Know the Standards for Playgrounds

The word SAFETY is used 27 times in this article not because we believe everything is SAFE but because the protection of our children from harm is paramount to our culture and personal belief system. We must be conscious of the use of the word SAFETY not as an absolute but as a worthy objective or concept that we as humans try to aspire to but cannot attain absolutely. SAFETY became the buzzword of the 1980s during the liability insurance crisis. The premise that ‘children must be kept safe’ got the attention of policymakers and public agency managers across the county. Using the word SAFETY provided funding for public works projects to attempt to mitigate the cost of litigation during the insurance crisis of the 1980s. It worked as evidence of the use of the word SAFETY in almost any performance standard or guideline created after 1980.

I think we can agree that nothing can truly be 100% SAFE. We can make specific performance requirements for environments that all people, especially young children are the ones most at risk of harm in just about everything they will come in contact with in their everyday lives. The risk of harm to just about any person, regardless of age, is part of the everyday life experience. Understanding the risk and harm is a requirement for all of us if we are going to be able to exist in the world around us. I can appreciate the word SAFE or SAFETY and what it implies as an objective in designing and maintaining public places we need and desire, especially those for our children.

Unfortunately, we cannot protect everyone from their own unreasonable actions. We can warn people of possible or probable consequences. We can warn them about the level of severity of the consequences of not heading the warning. We can mitigate unreasonable consequences when known in advance, but we cannot guarantee one’s safety 100% of the time. We must remember children are not employees in a factory under the scrutiny of OSHA requirements. We as adults should understand this yet many take for granted the safety of their children as an absolute.

The playground is indeed a child’s workplace to learn and practice life’s lessons. There through practice and repetition, they will develop their own set of risk assessment skills they will come to rely on as they go through life. We have all experienced this in our own personal development. We did not learn to walk without falling, again and again. Eventually most will learn to run, some better than others, however, nobody has ever gone through life without suffering some level of harm whether walking or running through life. We must stop blaming every bit of harm we experience on someone else. We must accept that with everyday life comes the risk of harm. Our job as public servants is to try and minimize unreasonable risk of harm by doing our jobs and mitigating hazardous conditions as best we can. For the kids’ sake. The remainder of this article is an update to a previous article that appeared in this magazine as it attempted to update the reader on the advances in public playground-related standards.

Know the Scope of the Performance-Related Standards for Playgrounds 

School recess or arranging a play date at your neighborhood park is not just about turning children loose on a playground—the playground rules, regulations, and standards of today reach far beyond teaching children to play well with others, tending to scrape knees, or putting an ice pack on a bump on the head.

There are voluntary standards for the design, installation, maintenance, and inspection of playgrounds to help ensure that children have as safe a play experience as possible when they go out to the playground to have fun.

California, for instance, was the first state to legislatively mandate new playgrounds be inspected by a Certified Playground Safety Inspector (CPSI), trained by the National Recreation and Park Association (NRPA) in the early 2000s. This legislation was considered by many to be another unfunded mandate. This legislation provided no funding necessary to make the repairs discovered through inspections that were necessary to bring these playgrounds back into compliance with the current requirements. The initial unintended consequences of this legislation resulted in removing existing play opportunities in communities with limited resources. Today, other States may be on the way to this type of legislation but only time will tell. 

We have learned over decades of injury studies conducted by the Consumer Product Safety Commission’s (CPSC) National Electronic Surveillance System (NEISS) that the frequency and severity of injuries continue to occur at the same annual levels. Nobody has been able to explain why with all the playground standards and guideline development efforts that have been put forth over the past 50 years to reduce both the frequency and severity of injuries, there has been no noticeable reduction in these injury statistics. On the bright side of injury prevention these standards have mitigated many of the causes of the most serious playground injuries and some eliminated altogether. The one factor contributing to injuries that we cannot seem to be able to address is what happens when a child sees a new challenge to conquer. Children will continue to take on almost any challenge along with all the risks or personal harm that come with it just for the fun of it. Unfortunately, when a child takes on an unreasonable risk they have yet to successfully experience and therefore cannot yet appreciate bad things can happen. Many children without the necessary cognitive or physical capability to enable them to manage the challenge will suffer the consequences. 

This is where the finger-pointing and blame game begins along with the legal process of finding the guilty party or parties to the proximate cause of the child’s injuries. At this point, everyone involved with the incident in any way is going to be named as a potential contributing factor to the plaintiff’s injury. Everyone will be named except for the injured child or those responsible for the child’s supervisor and well-being. 

Manufacturers, installers, inspectors, and playground buyers share a common goal when it comes to the developmental benefits of playgrounds and children at play. With that in mind, manufacturers spend a great deal of time designing great play structures that are challenging and fun, as well as being as safe as necessary to prevent most injuries.

The standards and best practices for playground installation and maintenance have been composed by the Consumer Product Safety Commission (CPSC) and the American Society for Testing and Materials International (ASTM). This information is taught in the Certified Playground Safety Inspectors (CPSI) course. 

ASTM International is one of the largest voluntary standards development organizations in the world and is a credible source for technical standards for materials, products, systems, and services. It plays an important part in the infrastructure for information-guiding design, trade, and manufacturing in the global economy, as it is known for high technical quality and relevancy in a specific market. The ASTM has set forth standards for performance requirements of equipment and surfacing, structure installation, and maintenance. These standards are revisited periodically, and changes are made as needed. Committees for writing these standards meet regularly to discuss current standards. The NRPA’s CPSI course is regularly updated with these new standards as this information is published thereby keeping the course on the cutting edge of best industry practices and performance standards.

The ASTM accepts any new committee members once they join by paying their annual dues. To become involved with one of these committees, log on to www.astm.org for more information. 

More ASTM standards public related to playgrounds 

• F355-16e1 Standard Test Method for Impact Attenuation of Playing Surface Systems, Other Protective Sport Systems, and Materials Used for Athletics, Recreation, and Play.

  This test method measures the impact attenuation of surface systems and materials, specifically the peak impact acceleration (“impact’ shock”) produced under prescribed impact conditions. This test method is applicable to natural and artificial surface systems intended to provide impact attenuation, including natural and artificial sports fields.

• F1487-21 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use.

  This specification provides the users with the minimum performance requirements that pertain to all playground equipment for public use as well as specific types of equipment performance requirements that pertain to the equipment and its related 3-dimensional space above and adjacent to the equipment including the use zone under and around the equipment that must provide a minimum amount of surface impact attenuation to minimize the likelihood of a serious head injury from a fall.

• F2373-11 (reauthorized 2017) Standard Consumer Safety Performance Specification for Public Use Play Equipment for Children 6 Months through 23 Months.

  This consumer safety performance specification provides safety and performance requirements for various types of public use play equipment such as, but not limited to, composite play structures, climbing structures, to-fro swings, spring rocking equipment, and slides.

• F1292-18e Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment. (Laboratory 3- Temperature Test to Determine its Critical Height Rating that is related to a not to exceed 200 Gmax and/or 1000 HIC impact threshold)

  This specification establishes minimum performance requirements for the impact attenuation of playground surfacing materials installed within the use zones of playground equipment. The test is performed in a laboratory that can condition the surfacing samples that must be drop tested at 3-temparatures (25-, 72-, and 120-degree Fahrenheit) A surface that passes this specification is determined to not likely cause a serious head injury. It does not address the likelihood of bone fractures which can occur at far less of an impact.

• F3351-19e1 Standard Test Method for Playground Surface Impact Testing in Laboratory at Specified Test Height. (This laboratory 3-Temperature test determines and certifies the surface shock absorption properties at a Specified Height above the surface that evaluates the surface based on their Gmax and HIC values described in Specification ASTM F1292.)

  This test method covers all playground surfaces to be tested in a laboratory setting at a specified drop height established by the manufacturer of the playground surface to determine shock absorption properties at the specified height above the surface and to assist all involved in selecting an appropriate protective surface system to evaluate various surfaces based on their Gmax and HIC values described in Specification F1292. The owner can specify prior to purchase a better performing surface by specifying a higher than the minimum required fall height of the equipment being installed along with a lower than the minimum required impact threshold of 200 Gmax and 1000 HIC.

• F3313-20 Standard Test Method for Determining Impact Attenuation of Playground Surfaces Within the Use Zone of Playground Equipment as Tested in the Field.

  This test method provides the only means of determining the impact attenuation performance of a playground surface on-site after installation in the field. It uses the same test method and equipment that simulates the impact of a child’s head on the playground surface. The results of this test method in the field can be compared to the results of the F1292 laboratory test along with the project surfacing purchasing contract requirements to assure the owner they are getting what they specified after installation.

• F2075-20 Standard Specification for Engineered Wood Fiber for Use as a Playground Safety Surface Under and Around Playground Equipment.

  This specification defines what Engineered Wood Fiber (EWF) is by establishing minimum requirements for the factors that determine particles size, consistency, purity, ability to drain, and heavy metal concentrations considered hazardous to children. If the owner purchases a product marketed as EWF it must be able to provide the owner with a certification certificate from a testing laboratory that indicates it complies with or exceeds the requirements of this standard and indicates the critical fall height rating for this material at various drop heights. If the manufacturer is claiming it meets the requirements of ASTM F1951 which measures the energy required to traverse the surface material as installed according to the manufacturer’s specifications. The same manufacturer installation requirements must be the same as for the laboratory test and any other in-the-field installation. The test results must show that the loose-fill wood material passes all the requirements of the F1951 laboratory test and F1292 before it can be called EWF. Any loose-fill wood product that is not in compliance with these standards is just wood landscaping mulch which may still have the necessary impact attenuation properties, but it is not as expensive as a fully compliant EWF Certified material.

• F2223-19a Standard Guide for ASTM Standards on Playground Surfacing.

  This standard guide covers standards for selecting and specifying surface systems for under and around playground equipment which must provide at a minimum enough impact absorption as required which should protect the user from experiencing a serious head injury resulting from a fall. This guide describes how to apply existing ASTM standards to evaluate the impact attenuation, accessibility characteristics, and product characteristics when selecting surfacing systems for use under and around playground equipment. There is no perfect surface system. Each has their positive and negative attributes. It is the responsibility of the owner or owner’s representative to select the best surface based on a number of factors including the project objectives and budget constraints. This guide should be used to assist the owner in developing purchasing specifications to ensure they have enough knowledge to understand what they are trying to buy and how best to specify the purchasing requirements.

• F2479-17 Standard Guide for Specification, Purchase, Installation, and Maintenance of Poured-In-Place Playground Surfacing.

  This guide is intended to assist the playground owner/operator, specification writer, designer, and other involved parties in determining the properties that can be considered regarding the poured-in-place (PIP) surface and set out considerations that the user of this guide should make to ensure a successful installation. This guide should not be used directly as a performance specification for poured-in-place synthetic materials system using some form of a chemical binder.

• F1918-21 Standard Safety Performance Specification for Soft-Contained Play Equipment.

  This safety performance specification provides safety and performance requirements for soft contained play equipment (SCPE.) Its purpose is to reduce the potential for life-threatening and debilitating injuries. This equipment is usually located indoors but many exist in outdoor locations. It is most easily described as a play area where the users are contained within a structure rather than a more traditional play area where the users are climbing about the outside of the equipment and falling out away from the equipment instead of falling within the equipment itself.

• F1951-21 Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment.

  This specification establishes minimum characteristics for those factors that determine the level of accessibility by measuring the energy a user would expend to traverse the playground surface as compared to the energy a user would expend going up an 8% ramp. If the energy to traverse a specified distance along the playground surface system following the test procedure protocol does not exceed the energy expended to go up the 8% ramped surface of the same length, the surfacing passes the test. This specification applies to all types of materials that can be used under and around playground equipment.

• F1816 Standard Safety Specification for Drawstrings on Children’s Upper Outerwear.

  This specification addresses the entanglement and strangulation hazard clothing drawstrings pose to young children. Strangulation caused primarily from secondary factors such as items worn around or on a child’s head and neck remain the number one cause of death on playgrounds.

• F2049-11r17 Standard Guide for Fences/Barriers for Public, Commercial, and Multi-Family Residential Use Outdoor Play Areas.

  This specification provides the recommended minimum requirements for denoting various types of fences/barriers for the protection of children's outdoor play spaces in public, commercial, and multi-family residential use locations. This specification excludes individual single family residential use play equipment locations. Interior fences located in a play area that has a perimeter fence established shall only have to comply with the latch height requirement indicated in 7.6.2.

• F1148-22 Standard Consumer Safety Performance Specification for Home Playground Equipment.

  This consumer safety specification provides requirements for various types of home playground equipment intended for use by children aged from over 18-months through 10-years. It is intended to address all play equipment for use on private residential property and not considered for the public’s use. Often owner/operators of public access property have often purchased and installed this play equipment on Homeowner Association Properties, at Childcare facilities, and even public schools and park facilities intended for use by very young children. This equipment is commonly found in big box commercial stores or online for the use on residential property only but still get installed in public settings primarily because the owner is not aware of these different standards. The public is an invitee in most of these instances and locations. Care should be taken to consult with proper authorities to determine what standard should be applied to which playground locations.

The First Government-Published Playground Safety Guideline in America

In the early 1970’s the CPSC was formed and in around 1974 the CPSC commissioned the National Recreation and Park Association (NRPA) to develop a national standard for public playgrounds. During the development of this draft standard, it was determined by all interested parties and the CPSC legal counsel that there was not enough rationale to support the draft national standard’s safety requirements. After much deliberation, it was determined that the information was still very useful and would be more appropriate to be put out to the public in the form or a Federal Government Guideline that would provide useful guidance to playground designers, manufacturers, childcare professionals various users groups and the general public-at-large. The Consumer Product Safety Commission was published in 1981. Their first handbook titled Public Playground Safety Handbook was published in two volumes, one for the consumer and the other for equipment designers/manufacturers. It was and is intended for use by childcare professionals, school officials, equipment buyers, park and recreational personnel, playground designers, and any other public members including parents and school groups. It was written for those child safety advocates concerned with the number of public playground injuries and those interested in evaluating the current condition of playgrounds.
The guidelines in this handbook were also written to help promote greater awareness among those who purchase, install, and maintain public playground equipment.

Venues addressed by these guidelines include:

• Commercial (non-residential) childcare facilities
• Institutions
• Multiple-family dwellings, such as apartments and condominiums buildings
• Parks, such as city, state, and community-maintained parks
• Restaurants
• Resorts and recreational developments
• Schools
• Other areas of public use

To give you an idea of how often changes have been made to the CPSC Public Playground Safety Handbook, here is an account taken from cpsc.gov.

• 1981 The first CPSC Handbook for Public Playground Safety was published, a two-volume set.
• 1991 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment, ASTM F1292, was first published.
• 1991 Two-volume set was replaced by a single-volume handbook, which contained recommendations based on a COMSIS Corporation report to the CPSC (Development of Human Factors Criteria for Playground Equipment Safety).
• 1993 The first version of the voluntary standard for public playground equipment, ASTM F1487 —Standard Consumer Safety Performance Specification for Playground Equipment for Public Use, was published (revisions or reauthorization must occur at least every 5 to 7 years).
• 1994 Minor revisions to the Handbook.
• 1997 Handbook was updated based on (1) staff review of ASTM F1487, (2) playground safety roundtable meeting held October 1996, and (3) public comment received and by a May 1997 CPSC staff request.
• 2005 The first version of the voluntary standard for playground equipment intended for children under two years old, ASTM F2373 — Standard Consumer Safety Performance Specification for Public Use Play Equipment for Children 6 Months Through 23 Months, was published.
• 2008 A Draft revised CPSC Handbook was distributed and ultimately withdrawn based on comments received from members of the ASTM F15.29 subcommittee. This draft was never approved by the CPSC Commission.
• 2010 The CPSC Handbook revision was approved by the Commission and published with many changes including the addition of toddler recommendations for children 6 months through 23 months. 

Various Playground Committees, in response to a CPSC staff request, submitted suggested revisions. Many of these suggested revisions were included in the 2010 Handbook revision. These 2010 CPSC Handbook changes include:

Equipment guidelines

• Age ranges expanded to include toddlers (children as young as 6 months through 2 years based on ASTM F2373.
• Some additional guidelines for various types of equipment were added mostly to harmonize as much as they could with the industry voluntary consensus standard ASTM F1487.
• Exit zone requirements for slides harmonized with ASTM F1487 however there are still some Handbook clause recommendations which are not yet harmonized with the ASTM F1487 Standard causing some conflict with State Laws that require compliance with one or the other documents or both.

Surfacing guidelines

• Critical height table revised.
• Suggestions for how to install loose-fill surfacing over asphalt was added.

General guidelines

• Suggestions on sun exposure added.

Other revisions

• Editorial changes to make the Handbook easier to understand and use.

Updates Since 2021 Regarding the CPSC Handbook and ASTM Standards

A revised CPSC Handbook has been in the works for several years. The revised draft Handbook should be out for public comment in the fall of 2024. 

Almost every playground-related ASTM standard has been revised as indicated by the current revision dates previously illustrated in the last two numbers of the previous list of ASTM playground-related standards. These two numbers represent the year in which the revised standard was published. 

The ASTM F15.29 Subcommittee responsible for the F1487 standard has been hard at work making additions to the performance requirements affecting all playground equipment regardless of type and additions to specific equipment performance requirements just as was previously done in the last two 2017 and 2021 revisions to ASTM F1487. These changes are based on a hazard-based assessment approach to the many traditional types of equipment but rather than being tied to the older traditional prescriptive standard approach to developing standards, standards writers were always trying to catch up to the market’s expansion but falling behind in this challenge as change was constant at almost breakneck speed. Standards writing organizations were constantly having to address specific equipment issues or create more exceptions to the existing standards. Because standards organizations like ASTM were not able to keep pace with today’s designers and equipment manufacturers, something needed to change. Manufacturers and equipment designers were always bringing new exciting play opportunities to the marketplace. Play value and risky play became the catchphrases of the times. 

A hazard identification and risk assessment process (HIRA) has now become part of the answer to this situation. This process places the responsibility of standards compliance on the manufacturer/designer of the playground equipment. They are now required by Clause 1.6.1 to assess whether their design and equipment is compliant with the general requirements of the standard. Section 1 Scope, Clause 1.6.1 says specifically, “The requirements in this specification are designed to mitigate the hazards typically presented by various types of equipment. New equipment may not specifically fit into the designated types listed in the specification; however, the designer or manufacturer, or both, shall use professional judgment to perform and document a hazard analysis and follow appropriate requirements to mitigate the hazards.”

“NOTE 1—See Appendix X1 at the end of this F1487 standard to find more information on how one might conduct such an assessment as stated in this section.”

Then, in Section 5, Clause 5.1 it states, “Playground equipment represented as complying with this consumer safety performance specification shall meet all applicable requirements specified herein. Anyone representing compliance with this specification shall keep such essential records as are necessary to document any claim that the requirements with this specification have been met.” 

While this is not the end of the discussion on what is a good design or what is compliant with all aspects of the standard it is a new beginning towards assessing the benefits of risky play against some level of acceptable risk (tolerable risk) of the owner, designer, and/or manufacturer. What is your appetite for risk? Are you risk adverse? There will always be some form of residual risk in everything we do. What is yours? 

To help in determining what the benefits are derived through play versus the risk of harm within the play and sport environment there is a new ISO Standard recently developed by the ISO TC83 Committee on Sport and Recreational Facilities and Equipment. The standard number is ISO 4980:2023. This standard requires a benefit analysis along with a risk analysis. These two independent processes are then evaluated to see if there is an appropriate balance between the two assessment processes as outlined in the standard. This ISO Standard is a whole new level of applying a HIRA process that considers the benefits of the activity or equipment that may far outweigh the risk of harm once the foreseeable use of any activity has been analyzed and mitigated to an acceptable level.

The Solution to Reducing Serious Playground Related Injuries

Playground Operations Education and Training Opportunities

There are many training opportunities online or in-person for people interested or responsible for playground design, manufacturing, installation, inspection, maintenance, and repair. NRPA CPSI Courses along with their one-day playground maintenance courses that are taught throughout the country year-round. www.nrpa.org/CPSI 

The Indiana University’s Eppley Institute for Parks and Public Lands is managing a two-day Playground Maintenance Technician Certificate Course in-person or an or a self-directed cohort online version of the same course. For more information go to www.playgroundmaintenance.org. 

A person without the basic training and knowledge of the function of, and important relationship between, the playground equipment and protective surfacing under and around the equipment will not be able to perform a thorough assessment of the play environment. They need to become educated on the current best practices for managing these facilities in compliance with the current standards and guidelines.

Originally written by Shannon Stockwell in 2009, updated in 2024 by Ken Kutska, Executive Director, International Playground Safety Institute, LLC