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Playground Safety Is No Accident

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©2021 International Playground Safety Institute, LLC B-1In Toronto, 2017, I attended a Bilateral Americas Conference related to the International Organi-zation for Standardizations (ISO) Technical Committee (TC83) Sports and other recreational facilities and equipment. The purpose of the conference was to consider whether it was a good idea to collectively work toward the harmonization of standards for public playgrounds. This conference resulted from a proposal made to the ISO TC 83 to adopt the EN1176 and EN1177 stan-dards as the international standard for public playgrounds. This initial effort failed to move for-ward but the topic and subsequent discussion did result in the establishment of a working group of international playground content experts from the various ISO voting member countries, to further investigate how a global playground safety performance initiative might lead to some level of understanding and harmonization wherever practical. Further discussion determined that the current national and international standards are already meeting the various national health man-dates. In lieu of the fact that there was no consensus to create an ISO playground performance standard, there was an agreement to investigate other options toward some form of harmoniza-tion within the many international and national standards-writing organizations, while acknowl-edging that performance standards should remain a decision of each nation member, based upon each country’s cultural and societal norms. There was one playground safety-related issue that received almost universal international support for some course of action. It was unanimously acknowledged, by all the participat-ing countries, that playground inspection and maintenance practices were lacking throughout the world. It was also noted, by those in attendance, that poor inspection and maintenance prac-tices were a major contributing factor to the frequency and severity of many serious playground injuries. This consensus was determined to be an area of collaboration and harmonization to improve upon the basic knowledge competencies required to implement an effective inspection and maintenance program that would promote more comprehensive and consistent inspection and maintenance processes. The basic overarching goal is to eliminate known playground hazards and enhance the general safety of the public play environment. After my initial review of exist-ing international playground safety-related performance standards regarding installation, main-tenance, and inspection requirements, it appeared there was a considerable amount of work to be done. What is universally lacking is a document that creates a guide or best practice for playground owners and inspectors to implement an effective and efficient management plan to maintain and/Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related InspectionsPART B

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Playground Safety Is No AccidentB-2 ©2021 International Playground Safety Institute, LLCor enhance the public play environments, based on the following guiding principles to inspect and maintain the public play environment to assure: • the public safety;• its operational function; and • aesthetics, cleanliness, and sanitation. of the playground equipment, its impact-attenuating surfacing within the equipment use zone, and ensure that the basic general safety-related concerns are being addressed throughout the entire playspace environment. After some online research and review of many international playground inspector programs and standards, it has become evident that there is a wide spectrum of organizations certifying inspectors through their own playground inspector certification programs. It was also noted there are varying levels of competence related to the different types of playground inspection processes. The scope of the day-to-day visual review of the playspace environment is quite different from the more detailed compliance assessment based on some best practices, a national or international government-mandated performance standard, or a playground owner’s internal standard operat-ing procedure, provided it is more far-reaching than applicable safety norms. This is not a new realization, since the creation of the earlier edition of Playground Safety Is No Accident in 1989, I have approached the frequency and content of each type of inspection in much the same manner as is being suggested by the international playground standards-writing community. As the scope of the playground inspection broadens, so comes the need to increase the inspector’s knowledge, skill level, and experience. Regardless of the tool created and used to implement the inspection process, there are a lot of gray areas within some of these international playground performance standards. It is for that rea-son the interpretation and application of these standards will not always end in a simple black-and-white solution. The scope of the subject matter involved in inspection, maintenance, and repair of public playspaces requires a certain amount of knowledge and experience the inspector must rely on to effectively do his/her job. This level of experience and depth of knowledge goes beyond the basic application of a playground performance standard’s requirements. Most maintenance and repair tasks can be easily identified and corrected with some basic knowledge, experience, and skill; however, when inspectors are called upon to combine all the different elements involved in play and the operation and management of the playspace, the process requires a higher level of knowledge and experience beyond the playground performance standard compliance. Some levels of inspection require knowledge and experience in areas of concern such as understanding the effects of local weather conditions, frequency of use, materials used in the manufacture of the equipment, type of surfacing materials, and the immediate general play environment conditions. Some types of inspections require the assessment of the entire playspace while considering chil-dren’s foreseeable behavior. I have come to realize that an inspection and assessment of a public play area is not solely a “technical” inspection. Some of these inspection processes also require some level of knowledge on child development to understand how and why children of all abilities play. Safety inspectors and maintenance technicians need to balance decisions about the safety of

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-3the play environment based on their understanding of the way children play, interact, evolve, and develop. Too often, inspectors base their decisions solely on the possibility of harm. Inspectors, especially compliance inspectors, need to weigh the known benefits of risky and challenging play against the probability of harm beyond what might be considered acceptable by local customs and practices. The owner of the playspace is ultimately responsible for setting the parameters for their risk tolerance. Regardless, the inspector needs to know the scope of their work before conducting any inspection. The scope of work and the inspection process should be clearly defined. Part of the playground inspector and maintenance technician training necessary to become effective and efficient in their respective job requirements is to be able to speak the same language related to playground management and safety concerns. There are many terms and definitions found throughout the various international playground standards and this document. While the terms and definitions seem like those commonly used in everyday spoken English, their meaning may be very different in the context of public playground safety. This document will use several terms and definitions as found in the current Consumer Product Safety Commission’s (CPSC) Public Playground Safety Handbook and ASTM playground-related standards. Most of these terms and definitions can also be found in the ISO TR 20183 Sports and other recreational facil-ities and equipment — Injury and safety definitions and thresholds — Guidelines for their inclusion in standards. Some new terms and definitions have been added to the previous version of this book as needed to harmonize the intent of the different levels of playspace inspections commonly being performed around the world. In other words, one world, one language when it comes to playground standards development. Since 1989 Playground Safety Is No Accident (PSINA) has used specific terms to describe the different types of inspection forms and their purposes. Each type has a different level of train-ing, knowledge, and experience required to perform the basic processes required of each type of inspection. I will be harmonizing terminology with regards to the scope of each type of inspection and the basic knowledge required for each type commonly used throughout the world. This is based on the review of international playground safety performance standards and their identi-fied types of inspection processes as noted and defined in the ISO TR20183:2015. These different types of playground inspections will be further defined throughout this book. The new terms for inspection types are different from those familiar with the first five editions of Playground Safety Is No Accident and the training they may have received in the National Recreation and Park Asso-ciation’s Certified Playground Safety Inspector course, but the scope and purpose of each inspec-tion type is identical with the previously used inspections found in previous versions of PSINA. The previously used terms for the various types of inspections were High Frequency Playground Safety Inspection, Low Frequency Playground Safety Inspection, and Playground Safety Compli-ance Audit Form. These inspections are now called Routine Visual Playground Inspection, Operational/Annual Main Playground Inspection, and Comprehensive Playground Com-pliance Inspection and Assessment (Audit). Playground Safety Is No Accident, 6th Edition, is introducing an additional inspection type that is referred internationally as the Annual Main Inspection. The name already defines the frequency of use. There appears to be an emerging trend worldwide toward legislatively requiring

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Playground Safety Is No AccidentB-4 ©2021 International Playground Safety Institute, LLCan annual inspection by a qualified independent third-party inspector or trained in-house staff person. Ontario, Canada, for example, has been requiring annual playground inspections for all licensed childcare centers. This is similar to what is being recommended or even required by some state and federal childcare licensing authorities. Ontario’s, annual main inspections also require protective surfacing compliance drop testing, since the performance of the surfacing is an integral part of the injury prevention mechanism. This type of Annual Main Playground Inspection is becoming more common whenever the owner has been determined to have a higher duty of care for the children under their supervision. As a result of this licensing or legislative requirement, the owner requires a higher level of inspector competency. An Annual Main Playground Inspection includes a thorough review of the entire play-ground environment, the playground equipment, and the performance of the impact-attenuating surfacing. As part of this inspection report, the inspector should be looking for visual evidence that the owner has been conducting Routine Visual Playground Inspections, previously referred to as High Frequency Playground Safety Inspections, including evidence of regular custodial and pre-ventive maintenance throughout the year. Since playground owners are required to retain written records related to the installation, maintenance, repair, and inspection of each playground, this evidence should be readily available for review by the inspector. Many of these initial playground historic records are provided by the equipment and surface system manufacturers. These records include documentation such as verification that the equipment and surfacing were installed accord-ing to the manufacturer/suppliers’ specifications. The inspector should also review the owner’s written inspection and maintenance records for additional evidence of routine playground main-tenance practices. The playground owner cannot effectively maintain and repair the playground without access to these records, therefore, it would be a good practice for the inspector conduct-ing an Annual Main Playground Inspection to be able to review some of these documents to attest to the playground owner’s diligence in meeting their minimum requirements for written documen-tation, as specified in the applicable local performance standards and guidelines. Through my involvement in various discussions toward the harmonization of international playground safety standards, I have come to better understand the similarities and differences within these national standards, as well as the differences within the various types of inspections. This is not a new concept, but defining the competency level of knowledge and experience needed to conduct these different types of inspections still needs more refinement and much broader dis-tribution within the playground stakeholders responsible for protecting children from playground hazards, by inspecting and maintaining a reasonably safe, clean, functioning play environment. I learned more than 30 years ago that there is a big difference in the levels of inspector and maintenance technician competencies necessary to perform these different types of inspections. I also found that there are just as many differences as there are similarities in current training opportunities available around the world. The one area of debate seems to be related to how much risk in various challenging play events is reasonable, when considering the probability of serious harm to children who may not have the level of cognitive reasoning, life experience, or skill level to make an appropriate choice. The EN 1176-1 Playground equipment and surfacing states:

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-5“Risk taking is an essential feature of play provision and of all environments in which children legitimately spend time playing. Play provision should aim to offer children the chance to encounter acceptable risks as a part of a stimulating, challenging and controlled learning environment. Play provision should aim at managing the balance between the need to offer risk and the need to keep children safe from serious harm.” The overarching goal of a playground owner, as stated by Julian Richter, a German play equip-ment designer and manufacturer, is that “we should provide as much play value as possible and as little safety as necessary.” In his vision of a safe playground environment it is essential that the inspector not only knows the technical content of the related standards, but also understands why and how to make risk assessments and/or a risk-benefit analysis. After reviewing methods of inspections and various inspection forms from around the world, it became apparent there are many ways in which inspectors conduct playground inspections. While the goal is the same, the content varies based on each type of inspection and the frequency with which each type of inspection is conducted. The most comprehensive inspection of the entire play environment would be compared to the content of a post-installation inspection. This type or level of inspection seems to be the most popular and generally recommended approach to ensur-ing the playground environment is following any local laws, national requirements, best practices, and societal norms. This includes assessing the conformity of equipment and the performance of the impact-attenuating surfacing where the children are likely to fall. This inspection should also identify maintenance deficiencies and safety-related concerns related to site amenities, landscap-ing, walkways, and other items in proximity to the playspace. This is the main difference between the current post-installation compliance inspection or Audit, as it has been referred to in previous versions of this book. The Canadian, European, and Australian model found in EN1176, AS4865, or CSA Z614 standards, is referred to as the Post-Installation Inspection. This inspection is similar, yet different in depth of scope, from the Annual Main Inspection. The content of these two types of inspections require some basic form of risk assessment based on the current condition of the playspace, taking into consideration any changes in user patterns, review of past injury data, and a thorough assessment of the current condition of the entire playspace. Deficiencies should be noted and discussed with the owner to determine what, if any, further course of action is warranted. Previous versions of this book suggest that the inspector, if required as part of their job description or their independent third-party inspection contract, establish a recommended course of action to address each non-compliant safety-related concern based on the possibility, probability, and consequence the intended user might experience if they come in contact with the non-compliant condition. This type of inspection, which includes a risk assessment, ultimately defines the owner’s current standard of care regardless of whether the playground or playspace is in total compliance with all applicable standards. The words, playground and playspace, are often used synonymously. It should be clear to the owner and the inspector what they are describing when using these words to define the scope of an inspector’s work. These words have different meanings to school officials, childcare providers, and park and recreation agencies, and it would

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Playground Safety Is No AccidentB-6 ©2021 International Playground Safety Institute, LLCbe beneficial to all concerned to carefully define within the scoping parameters that need to be addressed during the inspection process. A school playground is often described as the entire fenced-in school grounds, including hard surface, turf game areas, and the playground equip-ment apparatus area. A childcare provider’s playground is the entire fenced-in area, complete with walkways for wheeled toys, turf areas, and age-appropriate playground equipment areas. The community park playground is usually the play apparatus area and nothing more, but what about the areas adjacent to the playground equipment intended for children 2–12? The owner needs to consider other site amenities that make up the more inclusive playspace. The playspace will include shade trees, landscaping, walkways, shelters, picnic areas, restrooms, drinking fountains, fences, picnic tables, benches, waste receptacles, outdoor electrical lighting and outlets, and, last but not least, other natural features (e.g., lakes, rivers, streams, roads, and parking lots) reason-ably close to the playground apparatus area. (This type of inspection would be similar to a Post-Installation Compliance Inspection and Assessment or may be in the form of a rather comprehensive Annual Main Inspection.) This comprehensive Annual Main Inspection approach has been universally applicable throughout the world, yet the results and recommendations vary based on the local and national cultural and regulatory differences. These differences play an important role in the inspection process and outcomes, therefore, each country, state, local jurisdiction should consider imple-mentation of a playground inspection process as determined or mandated at a local or national level. Without such guidance the owner can proceed with their own recommendations that meet the local needs and cultural practices of their jurisdiction. This book provides basic guidance and tools to help create a comprehensive playground inspection program as playground owners work toward ensuring their playgrounds are in reasonable and substantial compliance with cur-rent ASTM public playground standards, CPSC Public Playground Safety Handbook, and where applicable, the U.S. Department of Justice 2010 ADA Standards for Accessible Design to make playgrounds reasonably safe for the general public. Checking the play equipment and adjacent play environment based on a risk assessment alone is another approach quite common in Europe and is often used in evaluation of “Nature or Natu-ral Play” environments. The basic focus of nature play advocates seems to be less on the safety standards for the typical steel and plastic post and deck play structures, and more on the benefits of being in contact with nature and natural materials in the play environment by utilizing loose parts, plants, dirt, water, and other natural materials. This risk assessment inspection process has been referred to and practiced throughout the European Union when evaluating an “Adven-ture Playground.” Many elementary schools in the U.S. have begun implementing “Nature Play” spaces. Advocates for these play opportunities believe the benefits of such play environments far outweigh the risk of serious harm. Adventure Playgrounds and Schoolyard Nature Play are quite different than the typical neighborhood playground. Supervision and control of the environment is one major consideration when evaluating the overall function and safety of the play environment. While the risk/benefit analysis may be useful throughout the European Union, the same cannot be automatically assumed based on the North American legal system. Playground owners and inspectors alike will need to use their knowledge and experience of known causes of injuries and

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-7a solid understanding of the basic playground equipment performance requirements. They also need to consider and apply the common safety-related practices as found in the U.S. Consumer Product Safety Commission that consider layout concerns, supervision, surfacing recommenda-tions, age-appropriate issues with various equipment, and other known hazardous conditions. There is an emerging hazard-based assessment approach when inspecting and evaluating equipment not specifically referenced in current performance requirements. This type of inspec-tion and analysis will also require a basic risk assessment analysis tool to help manage the pro-cess. Some play equipment does not seem to fit within the existing relevant standards based on types of traditional equipment. The compliance or conformity inspection will not work without some modification in the process. Whenever there are no performance requirements within the existing standards to give guidance for the inspector’s findings, the inspector should begin the review process with a general hazard analysis by applying all general equipment performance requirements. This option should specifically highlight the playground equipment in relation to the play environment and its reasonably foreseeable use. This process would also require a more sophisticated risk-benefit analysis of the equipment. This type of inspection or assessment would likely be compared to a comprehensive Hazard Identification and Risk Assessment (HIRA). A discussion of the process with some examples of how to apply the process can be found in the non-mandatory “Annex J” of the National Standards of Canada Z614:20 Children’s Playground Equipment and Surfacing. Note: This book will not be focusing on or addressing any specific risk assessment approach. We will, however, discuss the priority rating scale for identified non-compliant conditions. This priority rating scale is primarily used as a tool to assist the playground inspector to conduct a basic risk assessment for each non-compliant condition based on the possibility, probability, and consequence of the user coming in contact with each non-compliant condition identified during the comprehensive post-installation compliance inspection and assessment and for the Annual Main Playground Inspection. It can also be used to evaluate any deficiencies identified during any of the other types of inspections and recommend a course of action as to if, and when, corrective action is required. I will also present a flow chart illustration of the risk assessment process and one additional example of a risk assessment matrix tool with five levels of probability and five lev-els of severity of injury, to assist the owner and inspector in prioritizing their actions in mitigating the most serious concerns first. Regardless of the popularity of this risk assessment method as practiced throughout most of the European Union, inspecting the equipment and the rest of the play environment without identifying known hazards and other safety-related concerns can be a contradiction of inspection practices. Likewise, undertaking risk assessment and/or risk-benefit analysis, is a very restrictive inspection. The outcome of this option can also be in contradiction with the statement made earlier about risk-taking, as discussed in the introduction of European playground performance standards. The way in which children play and the public perception of injuries children sustain during play versus injuries they sustain during all aspects of daily life, varies throughout the world. Within

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Playground Safety Is No AccidentB-8 ©2021 International Playground Safety Institute, LLCthe United States, this difference of opinion can be seen from state to state, even town to town. It is vital that the inspector is aware of these differences within the local jurisdiction. The inspector, especially the independent third-party inspector, should also take into consideration the owner’s standard of care and any of the owner’s standard operating policies related specifically to their play areas. The inspector will also need to be familiar with the owner’s tolerance for risk as it relates to what the owner considers an acceptable level of risk or challenge. There needs to be a mutual understanding between the owner and the inspector, before the inspection process begins, that includes the scope of the inspection and the content of the final inspection report. Any indus-try standards used to conduct inspections, unless codified by some legislative authority, are rec-ommendations or best practices to guide the owner’s scope of work and the inspector’s required deliverables. For example, there is a big difference in how one local jurisdiction might approach its safety- related concerns related to pedestrian access and vehicular traffic in relation to the neighborhood’s play environment. How society reacts to pedestrian/traffic conflicts will likely be perceived dif-ferently in urban centers like San Francisco, Chicago, or New York as compared to rural Amer-ica. In many less-urbanized areas children still have the privilege of riding their bicycles around their neighborhood and to and from school. Pedestrian/vehicle conflicts are minimized based on lower volumes of automobile traffic in contrast to a much higher potential for pedestrian/vehicle conflicts in urban centers. And so, building “on” or “in” the proximity to heavily trafficked streets, while not desirable, becomes a necessity. Out of this necessity, children are educated, at an early age, of this danger and have an elevated awareness on how to deal with this and other potential urban living dangers in their daily lives. This is an early learned risk assessment skill for young urbanized children. Fencing of rural school and park playgrounds would not even be a concern but in an urban school or park, it would become more of a necessity for more reasons than just vehicular traffic. Cultural and socioeconomic differences should not be used as an argument to withhold chil-dren from a beneficial risk/challenge while playing nor should it be against the owner who has little to no options for where children’s playspaces are located. Performance requirements are not an absolute, one size fits all, approach. International standards accept the cultural and socioeco-nomic differences from country to country and the same should be said for the applications of standards throughout America. This book is based largely on the content of various American Society for Testing and Materi-als (ASTM) public playground-related standards and the Consumer Product Safety Commission’s (CPSC) Public Playground Safety Handbook. The International Playground Safety Institute, LLC (IPSI), and its agents accept that there may be variations in working practices in different juris-dictions throughout the world. Playground inspectors and maintenance technicians need to have specific competence to undertake all tasks related to the inspection, maintenance, and repair of a public play area, while including established local systems for compliance. Playground inspectors’ expertise cannot compensate for the lack of designers’ knowledge related to playground industry performance standards and government regulations. Playground owners are ultimately responsible for the management of their playgrounds and therefore need

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-9some appropriate level of knowledge within their organization. Playground equipment and sur-facing installers are required to have correctly detailed technical documents, as provided by the manufacturer, to guide their work, but they also need to have a level of knowledge about the most basic playground safety-related issues that could help to solve problems that are likely to arise during the installation process. Manufacturers should have an extremely high level of knowledge in all areas of playground design, installation, inspection, maintenance, and repair. User safety is the responsibility of everyone involved in playground design, installation, and operation from the playground’s inception to the end of its useful life and removal. Vital Types of Inspections in a Comprehensive Playground Management and Operation ProgramThis book provides examples of different types of inspections a playground owner should con-sider utilizing when implementing a comprehensive playground management and operation pro-gram. As the role of the inspector becomes more critical to the safety of the public, the levels of competence become more comprehensive in the inspector’s depth of knowledge and experience. Playground inspectors over time will continue to practice and enhance their inspection, mainte-nance, and repair skills and over time, they will become more capable of applying appropriate maintenance and repair practices. Actions might eventually involve making recommendations for further action such as taking defective unsafe playground equipment or entire play areas out of service. This depth of knowledge and experience does not occur overnight. Staff training is vital to the success of a comprehensive program of playground management. Information in this book should be shared with everyone involved in the management and day-to-day operation of their public playgrounds. The content of the book provides a road map for success in achieving safer public play environments for children. Like with any map, one must learn how to read it. The navigator must understand the various keys and symbols found on the map if they hope to find the destination in a reasonable amount of time. Likewise, a playground owner, manager, maintenance staff, or inspector must learn some basic playground safety-related concepts, including a new vocabulary, to truly understand all the parts of the management plan and the processes necessary to develop and implement a comprehensive playground management and operations inspection and maintenance program. The playground inspection process and the corrective actions necessary to address the main-tenance needs and repair processes required to maintain the intended function and standard compliance of the playground can be completed independent of one another. However, these two actions are more effective and efficient when combined into one process. This is especially true during the more frequent routine visual custodial inspection process. Inspection and main-tenance/repair go together like bread and butter. Both are equally important unto themselves but when implemented together they create a safer, clean, functioning playground environment free of hidden dangers. Only a trained playground inspector and playground maintenance technician can understand the need to identify and remove hazards a child cannot appreciate to create a rea-sonably safer environment.

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Playground Safety Is No AccidentB-10 ©2021 International Playground Safety Institute, LLCTo Recap the Inspection Types and Purposes Found in Public Safety Is No Accident, 6th EditionThe information provided in this document presents a framework for the competence of many different disciplines involved in the creation and management of public playgrounds. The level of training to establish the depth of knowledge and experience required to conduct each type of playground area or level of inspection has some similarities in purpose, yet they are very different when it comes to the extensive knowledge necessary to conduct a routine visual inspection versus a post-installation compliance inspection. This document will suggest different depths of educa-tion requirements for each inspection type, based on the current state of international practices and suggested specific objectives and competencies required for each inspection process. The following types of inspection processes have similar but different objectives. They each either establish the current standard of care of the play area or they maintain that standard of care, primarily related to the safety of the children. The four primary types of inspections being conducted around the world and included in this edition of PSINA are: • Routine Visual Playground Inspection (High Frequency Inspection)• Operational Playground Inspection (Low Frequency Inspection)• Annual Main Playground Inspection• Post-Installation Playground Inspection (Comprehensive Playground Compliance Inspection and Assessment) There are other, lesser-known, types of inspections that will be briefly discussed. One such inspection is referred to as a Risk Assessment or Risk/Benefits Analysis. This type of inspection is referred to as: • Playground Area Risk Assessment (Hazard Identification Risk/Benefit Assessment) There currently is no universally accepted example of a risk assessment process for new play-ground equipment types or new play area designs. There are, however, examples of risk assess-ment tools that are starting to be put into practice, while evaluating new playground equipment that does not fit into the current international playground safety performance standards. As men-tioned earlier, the CSA Z614:2020 non-mandatory Annex J is the most recent attempt by a stan-dards-writing organization to include some guidance for users of these standards in conducting a hazard and risk assessment of playground equipment that does not seem to fit within the current performance requirements of the standard. Currently, more and more countries in the European Union require inspectors to conduct risk assessments as part of the Annual Main Playground Inspection as well as the Post-Installation Playground Inspection. This risk assessment process is similar in theory to the final step in the Comprehensive Play-ground Compliance Inspection and Assessment Process (Audit) that has been part of this book for more than 20 years. The flow chart on the next page addresses the possibility of user exposure to some risk of harm, the probability that this exposure would result in harm to the most vulnerable users, and the probability that the severity of harm would be beyond any acceptable norms. What the inspector does with this information and how the probability and level of harm is tolerated

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-11Simple Risk Assessment ProcessStartYesNoEndIdentifying hazard scenarioEvaluate the level of harmCalculating the probabilityIs the risk tolerable?Risk ReductionScores in the report are calculated as Likelihood x SeveritySeverity >>Likelihood >>Very High probability, if the situation is not addressed an accident is almost certain5 Very High VL (5) L (10) M (15) H (20) VH (25)High probability, an accident is probable without any added factor4 High VL (4) L (8) M (12) H (16) H (20)Moderate probability, an incident is foreseeable3 Moderate VL (3) L (6) L (9) M (12) M (15)Some probability, requires a combination of factors to take place2 Low VL (2) VL (4) L (6) L (8) L (10)No signicant probability; lightning strike, freak accident1 Very Low VL (1) VL (2) VL (3) VL (4) VL (5)Very Low Low Moderate High Very High1 2 3 4 5No injury likely, e.g., damaged or soiled clothing, minor bruising, grazesMinor injury, laceration or bruising requiring rst aid onlyInjury requiring medical intervention, e.g., cuts requiring stitchesSerious injury including concussions or fracture of long bonesSevere injury involving a potential life changing injury or fatalitySeverity >>Note 1: Where, for example, a risk score of 10 is given, divide the score by the number below in the Severity axis (5) and this gives the score for Likelihood (2). The risk score can work in both directions, e.g., a score of 12 can be Likelihood 4 x Severity 3, or Likelihood 3 x Severity 4.Note 2: When we inspect we only see a snapshot of the current condition of the equipment. It is the operator’s responsibility to ensure that there is a continuing level of maintenance to keep the equipment in good working order and the site t for use.Risk Assessment MatrixRisk Assessment Method as described in “2010/15/EU (RAD\PEX).”Modied from “CEN/TR 17207:2018: (E) Table C.7.”

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Playground Safety Is No AccidentB-12 ©2021 International Playground Safety Institute, LLCor mitigated is a decision for the manufacturer/designer of the playground equipment. I would suggest the owner/operator and/or their designated representative conduct a similar assessment of the overall play area design and layout. The owner also has the ultimate responsibility, as they are the ones who approve the proposed playground equipment and final playspace layout. Another lesser known type of inspection that will be discussed is: • Post-Incident/Accident Inspection This type of inspection requires specific training in how to question witnesses and try to cap-ture the current condition of the play area, visually by video or digital photograhy and in writing, the conditions that existed at the playground leading up to the incident. (See Incident/Accident Report.) There are additional types of inspections performed by qualified playground inspectors prior to beginning the actual installation or and continuing during the installation process up to the final Post-Installation Inspection. These are: • Pre-installation Consultation• Mid-installation Surveillance Playground inspectors with higher levels of competency in both knowledge and experience can add value to the overall playground plan before the shovel gets into the ground. Having an extra set of experienced eyes review a playground design can save a lot of time and avoid expen-sive change orders and corrective action prior to and during the construction process. This book will not be discussing, in any detail, these less-frequently-used but nonetheless important, types of inspections. It is important to know these types of inspections or consultations exist. Owner/operators should ask their inspectors for advice but first they must confirm they are qualified to conduct such inspections. If they are not qualified, they will likely be able to refer someone who is. Owners need to consider whether they have an experienced Certified Playground Safety Inspector on staff with the necessary experience and knowledge of playground standards and best practices. The owner should take advantage of such a valuable in-house resource even if they have already hired a consultant or architect to design and manage their new playground project. As was pointed out earlier in this book, the primary focus will be on four types of playground inspections: routine visual, operational, annual main, and post-installation inspections. Routine custodial and/or routine visual playground inspections are much different in scope than the more comprehensive operational playground inspection and annual playground inspec-tion. These inspection types are different from the post-installation compliance inspection, other-wise referred to as the comprehensive playground compliance inspection and assessment which assesses the entire playground environment. As was stated earlier, the routine visual and opera-tional inspections maintain the standard of care and the annual and post-installation inspections establish the owner’s standard of care. The post-installation inspection involves a level of scrutiny that should be performed before the final payment to the playground installation contractors and before the playground opens to the public. A comprehensive playground compliance inspection (post-installation) is based on a national standard/guideline, local legislative action, licensing

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-13authority requirements, local building codes, or even the owner’s self-imposed requirements for the playground as they appear in the owner’s operating policy and subsequently in the project construction documents. The Post-Installation Playground Inspection process is a more comprehensive process which compares the playground to current industry performance standards and the local standard of care within the owner’s jurisdiction against the current existing conditions for: • Each piece of playground equipment• Playground equipment spatial layout • Performance of the impact-attenuating protective surfacing• General playground environment and site amenities While the playground post-installation inspection is only the beginning of a comprehensive playground management plan, it is the foundation of the owner’s overall playground management plan. Inspector Qualifications Required to Conduct Various Playground InspectionsAfter the post-installation playground inspection has been completed and it has been determined the playground is ready for use, the owner’s work has only just begun. It is the owner’s responsi-bility to make sure ongoing inspections are being conducted on a regular routine basis to identify all new non-compliant safety-related concerns on existing playgrounds resulting from rapid or evolving changes caused by such things as vandalism, natural disasters, exposure to the natural elements, wear and tear from normal use, litter, or a play component that simply breaks. The goal of the inspector is to identify, document, and alert the playground owner and/or their appropriate representative of these new or emerging deficiencies during the inspection process so they can be addressed by appropriate corrective action from a qualified playground maintenance technician. Regardless of the quantity or quality of these routine visual and operational playground inspections, some playground owners may have licensing or legislated inspection requirements for specific types of play areas. Some types of playground inspections may require specific inspec-tor education or certification to conduct these specific inspections. The playground comprehensive Post-Installation Inspection or the Playground Compliance Inspection and Assessment (Playground Compliance Audit) and the Annual Main Playground Inspection identifies or establishes the current standard of care for the public playground in com-parison to the current best practices of international playground equipment and surfacing per-formance standards and identifies all deficiencies. The purpose of all other types of inspections such as the more frequent Routine Visual Inspections, Operational Playground Inspections, and the Annual Main Inspection is to maintain the public playground’s established standard of care. This inspection process should address the immediate safety deficiencies of the play environment, function of the equipment and surfacing, and the overall cleanliness, aesthetics, and sanitation of the play area. One of the basic objectives of a routine visual playground inspection is to take care

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Playground Safety Is No AccidentB-14 ©2021 International Playground Safety Institute, LLCof the custodial needs of the play environment. Trash and debris are removed, surfacing is main-tained free of debris, loose-fill surfacing levelled, and the entire playground is briefly inspected for any sudden changes due to normal use, vandalism, or environmental conditions. During these inspections, work orders for remedial maintenance may be submitted when a more complicated repair is deemed necessary. Whenever corrective action is necessary to address new deficiencies and safety-related con-cerns, it is best that it be addressed at the time of the inspection. If a playground inspection detects concerns that might likely cause serious harm to users, the owner should immediately be made aware of the situation. This notice requires some form of immediate corrective action to eliminate the hazard or render the deficiency inaccessible. Timely and thorough inspections, coupled with the application of proper routine preventive maintenance practices, should be considered standard operating procedures. This action requires trained persons with knowledge in not just how to do something, but also why it is required and when it should be done to meet the manufacturer/designer requirements for proper function and safety of operation. While knowledge is most important it also requires a certain amount of skill which comes with experience and additional training. The matrix on the next page illustrates the areas of knowledge and level of competency required to conduct each type of playground inspec-tion and the appropriate and basic maintenance and repair procedures commonly found in a pub-lic play area. An inspector should possess some level of knowledge in each of the six basic areas of competency as identified by several international playground performance standard-writing authorities. The level of competence in each category required by the inspector will vary based on the type of inspection being conducted. A more detailed breakdown of each competence level of knowledge heading is listed after the matrix. Level 1 is the lowest level of knowledge required by the inspector to perform the scope of the type of inspection. When it comes to this level of inspection, the inspector’s knowledge or experi-ence level is next to none. They will learn what they need to know to do their job while on the job. Level 2 competence requires a very basic fundamental base of knowledge for a specific type of inspection. Level 3 competence requires enough knowledge, training, and experience necessary to perform the tasks required of the type of inspection process. Level 4 is a much more detailed and thorough competence level of knowledge, training, and experience in each of the competency categories below. A person with this level of competence should be qualified to conduct all inspec-tion types previously identified in this chapter. Even though the competency levels are shown in four columns, there still is a 5th level. Level 5 would be the highest level of competence in each of the six knowledge categories. This person would be considered an expert in a specific category based on the amount of education, training, and experience related to a specific area of exper-tise. A manufacturer’s lead designer would likely be considered a 5 in the competence category related to “Technical Playground Equipment and Surfacing Production.” A public injury plaintiff or defense attorney might be considered an expert in state and national laws of municipal codes and licensing requirements, and a college professor specializing in early childhood development would be considered an expert when it comes to all things related to a child’s behavior. These experts may be competent and qualified to render opinions related to their area of expertise but it

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-15is less frequent that they would be qualified as an expert in each of these six competence levels of knowledge required by the most comprehensive inspection, review, and analysis of a new product or a new playground layout and design. These reviews are based on a more comprehensive hazard identification and risk/benefit assessment process and would likely require a committee approach to the final analysis report, relying more on persons with more of an expert level of competency knowledge in one or more of the specific categories. The competence level of these knowledge categories can be further defined. The competency goals that a Level 3 inspector should have for Annual and Post-Installation Compliance Inspec-tions should include the following points of knowledge under each learning goal to be considered competent. Competence Level of Knowledge Necessary for Each Level of Inspection TypeLevel 1 Routine Visual Inspection Level 2 Operational and Annual Main Inspection Level 3 Annual Main Inspection/Post-Installation Compliance Inspection Level 4 Playground Layout, Equipment Design, Risk AssessmentIndustry Safety Performance Standards/Technical Reports 1 2 4 4/5Hazard Identication and Risk and Benet Analysis 1 1/3 3/4 4/5Technical Playground Equipment and Surfacing Production and Manufacturing Practices 2 2/4 4 4Child Development 1 2 3/4 4/5Environmental Impact on Materials/ Layout Design/Site Selection Issues 2 3 3/4 4/5Legislation: State or National Laws/State or County Licensing/Local Building Code Jurisdiction/Owner Policies and Requirements 1 2 3/4 4/5Note: Expert level of knowledge is not demanded for playground inspector, but some individuals may be experts at some elds of expertise. Experts may be consulted when a specic question arises.Key (1 = Lowest, 5 = Highest)(1) Next to none(2) Basic fundamental knowledge, skill, and training to perform the task(3) Suitable and sufcient knowledge, skill, and training to perform the task(4) Detailed and thorough knowledge, training, skill, and experience to perform the task(5) Highest possible level of competence to be considered an expert in a specic areaModied from “ISOTR PD CEN/TR 17207:2018 Playground and Recreation Areas – Framework for the competence of playground inspectors.”

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Playground Safety Is No AccidentB-16 ©2021 International Playground Safety Institute, LLCIndustry Performance Standards/Technical ReportsThe inspector should demonstrate at least the following abilities:— To reference the standards and other technical reports and show adequate knowledge and understanding of these. This will include, but not exclusively, the major measurements, test methods for entrapment, entanglement, protrusions, crush/shear, sharp edges and the use of templates, rods and probes, materials, substances, protection against falling, means of access, clearance zones, use zones, and all access and egress requirements, etc.— To know requirements and test methods for all types of equipment, installations, different types and methods of inspection, and frequency of inspection schedules, reports and documentation, performance requirements, and laboratory and field test methods for impact-attenuating surfaces (IAS).— To have sufficient knowledge about dangerous substances, flammability, foundations and loading, structural design, and use of legislative requirements for public play areas.— To have practical ability to identify faults and problems.Hazard Identification and Risk/Benefit Analysis (HIRA)The inspector should demonstrate at least the following abilities:— To carry out a HIRA assessment based on a systematic method which yields consistent results.— To explain the reasoning behind the assessment.— To identify mitigating, preventive, or control measures.— To have knowledge of the different types of playground injuries and varying causes of severity and frequency of accidents that occur in the playground environment.— To recognize the types and causes of accidents that have occurred on various types of equipment and to understand the need for mitigating action.Technical Production and Manufacturing Practices Common to Playground Equipment and Protective Surfacing The inspector should demonstrate at least the following abilities:— To have knowledge of the various types and styles of manufactured equipment commonly found in playgrounds.— To understand the major production and treatment processes commonly used in the manufacture of playground equipment, including their strengths and weaknesses.— To understand the function of impact-attenuating surfacing and to have knowledge of the surfaces commonly available, including the advantages and disadvantages of each.Child DevelopmentThe inspector should demonstrate at least the following abilities:— To have knowledge about children’s development and how this influences their play and actions in play environments.

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-17— To have knowledge about how different types of play environments and play equipment interact with children’s activities and actions and what equipment stimulates certain play activities and supports a child’s development.— To have knowledge about how the total play environment can be designed to meet all children’s needs for play, development, and learning regardless of their gender, age, and level of functioning.— To understand children’s need to encounter risks so they can establish their own risk assessment skills, which will contribute to their development.Environmental Impact on Materials/Layout Design/Site Selection Issues The inspector should demonstrate at least the following abilities:— To understand the design and layout principles of playgrounds.— To understand the need for separation between playgrounds and other recreational sporting activities.— To analyze and critique both proposed and existing playgrounds regarding, for instance, the need for separation of ages, user movement flows, support for supervision, and mitigation of hazards in close proximity and adjacent to the playspace.— To understand common maintenance and safety-related concerns with various site amenities, including fences, gates, tables, benches, walkways, drinking fountains, trash receptacles, shelters, information signage, etc.— To understand the advantages and disadvantages of commonly used surfacing materials.— To identify common shade trees, plants, and other vegetation with their potential hazards in or near to children’s playgrounds.National or State Laws/State or County Licensing/ Local Building Code Jurisdiction/Owner Policy and RequirementsThe inspector should demonstrate at least the following abilities:— To understand the needs for, and requirements of, inspection, record keeping and written documentation.— To know what local, state or national laws, standards, or guidelines apply and to understand their range and legal implications.— To know how to deal with the public, children, and self in a professional manner.— To recognize the vulnerable situations each of the mentioned parties may find themselves in. — To identify ways of reducing personal risk in various potentially difficult situations. Inspectors shall act professionally at all times when working around children and their caregivers. Inspector’s motives for being in and around playgrounds and taking photographs can be questioned.

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Playground Safety Is No AccidentB-18 ©2021 International Playground Safety Institute, LLCThe Need for Adequate TrainingTimely inspections and maintenance help to ensure the safety of the people using the play envi-ronment. Safety of the users is the foundation of the standard of care. Timely maintenance preserves the utility or function of the equipment. We want to keep it working as the designer intended. We inspect for wear of swing hangers or lubricate moving parts to keep them functioning and to prolong the life of the equipment. The goal is to protect and preserve this large financial investment on behalf of our children and those who invested in the development of the playground in the first place. Inspection coupled with routine maintenance should ensure that custodial tasks are being regularly performed to keep the area hygienically clean. Children and animals do make messes in play environments. Some of their messes may spread disease. Bad bacteria are not always visible to the naked eye. Learn how the play areas are being used by observation during routine mainte-nance and inspection procedures. Know the types of unauthorized users, like the local four-legged and winged residents who may frequent the playground area and create other public safety-related issues. Know what kinds of activities are taking place after normal operating hours. Unauthorized two-legged wildlife can also leave behind unsanitary conditions and, worse yet, hypodermic nee-dles and other drug paraphernalia for curious young children to discover. Inspections and routine maintenance also keep the area looking good. We want our play environments to be aesthetically clean and inviting. A messy house is not necessarily a dirty house, but it sends a message to our invited guests. The public will immediately form their opinion, either good or bad. By performing inspections and corrective maintenance and repairs, we are being proactive by eliminating safety-related concerns before they become a big problem or cause a serious injury. All too often, maintenance is perceived as a “fix it” task. This “reactive” approach to maintenance, with staff only responding when there is a problem, does not efficiently or effectively utilize the owners’ resources, nor does it ensure the safety of the users. A proactive approach is the best approach to performing timely inspections and maintenance to identify problems and take correc-tive action before something breaks or someone is injured. The frequency of inspections should be performed often enough to be able to proactively address recurring problems in a timely fashion. The importance of timely maintenance and repairs can never be underestimated. According to one study of injuries that resulted in litigation, more than one out of every three cases alleged that lack of inspection and maintenance was the cause of the injury. As Monty Christiansen, co-founder of the National Playground Safety Institute (NPSI) Program has written, “Imagine how much safer playgrounds would be if we just did two simple things . . . • Make sure all playground equipment has the appropriate surfacing materials under and around it.• Performed regular inspections and maintenance on the playground equipment and the immediate play environment.”

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Part B: Introduction to Levels of Knowledge Competence for Specific Types of Playground Safety-Related Inspections©2021 International Playground Safety Institute, LLC B-19Responsibility for Inspections and Maintenance Is a Shared Responsibility According to the various international playground performance standards, the manufacturer is required to provide the owner with “clear and concise instructions and procedures for the instal-lation of each play structure designed or provided, as well as a complete parts list.” They are also required to provide “inspection, maintenance, and repair instructions, including, but not limited to, what, when, and how to inspect, maintain, and repair.” (ASTM F1487) The owner is obligated to ensure that the equipment is installed according to the manufac-turer’s recommendations. They are also bound to maintain the surfacing within the use zone of each play structure in accordance with the performance standard requirements. The owner is also charged with installing and maintaining appropriate user information and warning signs and should keep accurate records of inspection, maintenance, and repair. The successful comprehensive playground inspection and maintenance program must have qualified and experienced inspectors and maintenance technicians. This book provides the frame-work for the competence of playground inspectors and the maintenance technicians and provides some inspector training tools to help in this endeavor. By implementing some if not all of these recommendations, the playground owner can implement the necessary steps to ensure that their playground inspectors and maintenance technicians can develop the necessary competencies required by persons conducting the various levels of inspections, maintenance, and repairs. The user of this document should understand that the process of implementing and/or man-aging a comprehensive playground inspection and maintenance program begins with the knowl-edge and understanding of the international playground-related terms and definitions commonly used throughout this book and commonly found throughout most international playground per-formance standards. Without this base of knowledge, the owner, inspector, and maintenance tech-nician will feel like they are in a foreign land trying to learn a new language while at the same time listening to input from others who do not seem to be speaking the same language, while at the same time, having to make management decisions on what is actually happening in real time. In summary, I would like to share a couple of concepts I have learned from the Playground Maintenance Technician (PMT) training program currently being offered by the Indiana Univer-sity’s Eppley Institute for Parks and Public Lands (www.playgroundmaintenance.org). The cre-ators of the PMT Course trademarked the slogan “Diamond of Care” ®PDRMA. This risk management approach applies to everything an inspector might be assessing. It is based on four points that are the cornerstone of the Playground Maintenance Technician course content. It starts with KNOWLEDGE. Inspectors must understand their role in maintaining a safer play area. They need to understand what they are dealing with as far as the many materials used to create a play environment. Knowing how naturally occurring conditions cause different materials to deteriorate over the playground equipment or protective surfacing functional life prepares an inspector/maintenance technician to take appropriate actions that could avoid a seri-ous injury. Playground inspector/maintenance technicians need to be able to identify deteriora-tion and evaluate the extent of material deterioration throughout the playground’s useful life.

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Playground Safety Is No AccidentB-20 ©2021 International Playground Safety Institute, LLCAcquiring this basic knowledge is key to the success of the playground inspector and playground maintenance technician. Only with this knowledge can they effectively and efficiently conduct the INSPECTION. The playground owner, or their designated agent, must adopt a good inspection form (tool) to assist the inspector with this step. The inspection form should include all items to be inspected. The content or scope of the inspection will vary based on the type of inspection being performed. Each type of inspection will have a different level of knowledge necessary to complete the inspection. Next, the owner’s inspector/maintenance technician should address all non-compliant safety-related concerns identified during the inspection process in a timely fashion based on the playground owner’s standard of care. This CORRECTIVE ACTION is a vital step in preserving the function of the play equipment and helping to provide a safer play environment for the users. The maintenance technician must also possess the basic knowledge and skills nec-essary to implement the appropriate corrective action. Finally, to complete the process the play-ground maintenance technician, who may also be the playground inspector, must DOCUMENT in writing the conditions needing corrective action, followed by a description of the corrective action once competed. I recommend this process be followed in any public facility inspection and management program based on the four simple principles of the “Diamond of Care.” The second concept is based on a quote from the principal author of the course manuscript, Maintaining Child’s Play ©PDRMA, that sums up the playground inspection and maintenance process, “Maintenance, like fine art, is 90% knowing how, 8% preparation, and 2% execution.” Monty Christian-sen, Professor Emeritus, Penn State University.