An alert and call for action – a new Standard threat to play provision

This is an alert. An alert to all those – across Europe and wider – where European play equipment and surfacing standards are held, or will be held, to apply.   A new Standard is being proposed, one that will further undermine play provision.

Proposed change

The particular proposed change I focus on here (there are others) aims to introduce a requirement for onsite testing of playground surfaces, in particular, synthetic ones, for example, rubber.

Negative consequences

The proposed changes – designated (prEN 1176-1:2016 (E)) – if implemented, will have an entirely negative effect on play provision, piling on significant additional costs or, in an effort to avoid additional costs, providers may well feel compelled to close or further dumb down existing provision.

To demonstrate the scale of the potential increase in costs, one local authority has calculated that an additional annual amount of £400,000 would be required if the proposed change to the Standard is implemented.

The critical point is that there is little to no evidence that the proposed change is necessary.  The UK Play Safety Forum is firmly against the poposal and I understand that both the UK and the German Standard committees have come out against it.  However, some other jurisdictions appear to be in favour.

Play Safety Forum

Robin Sutcliffe, Chair of the UK Play Safety Forum,  has written to the British Standards Committee on behalf of the Forum objecting to the proposed changes and expressing deep concern as to the potential consequences:

‘The forum believe that the case for surfacing itself is controversial and that the level of serious injuries sustained from impacts resulting from falls within playgrounds is not significant and could therefore not be significantly reduced by this measure. The increased costs will either reduce levels of investment in play or see policies of play spaces being removed, or, more probably, both. It therefore follows that if this measure is implemented it will have a serious impact on the wellbeing of children across Europe.’

A UK, Europe and world-wide matter

I have stressed before  that play equipment and surfacing standards are an international matter.  What starts or is agreed in one jurisdiction, pretty quickly spreads to others. This is in because Standards are one expression of  a  pro-free trade ideology.  Whether that ideology is right or wrong, one intent of Standard-making is directed at their international harmonisation in order to facilitate trade between nations and trading blocs. The Transatlantic Trade and Investment Partnership (TTIP) negotiations are part of this too and, as suggested in a previous piece, if implemented could potentially further hamstring and pile on the costs for those responsible for play provision.

A civil society matter

I have stressed previously that playground equipment and surfacing Standards are a civil society matter not to be determined by committees heavily weighted in favour of special interests and seemingly dominated by a medical-cum-engineering value orientation.  Having said that, one can begin to detect a stirring of civil society interest in, and a preparedness to take action on, Standards.

Call to action now

I want to urge all those responsible for, or involved in, play provision – play organisations, landscape architects, local authorities, educators, playworkers, and others – to write to their relevant national Standard committee objecting to the proposal to institute the on-site testing of  synthetic Imapct Absorbing Surfaces.

Closing date for comment

The closing date for comments has been extended to the 29 July 2016.  Comments from the UK should be sent to the BSI Programme Manager, Governance & Resilience Officer  copied to British Standards Institute secretary.

I repeat, though, that this is a Europe-wide and international matter, so I urge those in other jurisdictions to take up this call, and to circulate it.

I should be very interested to hear of any actions taken.

10 responses to “An alert and call for action – a new Standard threat to play provision

  1. July 16, 2016,
    Mr. Matthew Marshall, Program Manager,
    British Standards Institute,
    389 Chiswick High Road,
    London
    W4 4AL
    United Kingdom
    Re: Changes to En1177
    Dear Mr. Matthew Marshall;
    I am writing to you in relation to the attempt that a few are making in relation to requesting that BSI oppose the inclusion of field testing as a requirement in the next revision of the EN1177 and I presume to write on behalf of the children and caregivers who are not aware that children are exposed to significant hazards with every visit to the playground. The change would be of great benefit to users and the owners of playgrounds, who have an expectation that the surfaces upon which children are falling will prevent “disabling or fatal consequences” when in fact this is not true and failure of a surface to meet the minimal requirements of EN1177 puts children at even greater risk.
    In the past you have written to ASTM demanding production of a peer reviewed paper that establishes that the injuries do actually exist and that head injuries are a debilitating injury. I take the pleasure in attaching 2 such recent papers, one from the US CDC and the other from York University, in Toronto, Canada. These not only confirm that injures from falls are on the increase, but also indicate that in relation to societal thresholds, the head injuries that are being sustained are under reported and of a disabling nature. The CDC points out that the field test in ASTM F1292 was adopted as an optional test in 1999 and without being a requirement has not moved the needle on injury reduction. Their point is the field testing is available and must be done. But you already knew this because you have a member of the Sutcliffe Group active in your industry, whose corporate history lays claim to causing no head injury with the Sutcliffe swing seat, based on the 1975 Franklin Institute work. This has been supported by the requirement in En1176-2 (2008) to perform a test to ensure that these swing seats to not impart more than 50g.
    To oppose field testing would be embarrassing to BSI taken that BSI was a major contributor and voted in favour of the recently published ISO TR20183, which includes a number of definitions and injury thresholds that would support the proposed changes and the protection of children in playgrounds through field testing of surfacing. Beyond the TR20183, there is the CEN Guide 14 and ISO Guide 50 and Cen TR16148 that would suggest confirmation that surfacing that minimally meets the EN1177 would be beneficial in meeting the scope of En1176 and EN1177.
    The argument that this is a unique change and will result in astronomical costs to owners is ludicrous. The CSA Z614, Chidren’s playspaces and equipment, has required field testing as the measure of compliance of the playground protective surfacing since 1998. Since this is the requirement of the standard, the volume of testing is quite high and compliance to the Standard has been mandated into many provincial, municipal, school board and private programs and contracts. Coupled to this cost consideration is that CSA Z614 in 2007 moved the fall height for structures from the deck or platform to the top of the barrier or guardrail, effectively being the same as lowering the HIC to 700 and leaving the fall height alone. Please note that in both Canada (CSA) and the United States (ASTM) there is no maximum fall height or limit to test height. These difference have not caused a ripple in the playground industry or ownership even though Armageddon was predicted. I dare say that on a per capita basis there are more playgrounds and play opportunities available to children in Canada than the UK. As a result playing the financial disaster card, is just “hot air” and Chicken Little saying the sky is falling.
    Standards, particularly those that are to prevent injury, should be embraced and applauded. In consideration of what standards should be, we do not have to go beyond the BSI website with;
    Standards affect all of us, every day of our lives. Whenever we use a product or service, there’s a good chance there’s a standard to cover it, whether we’re using a washing machine, mobile phone, playground or sports stadium, driving a car, paying bills, eating in a restaurant, making a complaint…there are standards for all kinds of things. Put simply, standards make things better: safer, higher quality and easier to use. But as a consumer you don’t just benefit from existing standards. You can also help shape tomorrow’s standards
    Note the inclusion of playgrounds.
    The prevention of injuries in playgrounds has evolved since the 1970s. First and foremost was the prevention of death. In the 1980s there was discussion of Severity Index of 1000, the median value for survival and non-survival in simulated auto accidents. Technology allowed the introduction of the HIC, with a threshold of 1000, which Cen TR16148 has demonstrated the probability of death being 10-15%. In the meantime the tolerable injury threshold has been modified to less than death and include serious injuries including concussions that also have debilitating outcomes. Improvements in technology have allowed for cost effective testing of surfaces in the field. The ability to field test has been in place since the late 1990s and injury quantity and severity have not decrease. The voluntary application of the field test moves the public health need to mandating the test. The ability of the protective surfacing to protect is the concern and this brings with it the need to test surfaces to ensure they are compliant.
    The upcoming change to En1177 to require testing of surfaces in the field is a step that fulfills the goal of standards as stated above.
    Yours truly,
    EVERPLAY International Inc.

    Per: Rolf Huber,
    President

    c.c Adolf Russhold, convenor, CEN TC136/SC1/WG1

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  2. Is this not the pot calling the kettle black? This is a move to protect children in playgrounds and confirm that the expensive surfacing, synthetic, actually is below the 1000 HIC level, which is 18% risk of MAIS>4, severe (life-threatening with survival probable), and 3% risk MAIS>5 (critical and life-threatening). It is incredible that some of the opposition comes from the family associated with the Sutcliffe Swing Seat that was developed back in 1975 to be less than 50 g as a result of the findings of the Franklin Institute that head injuries are not likely to occur for impacts less than 50 g. This even went so far as to be incorporated into the EN1176 Standard. All for 1 to 3% of the injuries in playgrounds, while you fight against 68 to 75% of the playground injuries. Did anyone rally to the playground owners or was there a cry from the risky play advocates when owners were forced to spend millions of pounds, euros, dollars on any swing delivering less than 1000 HIC or 200 g. Time to give children a break. Pardon the pun.
    It is hard to believe that the UK, which was once a leader in playgrounds, has moved to being self-serving and lost all credibility with public health and play advocates around the world.

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    • Rolf, thanks for your comment. I see that you have left the same comment on Tim Gill’s blog where he reblogged my original post.

      It is sufficient that I endorse in total his remarks, and thank him for so promptly addressing the points you raise.

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  3. Reblogged this on grumpysutcliffe and commented:
    Rather than reinvent the wheel, I would recommend this blog to all who are involved in children’s play. However time is getting short. We would really welcome all those with an interest to respond urgently to Matthew Marshall at BSi in line with Bernard’s request.

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  4. Pingback: An alert and call for action – a new Standard threat to play provision | Bernard Spiegal | Rethinking Childhood

  5. I am very conflicted on this issue. I agree that requiring field testing of synthetic surfaces could result in prohibitive testing costs and numerous negative/ detrimental reactions. However, if we do not field test synthetic surfaces for effectiveness and longevity, how we will ever know if these, widely utilized and very costly surfacing option, truly live up to their advertised effectiveness? Might the cost savings be much greater, in the long run, if we discover that the initial high costs of installing these types of surfacing options is a poor and ineffective use of valuable resources. Not sure we can continue to hide our heads in the sand because we are afraid of what we might find and the resulting backlash.

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    • Bob, thanks for commenting. I think the crucial point is that there is little or no evidence to suggest that IAS significantly reduces serious injuries. And this refers to IAS currently in place. In the absence of such evidence, instituting the proposed onsite testing is simply to introduce a measure that, whatever the findings, will not alter that fact – but at great cost. In economic terms, that great cost is a way of transferring public money into commercial companies for no discernible benefit.

      My blog quotes the UK Play Safety Forum’s view, but it bears repeating:
      ‘The forum believe that the case for surfacing itself is controversial and that the level of serious injuries sustained from impacts resulting from falls within playgrounds is not significant and could therefore not be significantly reduced by this measure.’

      The real question is whether, given the paucity of evidence in respect of the effectiveness of IAS is whether IAS should form part of the Standard in the first place. There is agood case to be made that it should be a matter for local decision-making via the Risk-Benefit Assessment process.

      There is further authoritative comment on IAS by Professor David Ball here: https://bernardspiegal.com/2015/03/23/824/ and by the BC Injury Research and Prevention Unit http://www.injuryresearch.bc.ca/can-we-go-too-far-when-it-comes-to-childrens-injury-prevention/

      I hope this is helpful

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  6. Thanks for highlighting this issue Bernard – needless to say I concur both on the position you set out and on the need for supportive action. I will share it via my social media.
    I gather from BSI that the deadline for comments via the UK route has been moved forward to 18 July (according to an email I received from Matthew Marshall at BSI on 14 June). You may wish to amend your post to reflect this.

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