Can We Eliminate Serious Playground Injuries Through Legislation?

International Standards Addressing Playground Surfacing Compliance: Can we protect children against their own actions?

I am flying back to home after two trips to Europe. These trips allowed me to follow my passion to play as an adult while observing how adults from other parts of the world provide opportunities for children’s play.

What I observed in France, Hungary and Austria was a consistent attempt to comply with the European Playground Safety Standards. Their EN1176 Standard addresses the performance of play components and EN1177 Standard covers surfacing requirements for impact attenuation within use zone. You do not need to know the particulars of the EN equipment performance standard to understand that compliance should reduce life-threatening and debilitating injuries from known hazards based on injury data and industry experience over a very long time.

What I have found from my recent world travels is quite similar to my observations of children’s play spaces during my IPSI travels throughout Southeast Asia. Over the past twenty or more years their play areas have been influenced by the British, German, and Australian playground standards. All the international playground industry people I have been privileged to interact with are as passionate about the value of play for a child’s development as the rest of us and the safety of their children is equally important.

I will be discussing where I think the international standards community is headed. First I will share the possible outcomes from the TUV Austrian Academy Playground Safety Seminar held October 22nd in Vienna, Austria. What happens next at the TUV EN playground standards development committee will more than likely have some impact on the rest of the world. Conference participants were from throughout the EN, Australia, Canada, and the U.S. It was clear to me that we are all one big, most of the time, family when it comes to our passion for improving play environments and the child development benefits of play.

The importance of the reasonable and responsible design of these environments is important to our success. When we create a new play area and celebrate our ability to get it right, it can sometimes be as much an accident than some well executed grand plan. There are many more new play components and variations of each component in today’s marketplace than when I was a kid. Whenever someone comes up with a design for a new play event or a completely new play area concept, guess what? I am sure children thousands of years ago have probably already been there, done that. The play item of yesteryear was probably not made with any of the materials available today. I am also pretty sure there was no consideration for obstacle-free use zones and a soft landing as required by today’s standards. One more thing I am certain of is this new, old thing, was just as much fun back then as it is today.

Unfortunately, children of yesterday, today, and tomorrow will continue to have accidents and be injured as they try out new play experiences. Sometimes they succeed in their new challenges and sometimes they fail. Our job as parents and caregivers is to allow children the opportunity to live and learn life’s lessons at their own pace. After all, it is their life, not ours. Our job as stated earlier is to be responsible stewards of the play area design.

What is the meaning of reasonable and responsible design in the context of the TUV Austrian conference? It is the responsibility of the designer, manufacturer, and owner to conduct some form of risk assessment of their playground products and projects prior to actually approving the playground plan, and then purchasing and installing the equipment.

One thing I have observed throughout my world travels is play area impact attenuating surfacing is recommended, or in some cases required, to provide a level of impact mitigation where children are predicted to fall. My experience suggests their surface systems do not appear to meet the minimum requirement of our standards, but without field test verification one would never know for sure. Currently, the EN Standard only has a laboratory test standard for a maximum fall height requirement of 3 meters, which is just under 10 feet.

If the surface does not meet the minimum safety requirements as recommended in our industry standards and referenced within our standards scoping statements, how can it meet the needs of our children? I will discuss what we think we say in our standards versus what it means.

One universal fact about children regardless of origin is that they will fall, time and time again, throughout their lifespan. Worldwide falls are the number one cause of accidents and injury to children. How or why a person falls cannot be controlled but what they fall on can. International standards all speak of protective surfacing requirements. Everyone addresses this issue a little bit differently, but we all speak to the need for a surface that will help mitigate the unfortunate consequences of the unexpected fall. We even need to consider the intentional misuse or a jump of the child as they attempt to set a new personal record or accept a dumb challenge from a friend. Considering reasonably foreseeable misuse is a term that probably needs to be looked at when conducting a risk assessment of a product or play area design.

All international playground safety standards talk about eliminating death and permanently debilitating injuries, but will the performance requirements in each standard actually hit the mark? Parents and playground owners are told the surface system, as marketed as compliant to the standard, will do just that. Everyone is and has been using the benchmark of 1000 Head Injury Criteria (HIC) as the number we should not exceed while conducting the laboratory test.

So, how do we really know if our surface is compliant or more importantly will mitigate the potential for a serious injury? Up until the past few years the field test or post-installation test was not feasible. This is not the case today as there are several hundred of these field testing devices available throughout the world. The cost of such field testing is coming down as more people require field compliance testing as part of their purchasing requirements. ASTM F1292 surfacing standard for impact attenuation surfaces in playgrounds now gives the requirements for both laboratory and field testing.

What good is a laboratory test versus a field test after installation or during the life of the surface system? These issues and more were the primary focus of the one day Vienna conference. The purpose was to look at new research and technology that did not exist when the EN1177 standard was published.

The EN standard review process is already underway. Canada has just completed the review of their playground standard. Japanese Park Facilities Association (JPFA) is starting a review and revision of their 2002 standard. ASTM Subcommittees are always working on improving their standards, and I am sure they will be discussing the results of this conference as we move forward with our standards revision work.

Malaysia is holding their first conference on play and playground safety in Kuala Lumpur this week. They have created a professional association of sorts as a result of NRPA and IPSIs’ CPSI Courses the past two years. These Malaysian CPSIs will be sharing their knowledge with many during this conference, and they will be presenting the first Malaysian Playground Safety Requirements for all public playground owners. What Malaysian CPSIs are presenting to the general public and public playground owners is that public play environments are important to a child’s development. They realize children and their parents expect these areas to be safe and already compliant with international standards for playgrounds. Is this true or is it wishful thinking? Through attending the CPSI Course and the playground maintenance technician program they understand what is required by these standards and now they have some tools to help with the task of bringing all their playgrounds into compliance with accepted international standards.

This is great news for the children of Malaysia. While their play areas look acceptable to all who frequent them and to the CPSI Course participant prior to completing the program, the course participant’s opinions changed after completing the course. Malaysia is moving towards taking appropriate corrective actions as they identify areas needing improvement resulting from timely equipment inspection and maintenance.

The most pressing compliance issue I observed during my visits to this region was the deterioration of their unitary surface systems primarily caused by the harsh environmental conditions that exist close to the equator. There was little doubt the surfacing at most of these sites would fail the ASTM F1292 field test.

Worldwide there are several internationally accepted standards for testing compliance to the 1000 HIC performance compliance threshold for impact attenuation. They are: EN 1177 (Europe), AS 4422 (Australia), SS 495 (Singapore), CSA Z614 Part 10 (Canadian) and ASTM 1292 (International/USA). There might be other surfacing standards, however, these are the ones referenced most often in my international travels and training. The primary consistency among these standards is the reference to the maximum 1000 HIC compliance test limit and that the test is required to be conducted by and in a test laboratory. Field testing has been an option in the ASTM F1292 and is becoming an acceptable option in other international surfacing standards; after all, it is the only way the owner knows the surface is still performing within the allowable impact threshold limits of the standard or was initially installed correctly and within these allowable limits or the limits established by the owner in their purchasing documents.

This field test option is a major issue for any owner who is obligated to comply with the current standard regardless of which standard we are using. In the US the ASTM F1487 and the DOJ 2010 Standard require owners to maintain their playground surface within the use zone to within the acceptable limits or remove the play area from public access until the condition can be rectified. I think you can appreciate the importance of a field test method versus a laboratory test if you are responsible or will be held responsible for trying to maintain the use zone surfacing within the acceptable performance thresholds of the standard.

Ontario, Canada is the only jurisdiction that I am aware of that requires annual compliance drop testing in order that a childcare facility retain its annual operating license. Will others follow? I think maybe over time. How fast this might occur is anyone’s guess. The test method and compliance requirements are there in voluntary industry standards but these standards organizations cannot mandate they be required. Only government can create laws or licensing requirements that mandate such compliance and to what threshold limits and to which industry standard.

In the Vienna conference, I heard many participants from various countries urge TUV Austria and other government consumer advocate organizations in attendance to change to a field compliance test for impact attenuation of playground surfaces. It was well argued that compliance field testing is the only way a consumer knows the product they bought lives up to the marketing material the manufacturer of the proprietary surface system sold them on in the first place.

This brought out the other argument for field testing over laboratory testing as the best means to hold the marketplace accountable for the performance of their product. The initial cost of the surfacing product may not become the major deciding purchasing factor when contracts are awarded based on compliance with the standard and performance over an extended period of time.

The EN 1177 standard has a maximum fall height for any play equipment at 3 meters regardless of what the CPSC Handbook or ASTM standard would determine the fall height to be. If CPSC says the highest part of the climber, then many of our larger composite play structures and large climbing nets would be greater than 10 feet. If my play structure had a fall height of 10 feet or 3 meters based on the highest platform, would you want to consider the potential fall from above the platform, say the top of that platform barrier? It is the owner’s prerogative, as stated in ASTM F1292, to select the drop height at which you which the surfacing to perform.

If you manufacture a quality surface system that performs far better than the lowest bidder who meets the 3-meter maximum fall height for any play structure, wouldn’t you want to know how much better the other surface system’s HIC Values might be? I, as an owner/operator, would like to know what the surfacing Critical Height is in order to make a more informed purchasing decision. How about you?

These items and more were discussed by the participants and presenters in this one day conference. Next, I will discuss whether the laboratory test is even needed and should there be mandatory compliance field test requirements after installation and then consider follow-up testing at some reasonable interval thereafter.

Correction made 11-11-13: ASTM 1487 was incorrectly cited as ASTM 1497.

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Step 1 – International Standards Embracing Playground Surfacing Compliance Test Method

In Step 1, we will discuss whether EN 1177 or ASTM F1292 laboratory tests are even needed and should we consider mandatory compliance field test requirement after installation of your surface system. If post-installation field drop testing were to become a requirement of owner/operators prior to opening a playground to the public, maybe there should be consideration given for some form of mandatory follow-up compliance field testing at some reasonable interval throughout the life of the playground. After all, the F1292 standard states the owner/operator should take the playground out of service until which time the surface within the use zones is brought back into compliance.

 

I would like to go back to my observations from the October 22 TUV Austria Conference in Vienna Austria. Not every in attendance was of the same opinion on what in the European Union EN1177 surfacing standard should be revised. Some of the participants thought there was no improvement needed to the current playground surfacing standards. I heard some say the existing requirements go too far in trying to protect children from themselves.

One participant thought well-intended adults recommending improvements to this existing surfacing standard were taking away a child’s opportunity to develop risk assessment and problem-solving skills that evolve when children encounter challenging play events. The individual went on to say the element of fear is important and brings about a different kind of play and learning experience. While we might all see the importance of this point of view, a compliant surface system which absorbs most of the energy of the falling child is a better approach rather than the child’s body absorbing most of the energy.

Regardless of these comments, it appears the EN committee responsible for this standard will be making recommendations for some changes based on all the new research and information coming out on head injuries and the relationship of impact thresholds currently being used throughout the world to these and other injuries. What will be actually recommended by this committee is unknown, but there are some major differences that currently exist between ASTM and EN playground impact attenuating surfacing standards.

One of the major differences between ASTM and EN equipment and surfacing standards is determining fall height of play equipment. The other major difference is the lack of restricting the fall height of equipment to 10 feet (3 meters) regardless of the fall height of the equipment as determined by the ASTM Standards and CPSC Handbook. They also have a maximum critical height for surfacing at 10 feet (3 meters) regardless of the fall height of the equipment.

During the conference, there was not much discussion on changing fall height requirements for equipment, and within the USA this would prove problematic. Let’s look at the requirements for a three-dimensional net climber. Many of these climbers have fall heights greater than the EN1177 - 3-meter (10 feet) maximum critical height requirements for surfaces. I think we can all agree most children are very capable of using these kinds of play components without falling to the surface. In Europe, these large climbing nets have been around more than thirty years. These climbing net manufacturers state there is little or no injury data on falls from these climbing nets, and this may very well be the result of the above discussion of how fear and risk assessment by children can change the way they play.

We might also expect similar injury-free results for most fit, agile, and athletic children, but what about those who may not possess those traits at this moment of their life. We are all unique individuals. We each developed at our own pace. Most of us were not fortunate enough to become the biggest, strongest, and smartest of our peers. Nevertheless, every one of us deserves the opportunity to experience the developmental benefits of play. So what would you do or say if your child was one of the unfortunate few who fell onto the playground surface and suffered some serious head injury?

Playground surface system performance can be compared to a seatbelt in your car. Regardless of mandatory seat belt laws in the USA, how many of you still do not buckle up? How many of us have never had to use them? Just because we statistically may never have to experience using our automobiles’ passive safety systems, we still must buckle up. Take the seatbelt protective system a step further and add airbags to the discussion. Since most of us may never need to experience the benefit of a seatbelt, why would we want to pay for automobile airbags? Both passive safety systems are there to protect us from the probability of suffering a life-threatening or permanently debilitating injury if and when we are involved in an automobile accident.

If we put this passive safety system concept into practice within the public playground environment, the manufacturer and owner/operator should expect children to interact with challenging play equipment in unintended ways. We do not intentionally drive our cars into each other or a brick wall, but we can expect children to experiment outside their known physical, emotional, social, and cognitive capabilities in the playground. That is after all the purpose and major benefit of free play in the playground environment. Most of the time children play without incident, but sometimes the child is not successful in completing a task and accidentally falls. It is not reasonable to expect 100% success when a child undertakes a challenging activity. Some rate of failure is inevitable, and some failure should be accepted as part of child development as long as the resulting consequences remain within the limits of a societal norm.

What is the acceptable severity of injury we are all willing to accept within the scope of our safety standards? Once this question is answered we should be able to better evaluate the performance of the play equipment and the impact attenuating surface system under and around the play equipment where falls from the play equipment are likely to occur. This seemed to be THE question of the entire week during the November ASTM Committee meetings in Jacksonville, Florida.

Falls continue to be the number one cause of injuries on public playgrounds and this fact has not changed ever since the CPSC began gathering and analyzing injury data.

If we are ever going to make some progress in reducing the frequency and severity of fall-related injuries, we need to define, to some measurable degree, the type and severity of these types of injuries. The ASTM standards groups are in the process of taking this next step. Regardless of where we are in ASTM F1487, changes to the surfacing F1292 performance requirements will potentially have the biggest impact on reducing frequency and severity of serious fall-related injuries. Unfortunately, the scope of the ASTM F1487 standard does not appear to address the severity of injuries currently identified within the scope of both ASTM F1487 and F1292 standards. More cooperation between these two ASTM Subcommittees and CPSC will be necessary if we can ever hope to make any substantial reduction in serious injury reduction.

In Step 2, I will discuss some of the challenges facing our industry as we further evaluate the current level of performance the impact attenuating surface system standard provides and how these performance thresholds translate to a level of injury these standards currently address.

Step 2 – Whose Path of Action is Most Realistic and Reasonable to Measurably Reduce Serious Injury?

THE QUESTION:

Which came first? The chicken or the egg. Man has been pondering this question forever and now I feel like I am in the middle of the same conundrum with regards to performance requirements for play equipment versus performance requirements for impact attenuation surfaces within the play equipment use zone.

THE ANSWER:

The answer from ASTM F15.29 Subcommittee’s perspective with regards to the future direction of the F1487 standard is not so easy. Our Subcommittee has never been able to identify and analyze each and every piece of play equipment prior to its entry into the marketplace. We continue to struggle with coming up with specific equipment requirements not addressed by the general performance requirements for each of these play components in a timely fashion. My simple answer to this question is, “Not in my lifetime.”

BACKGROUND:

The staff of the U. S. Consumer Product Safety Commission (CPSC) presented a letter addressed to me as Chair of the ASTM International (ASTM) F15.29 on May 20, 2013. This letter was a follow-up to a written comment dated May 10, 2013, from CPSC staff regarding the F15.29 (12-03) ballot item #6. In this letter, it was noted that the specific types of playground equipment in section 8 of the ASTM F1487 Standard (balance beams, climbers, upper body equipment, sliding poles, slides, swings, swinging gates, merry-go-rounds/whirls, roller slides, seesaws, spring rockers, log rolls, track rides, roofs, and stepping forms) do not appear in the definition section of the standard. CPSC suggested we define these types of equipment in the terminology section of the standard.

The ASTM F15.29 Subcommittee discussed this letter during the May 20, 2013 meeting. The discussion continued into our Working Groups breakout sessions. The Subcommittee members in attendance concurred with the CPSC staff’s findings that it is difficult to keep up with the marketplace and define these new items in any timely fashion due to the speed at which the industry introduces new products into the marketplace from around the world.

While the CPSC staff realizes the lack of more definitions, to address new variations of play equipment may lead to differences in interpretations of the standard resulting in some products not meeting the appropriate performance requirements of the ASTM F1487 Standard. As a CPSI Course Instructor, I receive questions from CPSIs conducting compliance audits on how to evaluate these new products. The NRPA CPSI Course suggests a common sense approach to this dilemma as part of the course curriculum. The curriculum says we should not be claiming something is not compliant with the ASTM voluntary industry standard just because it does not fit into one of the existing types of specific equipment performance requirements.

This approach does not appear to go far enough for everyone concerned. So what should we do? The purpose of the standard is to protect the children by eliminating known hazards and reduce or even eliminate serious debilitating injuries and death. I think we can all agree we have made significant contributions to this end, however, there will always be some serious injuries and even deaths, and they may occur on a perfectly standard compliant playground. Can anyone protect everyone from every possible accident or a child’s own unreasonable actions?

Do you think it is reasonable and responsible to expect ASTM or CPSC to attempt to define each and every play component and/or variation of each type along with related additional specific equipment performance standards? The current playground equipment catalogs from around the world compared to those of just ten years ago demonstrate how many new play opportunities have been created. Many of these were never contemplated when the CPSC created their first handbook for public playground safety in 1981. The CPSC and the ASTM have been playing catch-up ever since the first standards and revisions of the 1990s. I have to ask if such a massive undertaking would do anything for the prevention of serious playground injuries. I also have to ask whether the CPSC’s request would be considered a step towards improved equipment performance requirements or a step towards restricting or dictating design.

In a draft letter to all members of ASTM F15.29 Subcommittee, I expressed my belief that any attempt to define each and every type or variation of play component is impossible if we are to stay within the scope of our performance-based voluntary industry standard. ASTM F1487 is not a design standard even though we seem to arrive at this notion within the current standard on certain specific equipment types.

During informal discussions and at our November ASTM F15.29 meeting some suggested our efforts to implement the CPSC staff’s recommendation, while well intended, would become a time consuming and very expensive exercise in futility and an impossible process to strategically manage. This process will end up costing ASTM Subcommittee members an enormous amount of human and financial resources, and we would never ever get to all the different types of play components before new ones enter the marketplace.

The ASTM democratic balloting process used in standards development is an open and participative democratic process and therefore it is a lengthy process. It would take years of commitment and effort to accomplish such a task on the backs of volunteers, many of whom spend their own resources to participate in the standards development process. We have to ask what will have been accomplished in the short term, say two or three or even five years down the road, to reduce the frequency and severity of serious injuries? I first suggest we evaluate what measurable reduction in the frequency and severity of NEISS reported injuries have occurred over the past twenty years.

I predict that if we implement the course of action being suggested in the May 20th letter, the ASTM F1487 standard and CPSC Handbook will become even more design restrictive while not addressing the existing hazards which result in truly serious injuries as defined in the International Standards Organization ISO TC83 Committee’s technical paper on terminology. While this report has not been published, I can see that it has gathered much international consensus and could give us something tangible to use as we attempt to focus on the big issues, such as life-threatening and permanently debilitating injuries.

The ASTM F1487’s scope states,

“This consumer safety performance specification provides safety and performance standards for various types of public playground equipment. Its purpose is to reduce life-threatening and debilitating injuries.”

So where are we today in reducing these types of injuries? I believe we have made progress in reducing deaths and debilitating injuries in public playgrounds primarily in the area of head and neck entrapment and entanglement, but I do not see a reduction in the frequency of injuries being tracked by the CPSC. Based on the fact that CPSC and the NEISS injury data reflect little or no reduction in public playground injuries, it suggests we might be approaching the injury prevention issue from the wrong point of view. We seem to continue on the same path of trying to close the barn door after the horse has already left.

CPSC states that over the past few years the design of playground equipment has undergone some radical innovations. In general, we all need to make sure that known safety standards are being addressed. Both ASTM and CPSC support innovations in playground equipment and believe playgrounds serve an important function in childhood development. The CPSC staff stated it so well in their May 20, 2013 letter, “playgrounds should allow children to develop physical and social skills, and part of that development.”

We can both agree new, innovative playground components should still follow the safety performance recommendations that both CPSC staff and ASTM F15.29 Subcommittee have worked to refine over the past several decades. We both can agree with the CPSC statement,

“Staff asks that the subcommittee recognize that the recommendations in the Handbook and the requirements in the standard are designed with respect to the hazards posed by the type of equipment.”

We also agree with the statement in the CPSC Handbook, Section 1.6,

“Because all playgrounds present some challenge and because children can be expected to use equipment in unintended and unanticipated ways, adult supervision is highly recommended. The handbook provides some guidance on supervisory practices that adults should follow. Appropriate equipment design, layout, and maintenance, as discussed in this handbook, are also essential for increasing public playground safety. A playground should allow children to develop gradually and test their skills by providing a series of graduated challenges.”

Section 1.7 Playground Injuries states,

“The recommendations in this handbook have been developed to address the hazards that resulted in playground-related injuries and deaths. The recommendations include those that address:

The potential for falls from and impact with equipment

The need for impact attenuating protective surfacing under and around equipment

Openings with the potential for head entrapment

The scale of equipment and other design features related to user age and layout of equipment on a playground

Installation and maintenance procedures

General hazards presented by protrusions, sharp edges, and crush or shear points

Section 2.4 Surfacing states,

“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 playground surfacing material is used.”

All this being said I personally suggest the ASTM F15.29 Subcommittee, responsible for industry performance requirements for public playground equipment, spend its time promoting child development through innovative challenging play opportunities following best industry performance specifications and not focus on trying to identify and define each and every type of equipment including all the variations as CPSC recommends in their May 20 letter. I would suggest our time be best spent on continuing our efforts towards a hazard-based approach to addressing a measurable level of injury reduction based on the current NEISS injury data analysis and the ISO definitions for hazard based risk assessment and the definition of serious injuries based on the accepted medical analysis.

What would help with either of these recommended courses of action are universally accepted definitions and descriptions of a level of injury we can all agree on and relate efforts for reduction of these injuries back to our standard’s scoping statements. This would better define our mission and the types of injuries the standard performance requirements are attempting to address. I believe this course of action best supports child development and supports more innovative equipment that challenges children at all levels and advocates for healthy risk during free play.

The course of action taken should also support those playground owner/operators who are attempting to offer such creative challenging spaces while giving equipment manufacturers and designers the freedom to meet the market’s expectations without restricting international free trade. Limiting liability to all for unreasonable misuse is something that needs to be addressed if we are going to be successful in this endeavor. In Germany, parents have a legal obligation for the health and safety of their children and if their children are injured, they will be held accountable. This sounds very reasonable to me and something North America needs to promote.

The standard development process the ASTM F15.29 Subcommittee has successfully embraced, over the past few years, is to address serious injuries through a thoughtful playground equipment safety performance based analysis following a strict hazard-based approach to known hazards and current injury patterns. Risk assessments should be conducted by trained and experienced playground designer/manufacturers that look at not just the intended design use but reasonably foreseeable misuse. We soon will have a set of ISO TC 83 terms and definitions that will have been accepted by the international community. Many international standards organizations contributed to the development of this list and definitions, and I hope to be able to release this list once approved.

These terms will help guide the risk assessment process used by the designer, manufacturer, and prospective buyer of public consumer products developed for use by children under the age of 14. Play equipment is just one of these products. I hope these terms will be used by those involved in conducting safety compliance inspections of public playground equipment areas and organizations responsible for the creation of playground safety standards and guidelines.

The one missing link in reducing serious injuries on playgrounds might just be the impact, or lack thereof, ASTM F1292 Standard has had on the reduction of the frequency of fall-related injuries. ASTM F15.29 follows ASTM F8.63 Subcommittee’s ASTM F1292 Standard as created and modified by this Subcommittee. This Subcommittee must be an integral partner in the future plan of action between ASTM and CPSC. Leaving out the impact attenuating playground surfacing requirements in future discussions will more than likely result in no meaningful reduction in serious injuries. The challenge is for all involved to come to some agreement on what the surfacing impact attenuating thresholds used in the ASTM F1292 standards should be. We need to understand what this outcome will be with some level of assurance that predictable falls from play equipment to the surface will provide enough energy absorption to address some predetermined level of injury likely to occur from the play equipment’s fall height.

Step 3 will cover the type and severity of injury we can likely expect when falls occur to surface systems currently compliant with the ASTM F1292 Standard and how this relates to the level of injury ASTM F1487 performance requirements are attempting to address.

Step 3: The Path of Action Must be Based on Universal Terms and Definitions to Reasonably Reduce Playground Injuries?

Two months ago I ended my column with the following statement: “Assuming the ISO TC 83 terminology paper 'Injury and Safety Definitions and Thresholds' is approved and published, I will discuss the definitions for different types of injuries and break down each type into various levels of severity.” As of the end of 2013, the document has not been voted on. It is out for a vote and appears to be moving forward towards approval, based upon comments from various international voting members. I will proceed with my thoughts on terms and definitions within this document and how they may impact international standards for child injury prevention. My comments will be directed primarily towards fall-related injuries and our current international impact attenuating surface standards.

I hope to put into perspective how playground-related injuries and the different levels of injury severity relate to a currently compliant playground surface system. This is not going to be easy but I am going to give it a shot. If nothing else, I hope to advance the discussion and provide some issues and facts to better understand the current standards for evaluating surface systems. This part is easy. The more difficult concept to explain, understand, and accept is, “Does the scope of ASTM F1292 standard for playground surface systems adequately address the scope of the standard as well as ASTM F1487?”

The answer to this question depends on whether the current and widely accepted impact attenuation thresholds adequately address the severity of injuries international playground standard’s performance safety requirements are attempting to address.

Let’s begin by defining an “injury,” and more importantly let’s understand the various levels of injury severity we are most concerned with and/or willing to address in our international playground-related standards. We do not want a child to suffer a serious injury, but what is a serious injury? It is easier to define than to accept when it is your child or grandchild on the receiving end of the pain and suffering.

Recently I read a statement by Jay Beckwith, an old friend and playground industry colleague, who regularly contributes to this newsletter. He said something so very simple, yet profound. Jay, I apologize in advance for not being able to repeat your exact words. Your point was that a child must fall in order to learn. This statement rings true and is so basic to human development. Look back at your own childhood. That may be difficult since we have little memory of our most early and formative year,s but we can all look back at things our own children, grandchildren, or even someone else’s children experienced early in life. How many stitches did you get as a child? Did you break an arm or leg? How many times did you say or hear from your spouse, “Should we take him to the hospital, is it broken?”

The research supports the child development benefits of free play coupled with Jay Beckwith’s comment on how we learn from our mistakes, which allows us all to become all we can be. Unfortunately, but understandably, sometimes someone gets hurt. We all seem to know and willingly accept this fact. If true, then the issue should come down to what level of injury we are willing to accept? In reality, there will always be some obscure injury where a child is seriously hurt beyond what society seems willing to accept. Thank goodness these types of injuries are exceptions rather than the rule. So when does the frequency and severity of these types of injury warrant action from a government agency or industry standards organizations?

I do not believe this question has been adequately and fairly addressed by the special interests at the extreme ends of either point of view. The current practice lacks a collective consensus taking into consideration a balance between the user safety benefits and the developmental benefits of increasing challenging and risky play opportunities or the cost of and the removal of hazards. The benefits from challenge and risk have been well documented throughout the world, yet nobody can seem to articulate an acceptable reference point where the risk and statistical probability of serious injury outweigh the developmental benefits of the challenge. I think we can agree that learning to be self-reliant and personally accountable for our own actions are important and necessary life lessons yet we cannot seem to accept the consequences of our actions.

Just as we have varying degrees of challenge in play events, we have varying degrees of injuries. A scraped knee or cut finger is a minor injury. A laceration requiring stitches is more severe, but amputation of a toe or finger from a sharp edge or crush hazard is both serious and debilitating and probably beyond what society is willing to accept. Unsupervised, children may make poor choices which contribute to their injury. Maybe at some developmental age of reason, they too should be held partially responsible for their own actions. Many injuries occur when inexperienced and unsupervised children play on equipment not intended for their developmental readiness. In this instance maybe someone other than the owner/operator or manufacturer has contributed to these injuries and should be held accountable for actions and outcomes beyond what a reasonable man would consider reasonably foreseeable misuse. Is this fairer to all concerned?

Some equipment designs may be considered to be inappropriate for the generally unsupervised and unsecured public setting yet we already have stated the importance and benefits of challenge and risk-taking. Many experts lament the lack of challenging play opportunities in public play areas. Providing graduated challenge in the play environment seems to be a reasonable approach for public playground designers, but how does the child know what challenge is appropriate for their use? Either the child does their own risk assessment prior to attempting a new challenging piece of play equipment or the parent does this assessment for their child and manages the situation.

Does the parent/caregiver always exercise good judgment? Some caregivers fail in the supervision of those under their care, which can result in serious injuries. Some international communities hold parents and caregivers legally accountable for their child’s injuries since they should not always be held accountable for their behavior. Children are just being children. In this instance elected policymakers have determined what is best for the common good and place the blame on the parent, not the child or the owner of the playground.

How and where society-at-large seems to place blame and accountability are issues that the legislative branches of government and the legal system need to seriously consider. Some fair and equitable solution is needed that addresses these concerns or we may lose free play opportunities as some units of government who provide these facilities take the quick and easiest solution available. Unfortunately, this choice is to avoid these potential loss exposures by removing these play facilities.

There are so many things at play here that when considering all the variables the task appears unmanageable. Avoidance is not the answer to the problem; it is another type of problem of kicking the can down the road thereby leaving everyone in the lurch who deserve a better outcome.

We continue to talk around all these variables from our differing points of view, but when it comes to balancing risk and challenge with user safety, nobody has come up with a workable solution to the question. There are many special interest groups weighing in on the subject, but thus far there has been a lot of finger-pointing and we do not appear to be any closer to a workable solution.

I would suggest the following as a possible solution. We could start by doing a better job of creating industry play area and equipment standards that meet the objectives of injury reduction if and when we define an acceptable and measurable level of injury outside of the occasional freakish incident. In order to accomplish this we need to agree on and define the injuries we will accept and which injuries we wish to reduce or eliminate. We may never eliminate all serious injuries, but we might be able to put measures in place to mitigate most of these injuries. We can do a better job of parent education and public awareness and then we must work towards holding parents/caregivers more responsibility for their own actions or inactions.

Many have criticized the various safety standards organizations for dumbing down our playgrounds or for reducing the number of play opportunities throughout the country. I disagree with this broad a general statement. ASTM F1487 is a performance-based standard but in some ways, it has become a bit design restrictive.

That being said, the ASTM F1487 standard and the US CPSC Handbook have contributed a lot to almost totally eliminating deaths and serious injuries related to head entrapment hazards. CPSC recalled heavy metal animal swings and glider style swings because of the number of deaths and serious impact injuries. These types of impact hazards have also disappeared as a result of this legislative call for removal. No one would argue the reduction or elimination of these types of injuries are not directly attributable to the 1991 CPSC Handbook and 1993 ASTM F1487 standard recommendations and no one would say these results are not a good thing.

The results of implementing these standards and guideline recommendations were not, for the most part, legislated through government action. These documents were disseminated to the public and those owner/operators of public playgrounds as voluntary consumer recommendations for best industry practice. The results of these recommendations are undeniable and yet, for the most part, unrecognized by the general public and most government officials. There is still much work to be done if we can trust the current injury statistics. The real question is how far should we go with this effort of voluntary or even mandatory safety performance requirements when we look at all the leading causes of serious injury and death?

I will not go any further in this column trying to explain where I think we should go and how we might get there. I do not wish to jump the gun so to speak with embracing any further direction until we can agree on some more terminology to define our approach to the problem and better define our mission as it relates to performance-based safety recommendations that still embrace the importance of risk-taking and increasing graduated challenging play opportunities. Some reasonable balance must be struck between these two equally important opposing points of view. I will continue my discussion on this subject next month.

Until next month, play safe but play. I plan on playing a bit with my playful friends this week at the US Play Coalition Conference on the campus of Clemson University. I hope to have many things to share with you after the conference. The spring looks very busy and full of many play-related education and training activities.

Immediately following the conference I will be presenting a second Playground Maintenance Technician Course sponsored by Clemson University and Gwinnett County Georgia Park and Recreation District. If things keep up as they have weather-wise, we all might be able to build snowmen or have a snowball fight. This could make for some great pictures.

March will include another trip to Malaysia to conduct the Certified Playground Safety Inspector Course and the Playground Maintenance Technician Course as they continue to work towards creating and implementing a playground safety policy for their country. They have created such a policy and requirements, and I look forward to learning more about the details and how they intend to implement their plan during my visit.

On a final note, I would like to congratulate the two CPSI classes I had the privilege of teaching earlier this year in Hong Kong and Singapore. Hong Kong had their best pass rate at 80% and Singapore likewise had their best results at 70%. I can tell you government employees and playground industry representatives from around the world take their responsibility for children’s safety seriously.

We all do our best, as best we can. Keep up the good work.

The Path of Action Must be Based on Universal Terms and Definitions to Reasonably Reduce Playground Injuries.

The document I mentioned in the previous step, “Assuming the ISO TC 83 terminology paper 'Injury and Safety Definitions and Thresholds'"  has been approved by the International Organization for Standards Technical Committee ISO/TC 83 for Sports and other recreational facilities and equipment, Subcommittee. I believe it is at their editor for printing where it will be given some sort of identification number similar to what ASTM does. I will share my thoughts on some of the terms and definitions within this document. I will try to relate how they may impact international standards related to child injury prevention in the future. My comments will primarily focus on fall-related injuries and their relationship to the current international playground industry impact attenuating surface standards.

I begin with my perspective on how playground-related injuries, and the different levels of injury severity, relate to currently compliant playground surface systems. The question which needs to be answered is, “Do the current fall impact thresholds within these standards address the level of injury, specifically life-threatening and debilitating, these international performance standards (ASTM F1487, ASTM F1292, EN1176, EN1177, CSA Z614) and the CPSC Handbook recommendations are attempting to address?” Each standard introduction and scope defines the objective of injury reduction while each one continues to admit there will continue to be many injuries sustained by children at play. Play environments are not, and 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. We must find the balance between safety versus risk versus hazard.

Some of these terms have been used synonymously and maybe after reading this article you may change your mind on a few things. Let us first define an “injury,” but more importantly define the levels of injury severity we are most concerned with and want to address in our international playground-related standards. Nobody wants a child to suffer a serious injury. What is a serious injury? It is easier to define than to accept when it is your child or grandchild on the receiving end of the pain and suffering.

Based on the new ISO TC 83 document, the terminology used to separate the severity of injury classes are defined as follows:

“Life-Threatening Injury: an injury to any part of the human body which are serious or resulting in permanent impairment, that would be categorized as AIS (abbreviated injury scale) of 4 (severe with survival probable) or greater.

Debilitating Injury: an injury that diminishes or weakens the human body and has a legacy of greater than 1 month and that could be categorized as AIS (abbreviated injury scale) of 3 (serious, but not life-threatening). Note; debilitating injuries would include requiring surgery, concussions that require removal from play to medical attention.

Serious Injury: an acute physical injury requiring medical or surgical treatment or under the supervision of a qualified doctor or nurse, provided in a hospital or clinic and includes injuries such as burns, fractures, lacerations, internal injury, injury to an organ, concussion, internal bleeding, etc.”

While these definitions may give us some frame of reference, we still need more information to help guide the layperson and the medical profession. What does “removal from play to medical attention” mean? What constitutes “medical attention?” Are we talking about a physician or a school nurse? Both have a level of medical training. When we mention fractures under serious injuries, are we talking about any fracture or one that requires reduction through surgery?

You will notice the categories, “life-threatening injury” and “debilitating injury” as it relates to the Abbreviated Injury Scale (AIS). The AIS system is a medical diagnostic and prognosis system. I foresee issues with the definition of serious injury and how it relates to the AIS. Additionally, there is some confusion between minor and moderate injuries AIS 1 and 2 and how the level of AIS defines the level of severity of a burn (as an example). For burns, the medical profession considers a 2nd and 3rd-degree burn and then factors in the body part and the percentage of the body or part that is impacted. I see some subjectivity involved here, but the medical training of the evaluator should address my concerns.

This scale originated in the automotive industry, where the current surfacing thresholds come from, and has become recognized within the international medical profession and should serve us well as we move forward with the debate on what level of injury society is willing to accept. The risk of a fatality for each AIS is minor 0%, moderate 0.5%, serious 2.1%, severe 10.6%, critical 58.4%.  This AIS diagnostic and prognosis system is defined as follows:

“The writing of standards and the elimination of hazards must have an evaluation system based on injuries. To this end, a universal injury evaluation system both for injury reporting and scoping in standards will benefit all involved. The risk evaluation is based on scoring systems, which may vary by country. It may be considered whether those tools should be part of the Standards written by ISO TC 83. This threshold for injury would be acceptable in the scoping of national standards to ensure universality for the elimination of hazards and risk evaluation. They may be mentioned in an informative annex or listed as a reference.

Medical Thresholds and Diagnostic Tools

Abbreviated Injury Scale (AIS):

A numerical rating for quantifying the severity of injury to a human based on the body region, anatomic structure, level of injury and injury severity that must be used in the scope of standards intended for safety or injury prevention. The range of severity is from 1-9.

Injury Severity Abbreviated	Injury Score
Minor injury	1
Moderate injury	2
Serious, but not life-threatening	3
Severe Potentially life-threatening, but survival likely	4
Critical with uncertain survival	5
Un-survivable injury (maximum possible)	6
Severity unknown	9

The AIS system also considers

• different parts of the body
  1 head, 2 face, 3 neck, 4 thorax, 5 abdomen, 6 spine, 7 upper extremities, 8 lower extremities, 9 unspecified

• the type of anatomic structure
  1 whole area, 2 vessels, 3 nerves, 4 organs [including muscles and ligaments], 5 skeletal [including joints], 6 loss of consciousness - head only - or the entire body

Summary:

Injury Prevention Thresholds for Scope of Standards

The scope of TC/83 calls for both product safety and promotion of trade and to this end, the user of the products in the standards should be able to rely on credible standards to ensure them that claims of compliance to a standard will effectively protect them from hazards and harm within the context of acceptable risk. The scopes of standards must clearly state the harm and risk to which the consumer and user of a product is exposed.

The provision of definitions and thresholds are only valuable if they are used in the development of standards and used, particularly in the scope of standards intended to prevent injury. The prevention statement of the scope shall assist the manufacturers, test houses and legislators in understanding the intent of the standards writers and specify the limitations related to prevention of injury.

The definitions and a carefully defined scope must by extension focus the standards writers in their deliberations and development of those performance standards.

It must be noted that using thresholds, terms and definitions is not intended to reduce the challenge or enjoyment of a sport or recreation activity, but to raise the awareness of the need to accept the risk, while working to avoid and limit risks in the context of reasonably foreseeable misuse.

This has and will continue to be a collaborative effort and should assist the sub-committees under ISO TC/83 and hopefully National and European Standard Bodies with similar scope as of ISO TC/83 to consider the need to harmonize terms and standards to assist ISO TC/83 in promoting international trade within the context of injury and risk prevention.”

Designers, manufacturers, owners, and operators should not be in the business of eliminating risk but rather managing elimination of hazards and injury prevention to allow children to be children. There will always be some residual risk of harm in anything a child is doing within their immediate environment as they undertake the graduated challenge opportunities within the play environment.

How does this impact ASTM F1487 and ASTM F1292 standards now and in the future?

I am responsible for facilitating the discussion which determines the direction and content of ASTM F1487. I am also a voting member of the ASTM F1292 standard. F1487 requires compliance with ASTM F1292. The international standards industry has been using the maximum impact attenuating threshold of 1000 HIC (Head Injury Criteria) as the gold standard for a compliant playground surface system. Previously, I have discussed what this threshold means in terms of AIS in my previous column. Also, I have discussed what our standard scoping statements suggest we shall address. I am starting to believe that 1000 HIC does not address the level of injury we profess to address in our standard.  We may be addressing the level of injury with regards to equipment performance, but the surfacing within our use zones is probably missing the mark as the scope or the CPSIA are currently worded. It is time to say what we mean and mean what we say.

The obstacles to meeting our current scoping statements 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 standards 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, which includes risk analysis and evaluation, has been conducted by the designer, manufacturer, and owner and reasonable risk reduction or protective measures have been taken based on the intended use and reasonably foreseeable misuse of the equipment.

I believe we can make progress in providing more graduated challenge 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. 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 for our children, the intended users, which they need and deserve. I will continue to work towards a solution and I urge everyone to get involved. You all have a dog in the hunt.

I leave you with this question. Can you define what tolerable or acceptable risk, or to put it another way injury threshold, is when it comes to your child? Are you willing to accept a child’s accident resulting in a mild concussion or even momentary unconsciousness? Are you willing to accept a leg or arm fracture? If your answer is yes, are you also willing to accept the same consequences if the accident involves your child?

NOTE: You may have noticed some of the words were bolded. These words are just some of the terms defined in this new ISO Document.