Play Area Ground Surfaces and the ADA
Play Area with Poured-in-Place Surface
Most play area ground surfaces must be compliant with the Americans with Disabilities Act (ADA). 2010 ADA Standard 1008.2.6 covers play area [playground] ground surfaces. The photo on the right is representative of a play area with a poured-in-place (PIP) composite surface.
NCA Longitudinal Study
From 2008 to 2012, the National Center on Accessibility (NCA) at Indiana University-Bloomington conducted a longitudinal study on the accessibility of playground surfaces. The research study was funded by the U.S. Access Board (USAB). The information presented in this publication is based on the research findings and presented as guidance to public playground owners and operators.
Longitudinal Study Cover
In 2014, based on the longitudinal study the USAB and the NCA published Surfacing the Accessible Playground - 7 Things Every Playground Owner Should Know About the Accessibility of Their Playground Surfaces. The first page is shown on the right. This document provides seven aspects of play area surfaces that every owner of a play area should know about before the installation. This article focuses on number 7 - Commit to ongoing maintenance of accessible playground surfaces as a responsibility of ownership.
There are three ASTM Referenced Standards that apply to play area surfaces and that are listed in the 2010 ADA Standards including:
ASTM F 1487-01 - Standard Consumer Safety Performance Specification for Playground Equipment for Public Use.
ASTM F 1951-99 - Standard Specification for Determination of Accessibility [Wheelchair Maneuverability] of Surface Systems Under and Around Playground Equipment.
ASTM F 1292- 99 or 04 - Standard Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment.
ASTM 1487-01 - Use Zone
Defines the use zone as the ground area beneath and immediately adjacent to a play structure or play equipment.
Provides for unrestricted circulation around the equipment and on whose surfaces where it is predicted that a user would land when falling from or exiting play structures or equipment.
The graphic above is representative of the use zone surrounding a ground level freestanding arch climber play component. A Use Zone is defined as the ground level area beneath and immediately adjacent to [under and around] a play structure or piece of equipment that is designated by ASTM F 1487, Standard Consumer Safety Performance Specification for Playground Equipment for Public Use, for unrestricted circulation, onto which a child could fall. A use zone is also sometimes called a fall zone. This is the play surface upon which it is predicted a user would land when falling from or exiting the equipment. This area must be filled with some type of resilient playground safety surfacing to help absorb some of the child’s fall. Use zones are designated areas surrounding each item of playground equipment which must be kept empty and free from other structures or decorations.
Note that use zones and accessible routes may or may not overlap. Designing the entire use zone as a congruent accessible route is recommended as a best practice to accommodate the free play behavior of all children navigating the play space.
ASTM F 1951 - Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment (Wheelchair Maneuverability)
Lab Test for Wheelchair Rolling Resistance
ASTM F 1951-99 is a laboratory test measuring the work force required for a 165 (+11 or -4.4) lb. individual in a manual wheelchair to propel across a given surface. This lab test establishes a uniform means to measure the characteristics of surface systems in order to provide performance specifications to select materials for use as an accessible surface under and around playground equipment. The photo on the right is representative of this lab test. Surface materials that comply with this standard and are located in the use zone must also comply with ASTM F 1292 for impact resistance. The test methods in ASTM F 1951 address access for children and adults who may traverse the surfacing to aid children who are playing. When a surface is tested it must have an average work per foot value for straight propulsion and for turning less than the average work per foot values for straight propulsion and for turning, respectively, on a hard, smooth surface with a grade of 7% (1:14). Because this is a lab test, owners of play areas should verify their surface complies with ASTM F 1951-99 before the surface is purchased.
2010 ADA Standard 1008.2.6.1, [Ground Surfaces] Accessibility, states, “Ground surfaces shall comply with ASTM F 1951 (incorporated by reference, see “Referenced Standards” in Chapter 1). Ground surfaces shall be inspected and maintained regularly and frequently to ensure continued compliance with ASTM F 1951.” As discussed above, the tests in ASTM F 1951 are primarily for resistance to rolling a manual wheelchair across the surface of the accessible route in a play area. These tests are in a straight line and include a 90 degree turn.
Playground Surface Excessive Gap
Advisory 1008.2.6, [Play Areas] Ground Surfaces, states, “Ground surfaces must be inspected and maintained regularly to ensure continued compliance with the ASTM F 1951 standard. The type of surface material selected and play area use levels will determine the frequency of inspection and maintenance activities.” The only required accessible surface area includes the accessible route from the entry of the play area, at least one connection to each accessible play component (points of entry and egress) and any clear space requirements adjacent to accessible play components. These surfaces should be inspected for run slope, cross slope, gaps, damage, change in elevation, vertical clearance, resistance to rolling a manual wheelchair across the surface, and impact from a fall. The photo above is representative of an excessive gap that has developed between two different types of surfaces.
While the ASTM F1951-99 protocol does not include a procedure for field testing outdoors at a playground, a field test method has been developed by the same engineering company that developed the original lab test method. A portable instrument known as a Rotational Penetrometer (RP) has been designed to measure the firmness and stability of surfaces. For the purpose of the NCA study, the Rotational Penetrometer was used as the field instrument to measure firmness and stability in lieu of the costly equipment for ASTM F1951-99. Documented research has shown the Rotational Penetrometer to have a high degree of repeatability and reproducibility (ASTM, May 27, 2005; ASTM, September 2010). These research findings also correlate to the lab test.
Again, the test described above is primarily for resistance to rolling a manual wheelchair across the surface of the accessible route in a play area. The RP design includes a wheelchair caster placed on a spring loaded caliber in a metal tripod frame which suspends the caster about 6 inches over the surface. When the caster is released, the spring load gauge replicates the force of an individual in a wheelchair over a given surface. The penetration into the surfaces is measured for readings of “firmness” and “stability.” The photo below is also representative of the rotational penetrometer.
Rotational Penetrometer Used to Measure Firmness and Stability of the Surfaces
National experts recognize the use of the Rotational Penetrometer as a portable and relatively easy device to use for surface testing. The field test method with the RP can be added to the assessment process just as measurements for slope, cross slope, change in level and openings are taken along segments of the accessible route for the play area. The RP can measure those segments for firmness and stability. This can be valuable in assessing how an installed surface performs over time.
ASTM F 1292-99 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment and ASTM F 1292-04 Standard Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment (Impact Attenuation)
2010 ADA Standard 1008.2.6.2, [Ground Surfaces] Use Zones, states, “Ground surfaces located within use zones shall comply with ASTM F 1292 (1999 edition or 2004 edition) (incorporated by reference, see “Referenced Standards” in Chapter 1).” The test in ASTM F 1292 is primarily for impact on the surface from a fall in use zones.
ASTM F 1292-99 and ASTM F 1292-04 establish a uniform means to measure and compare characteristics of surfacing materials to determine whether materials provide a safe surface under and around playground equipment. These standards are referenced in the play areas requirements of the 2010 ADA Standards when an accessible surface is required inside a play area use zone where a fall attenuating surface is also required. The ASTM standards cover the minimum impact attenuation requirements, when tested in accordance with Test Method F 355, for surface systems to be used under and around any piece of playground equipment from which a person may fall.
Impact Attenuation: Lab & Field Test
In the field, ASTM F1292-99/04, Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment, is also known as the “head drop test.” It is a test to make sure the surface in a play area use zone is resilient enough to prevent a life threatening injury from a fall. Resilient is defined as able to recoil or spring back into shape after bending, stretching, or being compressed.
During the test a 6 inch diameter aluminum hemisphere in the shape of a child’s head is dropped from the top of a tripod based on the fall height of play components. The aluminum hemisphere, or missile as it is called, contains an accelerometer. When dropped, the impact attenuation of the surface is measured in G-max and by the Head Injury Criteria (HIC). G-max is a measurement of the maximum acceleration, while HIC measures an integral of the acceleration time. The maximum values allowable by the standard are 200 for G-max and 1,000 for HIC. A TRIAX is the instrument used to conduct this test in the field. The photo below is representative of a TRIAX instrument.
TRIAX Used to Test Impact Attenuation or the Play Surface
So for ADA compliance the owners and operators of playgrounds and play areas need to complete frequent inspections of the ground surfaces for the accessible routes and use zones at these facilities. These inspections should verify compliance with the ASTM guides shown above. The results of these inspections should be documented and certified. Next we will discuss the use zone measurements.
How to measure the use zone in your play area
The basic measurement for a use zone is 6 feet from the perimeter on all sides of the play structure/element, assuming the play structure/element is not greater than 6 feet in height.
The minimum distance of six feet extends from the perimeter of the structure, or its outline when viewed from above. This usually means its base, but if part of the structure overhangs the base, it must be measured from there. If the structure is taller than 6 feet it will need more than a six-foot radius for its playground use zone, depending on the design of the the structure.
Swings
Kids love to jump out of their swings at the height of the arc and try to go as far as they can. This can be thrilling for them, but it means that plenty of care must be taken when designating your swing set’s playground use zone.
A good rule of thumb is that a swing set’s use zone should be at least four times the height of its top rail. Therefore, a swing set that stands 8 feet above the ground needs 32 feet of free use space along the line of the swing direction. This space is recommended to be 6 feet wide on both sides, so the entire use zone should be 12 feet wide by 32 feet in length, centered below the swing when at rest. Note that some swing use zones will overlap.
Slides
Like most structures, the standard playground use zone of six feet applies to slides. However, slides taller than six feet will need additional space around them. It is particularly important that there is plenty of space around the exit of the slide. This discourages other children from dangerously standing in the way, and keeps riders safe even if they move down the slide a bit too quickly. Special attention is typically paid to slides, as they are in what’s called an “entanglement zone”, which means that they are high risk for strangulation.
Climbers
Climbers, whether they are vertical or overhead, follow the same rules of safe playground use zones as other structures. This means a six-foot perimeter on all sides, or higher if the structure exceeds 6 feet in height.
Play Structures
It can be more challenging to provide an appropriate amount of safe use zone for play structures, since they feature so many different types of components linked together.
Keeping the ground around play structures free and unobstructed not only makes it safe for children to climb and play on the upper levels of the structure, it also allows them to run and play around the base. Kids will appreciate having the extra room for free form play activity. No matter how incredible the selection of playground equipment they have access to, kids will always find time for classic games like tag, and for that all they need is some friends and room to play. For these reasons, it is vital to keep play structures far away from each other.
Play Area Surface Maintenance
Maintenance is one of the greatest factors affecting the accessibility of playground surfaces. The accessibility standards require ground surfaces to be inspected and maintained regularly and frequently to ensure continued compliance with ASTM F 1951-99 and 1292. Therefore playground owners should have a thorough understanding of the care and maintenance required for their selected surface systems. Some surface materials may only require seasonal maintenance, while others may require weekly or daily maintenance. The frequency of maintenance is dependent on the surface material and number of users. A brief review of different types of surface materials follows.
Poured in Place Rubber (PIP)
PIP is a wear layer with larger rubber particles and finished with a custom top layer of granular particles. A binding agent is used and the material is poured out on site or “in place” as it gets its name. In the longitudinal study PIP was recorded as the surface material requiring the fewest instances of maintenance.
Maintenance discrepancies include areas where the surface has cracks, buckles, openings or a granular layer had worn away under high traffic areas like swings, transfer steps and the egress at slides. Cracking or flaking of the top layer can lead to divots and openings greater than 1/2 inch. While PIP has the fewest instances requiring maintenance, it is still notable because the surface repairs can be extensive. Repairs must be done by either the original installer or professional who is certified by the manufacturer, resulting in added costs. The patch repairs also necessitate cutting away a larger section of surfacing in order to fill and level the deficient area. The photo below is representative of PIP.
Play Area with PIP Surface
Tiles (TIL)
Tiles are bonded rubber constructed as 2 x 2 squares with interlocking sides.
TIL deficiencies include puncture holes greater than 1/2 inch in diameter and instances where the seams had started to shift or buckle. Puncture holes and shifting seams can create openings and changes in level along the accessible route and at clear ground space for playground equipment. Foreign particles can lodge in seams causing separation including lift from adhesive for the subsurface. Instances of cracking may occur as the product ages. The photo below is representative of TIL.
Swing Play Area with Composite Tile Surface
Engineered Wood Fiber (EWF)
EWF is processed wood ground to a fibrous consistency, randomly sized, approximately 10 times longer than wide with a maximum length of 2 inches. EWF is free of hazardous substances.
EWF is not to be confused with wood chips. The terms EWF and woodchips are often, incorrectly, interchanged. The difference between EWF and wood chips are the additional processes beyond the typical landscape chipper. Unlike woodchips out of the chipping equipment, EWF is shredded again, stamped/flattened and made pliable to the extent that the particles will weave together to create a traversable, impact attenuating surface.
EWF deficiencies include undulating surface material creating changes in level, along with running and cross slopes exceeding the maximum allowable standards. A common location for these discrepancies is at the transition where the EWF is paired with a unitary surface. Surface material is likely to displace at heavy use areas with motion, such as at swings, slides, sliding poles, climbers, spinners and teeter totters. The photo below is representative of EWF.
Play Area with EWF Surface
Hybrid Surface Systems (HYB)
HYB is a multi-layer system where the base layer may consist of either contained or loose particles like shredded rubber or carpet pad and the top layers may be outdoor carpeting, artificial turf, or rubber top mat.
HYB surface systems were observed to have minimal deficiencies, comparable to PIP. Deficiencies observed in HYB include separation at the seams that created openings and changes in level greater than ½ inch, shifting of loose fill in the base layer that may affect running and cross slopes, and artificial turf top layer that may experience a build-up of static electricity requiring application of an anti-static solution. The photo below is representative of HYB.
Play Area with HYB Surface
Other surface materials such as sand, pea gravel, and shredded rubber have been used in playground construction. However, if used as part of the ground level accessible route or included in the use zones of the surface, these surface materials must also meet the accessibility standards, including the referenced ASTM standards.
Before you Buy or Install a New Playground
Before you buy a new playground or resurface a playground surface, the dialogue with the manufacturer or sales rep should address:
Specific written instructions for installation.
Written description of the base, sub-base and required drainage system.
Results of ASTM F1951-99 laboratory tests, including the values for the baseline, straight propulsion and turning runs. The test results should also include a description of how the surface was prepared for the lab tests and should be consistent with the installation instructions.
Results of ASTM F1292-99/04, with written confirmation of the critical fall height for the surface material. These test results should include the depth of the surface material for drop heights. The critical fall height shall be higher than the fall height of the highest equipment on the playground.
Written description of the maintenance and frequency necessary to maintain the accessible route and use zones.
The field test procedures to assess the surface for impact attenuation and accessibility upon initial installation and periodically through the life of the product. This should include selection of an independent testing agent and optimum values for ASTM F1292-99/04 and ASTM F1951-99 when field tested.
A minimum 5-year warranty that stipulates compliance with ASTM F1292-99/04 and ASTM F1951-99, field testing strategy, limitations, exclusions or preconditions, remedies available to the playground owner, and process for making a claim.
Ask the manufacturer for a list of customers in the area that have installed the surface material in the last 5-10 years.
SUMMARY
In summary, play area surfaces can be made of several different materials. All of these surfaces still must be able to comply with the ADA Standards. The Standards have requirements for run slope, cross slope, gaps, damage, change in elevation, vertical clearance, resistance to rolling a manual wheelchair across the surface, and impact attenuation from a fall. Owners of play areas and playgrounds must inspect these installations often, depending on the surface material, to be sure compliance with the ADA Standards is met. Failure to maintain a playground in compliance with ADA Standards can expose the owner and operator of a playground to significant liability.
If you observe a facility that is not ADA compliant and you would like to know how to proceed, please see the link at What To Do When A Building Is Not ADA Compliant or Accessible, or call Richard at 615-752-0060.
ADA Inspections Nationwide, LLC, offers ADA/ABA/FHA accessibility compliance inspections for buildings and facilities, as applicable to the different laws, and expert witness services with respect to ADA/ABA/FHA laws for building owners, tenants and managers. Also, ADAIN offers consulting for home modifications as a CAPS consultant for people wishing to age in place in their homes. For a complete list of services please see ADAIN Services.
Thank you.
Article updated September 2021