HEALTH AND SAFETY GUIDELINES FOR OPERATORS OF INDOOR PLAY AREAS 0CT 1 7 1997 Massachusetts Department ofPublic Health Injury Prevention and Control Program Division ofPrevention Bureau ofFamily and Community Health Division ofCommunity Sanitation Bureau ofHealth Quality Management March 1997 1, INTRODUCTION A majority of injuries treated in hospital emergency rooms identified as "playground equipment- related" result from falls from equipment to the ground surface. Fatal injuries reported to the US Consumer Product Safety Commission (CPSC) involve falls, entanglement ofclothing or other items on equipment, head entrapment in openings, equipment tip over or structural failure, and impact by moving equipment. Soft Contained Playground Equipment (SCPE) includes large-diameter plastic tubes for children to crawl through, climbing nets, slides, pools or pits ofplastic balls, and padded floor surfaces. There are approximately 600 SCPE pay-for-play centers and over 7,000 similar play spaces at fast food restaurants in the United States. The American Society for Testing and Materials (ASTM) is currently investigating the possibility ofdeveloping voluntary standards for the construction and maintenance of indoor play areas. On March 20, 1996, CPSC issued a report entitled Soft Contained Playground Equipment Safety Review. This report, based on a six month review, thirteen on-site observations, and analysis of injury data, concludes that these play areas are safe alternatives to traditional outdoor playgrounds. Two potential hazards were identified, however: slides should be separate from, and climbing apparatus should not be installed in, "ball pools". CPSC received a report in 1995 that a 13-year-old boy (submerged in a ball pool) was killed when another child, using the slide, landed on the boy. The CPSC has entered into a voluntary agreement with Discovery Zone, Inc., which owns 50 percent of the pay-for-play market, to make these changes. In addition, CPSC has developed a SCPE Safety Checklist found as an attachment to this document. The guidelines enclosed stress that: Access for people with disabilities, including children with special health care needs, must be in compliance with the standards set in Title III ofthe Americans with Disabilities Act and the state's Architectural Access Board. The safety ofeach individual piece ofequipment, as well as the layout of the entire play area, should be considered when evaluating an indoor playground for safety. Equipment design should minimize the risk of falling and injuries from falls. The installation of protective surfacing, including padded flooring under and around all equipment, is crucial. Possible emergency situations should be anticipated by identifying a procedure for managing children with special health care needs, including evacuation ofchildren with mobility impairments. Adult supervision is critical to ensure that children's use ofequipment is age-appropriate, and they are using the equipment properly and within their physical abilities. 3 For the purposes of these guidelines, infant/toddler shall refer to children under two years of age, preschool shall refer to children between 2 and 5 years old, and school-age shall refer to children 5 to 12 years old. The guidelines contained in this document include indoor playground health and safety information. They do not constitute a Massachusetts Department of Public Health (MDPH) standard or mandatory requirement, and MDPH does not envision this guidance as the sole method to minimize injuries associated with SCPE. DESIGN CONSIDERATIONS AND EQUIPMENT SELECTION Because all play areas provide some challenge and because children can be expected to use equipment in unintended and unanticipated ways, adult supervision is always recommended. Play equipment should allow children to develop progressively and test their skills by providing a series ofgraduated challenges. The challenges should be appropriate for age-related abilities and should be ones that children can perceive and choose to undertake. Preschool and school-age children differ dramatically in physical size and ability, as well as in their cognitive and social skills. Therefore, age-appropriate playground designs should accommodate these differences with regard to type, scale, and the layout ofequipment. Attention should be given to the design and placement ofplay equipment. Equipment should be placed so as to allow adequate space to move from one activity area to another. Obstacles in the play areas, such as chairs, tables, barrels, or other protrusions from the floor may cause a child to trip. Merry-go-rounds may present a physical hazard to preschoolers who have little or no control over such equipment once it is in motion. Merry-go-rounds are not recommended unless the rotating platform is continuous and approximately round. Children should be provided with a secure means of holding on. Where hand grips are provided, they should have a diameter between .95 and 1.55 inches. In addition, no component, including the hand grips, should extend beyond the perimeter of the platform. The platform should be free ofopenings 5/16 ofan inch or greater. Merry-go-rounds should not move up and down (oscillate) and they should have a means of limiting the speed. "Climbers" refer to a wide variety ofequipment including, but not limited to, sliding poles, net climbers or "cargo nets", parallel bars, suspension bridges, climbing ropes, and composite structures with linked platforms. Climbing apparatus should not be installed in ball pools. Climbers should not have climbing bars or other structural components in the interior of the structure onto which a child may fall. Climbing equipment is generally designed to present a greater opportunity for physical challenge than other equipment. Because infant/toddlers and young preschoolers have not developed the upper body strength necessary for certain climbing activities, they should be separated and discouraged from using more challenging climbing components. 4 Offering an easy exit offequipment is particularly important on climbing devices intended for preschoolers. Their ability to descend develops later than their ability to climb up. Climbing equipment should allow children to descend as easily as they ascend. One way of implementing this recommendation is to provide easier means ofdescent, such as another mode of access, a platform or another piece ofequipment. For example, a stairway can provide a less challenging mode ofdescent than a vertical rung ladder or a flexible climbing device. Aflexible grid, such as a net climber or cargo net, is a non-rigid component of play equipment that significantly deforms or deflects during the normal use ofthe equipment [See Figure 1]. Net and chain t ' climbers use a flexible grid for climbing. Torn rope equipment or loose sewing connections in the cargo webbing may be an entrapment or tripping hazard. Tire climbers are also flexible climbers. These may have the tires secured tread-to-tread in the form ofa f t sloping grid or may be suspended individually to provide access to an elevated platform. Flexible components do not provide a steady means of u u support, and, therefore, require more advanced balance abilities than conventional ladders. Flexible grid climbing devices are not recommended as a sole means of access to equipment or areas designated for preschoolers. Figure 1: Flexible Grid Flexible grid climbing devices which provide access to platforms should be securely anchored at both ends. When one end is connected to the floor, the anchoring devices should be below the level of the playing surface. Connections between ropes, cables, chains or tires should be securely fixed and free of tears or frays. Preschoolers should be discouraged from using horizontal ladders, overhead rings, vertical climbing ropes, and sliding poles. The space between adjacent rungs of overhead ladders should be greater than 9 inches. The center-to-center spacing of horizontal ladder rungs should not exceed 15 inches. This does not apply to the spacing ofoverhead rings. The first handhold on either end of upper body equipment should not be placed directly above the platform or climbing rung used for mount or dismount. This minimizes the risk cfchildren impacting rigid access structures if they fall from the first handhold during mount or dismount. Sliding poles should be continuous with no protruding welds or seams along the sliding surface. The pole should not change direction along the sliding portion. The horizontal distance between a sliding pole and the edge ofthe access structure to the pole should be at least 18 inches. This distance applies to all points down the pole. All points on the sliding pole at or above the level of the access structure should not be more than 20 inches away from the edge ofthe structure, structure [See Figure 2]. 5 Because of the small size ofchildren's hands, the diameter of sliding poles should be no greater than 1.9 inches. The pole should extend at least 38 inches above the level of the access and the design of the access structure should minimize the possibility of interference from surrounding traffic that may be out ofthe line of sight of a user during descent. Individual, vertically suspended, climbing ropes should be securely anchored to a footing at the lower end to prevent the rope from being looped back on itself and forming a noose or becoming a tripping hazard. Swinging exercise rings, except overhead hanging rings, are not recommended. Exercise rings and trapeze bars are considered to be items ofathletic equipment and are not recommended for public playgrounds. To avoid groin injuries from falls, balance beams should be no higher than 12 inches for preschoolers and 16 inches for school-age children. The support posts for balance beams should not pose a tripping hazard. Figure 2: Sliding Pole Trampolines are also not recommended for use at playgrounds. However, ifthey are available for children's use, they should have trained personnel supervising the activity and four spotters who warn thejumper if he or she is moving offcenter and push him/her back if there is movement toward the edge. There should be only one person on the trampoline at any time. A safety pad should cover the trampoline frame and springs. The impact absorbing surface should extend a minimum of six feet around the perimeter. The condition of the trampoline should be checked for tears or detachments. Supervision and signage should encourage mount and dismount by climbing on or off, not byjumping. As an additional precaution to reduce the height of a fall, the trampoline can be placed over a pit deeper than three feet. Slides should be separate from, and not installed in. ball pools. Slides should be free of gaps and any pinch, crush, shear, entrapment, or entanglement catch points. It is recommended that the average incline of the sliding surface not exceed 30°. and any change in the slope of the slide, such .... in a wave slide, should net allow a child to lose contact witn .ne sliding surface. The sides of a flat sliding surface should be no less than four inches high. The minimum internal diameter of a Tube Slide should be no less than 23 inches. Roller slides should not be used unless frequent maintenance can be guaranteed. The spaces between rollers should not admit a neoprene rod 3/16 of an inch. Consideration should be given to extra supervision on areas that include Tube Slides. Special precautions should be taken in order to prevent pile ups at the bottom of a slide. When a child prepares to slide down a Tube Slide, a Spiral Slide, or a slide that exits in a ball pit, he or she should have a clear view of the previous slider(s). Supervision should include an "All Clear" signal; children may not move out of the exit zone quickly, so extra attention must be paid in order to prevent pile ups. 6 CONSTRUCTION AND INSTALLATION Installation, maintenance and use ofequipment, including surface materials, should follow the manufacturer's instructions. Installers, ifdifferent than the manufacturer, should not deviate from these instructions. The manufacturer's instructions should be kept on file by the operator. All play structures must earn' a durable warning label and separate manufacturer's identification. Labels should not be able to be removed without a tool. When properly installed, the equipment should withstand forces that may overturn, tip. slide or move it in any way. Care should be taken with the use of flammable materials. Flooring, upholstered and plastic furniture, and hanging decorations present potential hazards. Burning plastics generate excessive heat and smoke in a fire. Manufacturers may use testing laboratories for assessing flame resistance and the risk of flammability. This information should be supplied to play facility operators from the manufacturer and kept on file. Some unitary materials (mats, tiles, and poured rubber surfaces) can be laid directly on hard surfaces such as concrete. Others may require expert under-surface preparation and installation by the manufacturer or a local contractor. Undersurfacing may be critical for thinner materials. In addition, such materials should be installed on uniformly level surfaces since full rubber tiles may curl up and cause tripping if installed on an uneven surface. All paints and other similar finishes must meet the CPSC regulation for paint (0.069c maximum lead by dry weight). The manufacturer should ensure that the users of play equipment cannot ingest, inhale, or absorb potentially hazardous amounts of substances as a result ofcontact with equipment. Operators ofplay facilities should maintain documentation from the manufacturer that the treatments applied to the equipment will not present a hazard to the consumer. All hooks, including S-hooks. should be closed as tightly as possible [See Fig..ie 3]. When installed and tightened in accordance with the manufacturer's instruction, all fasteners, connecting, and covering devices should not loosen or be removable without the use of tools. Lock washers, self-locking nuts or other locking means should be provided for all nuts and bolts to protect them from detachment. Hardware in movingjoints should also be secured against unintentional or unauthorized loosening. Bearings used in movingjoints should be easy to lubricate or be self-lubricating. Nuts, bolts and other protrusions should be recessed and. ideally, be capped. In addition, no opening should be greater than 5/16 of an inch and less than 3 1/2 inches; openings of this size pose a finger entrapment hazard. There should be no sharp points, corners, or edges on any components ofplay equipment which could cut or puncture children's skin. There should be no accessible pinch, crush, or shearing points on play equipment that could injure children or catch their clothing [See Figure 4]. Such points can be caused by components moving relative to each other or to a fixed component when the equipment moves through its anticipated use cycle. To determine ifhazards ofthis type exist, consider the likelihood ofentrapping a body part and the configuration and closing force ofthe components. Figure 4: Pinch-Crush Parts Protrusions or projections on play equipment should not be capable ofentangling children's clothing; such entanglement can cause serious injury or death by strangulation. No protrusion should extend beyond the face ofthe gauges recommended by CPSC [See Figure 5]. Particular attention should be given to avoiding protrusions or projections at the top ofslides to minimize the risk ofentanglement with clothing. Since clothing with hoods or drawstrings have been implicated in serious injury and fatality, children should be discouraged from wearing these or an; other loose material (scarves, name tags, necklaces on strings, etc.) while on play equipment. Figure 5: Protrusions or Projections Fixed equipment, as well as moving equipment in its stationary position, should be tested for entrapment hazards. A component or group ofcomponents should not form openings that could trap a child's head, regardless of his or her height above the ground. Even those openings that are low enough to permit children to touch the ground with their feet can present a risk of strangulation for an entrapped child. Younger children may not have the necessary cognitive ability and motor skills to extricate their heads, especially if scared. A child's head may become entrapped ifthe child attempts to enter an opening either feet first or head first. Head entrapment by head-first entry generally occurs when children place their heads through an opening in one orientation, then, after turning their heads to a different orientation, they are unable to withdraw from the opening. Head entrapment by feet-first entry typically involves children who are sitting or lying down and slide their feet into an opening that is large 8 enough to permit passage oftheir bodies but not large enough to permit passage of their heads which then become entrapped. An opening may present an head entrapment hazard if the distance between any interior opposing surfaces is greater than 3.5 inches and less than 9 inches. When the dimension ofan opening is within this potentially hazardous range, all dimensions ofthe opening must be considered together to fully evaluate the possibility ofentrapment. This applies to all completely-bound openings, except where the ground serves as an opening's lower boundary. The most appropriate method to determine whether an opening is hazardous is to test it using the following fixtures, methods, and performance criteria. When tested in accordance with CPSC B2.1, B2.2 and B4, an opening conforms to the requirement if the opening does not admit a template 3.5 inches by 6.2 inches or admits the 3.5 X 6.2 template and also admits a round template 9 inches in diameter. An opening fails to conform to the recommendation if it admits the smaller template but does not admit the round template. In cases ofa completely-bounded opening with a depth of penetration such as a vertical wall behind a stepladder, the entrapment potential depends not only on the dimensions of the opening between adjacent steps but also those of the horizontal space between the lower boundary ofthe opening and the barrier [See Figure 6]. A child may enter the opening between adjacent steps feet first and may proceed to pass through the space between the rear of the lower step and the barrier and become entrapped when the child's head is unable to pass through either of these two openings. The procedures for conducting this type of test are described fully in the CPSC Handbookfor Public Playground Safety. Climbing components, such as flexible nets, require two three-dimensional test probes because the size and shape ofthese openings can be altered when force is applied, such as when a child climbs on or falls through the openings. A non-rigid opening may conform to the requirements in one of two ways: 1)the opening does not permit complete passage of the smaller template in accordance with the procedures described in CPSC, or 2)the opening allows complete passage of the small template and the round template when tested in accordance with the procedure in CPSC. A non-rigid ope^:ig does not conform to the entrapment requirements if it allows complete passage of the smaller template but does not allow complete passage ofthe round template. 9 The angle at the point of any intersection should not be less than 55°, unless the lower leg of the angle is horizontal or projects downward. A rigid shield may cover angles less than 55°. Cables, wires, ropes or similar flexible components should not be suspended between play units within 45° of horizontal ifless than seven feet above the play surface. These suspended hazards should not be located in areas ofhigh traffic because they may cause injuries to a moving child. LOCATION, SIGNAGE AND AGE SEPARATION Safety guidelines should be clearly posted. The guidelines should explain proper equipment use. Nothing can replace appropriate supervision in creating a safe environment, but signage can assist the user and the supervisor in monitoring play behaviors appropriately. Signs should provide warnings and rules for proper usage. Consolidate as many signs as possible; excessive warnings in one setting may confuse the user. Signs should, wherever possible, use both symbols and short, simple, bolded statements. Prohibition signs should carry the international symbol in red: a circle with a slash from left to right. A triangle with an exclamation point should precede the word warning on signs. Children that meet the size restriction for the toddler sections should not be allowed in the older children's section(s). Smaller children are at a disadvantage in a collision with a larger child. Older, larger children should be prevented from playing in the toddler section. It is recommended that play facilities have separate areas for younger children with appropriately sized equipment and materials to serve their less advanced developmental levels. The design and scale ofequipment should make the intended user group obvious. The areas should be separated at least by a buffer zone of ample physical space. Signs posted in the play area can be used to give some guidance to adults as to the age appropriateness of the equipment. The play area should be organized into different sections to prevent injuries as a result of conflicting activities and children running between activities. Moving equipment, such as merry- go-round and cable rides, should be located in a corner or on the edge of the play area. Slide exits should also be located in an uncongested area. Active, physical activities such as slides or ball pits should be separate from more passive or quiet activities such as sandplay tables or doll play areas. In addition, popular, heavy-use pieces ofequipment or activities should be widely separated to avoid crowding in any area. The layout ofequipment and activity areas should be planned to avoid visual barriers; there should be clear sightlines everywhere in the play area to facilitate supervision. Ideally, adults should be able and encouraged to accompany the child through the structure at least once in order to know what is there and to ensure the child knows how to use it. Infant/toddler areas should provide appropriate spaces for adults to supervise the play. Signs should be posted that tell adults how to reach a child in all pans ofthe play structure. 10 PROGRAM OPERATIONS Although these suggestions are meant to prevent injury or illness, the fact remains that personnel may need to respond to an emergency, usually with no advance warning, and may need to activate the emergency medical service (EMS) system. In order to be ready, every indoor play space should have an up-to-date written plan for responding to an emergency. All staffshould be familiar with the plan which should describe four areas ofresponsibility: recognizing that an EMS emergency has occurred; providing immediate first aid; contacting the local system; and familiarity with the map ofthe Evacuation Plan as well as an alternate route. The telephone numbers of the local EMS system, the locations of first aid kits, fire extinguishers, and routes of evacuation should be clearly posted for all personnel and adults. Upon employment, each employee should be required to review the Emergency Plan. At least one clearly identified staff person trained and certified in First Aid and CPR should be on site during hours ofoperation. Staff should be able to demonstrate familiarity with the policies and procedures and to locate and operate fire extinguishers. The facility should have a plan for emergency transportation to a local hospital or health care facility, a roster ofchildren within the facility at any give time, and designated personnel responsible for maintaining the first aid supplies. Since proper care within the first hour or so following a dental injury may save a tooth, the facility should maintain the names, phone numbers and addresses of licensed providers of pediatric dental care who have agreed to accept emergencies. Safety guidelines should be clearly posted. The guidelines should explain proper equipment use and operator policies. Staff should be trained in and familiar with all safety-related policies and procedures. The fire/evacuation procedure should be approved by a fire inspector and practiced by staff regularly. Anticipate possible emergency situations by identifying a procedure for managing an evacuation ofall children including those with special health care needs or mobility and sensor) impairments. Choking on food or objects is of special concern. Size, shape, and consistency are the most likely factors in determining whether a food or an object is apt to block the airway. Round foods, conforming or pliable foods, and foods ofa size that can obstruct the airway are particularly hazardous. These food may include hot dogs, nuts, hard candies, carrots, popcorn, chewing gum, grapes and raisins. These types of snack food should be avoided in food service areas. Children will put anything in their mouths. Small, chokab'e objects should be discouraged from being brought into indoor play areas. These objects may include small parts of a toy, deflated balloons, jewelry, button batteries, safety pins, crayon pieces and coins. All chokable items, both edible and non-edible items should be prohibited from use on SCPE. The use ofepinephrine (or epi pens) requires a physician or a properly trained certified EMS A professional. child with no history of allergic reaction should be transported to a hospital facility by ambulance. When a child has a known allergy or pre-existing medical condition. 11