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.