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Differences between CPSC Guidelines & ASTM Standard Specifications, Part I

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






Many of the technical requirements stated in CPSC Guidelines are already synonymous with those found in ASTM F1487-07ae1, the "Standard Consumer Safety Performance Specification for Playground Equipment for Public Use." There are many requirements in the ASTM Standard that are not found in the CPSC Guidelines.
Photo Courtesy of Pam Blough, ASLA


In 1981, the Consumer Products Safety Commission (CPSC) published voluntary, non-mandated, safety guidelines for public use playgrounds. These guidelines were issued as a two-volume set of documents. It was revised in 1991 as a single document (#325), and again revised in 1994 and 1997. The changes in the revisions have reflected new injury data and changes in products sold in the marketplace. It is currently being revised again.

CPSC offers many publications that are available free, while the American Society for Testing and Materials (ASTM) Standards have to be purchased. CPSC clearly offers an easier method of distribution of playground safety information in this manner.






CPSC requirement not addressed by ASTM: Bare or painted metal platforms, whirls, or slide beds are out of the direct sun (gets hot, causes burns). There are "hundreds" of incidents where this has resulted in severe burns and costly litigation. In fact, it resulted in one manufacturer and CPSC issuing an alert with corrective measures.


It has been questioned by some whether CPSC should include any technical requirements at all and, if so, should not conflict with those technical requirements stated in the new ASTM #F1487-07ae1 Standard. If CPSC does retain any technical requirements that conflict with those stated in ASTM, then CPSC should provide rationale and injury data for those technical requirements. Since the inception of their guidelines, CPSC has reached their conclusions based upon the 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 #325 have been specifically 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.






The ASTM playground standards have been considered a "manufacturing standard" by some, while the CPSC Guidelines have been considered a "consumer guideline" by others. Most manufacturers attempt, or do comply with both of them, while others do not. However, since they are guidelines, you should ask for written verification when specifying playground equipment.
Photo courtesy of Playground Advisory


Both the ASTM standards and CPSC guidelines should be taken literally, because these are the "standards of care" for the playground industry in the U.S. The largest single member category of ASTM subcommittee F15.29 members are manufacturers, and are on most of the ASTM subcommittees. The ASTM playground standards have been considered a "manufacturing standard" by some, while the CPSC Guidelines have been considered a "consumer guideline" by others. Most manufacturers attempt, or do comply with both of them, while others do not. They are both used and considered by the majority of those in this playground arena for the various phases of playgrounds safety, such as design, planning, layout, installation, supervision, maintenance, inspection, audits and, of course, by attorneys in litigation. The primary focus of the CPSC guidelines is to protect consumers, which are the children.

Public use playground standards published by ASTM have conflicted with standards and guidelines from other countries for some time now. The ASTM subcommittee has put off attempts to harmonize with the CSA (Canadian) Standards, basically due to differences of opinion and injury data between the two countries.

The ASTM F15.29 has long considered, and in fact adopted, certain requirements that were only found in the CPSC Guidelines (document #325). There are still many requirements left for ASTM to adopt, such as sight lines into the equipment, hot metal platforms and slides that cause severe burns, etc.






The primary focus of the CPSC Guidelines is to protect consumers, which are in this case children.
Photo courtesy of Schoor DePalma


Many of the technical requirements stated in CPSC Guidelines are already synonymous with those found in the ASTM public use Standard. It should be noted that there is a multitude of requirements located in the ASTM Standard that are not found in the CPSC Guidelines. However, there are numerous areas where CPSC has a requirement that is not found in the ASTM Standard at all. This article defines what requirements are found in CPSC that are not in the ASTM #F1487-07ae1 Standard. It also provides some rationale that may or may not be printed in the CPSC document for certain requirements.

CPSC Requirements Not Addressed by ASTM

General Hazards

4.5)

  • Suggests to look for surfacing level marker labels, which is critical to maintaining the minimum level of surfacing to reduce the likelihood of injuries.

4.5 and Appendix "C"

  • Loose fill surfacing is not installed over hard surface (concrete, asphalt, etc.)
  • Loose fill surfacing has borders installed or is excavated.

6.1 and Appendix "A" & "C"

  • Proper drainage, slope not too steep

6.2, 12.4.5)

  • Heavily used equipment is dispersed
  • Slides located in uncongested area.

6.2, 11.6, 12.4.8)

  • Requires "clear sight lines everywhere on the playground" ("Layout & Design").

6.3)

  • Does not allow the following in areas with children under five years of age: free-standing climbers with flexible components; parallel bars; chain/cable walks; free-standing arch climbers; sliding poles (vertical); spiral slides more than 360 degrees (the rest in the list are recognized by ASTM)
  • Suggests to separate the 2-5 & 5-12 age groups in the same playground area.

7.2 and Appendix "A"

  • Nothing dented, broken, missing, etc.

8.3, 12.4.4)

  • Bare or painted metal platforms, whirls, or slide beds are out of the direct sun (gets hot, causes burns). There are "hundreds" of incidents where this has resulted in severe burns and costly litigation. In fact, it resulted in one manufacturer and CPSC issuing an alert with corrective measures.

9.1)

  • Shows the drawstring warning label information. (Authors' opinion: This should be required to be located on the playground, not just on this page of this document).

9.7)

  • Retaining walls are highly visible and change of elevation is obvious, or consider bright color.

Appendix "A"

  • Surfacing is not deteriorated
  • Trash receptacles are not full or missing

Appendix "C"

  • Shredded tire used for surfacing do not contain steel and are not flammable.
  • Rubber surfacing tiles are not curled up.
  • Surfacing type is effective in freezing temperatures.







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December 14, 2019, 7:45 am PDT

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