In my last post, I used the example of a wobbly bridge to highlight why it is hard to manage risk in play spaces. I promised to say more about the role of equipment standards in managing risk, and why they need to be rethought. This post delivers on that promise.
There are standards for many businesses, industries and product types, and they do a number of jobs. One job is to draw up criteria that aim to reduce the likelihood of injuries. So for instance, the British Standard for the positioning of lights on motorcycles presumably aims to ensure that lights are easily seen and thus help to reduce motorcycle accidents.
Safety is a good reason for having standards for playground equipment. After all, it is obvious that manufacturers should not make structures that are built with inadequate materials, or come up with designs that can crush fingers or are at risk of collapsing. The picture is that standards help to eliminate hazards or sources of harm. But not all aspects of standards fit with this picture.
Think again about that wobbly bridge. Here, the hazard – the wobbliness – is a benefit as well as a risk, and so not something we want to eliminate. Things get more complex once we recognise the value of risk.
But can’t standards take this ‘beneficial risk’ into account? So the relevant part of a standard can specify just how wobbly a bridge can be (to use the kind of non-technical language that no engineer would ever use).
This is in fact what many parts of play equipment standards do. They do not aim to eliminate all risks, remove all hazards, or achieve absolute safety. Rather, they give a view about where the balance lies between safety and other goals.
The central problem with standards is that they give a one-size-fits-all answer to that question about where the balance lies. They close down judgement and decision-making. To quote my sometime collaborator Bernard Spiegal from a post of his last September: “they trespass on, or colonise, areas where they have no right to be.”
Sometimes, one-size-fits-all is fine. For instance, a single standard for the weight-bearing capacity of a swing is a good idea. For your average swing, we would all want to be sure that no matter how light or heavy we are, it will support our weight.
However, standards cover many topics that would be better left open to judgement. After all, play spaces are – or should be – places that are shaped by all sorts of factors. Factors like the age and abilities of the children who use them, the nature and style of supervision, the goals they are designed to meet, their locality, and the attitudes of parents and of wider society.
Those outside the industry have little idea of how extensive playground standards are. The British Standards Institution (BSI) website lists 13 current documents on outdoor playground equipment and surfacing (the number has grown significantly over the years). One version of the current set, produced by the BSI’s German equivalent, runs to over 400 pages of dense text and diagrams. While some of this material is sound, and has a basis in objective fact, much is subjective, and open to question.
Here is an example of a part of a standard that is open to question (taken from a previous post of mine). Discussing the image below – of a structure in a public playground in Islington, London – I said:
Look at the steps leading to the raised platform. They are wonky, and unevenly spaced. As such, they are in direct contravention of British (in fact, European) play equipment standards. These state: “The inclination of stairs shall be constant […] The treads shall be spaced equally, shall be of uniform construction, and shall be horizontal within ± 3°.”
So far as I know, no child has had a serious accident on these wonky steps. I am told that the playground (presumably including these steps) has been inspected, and is deemed to be safe. If so, it raises the question: why is the European Standards committee drawing up rules about the inclination and spacing of steps?
This problem is made worse by the fact that all too often, standards are given a status that they do not have. They are seen not as one possible answer to the question “where does the balance lie?”, but as the only answer to that question. They are seen as a being the sole benchmark of good safety practice, and are treated as in effect a legal requirement, even though in most countries, they are not. When schools or councils ask themselves – or their lawyers or insurers – “how do we avoid getting sued if a child has an accident on our playground?” the near-universal reply is “make sure your equipment meets the standards.”
This can become a self-fulfilling prophecy. If everyone says that good playground safety practice is all about compliance, then failure to comply is seen as a sign of negligence by the courts, just as it is by everyone else.
Those involved in (thankfully rare) legal cases tell me that the courts do indeed set great store by standards compliance. In fact, compliance may not be enough: according to the Royal Society for the Prevention of Accidents, the standards themselves state: “compliance with a British Standard cannot confer immunity from legal obligations.”
None of this is to say that standards should be scrapped. I am not arguing here for the complete deregulation of playgrounds. To repeat my point above: some aspects of equipment design and construction need to be clearly specified, and manufacturers should be expected to meet these specifications. Furthermore, it may well be the case that the original introduction of standards led to a reduction in cowboy manufacturers and to the removal of equipment that was genuinely dangerous (though I would like to see hard evidence of this, rather than anecdotes and assertions).
Standards urgently need revisiting. They are not just technical documents, and not just a minor aspect of playground design. Their contents have a chilling effect on designers and providers, especially those who wish to move away from the ‘KFC’ (Kit, Fence, Carpet) design formula. My aim here is not to get rid of standards, but to kick-start some serious discussion about them.
Acknowledgement: as with my last post – and indeed much of my thinking on risk in play – I want to acknowledge the work of David Ball and Bernard Spiegal, co-authors with me of Managing Risk in Play Provision: Implementation Guide – and of Harry Harbottle, veteran of playground equipment standards committees. The views here are my own.