I need to alert readers to a real and present danger.
Before proceeding, however, I enter a plea. A plea that you stick with this article despite the fact that the subject may – until now – have been a turn-off. I say again: I am about to speak about a real and present danger.
The subject is play provision Standards, in this case a new Standard in respect of IAS (Impact Absorbing Surface) being proposed by ASTM’s (American Society for Testing and Materials) playground surfacing committee.
Do not imagine that any changes will affect only the USA. Eventually, the likelihood is that they will affect Standards across national boundaries.
Why a turn-off?
For those readers who want immediately to find out more about the detail and potential negative consequences of the proposed – and likely as not imminent – changes, skip the next eight paragraphs to get to more detail.
But I think it it useful before getting into detail to first say a few words as to why the subject of play equipment and surfacing Standards seem not to command the attention of those otherwise deeply concerned about, and often responsible for, children and teenagers’ play opportunities.
One possible reason for the ‘turn-off’ is that Standards are routinely presented as firmly located within the purview of ‘objective’ science, praying in aid ‘evidence-based’ data – a plethora of numbers attached to acronyms and abbreviations, seemingly impenetrable to ordinary folk. It all appears terribly, terribly technical and recondite. For experts only.
‘Evidence-based’ is the ground on which Standards formally stand. Yet, in their presentation to the wider world, an irony-laced twist occurs: the seemingly objective technical ‘facts of the matter’, now reified in a Standard, are promulgated as the irrefutable emanations of ‘common sense’ – beyond argument or counter-view. Yet, as in the case I speak of here, there can be substantial cause for doubt.
In fact, play equipment standards are shot through with barely acknowledged value-based assumptions through which the evidence – and what constitutes evidence here is a contested area – is weighed, shaped and filtered.
So far as Standard decision-making structures and processes are concerned, in practice they combine to form a quasi-private world, not easily susceptible to scrutiny or questioning by those daily working at play provision’s front line or, indeed, those concerned with national and local policy in respect of play. There is something distinctly biblical about the process of formulating Standards: it puts me in mind of Moses on Mount Sinai, out of sight to the multitudes below, cooking up with God the written ten commandments (and, lest you forget, 613 oral ones) and then delivering them to the not altogether enthusiastic People at mountain’s foot who nevertheless agree, perhaps in bemusement, to adhere to them.
Our responsibility too
Nevertheless, whilst there are legitimate grounds to question play equipment and surfacing Standards, along with the structures and processes that generate them, there must also be concern that those responsible for play provision – whether at the policy level or at the ‘front line’ – have largely failed to bring to the admittedly quasi-obscure world of Standard formulation, the values, insights and observation-based knowledge that animate the best of play provision. As suggested in our paper ‘Children’s Play Space and Safety Management: Rethinking the Role of Play Equipment Standards‘:
‘Play providers have in effect ceded their authority to make value-based decisions to forms of technical expertise….’
That quasi-obscurity, however, only identifies a difficulty, it cannot function as adequate excuse for absenting ourselves from debate, critique, or opposition to the current dispensations of Standard-making bodies.
The peer reviewed paper, ‘Children’s Play Space and Safety Management: Rethinking the Role of Play Equipment Standard’, referred to above offers a critique of Standards and the process of their formulation. It’s a good and easy read, this not said only because I am among the co-authors with Professor David Ball, Harry Harbottle and Tim Gill.
So, what’s up? What’s the worry?
The danger that prompted this piece lies in the ASTM (American Society for Testing and Materials) seeking to secure, may indeed have secured, a reduction in the Head Injury Criterion (HIC) value of Impact Absorbing Surfaces (IAS) from the current HIC1000 to HIC700.
The potential negative consequences are not difficult to understand. If this change is ratified, and it seems the wind is blowing in that direction, there are real fears that it will have counter-productive consequences on children and teenagers’ play provision, eventually pretty much worldwide.
The practical potential consequences of a reduction in HIC are quite straightforward. It will in practice confront play provision providers with the option to:
- spend more on surfacing if fall heights remain constant
- and/or lowering the current fall height to accommodate the revised Head Injury Criterion.
Thus, possible consequences include: a reduction in play provision overall because of increased costs or increased expenditure on only some existing playgrounds, with others closed or mothballed; a reduction in children and teenagers experience of risk; a furthering dumbing down of playgrounds; a general diminution of the play experience, along with the possibility that children and teenagers will seek the experience of height in places considered more potentially hazardous.
In addition, although the change in standard may not formally be retroactive, it nonetheless could have an impact on parents, insurers and courts who may well treat the revision as applying to all existing provision. One can speculate that whatever the formal position, the psychological affect could be to make those responsible for play provision – whether in public playgrounds or in school grounds – anxious about their existing provision, no matter that it had not previously been a source of concern.
ASTM has of course it owns ground for justification:
‘The current standard for the measurement of impact attenuation on playground safety surface systems is based on outdated data and, in light of more recent research, is woefully lacking in its ability to safeguard children using these playgrounds.’
And the suggested motivation for change impeccable:
‘From a more humanistic perspective it will also serve to minimize the risk to countless children and young adults of suffering a TBI from a fall at a playground. To do anything less is an abdication of responsibility by ASTM in general and F08 specifically.’
However, notwithstanding the appeal to the moral high ground, ASTM’s approach, its stated rationale, and the degree to which it has subjected its proposals to a comprehensive risk-benefit analysis is, at the very least, open to question. Thus, precisely because of the gravity and potential negative consequences of the proposal, formal opposition to the suggested change has been registered by the UK Play Safety Forum (PSF), the International School Ground’s Alliance (ISGA), and the British Standards Institute’s Children’s Playground Equipment Committee. What has been quite reasonably requested is that a proper review is conducted that:
‘ would provide a written, publicly-available document for comment by all stakeholders. In our view such a review should contain:
‘A clear statement of aims of the measure / intervention
- the scientific evidence
- a quantification of the effectiveness of the measure
- an account of the costs of the measure and who would bear them
- an examination of any unintended consequences including consideration of wider implications e.g. effects on play value, health and well being of children and the probable effects on the amount of play provision.
A decision should then only be taken after comments have been received and considered.’
The quote above in italics is from the UK PSF’s letter to the relevant ASTM committee. The ISGA letter is couched in similar terms. What is important to note is that the request is for a public, transparent, comprehensive examination of the issue under view. Something significantly wider – and more open – than is accommodated by ASTM processes.
This all raises questions about the degree to which decisions by in particular play equipment and surfacing Standard-making bodies can be considered authoritative, an issue likely to be exacerbated should the proposed Transatlantic Trade and Investment Partnership (TTIP) treaty be ratified. But irrespective of TTIP, standards are sufficiently international in practice for those responsible for play provision – the ‘absent voices’ – across jurisdictions to now take an active role in opposing insufficiently scrutinised changes. I and others would certainly be happy to support such moves.
Wherever you are – there is small chance at present of escape
Do not imagine that the effects of any change in American standards will not ultimately affect you, wherever you are. Standards are increasingly international – what is decided in one jurisdiction pretty quickly affects others. This is because one of the overriding goals of Standards generally is ‘harmonisation’; that is, ironing out the difference between different countries’ Standards and specifications in order to facilitate free trade.
Earlier in this piece I quoted from the UK Play Safety Forum’s letter to the ASTM sub-committee. Below I share in full the International School Ground Alliance’s letter. To my mind it is significant that ISGA encompasses a range of practitioners in play, from designers to teachers to natural play environment proponents and more besides. I would encourage others to make representations either individually or organisationally. Do share the information if you do.
The International School Grounds Alliance Letter
By email: Harvey C Voris (firstname.lastname@example.org)
03 December 2014
Harvey C Voris.
ASTM Sub Committee FO8.63,
Paramount Fitness Corporation,
8381 Deepcliff Drive,
Dear Mr Voris,
Proposal to reduce HIC1000 to HIC700
I am writing to you on behalf of the International School Grounds Alliance (ISGA) Leadership Council in your capacity as Chairman of the ASTM sub-committee F08.63 responsible for Children’s Playground Surfacing.
The ISGA is an international network of educational, play, environmental organisations and authorities, along with landscape architects. The ISGA’s membership comprises organisations and individuals working in the USA, Canada, Europe, Africa and the Antipodes and has day to day experience of the widest possible range of play places across a range of settings, from schools, to parks to nature reserves, and more. The ISGA’s commitment to play and its role in assuring children and teenagers’ well-being is set out in the accompanying Westerbeke Declaration, also found at http://www.greenschoolyards.org/.
We learn with concern that ASTM is to consider reducing the HIC Value of Impact Absorbing Surfaces for children’s play from HIC1000 to HIC700. We question both the process by which ASTM reaches its decisions, and the substance of the proposal itself. It is our strong view that there should be no premature judgment in this matter.
We note the potential negative, severe consequences if such a reduction in HIC values is agreed. These include, but are not limited to, the potential additional costs to provide play opportunities – and the possible reduction in the same given limited, and often decreasing, budgets – and the curtailing of a range of children and teenagers’ beneficial play experiences.
We therefore endorse the approach of the UK Play Safety Forum in its letter to you and, with them, request that a proper, impartial, publicly available review of the proposal is undertaken before any conclusion is reached as to the desirability of the proposed reduction in HIV values. Such a review should include:
- a clear statement of aims of the measure / intervention
- the scientific evidence
- an account of the financial costs of the measure and who would bear them
- a comprehensive risk-benefit analysis including consideration of wider implications e.g. effects on play value, health and well being of children and the probable effects on the amount of play provision.
A decision should then only be taken after comments have been received, published and considered by a wide range of stakeholders.
The fact that the ISGA Leadership Council is writing to you is a measure of the importance we give to this matter, along with our firm conviction that premature judgment in this matter will not serve the best interests of children and teenagers.
We look forward to your response.
for and on behalf of the ISGA Leadership Council
Replies in the first instance to Bernard Spiegal, email@example.com
 For the avoidance of doubt it is probably worth me saying that I don’t doubt that Standard-making bodies have authority and legitimacy in terms of their self-generated structures and procedures. What is in doubt is their authority, as currently constituted, to affect matters that have wider social policy implications.