Category Archives: Regulation

Reforming play equipment and surfacing Standards: a few thoughts

I think it fair to say that within the broad community of play advocates – play designers, landscape architects, play provision providers, pedagogues – play equipment and surfacing Standards have not been a hot topic of debate or contention. For some they were, and continue to be, a form of assurance as to the ‘safety’ of a product; and, in addition, they may even be taken as a proxy indicator of that quasi-mystical quality: play value.

For others, Standards in their current form are a source of bemusement, if not irritation, seen as impeding the possibility of creating rich and varied play environments.

But what this diverse constituency  has in common,  is the shared sense that play equipment and surface Standards descend as from on high, are created via processes and people they know not, but whose pronouncements  have the force and authority of Holy Writ, to be adhered to, but not questioned.

That was then. Now is now.  

‘Now’ is marked by the steady growth, and the coming together, of a diverse  constituency of pedagogues, play advocates, academics, designers, individuals from within Standard-making bodies, all seized of the need to examine Standards, how they are formulated, who formulates them, their scope and their practical consequences ‘on the ground’.   And this constituency is growing. Continue reading

A renewed, misguided ASTM attempt to change surfacing standards, a Guardian editorial and risk-benefit assessment

‘Bicycle helmets save lives’ a Guardian editorial pointed out today (27.09.2016) referrencing recent Australian research.

The editorial then posed the question:  Should wearing cycle helmets be made compulsory?  Now read on for the editorial’s succinct explication of a form of reasoning we have come to know as risk-benefit assessment.

‘From the point of view of accident reduction, the answer is entirely clear. Helmets do prevent some head injuries, and these can be very serious even when they are not immediately fatal. On the other hand, they are extremely rare. You would have to cycle tens of thousands of hours in Australia to get an injury requiring medical treatment. More than 10 times as many Americans were shot dead in 2014 as died cycling and, despite the headlines, most Americans are never going to be shot at in their lifetimes. The benefits of cycling can’t be translated into such striking figures but there’s no doubt that regular exercise prolongs and improves life in every way, and cycling is one of the best ways to make gentle exercise a daily routine….’

‘…Risk reduction cannot be the only grounds on which policy is decided. If that were the case, helmets would be compulsory for pedestrians as well, since it would reduce the seriousness of some injuries, and undoubtedly save lives too. The ultimate aim of public policy must be to enable and encourage human flourishing, and because we are complicated and contradictory creatures, that must involve a degree of self-contradiction and the balancing of some goods against others.  The sense of freedom and spontaneity that cyclists enjoy is not an illusion and has real value.’

It is a salutory paragraph that members of the ASTM (American Society for Testing and Materials) committee on play equipment and surfacing would do well to read. Continue reading

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. Continue reading

There is a link, I promise: Transatlantic Trade and Investment Partnership (TTIP) and play

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). Continue reading

Discordant harmony

From a simple humanitarian perspective, it’s easy to be outraged at some countries’ response to the current refugee crisis. The UK’s response is, I think, simply shameful. And, once again, from a straightforwardly humanitarian view, Hungary’s response is both cruel and brutal. These sentiments are easy to feel, and as easy to express.

But from a different perspective, the ‘refugee crisis’ throws light on some of the fault lines inherent in, and dangers attending, the project known as the European Union (EU) as currently conceived.

The EU has as one of its core aims the ‘Harmonisation’ of policies and practices across its member states. Though a term used in particular in respect of trade relations – the aim of removing trade ‘barriers’ – it is applicable to a wide swath of policies agreed or imposed on its members.

Interesting word ‘harmonisation’. The image it conjures, and no doubt is designed to evoke, is that of unity, one formed of divergent tones, pitches, individual and unique features to become, as the dictionary has it, ‘in agreement’, ‘justly proportioned’, ‘concordant’, ‘congruous’. Continue reading

After Standards’ reform: The sunny uplands of possibility?

As a topic of conversation, the role and scope of play equipment and surfacing standards[1] may appear somewhat dry and technical, a bit of a turn-off.  But consider this:

  • The playground equipment and surfacing industry here in the UK has an estimated annual turnover in the order of £170m – £200m, a significant proportion of which is in effect funded by taxpayers and charitable funders.  Question has to be: Does that spend represent value for money, is it doing the best possible work for children’s play opportunities?
  • And a wider question: Are decisions about the detail of play provision spending lodged in the right hands?   Is decision-making about play provision well-balanced, or askew?

Those latter questions should counter the notion that questions about standards are merely dry and technical.  In this article I speculate as to what benefits might flow from a rationalisation of play equipment and surfacing standards. Continue reading

Observations on Impact Attenuation Criteria for Playground Surfaces by Professor David Ball

I reprint in full an important and helpful paper by David Ball, Professor of Risk Management at the Centre for Decision Analysis and Risk Management. The paper, ‘Observations on Impact Attenuation Criteria for Playground Surfaces, discusses some of the questions and tensions that inevitably arise whenever risk management decisions need to be made.

The paper – prompted by the American Society for Testing and Materials’ (ASTM) proposal to revise downwards the Head Impact Criterion for playground impact absorbing surfacing – is of wide relevance in that it sets out a way of thinking about risk in the context of wider social policy goals. I urge anyone involved in making decisions about children and teenagers’ play and learning to read the succinct and clear paper that follows.

The paper has been sent to ASTM.

Centre for Decision Analysis and Risk Management

 OBSERVATIONS ON IMPACT ATTENUATION CRITERIA FOR PLAYGROUND SURFACING

David J. Ball, Professor of Risk Management, 

Centre for Decision Analysis and Risk Management

Background

1.  This note is prompted by a proposition, originating from the ASTM in the USA but which was also considered by CEN in Europe in 2014, to revise the Head Impact Criterion (HIC) for playground impact absorbing surfacing (IAS) downwards from 1,000 to 700. The stated aim is primarily to reduce the risk of brain injury from headfirst falls to the ground, though some also refer to a reduced risk of long bone fractures as another benefit.

2.  Although on the face of it the proposition sounds entirely rational it is a cause of controversy. On the one hand, in support of the proposition, there is evidence from road traffic accidents and other non-play environments that children may sustain brain injury at a HIC of 1,000 or less. For some this immediately implies that action is needed in all settings where children are potentially at risk of head injury. On the other hand, there is concern that an intervention of this nature might have significant and unintended consequences for play provision with knock-on implications for overall child welfare because play is an essential constituent of growing up.

3.  Both concerns are legitimate. It can be assumed that all parties want the best for children, but it has not been agreed how this is to be achieved. This discord might be attributable to deficiencies in communication between the parties involved. The situation does indeed appear to resemble a classic stand-off between parties who seek the same ultimate goal – the welfare of children and young people – but approach it from different perspectives. Continue reading