The recent visit to San Francisco/Berkeley gave me the opportunity to meet with like-minded and partially-like-minded people. One issue in particular kept coming up and that is the way people felt hemmed in by standards, regulations, and notionally non-mandatory guidelines that in practice were treated as formal requirements .
This disaffection was not restricted to those responsible for play provision, but was felt more widely. If I had to sum up the general feeling as I encountered it, it is this: that in the USA the tendency was to over-prescribe the detail of what may or may not be done in too many areas of endeavour. The paradoxical effect of this is to undermine the capacity of duty holders (I use the term loosely here to identify all those who have a formal role in decision-making, whether as professional or volunteer) to make informed judgments in the light of their ‘reading’ of the always particular, changing, situation-specific circumstances that they confront. Instead of being able to exercise judgment, the pressure was to act as mechanicals, to follow a sort of universal script deemed to be suitable for all occasions. In an odd, paradoxical sort of way, the scripts – standards, regulations, guidelines – seemingly written to enhance best possible action and outcome in the real world, end up being other-worldly, conjuring the fiction that messy reality can be engineered into a pre-formed, one-size-fits-all template.
This is not to say that standards, regulations and guidelines do not have a role to fulfil, that they cannot be helpful. But their potential helpfulness is predicated on them inhabiting only the territory and terrain to which they are suited. Too often, standards, regulations, and guidelines have been allowed to colonise those areas where individual judgment should hold sway. Judgment works outwards from general principles and values, not from the attempted precision of rules.
More on this anon. For the moment, I want simply to summarise points about play equipment standards and play equipment inspections that I have made elsewhere and more extensively, and which happily coincide with Tim Gill’s current blog on play equipment standards. That there is coincidence of view will be of no surprise to regular readers. It’s worth adding here we are both members, with Professor David Ball and Harry Harbottle, of the York Group that is looking more closely at the questions raised here. What follows applies as much to the UK as it does to the USA.
Thus, in summary, a critique of play equipment standards as currently formulated is based on the following:
- standards are designed to facilitate domestic and international trade – the motivating force is to create open markets not creating best possible play opportunities
- the manner of their making is flawed – play equipment standard-making bodies are dominated by equipment manufacturers
- the actual standards agreed in any particular case can be the result of horse trading on what is best for a particular manufacturer or jurisdiction, not an assessment of what might be ‘best’ in terms of play
- standards arise out of an engineering-cum-technical ‘world view’ rather than a psycho-social ‘world view’ which is more able to consider and address the ‘whole’ person
- the ‘evidence’ upon which at least some of the standards are said to be based is, at the very least, open to question, not least in its applicability to real-time, infinitely variable, actual behaviour of children and teenagers at play
- standards as currently formulated ‘trespass’ into territory that is beyond their field of competence. That is, they extend themselves beyond more or less objective matters – e.g. tensile weight of a platform – to stipulations that seek to limit or govern the infinitely variable behaviour of actual playground users: matters that should be for locally sensitive, experienced-based decision-making
- adherence to standards is seen – and at the very least is implicitly represented – as being the same as addressing the wider, value-based question of what constitutes an ‘acceptable level of risk’, or what might constitute in any particular case ‘beneficial risk-taking’. Play equipment standards cannot stand proxy for these type of judgments
- inspection regimes reinforce and extend the failings of the standards.
To reiterate: nothing said here suggests standards do not have a role to play if properly formulated. Nor is anything said here a critique of play equipment as such. There’s good and bad equipment, as with any other product. In addition, various discussions I have had indicate there are equipment designers eager to be more creative once released from the shackles of inappropriate standards.
It has been said that the combined weight of public opinion, judicial opinion, insurance opinion, and timorous public authorities militates against even the possibility of having a far-reaching discussion about standards. I cannot accept this. If there is validity in the arguments, if they are worthy of concern and therefore debate, the journey towards change needs to be undertaken no matter how difficult the initial steps may be. In other words, there are questions here about what constitutes public benefit and how it is to be determined. I have a bash at addressing those questions in an essay on ‘structural imbalance’.
I sense that the sort of points raised here and elsewhere have salience for quite a large constituency, one that has yet to recognise itself as such, that at present is muted. It needs to find its own voice. This should be read as an invitation.