I accept that at first blush it might seem odd to link words such as play, children, teenagers, risk-taking to the international trade talks currently being conducted between the European Union and the United States of America. But there is a link, and it is potentially a threatening one. The talks, known as the Transatlantic Trade and Investment Partnership (TTIP), has as its general aim the lowering of what are described as ‘barriers’ to trade between, in this case, the EU and the USA.
One aspect of the so-named ‘barriers’ are Standards. Standards in respect of, among others things: environmental protection; specification of electrical goods; of additives to food; in respect of cosmetics and testing; and standards in respect of, well, play equipment and playground surfacing.
The TTIP negotiations are conducted in virtual secrecy – itself a major source of concern – but Greenpeace has managed to acquire confidential papers that reveal, in part at least, the state of play between the parties. The now released confidential papers are, says Greenpeace, at some variance from the EU’s publicly expressed opinion. Part of what is revealed is the US demand that the EU be put under an obligation to inform the US, in advance, of any planned regulations and to allow them the same ‘input into EU regulatory processes as European firms’ (Source: Guardian. 2 May).
The Guardian goes on to explain that ‘American firms could influence the content of EU laws at several points along the regulatory line, including through a plethora of proposed technical working groups and committees’.
Let me now narrow down and link all this to what should be a source of concern as it could affect play provision. Readers will know – or most certainly should know – that there has been widespread concern, and opposition, to ASTM’s (American Society for Testing and Materials) proposal to lower the threshold for Impact Absorbing Surfaces from HIC1000 to HIC700. The arguments against this proposal have been well-made and will not be rehearsed again here. (Some links to those arguments are at the end of this piece.)
Irrespective of the TTIP negotiations, Standards are increasingly international (we’re all aware of European Standards) and their thrust and intent is to extend that internationalisation, with or without TTIP. The aim is the ‘harmonisation’ of standards and regulations in order to promote free trade. Whether this is a desirable economic objective or not is a matter of debate, but what is clear is that, in the narrow area I’m focusing on here – play equipment and surfacing standards – the pursuit of free trade objectives can run counter to the pursuit of social goals. The ASTM proposal in respect of IAS is ample demonstration of this.
This article, then, is by way of an alert. An alert to civil society – in particular, that aspect of civil society that is concerned about children and teenagers’ play – that it needs to take a more active and critical interest in the standard-making process, a need now further underlined by the potential threat that TTIP represents.
To clarify this additional level of threat: if the US proposals in respect of the role it wishes its industry to play in the formation of EU Standards is accepted, then there is a real and present danger that Europe will be burdened with regulations that waste vast amounts of money, and do children and teenagers no good at all. From my perspective, this is all tied up with the more general need to take a critical look at play equipment and surfacing standards, here in Europe, and beyond. Civil society – play organisations, landscape designers, local authorities, and others – need to roll their sleeves up on this.
The links I promised:
BC injury and prevention project: http://www.injuryresearch.bc.ca/can-we-go-too-far-when-it-comes-to-childrens-injury-prevention/
While I share all the concerns of Greenpeace and others about TTIP, there is a paradox here. ASTM’s proposals (which if I understand them correctly, would involve reducing from 100cm to 70cm the potential fall height from equipment that triggers the requirement for standard-compliant IAS) are surely a call to tighten regulation, not loosen it. Our concern is precisely that this unnecessary safety overkill would force playground managers to waste resources on extra IAS (thereby no doubt making lots of money for ASTM’s member companies). That would clearly be a restraint of trade, and as such, seemingly the antithesis of what TTIP is meant to be about. Although if you want to argue that “free trade” is just a slogan, and that what TTIP is really about is simply forcing the world to do business on US terms, whatever those terms may be, then I wouldn’t disagree.
That’s precisely right, Mark. ASTM’s attempt to tighten surfacing standards would, paradoxically, potentially work in a directly oppositie direction to TTIP’s general intent, which is to loosen standards. And yes, TTIP would increase the power of international corporations, many American owned. Much to be concerned about, even in our neck of the woods.