This column continues my thoughts on using a hazard based approach to equipment performance and safety. Where does the responsibility lie for children's safety on the playground? Playground owners? Playground managers? Designers? Safety inspectors? Yes! Review Part 1 here.
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 owners should evaluate risk and make recommendations. You could still move the 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 International (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 play space, 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 manufacturer 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 apply 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 Certified Playground Safety Inspector (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 National Recreation and Park Association (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 play space. 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, play spaces 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 play space when it comes to injury prevention. Well-designed and constructed play spaces in compliance with the requirements of this standard create a foundation for play within the context of injury prevention. Regardless of how well the play space 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 play space. Play spaces complying with this standard provide a formal environment focusing free play activity to a specific location 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 play space where appropriate injury response can be delivered in a timely fashion.
Part 3 is coming...