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.
Rethinking Childhood 
Reblogged this on Old School Garden.
Tim, Excellent. It is of the first importance that Standards, and the detrimental affect they too often have on play provision, is the subject of debate. Not simply debate within ‘play’, but more widely in civil society. Certainly, in the UK as least, the ‘play world’ – not least the four national bodies – have to date not felt able to engage with this subject for whatever reason. (And for further comment at another time).
It is also imporatnt to know that, certainly for Europe, the USA (where I am about to speak on this very subject) and Canada a primary motivation for producing standards is the economic harmonisation of markets on an essentially free-trade agenda. Whatever the merits of Standardisation from a trade/economic perspective, this motivation confers no authority on the standard-makers to make public benefit judgments about, in this case, what is good for children, what constitues an ‘acceptable level of risk’ and so forth. I look forward to reading others’ comments on this subject.
Bernard – thanks for the comment, and the reminder that standards serve many roles, not all of them always aligned. Enjoy your stateside trip!
Alright, it is important to understand that “Standards” and or “Guidelines” in the USA and I presume every place else, are not building codes. They are not Law and are only voluntary accepted practices. As a Designer and Builder of my designs, it was ultimately up to me to decide what Guidelines I felt where correct and which I would deviate from for creative or disagreement reasons. In the end, I was the party responsible for what and how I constructed my designs. The Consumer Product Guidelines nor the ASTM Guidelines, or anyone on the committees that wrote these guidelines was not going to be legally responsible for my work, just me. Here is the problem with the Standards and Guidelines as they stand today; they were mostly written by Manufactures that design with computer programs and manufacture with computer driven machines. Their computers do not understand or have the capacity to propose or manufacture platform steps like the ones in your example. If you truly wanted to write meaningful and affective Standards they will have to deal with much more in-depth issues of design, risk, intended use and miss-use. Today, any Designer could propose a playground structure that meets all the Standards and Guidelines written, to the letter and still be the most dangerous Play Structure ever built. As a Designer, the most important skill set one needs to develop is the ability to understand how children approach play and play opportunities, but most important of all, the ability to recognize all the alternative uses and potential opportunities for miss-use that they have created and evaluate the risk verses the rewards. Anymore, most injures do not have direct correlation to any Standards. They are directly associated with children attempting to utilize play opportunities and equipment beyond their intended function. It is every child’s God given talent and mind set, to find the flaw or oversight in every Designer’s or Computers creation and there is none more skilled at these task then children. Sorry, but passing the Test to be a Certified Safety Inspector by no means makes you a Qualified Safety Expert or Designer of Children’s Play equipment. As I said before,for any New Standards to have meaningful impact, someone needs to step up, with the courage/ experience and publish Design, Safety and Risk Standards that deal with issues far beyond structural stability, pinch points and head trap zones.
In designing, building and teaching the design and build of adventure playgrounds to playworkers, I have always emphasised the ability of the user to assess the risks of the play opportuities which are designed in.
In the case of staircases, if a thing looks like a staircase, it must behave like a staircase because the user will make an assumption based on their experience of staircases, without taking the time to assess the risks of not doing so.
The staircase pictured looks nothing like a staircase and so invites the user to approach it differently than they would the one at home/at school/in the shopping centre. That is where its ‘safety’ lies, not in its designed dimensions. If it did look like any staircase, then it would be wrong of it to have differences which one only found out about after one had missed one footing.
I have said before, on FreePlay network, that self build playgrounds say “we made this place to be like this so that it would not be like anywhere else” and that this is a permissional message to players. It is also a message which alters the way the structures will be approached and engaged with, so encouraging risk assessment by the user.
Perhaps the standards should be how much a piece of play equipment looks ordinary or like anywhere else…
If the boundaries of regulations / guidance / laws are subject to interpretation through establishing case-law, then to what extent should play equipment “rules” (which may appear foolish through bureaucracy), be open to interpretation by wise players … trusting the agency of children towards mastery of their own risk taking?
The access to the tower shown in the picture would not be classed as stairs; so they wouldn’t fail the clause of the standard that you mention. The main problem with standards is not what is contained within; its a lack of understanding and a lack of knowledge in their application; some of the comments we see from so-called inspection experts are frightening.
We have worked with numerous organisations developing exciting play areas over the years and we have used our knowledge of the standards to assist in making judgments on what should or shouldn’t be done; This doesn’t mean that designers have to be restricted in what they do, its more about removing any unnecessary hazards that do not offer any benefit to the user. For example…. what is the benefit in having finger entrapments between decks on a platform? This is something that can quite easily be designed out using our knowledge of the standards.and would not have any negative effect on the design, so why not ensure that they are designed out?
It is extremely important to remember that standards are a tool to be used, they are not the holy grail and people shouldn’t hide behind them. Maybe the real issue here is that people need to be educated in what the standards are how to use them? On numerous occasions we have noted very minor standards failures on our inspection reports, and based on risk assessment / risk benefit we have not recommended any remedial action is undertaken; only then to find that the operators still insist that changes have to be made!
Bob, Simon/panegyric Alyson and Jon – thanks for your comments. My responses here echo some of my contributions to the lively debate on this post in the LinkedIn ‘Playground Safety: Balancing Play Value & Injury Prevention’ group.
Simon, Alyson, needless to say I support your calls for greater recognition of children’s ability to manage risk, and for a more thoughtful response to this from designers and standard-setting agencies.
Jon – we can argue about whether my image shows steps or something else. But the bigger question – which you don’t answer – is why should the regularity of steps be a matter for standards? Why cannot the provider and designer make that decision themselves?
Bob – I am with you in thinking that standards bear a questionable relationship to real-life injury reduction. But I don’t think the answer is to make standards more extensive – in my book, playgrounds are safe enough places already (if not too safe). For me, what’s more important is to work out how standards can give more flexibility – for instance for designs aimed at children of different ages or in different contexts – and how they can give clearer messages about risk, and about their own legal status and application. After all, you and Jon and I may know they are not (in most countries) a legal requirement, but many people think they are. These are not marginal questions, they are central to figuring out the right role for standards and the territory they should cover.
Tim, I am not in favor of tougher Standards as they are written today but more meaningful/real use information. Jon, talked about how often times they find minor infractions that they do not evaluate as real problems or important safety issues worth correction and I agree. My concern is that the Standards focus on manufacturing and physiological issues not performance and risk realities. To truly evaluate a play structure or play environment for safety and acceptable risk factors it is necessary to possess and not be afraid to express, opinion based on understanding and experience. Most inspectors I have run across have no ability nor give any consideration to factors that are not covered by the Standards. This is not their fault, they only know what is covered by these Standards and are only required to deal with that information. The first question I would always ask clients that wanted me to perform a Safety inspection: “ Are you interested in whether your equipment / play area meets all safety and accessibility Guidelines or are you interested in whether you play area is Safe for children to use? “ It has always been my contention that the Standards or Guidelines are only a basic starting point and that even if followed to the letter does not guarantee safe outcomes. Too often I was called in, after the fact, to rectify safety issues that had nothing to do with the Standards or Guidelines. Someone needs to teach a class or provide information on the real life scenarios and how children approach and utilize play opportunities. Simple stuff, like; if you put that there they will be able to climb up on top of that, that works climbing up but how are they going to get down, the exit from that slide is going to cause traffic flow problems and collisions because it is in the major flow pattern, etc. etc. there are thousands of questions and possibilities, you can never anticipate all of them and really do not want to. Understanding and evaluating acceptable risk requires information and today we are not providing enough meaningful instruction. This should not be viewed as a limitation on design and creativity but rather an expansion of the possibilities and quality of the services provided. This is not something that should be left up to children.
Thanks for this Bob. I agree that standards need to be more meaningful, not tougher. I also agree that safety has little relationship to standards compliance. We also need to help clients/providers to be more clear, and feel more confident, about the value judgements that are being made around risk.
Pingback: American musings: Handbooks, Standards, and over-regulation | Bernard Spiegal
Pingback: The wobbly bridge, or why it is harder to manage risk in playgrounds than factories | Rethinking Childhood
Pingback: Standards, regulations, guidelines and the muted voice | Bernard Spiegal
Pingback: An open letter to ASTM, and to anyone who wants to see a thoughtful approach to playground safety | Rethinking Childhood