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Differences between CPSC Guidelines & ASTM Standard Specifications, Part II

By Scott Burton, CPSI, SAFE and Dr. Art Mittelstaedt






CPSC mandates tot (infant) swing seats be at least two feet above the surfacing, whereas ASTM says one-foot for all ages and all seats, including tot seats.


To recap from part I, back in 1981, the Consumer Products Safety Commission (CPSC) published a two-volume set of documents of nonmandated, safety guidelines for public use playgrounds based on National Electronic Injury Surveillance System (NEISS) injury data, studies and tests performed on equipment and surfacing, and in consideration of any "unreasonable risks of serious injury or death" (as found in recall notices). The CPSC guidelines were revised in 1991 in a single document (#325), revised in 1994, 1997 and is now being revised again.






CPSC guidelines say the slope to define a stairway is no more than 35 degrees vs. ASTM's requirement of less than 50 degrees. CPSC's rule does not allow for the 35-50 degree range.


The CPSC Guidelines are considered by some as consumer guidelines. While many technical requirements in CPSC are found in ASTM F1487-07ae1 ("Standard Consumer Safety Performance Specification for Playground Equipment for Public Use"), generally considered a manufacturing standard, there are many requirements in ASTM not found in CPSC.






There are far too many instances of 'interpretation' when one is only looking at quantifiable conclusions, such as the height of a slide or a pipe wall, or a six-foot use zone to the edge of a concrete sidewalk.


The CPSC Guidelines #325 have been adopted into law in some form or its entirety in at least 17 states. The ASTM Standard #F1487 has been adopted into law in some form or its entirety in seven states. Clearly, at least 10 states have recognized the CPSC Guidelines as the primary standard of care that prevails over the ASTM Standard Specification. Note: CPSC offers many publications that are free, while you have to buy the American Society for Testing and Materials (ASTM) Standards.






Handrail heights on stairways and stepladders are different for CPSC guidelines. The vertical distance between the top front edge of the step and top surface of the rail must be 22"-26" for 2-5 year olds, vs. 22"-38" for all ages in ASTM (and 5-12 year olds in CPSC).


CPSC Requirements Not Addressed by ASTM

Various Hazard Identification

5.1.2 -- Slides

  • The slide use zone at the exit end of slides is calculated differently than ASTM. The slide entry height, minus the exit region height = slide height (H). H+4 ft. measured from 5 degrees (on exit region of bedway, or end of slide exit if 5 degrees is unknown) is the use zone, a minimum of 6 ft. and max. of 14 ft. ASTM says the height of the slide (entry point height, less exit region height) is the use zone, 6 ft. minimum, 8 ft. maximum. CPSC exempts sides of embankment slides for use zone, while ASTM does not.

6.3 & 12.1.4 -- Age-Separation of Equip./Arch Climbers

  • Free-standing arch climbers are not recommended for children under 5 years.

6.3, 12.1.6 -- Sliding Poles

  • Sliding poles are not recommended for children under 5 years.

7.1.1 & 9.7 -- Stability/Tripping Hazards

  • Footings are below base of surfacing.

10.1 -- Stairways, Ladders, Handrails

  • Platforms over 6 ft. tall (except free-standing slides) have an intermediate standing surface (to go back).
  • Flexible climbers not recommended as the sole access to equipment for preschoolers. Note: ASTM states this requirement but does not limit it to any age range of users.

10.2.1 -- Rungs

  • All rungs should be secured in a manner that prevents them from turning. Note: In ASTM 8.2.1 there is a similar rule but only applies to climbers, whereas CPSC includes this for climbers, stairs, ladders.
  • Table 2: CPSC says the slope to define a stairway is no more than 35 degrees vs. ASTM's requirement of less than 50 degrees. CPSC's rule does not allow for the 35-50 degree range.
  • Handgripping diameter is not restricted to only "rigid" rungs like ASTM specifies. It was the intent of CPSC to not apply this to nonrigid rungs, and they will likely make this correction in the next draft.

10.3.1 -- Handrail Heights

  • Handrail heights on stairways and stepladders are different for CPSC. The vertical distance between the top front edge of the step and top surface of the rail must be 22”-26” for 2-5 year olds, vs. 22”-38” for all ages in ASTM (and 5-12 year olds in CPSC).
  • CPSC says to have a continuous handrail the full length of the access on stairs and steps "regardless of the height of the access," whereas ASTM limits a handrail to those with more than "gone tread."

11.2, 11.6 -- Guardrails

  • Guardrails and barriers are not climbable
    11.3 (paragraph 4) -- Guardrail Heights
  • For preschool-age children, platforms that are layered and are more than 20 inches apart have guardrails or barriers.
  • For school-age children, platforms that are layered and are more than 30” apart have guardrails or barriers.

11.6 -- Other Design Considerations for Guardrails

  • Guardrails and barriers do not hinder supervision or viewing

12.1.2 -- Design Considerations

  • Climbers should not have climbing bars or other structural components in the interior of the structure onto which a child may fall from a height of greater than 18 inches. This was originally intended for tower climbers and Geodomes, but applies to other climber designs as well to reduce (primarily) internal injuries.
  • If an arch climber is used as an access component (i.e.; an elevated platform on a composite structure) and there is no other access component, the top rung is no more than 18” below the platform (no max. distance if other access is present). Note: CPSC references Section 10 for "stepped platforms," but that is a typo from the 1994 edition, as stepped platforms are in 11.7. (Editor's note: Search online for CPSC #325 and you will find the entire document.) Climbing devices intended for preschoolers offer an easier, alternate choice of descent.

12.1.4, Table 2 -- Arch Climbers

  • Arch climber rungs must be no more than 12” apart "tread to tread" (or, on center).
  • Arch climber rung width must be no more than 12” (for ages 2-5) / no more than 16” (for ages 5-12)

12.1.5 -- Horizontal Ladders, Rungs

  • Suggests that user ages remain 4-12 for horizontal ladders and overhead rings.
  • Maximum length of chains suspending overhead swinging rings is 12 inches. Note: The ASTM max. is 7” including connectors ("S" hooks, etc.), so ASTM is more stringent.
  • For 2-5 year old users, overhead rungs are parallel to one another and evenly spaced.
  • For 2-5 year old users, fixed horizontal ladder rungs must remain no more than 12 inches apart.
  • 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 (to prevent impact).

12.1.6 & 12.1.9 -- Sliding Poles/Climbing Components

  • Sliding pole and its access structure are not located where it interferes with traffic from other events (such as horizontal ladders, etc.).

12.1.9 -- Layout of Climbing Components

  • The design of adjacent play structures should not facilitate climbing to the top support bars of upper body equipment.

12.2 -- Merry-Go-Rounds

  • Whirls (merry-go-rounds) have no openings between the axis and the outer edge that allow a 5/16 inch diameter rod to pass through.
  • CPSC says the max. speed is 13 feet per second, while ASTM's formulas are more stringent for speed on whirls less than 10 feet in diameter. Note: ASTM exempts whirls that are less than 20 inches diameter from speed limitation tests, while CPSC does not.

12.4.3 -- Slide Platforms

  • Minimum platform depth for slide entry is 22 inches. ASTM requires a minimum of only 14 inches. The scientific studies done by CPSC for this subject took into consideration various factors. CPSC (22”) will pass most slide platforms, but ASTM (14”) will restrict the space for users on those that fail CPSC's requirement.
  • Handholds (when applicable) are required to extend high enough for the largest child in a standing position and for the smallest child in a sitting position.
  • There should be a means to channel user into sitting position. The design does not encourage climbing.

12.4.5 -- Slide Exits

  • Slide exits are located in uncongested area (also in 6.2).

12.4.6 -- Embankment Slides

  • Embankment slides are no more than 12” above the surfacing, and minimizes the likelihood of skateboarders / bicyclists using it.

12.4.7 & 6.3 -- Spiral Slides

  • Spiral slides that turn more than 360 degrees are not recommended for children under 5 years.

12.4.8 -- Tube Slides

  • Tube slides are designed to prevent sliding on top (outside) of tube.
  • Tube slides are designed to allow a line of sight into the tube.

12.6.2 -- Single-Axis Swings

  • CPSC identifies "plastic" swing seats as acceptable.
  • Strap (belt) swing seats must be at least 12” above the surfacing for 2-5 year olds, and at least 16” for 5-12 year olds (whereas ASTM says 12” for all ages and all seats, including tot seats).
  • Swings intended for children under 5 years of age must have the pivot points no higher than 8 ft. above the surfacing.

12.6.3 -- Tot Swings

  • Tot swing seats are on a separate structure or separate bay from other types of swings.
  • Tot (infant) swing seats must be at least two feet above the surfacing (whereas ASTM says one-foot for all ages and all seats, including tot seats).

12.6.5 -- Swings Not Recommended

  • Rope swings are not allowed (may form a loop and strangle user).






Rope swings are not allowed under CPSC guidelines (may form a loop and strangle user). You're not likely to find a rope swing on a city playground, however, we know of one at a Pennsylvania water park.


Conclusion

The only time that there is confusion in the marketplace is when there happens to be a misinterpretation of a requirement, or which of the two guidelines is more stringent. Follow the most stringent rule and it becomes confusion-free. Professional judgment usually does not come into play. For example, ASTM and CPSC differ on how to calculate the use zone of a slide exit region. Assuming there is legitimate rationale for both, one simply needs to perform both methods and select the more stringent of the two. There are far too many instances of "interpretation" when one is only looking at quantifiable conclusions, such as the height of a slide or a pipe wall, or a 6 ft. use zone to the edge of a concrete sidewalk. There is nothing to misinterpret here, yet "It's a matter of interpretation" is typically used as an excuse. It works both ways. A playground inspector could identify a "hazard," but when the error of the conclusion is pointed out, the inspector may be the one making excuses. It may be lack of training and/or retention of the rules by the individual. The point is, most of it is cut and dry if the rules are understood in the first place.

There are many things CPSC should include that are in ASTM, such as restricting overhead obstructions like tree limbs and power lines located close to users. We urge CPSC to continue with its technical performance requirements, since there is an established rationale for them.

It is not the duty of CPSC to drop technical requirements because some folks do not like it. Any injury data or research-related differences in technical performance requirements in the CPSC #325 document that contradicts ASTM #F1487 should be fully supported.







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October 15, 2019, 4:54 am PDT

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