lack of inspections, maintenance, and corrective action. This is a whole different story. Hazard elimination must be unobtrusive and it results from ongoing adult assessment and review of the playspace.

For the hazard based approach to playground standards to move forward the playground equipment design and playspace post injury investigation cannot be measured in the same way as the workplace environment. Society must first set an acceptable threshold for injury. Today we are debating if this will be based solely on prevention of death or life-threatening as it was 40 years ago or be focused more on concussion and long-bone injury or those defined by the CPSC as a societal surrogate in the CPSIA. The goals and objectives are quite different for each environment. Regardless, the manufacturer and designer of the playground equipment and use zone surface system should be conducting their own risk assessment of the prototype piece of equipment or new surfacing system to determine whether or not it is appropriate for the intended user regardless of any reasonable foreseeable misuse by the child/user.

So how does this new hazard based approach get implemented?
A colleague of mine read my response in the “NRPA Connect” Playground Safety Forum on a question related to a stand-up spinner and its attachment to a composite structure. He thought my response was brilliant. How could I disagree? Just kidding. The person was challenging the layout and spacing for a stand up spinner that was attached to the support post of an overhead ladder that was connected to a much larger composite structure. This is maybe too much for one to analyze without a picture but basically it was all one big composite structure. My response went as follows:

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

Brilliant!? Well maybe not so but the point is that we at ASTM F15.29 Subcommittee have been working on a way to change our approach to evaluating playground environments and writing standards and guidelines. We see a desire to change from a prescriptive equipment performance/design approach to a hazard based approach when it comes to specific types of specialized equipment, taking into consideration function and what can go wrong. This approach focuses on the injuries that could occur rather than trying to keep up with ever-changing equipment configurations and reacting to injuries that become obvious years later.

My colleague said he was doing a lot of thinking about this new approach to safety standards development. He loves the potential paradigm shift, however he is concerned it may create a double edged sword. One side provides for the opportunity for more challenge in the playspace but the other side of implementing this hazard based approach could create a trickle down negative impact on the industry by adding a degree of responsibility and risk assessment they are not currently used to. This is of particular concern for the manufacture that copies and implements a design and without understanding all of the hazard mitigation in the original design. He was not concerned about the logistics of what the ASTM would have to go through to change the current standard. His concern was more centered on how it would applied in the field. He was concerned about the final result when the end user and/or their post installation compliance inspector applies these changes. He sent me the following four points.

1] Hazard based approach looks at a finite number of possibilities – We should all know what hazards are present in playground environments. We have injury data and there are a finite number of possibilities therefore there should be no need to try and keep up with manufacturer’s research and development.

2] Current CPSI training and certification – The hazard based approach would render the current CPSI Course training program obsolete. We might be able toss out a lot of the number memorizing but we would need to bring in more information to create a better understanding of child development and how children play. This would create another opportunity to develop a new training program. Maybe we all could agree to get rid of “inappropriate use” as a fall back response to a new rash of injuries. Maybe we could avoid some of the compliant yet potentially hazardous conditions by creating a universal understanding of child development, how they play, and understanding how to deliver an environment and range of activities that meets all children’s developmental needs.

I was reminded of a brainstorming session the old National Playground Safety Institute Executive Committee held during a NRPA Conference We were asked about potential new playground training opportunities as well as tweaking the “current” training. One of the suggestions was to change the current CPSI course outline from following the ASTM table of contents to using the “Dirty Dozen” as the new course outline. He thought this approach was more in line with how children play.

3] Does this hazard based approach open up the opportunity to consider something non-compliant because their thought process crossed over from just eliminating known hazards to eliminating risk and challenge and perceived safety issues? Would this become the easy way out for some who would like to eliminate playgrounds because it is easier to avoid more potential liability than to manage the public playground as it should be maintained in the first place? This brings us back to the need for all involved in public playground management to understand the difference between the terms, hazard and risk. Would an inspector justify removing some piece of equipment by misunderstanding this hazard based approach? The hazard based approach is not a risk avoidance approach? Would a hazard based approach set in motion an exponential increase in “professional judgment”? Would risk and loss control managers and attorneys rule the day (again)????

4] Connecting the Dots – The key to this hazard based approach may rest in our ability to train playground managers, designers and safety inspectors to connect the dots between the perceived potential hazards and how, when, and where to cite the new ASTM standard. Can we accomplish the objective while still allowing for graduated challenge play opportunities for all children? Understand that every challenge presented in a play environment may not be developmentally appropriate for everyone 100% of the time. Connect this reality to the fact that children will be seriously injured on even the most compliant playspace. This hazard based approach is a much needed concept that everyone including the users, policy makers, and legislators and our judicial system must embrace.

In conclusion, Playspaces that comply with this Standard will not prevent all injuries. There exists a shared responsibility among the design consultant, owner/operator, caregiver, equipment manufacturer, surface system provider and installer/assembler of the playspace when it comes to injury prevention. Well-designed and constructed playspaces in compliance with the requirements of this Standard create a foundation for play within the context of injury prevention. Regardless of how well the playspace is designed, adult caregiver supervision of children is still vital to injury prevention especially when an unsupervised child exercises unreasonable misuse or abuse of the playspace. Playspaces complying with this standard provide a formal environment focusing free play activity to a specific locations rather than an inappropriate location or activity of the child’s choosing because of boredom due to the lack of challenge at the local public playground. Although injuries will occur in any play environment, it is better they occur in a well-designed public playspace where appropriate injury response can be delivered in a timely fashion.

Risk versus Hazard or Graduated Challenge versus Equal Access for All
How we approach the implementation of the hazard based approach in a playspace with a good variety of graduated challenges for all users goes beyond the risk assessment of the play component and surface system. The level of challenge required and desired by children varies enormously with their age and physical, emotional, social and intellectual development. Therefore, it is almost impossible to design a piece of playground equipment that meets the needs of the individual child while meeting the needs of all children all the time. Playground equipment areas that children find attractive are generally those that present various levels of difficulty referred to as graduated challenge. Children can explore solutions to these challenges and practice their newly acquired abilities in carefully designed settings, where the hazards have been assessed and are managed by adopting supervisory and design techniques.

What I mean by supervisory and design techniques has to do with each owner/operator’s philosophy on free play. Does the owner/operator have an operational policy for their supervisors to follow? Does the policy and/or standard operational procedures come with a set of playground rules? Maybe there are no rules? I think the fewer rules the better. Another risk management approach by the owner/operator might be to select age appropriate equipment that fits the needs of the intended users and the space allocated to the playspace. Not all compliant or age appropriate piece equipment as determined by the manufacturer and playspace designer may be appropriate for every location. The owner/operators need to take the many things into consideration when approving a playspace plan based on their own operation guidelines and approach to free play and risk management.

Adult caregiver supervision of children is an important aspect of risk assessment management and intervention when a child is demonstrating unreasonable misuse or abuse of the play equipment. The value of supervising a young child’s behavior should not be underestimated. In the context of injury prevention it goes beyond just observation. Supervision includes the review of the playspace for objects and blatant failures through vandalism or severe environment forces such as; flood, ice storm, earthquake, ultraviolet and thermal radiation. Weather plays an uncontrolled factor in the play activity. Discouragement of an activity on the part of the child playing that would clearly expose them to a hazardous situation such as; climbing on a roof or wearing a bicycle helmet when on the playground equipment or playing without proper footwear should be mitigated through the strategic placement of information signs and warnings. Signage and warnings, although directed at everyone, are clear messages to the caregiver with regards to behavior modification aimed at injury prevention.

Beyond adult supervision precautions need to be taken by play owner/operators to reduce the severity of injuries if children make the wrong judgment however the possibility of harm cannot be completely removed. Like other physical activities, the use of public playground facilities involves the residual risk of injury. The manufacturer must take into consideration the behavior of children given reasonably foreseeable misuse and assess their designs and structures from the point of view of exposure to hazard or the intended user’s frequency of failing due to the challenge presented. The elimination of a hazard such as frequency of falling from a piece of manufactured play equipment might fall to another manufacturer’s product within the playspace, such as the surfacing supplier, but it is the responsibility of the equipment manufacturer to point out the risk of the fall. This risk assessment responsibility extends to the consultant, and owner/operator who along with the manufacturer should analyze the entire playspace and determine what residual risk may remain and design for a different outcome. The other possible solution might be to provide user information and warnings. The typical public playground performance specification recommends minimum requirements for playground equipment and the surface adjacent to the play equipment. In the USA these standards have evolved through the ASTM standards development process. This process is an open democratic consensus based process. Often injury prevention is the application of mitigating measures to remove, reduce, or guard against by the use of a protective device certain exposures to risk. For example, the risk of injury from falls may be mitigated thereby reducing a severe or life-threatening injury to a serious injury through better impact attenuation performance. In the risk assessment approach a reduction in the equipment fall height might be one item for consideration. Raising the minimum height for the barriers around the elevated platforms might be another consideration. Further risk analysis and discussion of the option to raise the barrier height from 38 inches to 60 or 72 inches might seem appropriate but in reality it would actually increase the equipment fall height when applying the assumption of reasonable foreseeable misuse. After a more detailed assessment it might be more appropriate to add some additional strategically located handholds at all elevated access egress points along with selecting a better surface system which performs in excess of existing minimum requirements. This could be the best solution for everyone including the children.

Another major mitigating factor to prevention of injuries is the provision of inspections and maintenance by the owner/operator or their representative. Post installation inspection of the structures and surfacing to standards and contractual requirements establishes compliance to the standards from the beginning. Once the first child plays in the playspace it belongs to the owner/operator and other than warranties, the manufacturer, supplier, and installer/assembler have moved on. The owner/operator shall maintain this compliance for the remainder of the playspace’s useful life. The owner/operator shall have established a budget, prior to purchase of the playground, for the ongoing inspection, maintenance, and repair of the play structures and surfaces taking into consideration the information that is provided by the manufacturer on maintenance and functional longevity. Timely inspection and maintenance is the ongoing key to long-term injury prevention. They also preserve the function of the equipment and surfacing while reducing more costly repairs and premature replacement.

Preventing life-threatening, long term debilitating injuries, and death are the current focus of this standard. While prevention of all injuries is not possible, prevention of one type of injury can lead to a reduction in severity of others which gets us all closer to today’s standard injury thresholds. We cannot reduce the frequency of “failure” if we are to provide playspaces and playground equipment that increase graduated challenges, but we can mitigate the severity of the injury when failure does occur.

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

Reasonably Playground Design – Risk and Challenge versus Safety Issues versus Hazard Prevention.

October 26th, 2014

Reasonably Playground Design – Risk and Challenge versus Safety Issues versus Hazard Prevention
By Kenneth S Kutska, CPSI, Executive Director
International Playground Safety Institute
August 24, 2014

Last month I shared my perspective on playground related injuries and how the severity of injuries do not necessary correlate with the notion a currently compliant playground will eliminate or substantially reduce the frequency or severity of injuries. The question which needs to be answered is whether or not our performance requirements for both equipment and impact attenuation surface systems are addressing the level of injury our standards purport to address. The various international playground performance standards (ASTM F1487, ASTM F1292, EN1176, EN1177, CSA Z614) and the CPSC Handbook state in very general terms the types of injuries they are attempting to address. Each standard introduction and scoping statement states the objective of injury reduction. Every standard and guideline I have read acknowledges there will continue to be many injuries sustained by children on even the most complaint play environment. Children’s play environments should not be inspected as if the inspector were an OSHA inspector in a workplace. Children are expected to challenge themselves beyond their current level of proficiency. This is all part of child development process. The challenge for playground designers, owners and manufacturers is to find balance between the safety issues and need for more challenging equipment. Challenging equipment presents a child with the opportunity and need to perform their own risk assessment. It is one thing for a child to take a risk but do they have enough experience to differentiate between challenges that introduce new elements of risk versus a hazardous condition. A young child cannot appreciate the probable consequential outcome when they come in contact with a truly hazardous condition.

Designers, manufacturers, owners and operators should not be in the business of eliminating risk. It can be done through the creating various levels of graduated challenge. We need to focus on assessing and managing risk while eliminating hazards and allow children to be children. Children face some forms of risk and hazards each and every day. Children need the opportunity to learn from these challenges and the personal choices they make and a well-designed somewhat controlled environment. The child’s decision on whether or not to undertake the challenge offered from the various graduated challenge opportunities within the play environment is part of that important personal development process.

I believe today’s playground standards and guidelines have provided much needed guidance to eliminate most of the hazards which existed decades ago. We have eliminated head entrapment, entanglements and protrusion hazards and the deaths associated with these know hazards but we still have children who are seriously hurt or even die as a result of some unfortunate accident. Over the past 25 years the NRPA, and its National Playground Safety Institute, have provided valuable training to better understand and eliminate the root causes of most severe playground injuries. Designers and manufacturers have taken these Federal recommendations and voluntary industry consensus based standards and in good faith have worked to provide more fun and challenge on the playground. The issue of what happens when a child fails to safely execute a skill necessary to complete some challenge on the playground still remains. Who will be held accountable and for what? The child? The parent? The owner of the playground? The manufacturer? The installer?

I ended last month’s column by outlining what I see as our next step. We must address the obstacles to meeting our current Standard’s scoping statements. These obstacles are;
• the need to reconcile the difference between the definitions for a “serious injury” according to the AIS System and the Consumer Product Safety Improvement Act and what our standard’s scope says.
• the playground industry’s agreement on the risk assessment process based on the possibility, probability, and level of injury likely from a fall to a surface just under 1000 HIC, which is a 16% risk of AIS >4.
• the need to accept the residual risk or harm after a risk assessment has been conducted by the designer, manufacturer and owner and reasonable risk reduction or protective measures have been implemented based on the intended use and reasonable foreseeable misuse of the equipment.

I believe we can do more to provide more challenging opportunities within the play environment while minimizing the liability exposure to designers, manufacturers and owners of public play areas if we can address these issues. Frivolous lawsuits need to end. Nobody wants a child to get hurt but we all know from experience we cannot protect each child from themselves when involved in free play. Children will fall and run into things and take risks they may not be developmentally ready to safely execute.

I would suggest a few action items. We need to come up with a better definition or concept of exactly what we are trying to create within a child’s play environment. This needs to be easy to understand by the general public, policy makers, and the entire playground industry. We need to identify and understand the hazards we wish to eliminate from the play environment. Finally, and as difficult as it sounds, we need to identify and agree upon what level of injury we, as a society, can accept. If we ever hope to be successful in accomplishing these items it will take a sustained major public awareness and education campaign directed towards all levels of all stakeholders.

Without some clarification to our playground standards scoping statements and performance objectives, the dark cloud of uncertainty will continue to inhibit our ability and desire to provide the types of age appropriate challenging and risky play opportunities our children need and deserve.

I left you last month with this question. Can you define what tolerable or acceptable risk of some level of injury severity should be generally accepted by society? In order to answer this question we all need to have a broader understanding of injury severity. We have all suffered a scrapped knee or elbow in our lifetime. Some scrapped knees are more severe than others as we can probably all relate to as well. We know when a scrape becomes a laceration requiring a few stitches it is more severe and also requires professional medical attention beyond what mom or dad can do for that skinned knee. When that laceration is so severe that it requires many more sutures at different layers of tissue we know more medical skill and attention is required for this severity of injury. Skin burns are another example of level of severity of injury. Who has not had a burn over the course of their life? Most of us have experienced a good sunburn at some time. It may not be healthy but it is not life-threatening. It could be. The sun is a leading cause of skin cancer and many people have died as a result of skin cancer. What I have just introduced is the concept of probability. Basically, what are the odds that I might end up with skin cancer? Are you or society will to accept those odds because the cost to eliminate any chance of skin cancer are either too great of the odds of getting skin cancer is so small everyone is willing to live with the consequences. So what is tolerable or acceptable when it comes to injury severity?

In my previous column I introduced a means of assessing injury severity through the use of the Abbreviated Injury Scale (AIS). If you look on Wikipedia for AIS you will find the following information. www.trauma.org

About AIS
The Abbreviated Injury Scale (AIS) incorporates current medical terminology providing an internationally accepted tool for ranking injury severity. The AIS© is an anatomically based, consensus derived, global severity scoring system that classifies an individual injury by body region according to its relative severity on a 6 point scale.

What is the Abbreviated Injury Scale (AIS)?
The Abbreviated Injury Scale (AIS©) is an anatomically based, consensus derived, global severity scoring system that classifies each injury by body region according to its relative importance on a 6-point ordinal scale (1=minor and 6=maximal). AIS© is the basis for the Injury Severity Score (ISS) calculation of the multiply injured patient.

Injuries are ranked on a scale of 1 to 6, with 1 being minor, 4 severe and 6 an unsurvivable injury. This represents the ‘threat to life’ associated with an injury and is not meant to represent a comprehensive measure of severity. The AIS is not an injury scale, in that the difference between AIS1 and AIS2 is not the same as that between AIS4 and AIS5. There are many similarities between the AIS scale and the Organ Injury Scales of the American Association for the Surgery of Trauma.

AIS Score Injury
1 Minor
2 Moderate
3 Serious
4 Severe
5 Critical
6 Unsurvivable

There are nine AIS chapters corresponding to nine body regions:
1. Head
2. Face
3. Neck
4. Thorax
5. Abdomen
6. Spine
7. Upper Extremity
8. Lower Extremity
9. External and other.

The AIS provides standardized terminology to describe injuries and ranks injuries by severity. Current AIS users include, health organizations for clinical trauma management, outcome evaluation and for case mix adjustment purposes; motor vehicle crash investigators to identify mechanism of injury and improve vehicle design; and researchers for epidemiological studies and systems development, all of which may influence public policy (laws and regulations).

Some users are interested in its standardized injury descriptor capabilities; some are interested only in its injury severity assessment; and some in both. The AIS Uses and Techniques course allows people to learn how to correctly code injuries according to established rules and guidelines, which increases interpreter reliability worldwide.

Health and research records of all types may be coded in a prospective manner. AIS codes may be assigned using algorithms that map other commonly used disease and injury codes — such as the WHO-originated International Classification of Diseases. Some of these maps have been programmed into trauma registry and medical record software, and may be proprietary tools. Some others have been made available by the original developers.

History of the AIS
In 1973, the Association for the Advancement of Automotive Medicine (AAAM) assumed the lead role for continuing the development of a scale to classify injuries and their severity, originally begun by a joint committee of the American Medical Association (AMA), Society of Automotive Engineers and the AAAM in 1969. The first scale was published in 1971 in the Journal of the AMA, titled: “Rating the Severity of Tissue Damage – The Abbreviated Injury Scale”. Publication of the 1980 revision of the AIS was enthusiastically embraced by the trauma research community as a useful and reliable injury assessment tool. Today, the AIS is the global system of choice for injury data collection and has become the basis for a number of derivative scales in use (e.g., Injury Severity Score, TRISS, ASCOT). Over the years, the AIS has been translated into French, German, Italian, Chinese, Spanish, and Japanese.

Today
The AIS has been continuously improved since its inception. The current edition, AIS© 2005 Update 2008, represents a five-year revision process involving hundreds of contributors in the USA, Canada, Australia, New Zealand and numerous European countries. The AIS© 2005 Update 2008 is significant in its total restructuring of injury classifications for both upper and lower extremities, and the pelvis, body regions that are significant in nonfatal long-term impairment and disability. The new classifications give in-depth researchers and investigators a tool to record injuries in these body regions with greater precision and detail.

Severity
Abbreviated Injury Score-Code is on a scale of one to six, one being a minor injury and six being maximal (currently untreatable). An AIS-Code of 6 is not the arbitrary code for a deceased patient or fatal injury, but the code for injuries specifically assigned an AIS 6 severity. An AIS-Code of 9 is used to describe injuries for which not enough information is available for more detailed coding, e.g. crush injury to the head.

The AIS scale is a measurement tool for single injuries. A universally accepted injury aggregation function has not yet been proposed, though the injury severity score and its derivatives are better aggregators for use in clinical settings.In other settings such as automotive design and occupant protection, MAIS is a useful tool for the comparison of specific injuries and their relative severity and the changes in those frequencies that may result from evolving motor vehicle design.

Abbreviated Injury Score
AIS-Code Injury Example AIS % prob. of death
1 Minor superficial laceration 0
2 Moderate fractured sternum 1 – 2
3 Serious open fracture of humerus 8 – 10
4 Severe perforated trachea 5 – 50
5 Critical ruptured liver & tissue loss 5 – 50
6 Maximum total severance of aorta 100
9 Not further specified (NFS)

What Level of Injury Severity is Acceptable Today?
The following information is summarized from medal.org web site where they combine the Abbreviated Injury Scale (AIS) and the Injury Severity Score (ISS) to assess patients involved in traffic accidents. This assessment process makes use of the Abbreviated Injury Scale (AIS) and its value correlates with the risk of mortality. Another way to look at this based on my early analogy to sun exposure is how much sun are you willing to expose yourself to in order to have a nice year round suntan based upon your own assessment and choice to worship the sun year round versus the probability you will die from skin cancer.

I looked over several types of injuries sustained in car accidents that somewhat related to injuries sustained on a playground. Most of these are direct result of impact from a body in motion to the surface or some other playground equipment surface. Generally the higher the impact the more severe the injury sustained.

Minor Injury (AIS 1)
• Aches all over
• Minor lacerations, contusion and abrasions (simple Closure)
• 1st degree burns
• Small 2nd and 3rd degree burns
• Cerebral injury with headache or dizziness but no loss of consciousness
• Whiplash complaint with no anatomical or radiological evidence
• Abrasions and contusions of ocular apparatus (lids, conjunctivae, cornea, uveal injuries)
• Vitreous or retinal hemorrhages
• Fractures and/or dislocation of teeth
• Chest muscle ache or chest wall stiffness
• Abdomen muscle ache
• Dislocation of digits

Moderate Injury (AIS 2)
• Extensive contusion or abrasion
• Large laceration
• Avulsion less than 3 inches wide
• 2nd or 3rd degree burn involving 10-20% Body Surface Area
• Cerebral injury with/without skull fracture, less than 15 minutes unconsciousness, no post-traumatic amnesia
• Undisplaced skull or facial bone fractures or compound fracture of nose
• Laceration of the eye and appendages
• Retinal detachment
• Disfiguring lacerations
• Whiplash severe complaints with anatomical and radiologic evidence
• Simple rib or sternal fracture
• Major contusion of chest wall without hemothorax or pneumothorax or respiratory embarrassment
• Major contusion of abdominal wall
• Minor sprains and fractures to extremities and pelvic girdle
• Compound fracture of digits
• Undisplaced long bone or pelvic fractures
• Major sprains of major joints

Serious Injury (AIS 3)
• Large lacerations involving more than 2 extremities
• Large avulsions, ≥ 3 inches wide
• 2nd or 3rd degree burn involving 20-30% of Body Surface Area
• Cerebral injury with or without skull fracture, with unconsciousness more than 15 minutes, without severe neurological signs, brief post-traumatic amnesia (less than 3 hours)
• Displaced closed skull fracture without unconsciousness or other signs of intracranial injury
• Loss of eye
• Avulsion of optic nerve
• Displaced facial bone fractures or those with antral or orbital involvement
• Cervical spine fractures without cord damage
• Multiple rib fractures without respiratory embarrassment
• Hemothorax (presence of blood in the pleural cavity (between lungs & inner chest wall)
• Pneumothorax (presence of air or gas in the pleural cavity)
• Rupture of diaphragm (the muscular wall separating the thoracic from the abdominal cavities)
• Lung contusion (bruised lung)
• Contusion of abdominal organs (bruised liver, spleen, pancreas or kidney)
• Extraperitoneal bladder rupture
• Retroperitoneal hemorrhage
• Avulsion of ureter (tearing off or away)
• Laceration of urethra
• Thoracic or lumbar spine fracture without neurological involvement
• Displaced simple long bone fractures
• Multiple hand and foot fractures
• Pelvic fracture with displacement
• Dislocation of major joints
• Multiple amputations of digits
• Laceration of the major nerves or vessels of extremities

Severe Injury (AIS 4)
• Severe lacerations and/or avulsion with dangerous hemorrhage
• 2nd or 3rd degree burns involving 30-50% of Body Surface Area
• Cerebral injury with or without skull fracture with unconsciousness of more than 15 minutes, with definite abnormal neurological signs; post-traumatic amnesia 3-12 hours
• Compound skull fracture
• Flail chest
• Pneumomediastinum
• Myocardial contusion without circulatory embarrassment (bruised heart muscle)
• Pericardial injuries (damage to the heart sac enclosing the heart)
• Minor laceration of intra-abdominal contents (to include ruptured spleen, kidney and injuries to tail of pancreas)
• Intraperitoneal bladder rupture
• Avulsion of genitals (tearing away or torn off)
• Thoracic and/or lumbar spine fracture with paraplegia
• Multiple closed long-bone fractures
• Amputation of limbs
• Multiple open limb fractures

Critical Injury (AIS 5)
• 2nd or 3rd degree burns involving >50% of Body Surface Area
• Cerebral injury with or without skull fracture with unconsciousness of more than 24 hours; post-traumatic amnesia more than 12 hours
• Intracranial hemorrhage
• Signs of increased intra-cranial pressure (decreasing state of consciousness, bradycardia under 60, progressive rise in blood pressure, or progressive pupil inequality)
• Cervical spine injury with quadriplegia
• Aortic laceration
• Rupture, avulsion or severe laceration of intra-abdominal vessels or organs, except kidney, spleen or ureter
• Major airway obstruction

I will make the assumption that injury severity diagnosis beyond an AIS 3 is unreasonable and therefore not acceptable. we are living in the acceptable boundaries of types of injuries that fall within the diagnosis or AIS 2 and 3. Can we accept with the injuries we have identified in the scope of an AIS 3? I think when we look at some of these injuries a bit closer, we might find some to be considered permanently debilitating with survival probable. Are you alright with that? If not, where would you draw the line? What are some of the % probability of death for these AIS 3 injuries? Survival is probable for AIS 3.

When we look at the list of AIS 3 injuries you will see that the ASTM F15.29 Subcommittee responsible for the content of ASTM F1487-11 has actually made many significant contributions towards eliminating hazards and severe injuries through general performance requirements. I stated earlier we have developed requirements to minimize the potential of skull fractures, lacerations, loss of an eye or damaging internal organs with our protrusion gauges and test methods. We have addressed the potential for head and neck entrapments and the potential for death because of anthropometrically designed torso and head probes and a test method. We have a swing impact or suspended component dynamic impact test to minimize impact injuries and recognize new products and materials that do not pose the same safety concerns of similar play events of 30 to 50 years ago. All this being said there will always be new challenges and opportunities when designing new innovative play component concepts and there will always be a number of serious and severe injuries and some deaths that will occur on even the most compliant playground.

We do need to agree on a vision for reasonable play equipment performance standards and then address the known hazards. At the same time, we must also understand children will continue to overestimate their abilities while testing their own limits. They will continue to learn and problem solve as they process the circumstances of a challenging situation. They are doing what each and every one of us did as a child and when these AIS 2 and 3 injuries occur they to will survive. Unfortunately some children will suffer some trauma, discomfort, and probably some temporary mobility challenges and the parents will also have to deal with some inconveniences. There will also be medical bills to pay but we all should have health insurance. We have to get over the notion every injury can be avoided or even should be. We cannot be held expected to protect every child from all injury. That is unreasonable if we are to hope for fun challenging free play opportunities our children all need and deserve.

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

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