How does the hazard-based approach work? Our Objective
“Playground safety performance requirements shall be developed and applied to focus on the hazards posed by equipment’s design, movement, and layout, whether free-standing or in combination with other components, and should address the issues of intended and reasonable foreseeable use rather than exempting that equipment from all but the most basic requirements of the past.” Kutska, Part 2 of 3, Hazard Based Approach to Standards Development
Last September I wrote about this concept of hazard based standards development. In this article I am referencing below a post I made on the NRPA Connect social media page created for CPSIs. I walked him through the assessment process I might use in evaluating this design. The person was challenging the layout and spacing for a stand up spinner that was attached to the support post of an overhead ladder that was connected to a much larger composite structure. This is maybe too much for one to analyze without a picture but basically it was all one big composite structure. My assessment process went like this:
“What is your citation for your findings? Remember use zones may overlap for composite structures. Rather than use zone issues there may be more clearance related issues. I do not discount your concern but right now IPEMA Certification Program would consider this compliant. It may not be best design but now is not the best time to bring up this concern. Planning stages is when owner should evaluate risk and make recommendations. You could still move spinner and make it a free standing play event if you have money and space but the owner will be footing bill. We are working on this very subject at ASTM as we see rotating equipment and composite structures requiring a second look. Ask yourself, what are the hazards? Falls to surface. Impact by spinning equipment. Impact from limited clearance. Loss of balance from rotating equipment leading to lateral discharge from inadequate upper body strength and lack of gripping or grasping surfaces. Is there sufficient circulation area around adjacent play events? All reasonable concerns. Now ask what the standard allows at a minimum and then ask what a reasonable person would allow given your specific end user and owner’s philosophy for free play.”
I stated that for the hazard based approach to move forward we cannot continue to evaluate playground equipment during a post-injury investigation in the same manner, with the same objectives, as if the injury occurred in a workplace environment. We have to look at what the safety issues are during reasonable and foreseeable use. Assuming the standard has established society’s acceptable threshold for severity of injury, the designer and manufacturer of the playground equipment should be conducting their own risk assessment of their equipment to determine whether or not it is appropriate for the intended user during both intended and reasonable foreseeable use.
Equipment designer/manufacturers shall make recommendations on age appropriateness and should recommend minimum use and clearance zones based on intended design use and reasonable foreseeable misuse. Also the playground area designer and owner need to consider all these things and more during the design process. Other than the age range of intended users and age appropriateness of specific pieces of equipment, all other special requirements within the standard are stated as minimums. These minimums may not meet the owner’s needs for the scope of their project.
The owner and designer need to work together and conduct their own project assessment and answer the following questions: define the intended users, what if any supervision will be present, intended user load, level of accessibility, access to and from the playground, environmental concerns, border safety concerns, and most importantly, what level of impact attenuation their surfacing system shall provide based on the fall height of the equipment. Remember, the surface system needs to perform to these minimum standards throughout the life of the playground. Therefore, the owner may want to consider specifying surfacing to perform well under the minimum impact requirements for the fall height of the equipment or even specify a surfacing performance threshold less than minimum required to provide more fall protection under and around the more challenging pieces of motion and upper body equipment. When it comes to protective surfacing, use zones, and clearance zones, these requirements are stated as minimums. Therefore, it is ultimately up to the owner’s risk assessment during the conceptual playground design to establish their own balance between how safe is safe enough and how much risk and challenge is too much.
Children will continue to be injured while enjoying the thrill of the challenge as they test their skills. We also know the primary causes of debilitating and life-threatening injuries in children ages 2-12. Falls have always been the number one cause of injuries on playgrounds and one of the major causes of playground deaths. We also know that impact by moving and even stationary equipment is another major factor. We know entanglements caused by projections or specific dimensions along with how we dress our children to play on the playground are the number one cause of playground-related deaths. We know that projections of specific sizes and shapes can impale a falling or moving child causing many different types of injuries. We know that sharp points or edges cause lacerations. We know that heavy suspended moving components that come in contact with the user’s body, especially their head, can cause serious brain injury.
How we approach these known causes of serious injuries, which fit within the medical profession’s measureable definition of debilitating or life-threatening, is our challenge. We cannot look into a crystal ball and predict with any certainty the future, but we have learned from the past and must act responsibly. Now is not the time to go back to some of the design practices of the past for the sake of new product design, especially when the past has shown time and time again the unintended consequence of an unsupervised child’s reasonable foreseeable behavior. That is the real challenge to play equipment designers, manufacturers, and playground standards writers.
Do you have the ability to assess the play environment and the equipment within this environment during the play area design process and ultimately to come to a reasonable balance between safety considerations and the need for challenge and risk in a child’s play environment? That should be our main objective. If we do not get this right, children will find what they are looking for in places with far more hidden dangers and risk of harm than should exist in any well-designed playground.
For these reasons, the ASTM F15.29 Subcommittee is working towards a hazard based approach to reduction of those injuries deemed unacceptable to society as a whole. Julian Richter, founder of the German playground equipment company Richter Spielgerate GmbH, said it best, “We should have as much play value as we can possibly afford, but only as much safety as is necessary.”
More on the status of this approach to standards writing will be coming in future columns.