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Playground Safety And The New ADA Requirements

Doug Kirkus CPSI(888) 313-0839

dkirkus@safety-benefits.com

Overview• ADA Concerns & Compliance

• Standards & Guidelines

• Surfacing Issues

• “Not All Equipment Is Equal”

Other Countries• A friend of mine sent me some pictures of

playground equipment overseas

• He told me that he was surprised at the dangers that he saw on their playgrounds

• So the obvious question. . .

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AREPLAYGROUND STANDARDS & GUIDELINES NEEDED???

PLAYGROUND EQUIPMENTABROAD

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PLAYGROUND EQUIPMENT

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WE STILL HAVE SOME

WORK TO DO!

New ADA Standards• For Accessible Design

took effect on March 15, 2012

Accessible Playgrounds• Even though a playground may be

“accessible”, everyone uses it

• Playgrounds are not exclusive to any one group

• That’s not true of non-accessible playgrounds

• What we refer to as “accessible” playgrounds most likely won’t carry that label in the not too distant future

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ADA Regulations Published September 14, 2010• DOJ rulemaking in process since 1994

• Title II regulation (public entities) affects all of the 1,900 SD units of local government• Title III regulation affects more than 7,000,000

nonprofits and businesses nationwide

• 2010 Standards for new construction and application to existing sites, became effective on March 15, 2012

IPEMA Explanation• “IPEMA Takes Proactive Stance on New

ADA Standards” article• Spring 2012 issue of “Playground Magazine”

• Existing play areas are not required to meet the 2010 Standards by March 15, 2012

• March 15, 2012 is the DOJ compliance date for all entities/companies covered by Title II and Title III to begin using the new 2010 Standards

What Does This Mean?• All new construction and alterations to

existing facilities should begin utilizing these standards

• Playgrounds built prior to March 12, 2012 are subject to review if they are undergoing alteration, if physical barriers exist or if communication barriers exist to the program, good service or activity offered at the facility

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DOJ’s 2010 Standards. . .• Trigger access if you are building a new

playground or making an alteration to an existing playground

• In both cases, owners need to provide primary means of access to the playground• Which has been the industry’s responsibility for

more than 20 years

• The key, according to IPEMA, is to have a plan of attack on how to comply in all stages of designing and building playgrounds

“The bottom line is. . .”• “You better know what you have and how it

does or does not comply with these rules”

• “You should audit all of your playgrounds to these standards”• “Either do it yourself or hire someone to do it”

• “Then have a transition plan as funds and manpower are available”

“Identify, prioritize and then have a plan to make them accessible”

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Public Playground Accessibility Checklist – No. 1

• Public playgrounds must have an accessible route to the play area

• Preferably 60” wide, max. running slope of 1:20 and max. cross slope of 1:48

• The route to the play area is an accessible route if:• Min. width is 36” and max. slope is 1:12

• Any running slope over 1:20 or 5% is treated as a ramp with handrails and landings

Public Playground Accessibility Checklist – No. 2

• Within the play area, the safety surfacing must comply with ASTM F 1292-99 or -04 Standard when located within the use zone for proper impact attenuation

• All accessible routes within the play area, clear floor or ground spaces at play components are required to be accessible and turning spaces must comply with ASTM 1951-99 Standard (Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment)

Public Playground Accessibility Checklist – No. 3

• Within the play area, the accessible route must be at least 60” wide, with a max. running slope of 1:16, a max. cross slope of 1:48 and a min. of 80” overhead clearance

• For small play areas of less than 1000 sq. ft. in total size, the accessible route must be at least 44” wide, with a max. running slope of 1:16, a max. cross slope of 1:48 and a min. of 80” overhead clearance

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Public Playground Accessibility Checklist – No. 4

• Composite play structures that include a transfer system as a means of access must meet the following criteria:

• Transfer platform height must be between 11” – 18” with clear min. width of 24” and depth of 14”

• Transfer steps are max. of 8” high and include handholds to aid movement

• Min. 30” x 48” transfer space must be provided adjacent to the transfer platform

• The 48” long min. dimension of the transfer space shall be centered on and parallel to the 24” long min. side of the transfer platform

• The side of the transfer platform serving the transfer space shall be unobstructed

Public Playground Accessibility Checklist – No. 5

• Composite play structures that include ramps that connect elevated play components as a means of access must meet the following criteria:

• Elevated ramps must be at least 36” wide, max. running slope of 1:12 and max. length of 144” (12’) before providing a landing

• Elevated ramps must include handrails on both sides meeting hand gripping criteria and with a height between 20” – 28”

• Elevated ramps with handrails, barriers beyond the ramp edge and barriers not extending within 1” of the ramp surface must have edge curbs at least 2” high for the entire ramp length. No handrail extensions are required.

• When elevated ramps change in direction a 60” x 60” min. level landing must be provided at both the top and bottom of each run

Public Playground Accessibility Checklist – No. 6

• Elevated ramps and accessible platforms attached at ramp levels shall have no openings on the surface greater than ½” and vertical change in level less than ¼” or up to ½” with a 2:1 beveled edge

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Public Playground Accessibility Checklist – No. 7

• Wheelchair-accessible platforms require guardrails or barriers

• Openings for access/egress play components shall be narrowed to 15” or less

Public Playground Accessibility Checklist – No. 8

• Advisory Reach ranges for accessible manipulative and interactive sensory and communicative components must have reach range heights between:

• 16” - 44” for 9 - 12-year olds, • 18” - 40” for 5 – 8-year olds and • 20” – 36” for 3 – 4-year old

user age groups

Public Playground Accessibility Checklist – No. 9

• Ground level upper body equipment intended for use by a person using a mobility device must be less than 54” above protective surfacing

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Public Playground Accessibility Checklist – No. 10

• Ground level play tables and components for users over 5 years old must have a min. vertical knee clearance of at least 24” high, a min. depth of at least 17” deep and a min. width of at least 30”

• The max. top playing surface shall not exceed 31”

Public Playground Accessibility Checklist – No. 11

• Composite play structures must have elevated accessible routes by ramp and/or transfer systems to connect at least 50% of the elevated play components

• Large composite play structures with more than 20 elevated play components must have at least 25% of the elevated play components connected by elevated ramps

Public Playground Accessibility Checklist – No. 12

• Play areas must have the min. number of accessible play components and types on the accessible routes per the following criteria:

• Remember it is one of each type at ground level and 50% elevated that must be accessible

• The trigger to use the table is for Additional Number and Types

• Where elevated play components are provided, ground level play components shall be provided in accordance with the Table 240.2.1.2 and shall comply with 1008.4 (Play Components)

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Exception• If at least 50% of the elevated play components

are connected by a ramp and at least 3 of the elevated play components connected by the ramp are different types of play components, the play area shall not be required to comply with 240.2.1.2

Recommendation

Standards & Guidelines• Guidelines

CPSC – “Public Playground Safety Handbook”

• Standards ASTM F1487-11 “Standard

Consumer Safety Performance Specification for Playground Equipment for Public Use”

• Voluntary in SD But can be used in civil litigation

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“The Dirty Dozen”• Produced by the National

Recreation and Park Association• Certified Playground Safety

Inspector (CPSI) Program

• Reviews top 12 playground hazards in America’s playgrounds

Video• “The Dirty Dozen”

• 14 minutes

• Contact SBI for a free copy

Did You Know?• Improper surfacing material under

playground equipment is the leading cause of all playground related injuries

Over 79% of all accidents on playgrounds are from children falling

from equipment

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#1 – Improper Protective Surfacing• The surfacing under and around playground

equipment is one of the most important factors in reducing the likelihood of life-threatening head injuries

• A fall onto a shock absorbing surface is less likely to cause a serious head injury than a fall onto a hard surface

However, some injuries from falls, including

broken limbs, may occur no matter what surfacing

material is used

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ASTM F1292 – Fall Heights• Provides a “critical height” rating of the

surface

• This height can be considered as an approximation of the fall height below which a life-threatening head injury would not be expected to occur

• Manufacturers and installers of protective surfacing should provide the rating for their materials

RatingsFall Height• Is the distance between the highest

designated play surface on a piece of equipment and the protective surface beneath it

• The rating should be greater than or equal to the fall height of the highest piece of equipment on the playground

Example - Fall Height for a Swing• The fall height for

swings is the vertical distance between the pivot point and the protective surfacing beneath it

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Unitary Surfacing Materials• Generally these are rubber mats and tiles or

a combination of energy-absorbing materials held in place by a binder that may be poured in place at the site and then cured

• Some dark colored materials exposed to intense sun have caused blistering on bare feet

• Have the manufacturer supply F1292 test data identifying the critical height rating of the material

Loose-Fill Surfacing Materials• Generally we think of landscaping-type

materials that can be layered to a certain depth

• Examples: • Wood mulch, • Wood chips, • Sand, • Pea gravel and • Shredded/recycled rubber mulch

Engineered Wood Fiber (EWF)

• Engineered wood fiber (EWF) is a wood product that may look similar to landscaping mulch but is specifically designed for use as a playground safety surface

• EWF products should meet the ASTM F2075 “Standard Specification for Engineered Wood Fiber” and be tested to comply with ASTM F1292

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Rubber Mulch• Make sure these products have been

tested and comply with ASTM F1292

9 Important Tips1) Loose-fill materials will compress at least

25% over time due to use and weathering

2) Loose-fill surfacing requires frequent maintenance to ensure levels never drop below the minimum depth

3) The perimeter of the playground should provide a method of containing loose-fill materials

9 Important Tips (cont.)

4) Consider marking equipment supports with a minimum level to aid in maintaining the original depth of material

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Minimum Level Markings

9 Important Tips (cont.)

5) Good drainage is essential to maintaining loose-fill surfacing

6) Critical height may be reduced during winter in areas where the ground freezes

Playground Surfaces in the Winter??

ASTM F1292• Standard requires

testing of the surface’s ability to provide full protection at 3 prescribed temperatures

• Lowest temperature at 21 degrees F.

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9 Important Tips (cont.)

7) Never use less than 9 inches of loose-fill material

8) Some loose-fill materials may not meet ADA accessibility guidelines

9) Wood mulch containing chromated copper arsenate (CCA)-treated wood products should not be used

Minimum Compressed Depths

Loose-Fill Over Hard Surface

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Wear Mats

Wear Mats

Equipment Not Covered By Surfacing Recd.

• Recommendations do not apply to equipment that requires a child to be standing or sitting at ground level

• Examples:• Sand boxes• Activity walls at ground level• Play houses• Any other equipment that children use when

their feet remain in contact with the ground surface

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Example of Exemption

Insufficient Cushioning

Good Example

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#2 – Inadequate Use Zone• A use zone is the area under and around

playground equipment where a child might fall

• A use zone should be covered with protective surfacing material and extend a minimum of 6 feet in all directions

• These areas are also designated for unrestricted circulation around equipment

• Different rules apply to different equipment

SELF -INSPECTIONS

Inspection Items There should be no missing, broken or worn-out

components

All hardware should be secure

The wood, metal or plastic should not show signs of fatigue or deterioration

All parts should be stable with no apparent signs of loosening

Surfacing material must be maintained

Check for signs of vandalism

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Use Checklists“If it is not on paper,

it didn’t happen”• Frequency is going to depend on use

• Daily visual inspections during peak use• Weekly or monthly documented inspections??

• Sample audit and inspection checklists are available from SBI

• Injury reports should also be kept as long as you have the equipment

Not All Equipment Is Created

Equally

Make Sure New EquipmentMeets the following:• U.S. Consumer Product Safety Commission

(CPSC) guidelines for public playgrounds

• ASTM F1487, “Standard Consumer Safety Performance Specification for Playground Equipment for Public Use”

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IPEMA• Provides a third-party

certification service

• Whereby a designated independent laboratory validates a participant’s certification of conformance to ASTM F1487 standards

Looks Can Be Deceiving

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Residential/Commercial1) 2.3.1 Swinging dual exercise

rings and trapeze bars

2) 5.3.6.5 For slides that are part of a component structure, the min. use zone between access components and the side of the slide chute should be 3 feet

3) 5.3.8.3.1 Swings should not be attached to component structures

4) 5.3.8.4.1 Multi-axis swing use zone should never overlap the use zone of any other equipment

Equipment Installation• Should be done by the supplier or at least

supervised by the supplier

• Several instances where good equipment has been improperly installed

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Playground Safety Training• SBI is offering FREE training classes

• Spring 2013

• Training divided into 2 parts• Classroom• Hands-on

• Host site needs to furnish (contact SBI if interested)

• Classroom• Playground• Refreshments

QUESTIONS??

Conclusion• Times have changed since many of us grew

up playing on playgrounds

• Living in a litigious society where people are less willing to accept responsibility for their own actions

• Have a moral and legal obligation to provide safe playgrounds for the children and grandchildren of our communities

Be Pro-Active!!

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Doug Kirkus Safety Benefits, Inc.