Category Archives: United States of America

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

ASTM and Surfacing Standards – back again, so organise

As you will see from Tim Gill’s blog – Playground Safety: Troubling New Move From ASTM – and the quote below, there appears to be a renewed attempt to amend ASTM surfacing standards, albeit in what looks like a surreptitious way.

‘Overall, the proposal appears to focus on how surfacing is safety-tested once it has been installed (so-called ‘field testing’). Members of the relevant ASTM committee tell me that a change to the head injury criterion or HIC (the key feature in the ASTM proposal rejected earlier this year) is discussed in the proposal. Even though I gather a HIC change is not a substantive feature, the proposal appears to be the latest in a series of efforts to advance this controversial position.’

The arguments against a change to HIC values have been well made and need not be repeated here.

Connect, communicate, organise

There is international, widespread, authoritative opposition to changing the HIC criteria in the absence of close, public, transparent scrutiny of the evidence claimed in support of such a proposal. Thus far, there has been no attempt to respond positively to these demands.

A key problem – and major weakness – for those opposing ASTM proposals is that our opposition is fragmented, comprising of individuals and organisations that have yet to harness the potential of a combined, more systematic approach.

This is in stark contrast to ASTM. It has the organisation and financial ability to advance its interests.

Tim is right to say that he, I and others have urged the need for a wider debate.

But it is not only a question of debate.

Irrespective of the likelihood that the current proposal will actually be passed, there is a need to create some form of formal or quasi-formal grouping, particularly perhaps at this time in the USA from where the current HIC proposals emanate, to address over the long term questions about Standards and Standard making.

At present, discussions about play equipment and surfacing Standards are conducted on the terms set by Standard-making bodies, in this particular case, the ASTM. One can’t help but believe that this court is rigged in favour of sustaining its assumed exclusive right to generate stipulations that too often weigh heavily on play provision, with questionable benefit. This is not to say that Standards have no role to play – they do. But current structures and processes for formulating them are fundamentally flawed.

Given that so many jurisdictions make Standards mandatory, and others treat them as though they were, we are in fact dealing with a publicly unaccountable body that affects public policy – and public expenditure – in a profound and disturbing way. It is not a minor matter. Still less merely a technical one.

It seems to me that those of us arguing for a different approach to Standards and Standard making must, as a matter of some urgency, move from the current position of erupting into bursts of objection to this or that proposal, to creating some form of inter-connected, authoritative entity that can stimulate and sustain debate about Standards and Standard making over the long term – getting to the heart of the matter, one might say. This is particularly pertinent at this time for the USA.

It is the case that Standards are an international matter, have impact accross jurisdictions.  But there is no escaping the fact that individual jurisdictions need to organise for themselves as the first, necessary step towards creating a cross-jurisdiction network capable of making the case for a more reasoned and reasonable approach to play equipment and surfacing Standards and Standard making.

 

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

ASTM surfacing proposal – opposition mounting

In this brief post I can do no better than direct your attention to the joint open letter to the ASTM committee by the Chair of the UK Play Safety Forum, Robin Sutcliffe and Tim Gill.  It makes cogent and informed points that underscore the reasonableness of those urging ASTM to defer passing its current proposals in respect of  playground surfacing.

In a similar vein, I urge you to read – if you have not already done so – Jay Beckwith’s blog on the same subject.

I add two points of my own:

1.    It is important to value, to hold fast to, our common sense, observation and experienced-based knowledge about children, their competency, behaviour, and risk assessing capabilities.  ‘Objective’ statistical data represents but one form of evidence.  It says nothing in particular in the absence of a value-based framework within which ‘facts’ can be weighted and assessed.

2.  It is clear that opposition is growing to the ASTM proposals.  Voices are being raised, arguments made, blogs being written.  It strikes me – as it has done for some time – that there is also a need to organise, to generate an institutional form that can build on current concerns, and which can channel, inform and maintain a much needed, wide ranging discussion about play equipment and surfacing standards.  I hope my American friends will not accuse me of trespass if I suggest that this move is most immediately pressing in the USA.

I intend to return in more detail to the issues raised here and in the blogs referenced above in March once back from India where – on a recalcitrant guest house keyboard – this note has been written.

A final observational note: if you want proof of the competency of children, and their capacity to care for one another, visit this amazing country where such evidence is daily before one’s eyes.

 

American musings: Handbooks, standards, and over-regulation

I thought I’d give this blog an American slant since I’m here in the San Francisco area talking about, well, risk, standards, parks, (over) anxious parents – that sort of thing.  

I’m here courtesy of the efforts of Lisa Howard and Sharon Danks, both of Bay Tree Design and the International School Grounds Alliance (ISGA), a grouping that is slowly extending its reach and gathering its strength.  Long in the preparation, and cooked slow for added succulence, the developing international alliance draws on, and contributes to, the expanding knowledge-base – both theoretical and practical – of the benefits and challenges involved in greening school grounds.  A  key component of its belief system is that school grounds are for the community as a whole, and not to be treated as sequestered enclaves for school use alone.   (PLAYLINK declares an interest here, it is one of the founder members, but credit for ISGA’s  conception and its activities, belong elsewhere).

Public Playground Safety Handbook

In preparation for this trip, I took a look at the what appears to be the bible for American playgrounds, the ‘Public Playground Safety Handbook’, published by the Consumer Product Safety Commission.  Here in California it is effectively mandatory to adhere to its provisions for all projects involving public money –  this effectively captures, for example, most schools, parks and public playgrounds.

Sophisticated readers, and adepts in the language of play and risk, will almost certainly have given an  involuntary start on seeing the word ‘safety’ in the handbook’s title.

Continue reading