Accessible Play Areas as Defined by the ADA
Some information below provided by the US Access Board
Play Area with Play Components
Most play areas must comply with the Americans with Disabilities Act (ADA). The photo on the right is representative of play components installed in a play area.
A play area is defined in the 2010 ADA Standards as “a portion of a site containing play components designed and constructed for children.” A play component is defined in the 2010 ADA Standards as “an element intended to generate specific opportunities for play, socialization, or learning. Play components are manufactured or natural; and are stand-alone or part of a composite play structure.”
ADA compliance at play areas is important because this is an opportunity to teach inclusion and integration to the disabled and not-disable and the young and not-so young at the earliest possible time.
Accessible play areas are covered primarily in the 2010 ADA Standards 240 and 1008. Other Standards may be applicable to a play area installation such as for parking and accessible routes to the play area. The first regulations for accessibility of play areas were published in 2002. In 2004 updated guidelines were published. Any new construction or alterations for play areas that were completed after March 15, 2012 should comply with the 2010 ADA Standards. Because play areas were not addressed in the 1991 ADA Standards, play areas are excluded from safe harbor provisions. Play areas for federal sites were covered in the Architectural Barriers Act (ABA) starting on May 8, 2006.
2010 ADA Standard 240.1 [Play Areas] General, states, “Play areas for children ages 2 and over shall comply with [Standard] 240. Where separate play areas are provided within a site for specific age groups, each play area shall comply with [Standard] 240.” The following exceptions apply:
Play Area at Home Based Day Care
1. Play areas located in family child care facilities where the proprietor actually resides shall not be required to comply with [Standard] 240. [This could include a home-based day care facility. The installation shown on the right is representative.]
2. In existing play areas, where play components are relocated for the purposes of creating safe use zones and the ground surface is not altered or extended for more than one use zone, the play area shall not be required to comply with [Standard] 240.
3. Amusement attractions shall not be required to comply with [Standard] 240. An amusement attraction is defined as “any facility, or portion of a facility, located within an amusement park or theme park which provides amusement without the use of an amusement device. Amusement attractions include, but are not limited to, fun houses, barrels, and other attractions without seats.”
4. Where play components are altered and the ground surface is not altered, the ground surface shall not be required to comply with [Standard] 1008.2.6 unless required by [Standard] 202.4, [Alterations Affecting Primary Function Areas].
Therefore, those play area facilities that are covered by the 2010 ADA Standards include:
State and local governments (Title II) – schools, municipal parks and recreation departments, state parks, etc.
Places of public accommodation (Title III) - privately run day care at a public facility, private schools, quick serve restaurants, shopping malls, etc.
Those play area facilities that are not covered by the 2010 ADA Standards include:
Child care centers that are actually run by religious entities such as a church run day care which includes religious instruction
Private residential – HOA rules may apply
Play areas may be located on exterior sites or within a building. Where separate play areas are provided within a site for children in specified age groups (e.g., preschool (ages 2 to 5) and school age (ages 5 to 12)), each play area must comply with 2010 ADA Standard 240.1. Where play areas are provided for the same age group on a site but are geographically separated (e.g., one is located next to a picnic area and another is located next to a softball field), they are considered separate play areas and each play area must comply with 2010 ADA Standard 240.1.
Note that soft contained play structures are not the same as a play area.
Types of Construction: New, Additions, and Alterations
Play areas can be built completely new from the ground up, additions can be installed at an existing play area, and alterations can be made to an existing play area. As discussed above, new construction should comply with the 2010 ADA Standards.
Play area additions should also comply with the 2010 ADA Standards. 2010 ADA Standard 240.1.1, [Play Areas] Additions, states, “Where play areas are designed and constructed in phases, the requirements of [Standard] 240 shall apply to each successive addition so that when the addition is completed, the entire play area complies with all the applicable requirements of [Standard] 240.”
For example, a play area is built in two phases. In the first phase, there are 10 elevated play components and 10 elevated play components are added in the second phase for a total of 20 elevated play components in the play area. When the first phase was completed, at least 5 elevated play components, including at least 3 different types, were to be provided on an accessible route. When the second phase is completed, at least 10 elevated play components must be located on an accessible route, and at least 7 ground level play components, including 4 different types, must be provided on an accessible route. At the time the second phase is complete, ramps must be used to connect at least 5 of the elevated play components and transfer systems are permitted to be used to connect the rest of the elevated play components required to be located on an accessible route.
Alterations vs. Maintenance
An Alteration to Replace Play Area Surface
Some times it is difficult to know if a project is an alteration or normal maintenance. The 2010 ADA Standards define alteration as “A change to a building or facility that affects or could affect the usability of the building or facility or portion thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, changes or rearrangement of the structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions. Normal maintenance, reroofing, painting or wallpapering, or changes to mechanical and electrical systems are not alterations unless they affect the usability of the building or facility.” Examples include removing a climbing play component & replacing it with a spring rocker, or changing the ground surfacing. The photo above is of the installation of a new play area surface.
Worn S Hook and O Ring
Normal maintenance activities such as replacing worn “S” hooks or topping off ground surfaces are not considered alterations because you are only returning to the characteristics that were already there. The photo on the right is of a worn “S” hook and “O” ring, perhaps for a swing set. In this case both elements of the installation should be repaired or replaced.
Remember, when altering a primary function area, there is an additional obligation to ensure the path of travel to the altered primary function area is accessible. In other words, in compliance with the ADA. It is in these cases that the 20% Disproportionality rule may come into play. See § 36.403 Alterations: Path of travel, (f) Disproportionality, for Title III facilities. A similar rule applies to Title II.
In all play area installations that must comply with the ADA, Title II and Title III facility owners and operators of play areas must maintain the accessible features and elements in working order.
Terms and Application of Play Area Standards
In the second paragraph above the definitions of play areas and play area components were provided. Another example of an accessible play area with play components is shown in the photo below. Note the green accessible route within the play areas and the concrete accessible route to/around the different play areas.
Aerial View of an Accessible Play Area
In the photo above there is a combination of ground-level and elevated play components. Note that not all play components are accessible, which is allowed by the ADA Standards.
Geographically Separated Play Areas
Also in the photo above you can see there are two play areas geographically separated by the concrete walkway, one large play area and one small play area. The smaller play area is designed for younger/smaller children. Both play areas must be accessible. Remember, 2010 ADA Standard 240.1 [Play Areas] General, states, “Play areas for children ages 2 and over shall comply with [Standard] 240. Where separate play areas are provided within a site for specific age groups, each play area shall comply with [Standard] 240.” The graphic on the right is also representative of this requirement because there are two play areas on the same site but geographically separated by a school building.
Aerial View - Area of Sport Activity
It is important not to confuse a play area with an area of sport activity. An area of sport activity is defined in the 2010 ADA Standards as “that portion of a room or space where the play or practice of a sport occurs.” The photo on the left is representative of an area of sport activity where there are fields for baseball, softball, soccer, and also some tennis courts. The same would apply to other sports like football, miniature golf, and frisbee golf. Play areas can be co-located with areas of sports activities, but these two types of facilities are considered separate with respect to the ADA. For additional information please see Sport Activity Floor and Ground Surfaces.
Accessible Routes
The requirements for an accessible route are different depending on whether you are inside the play area or outside the play area. The photo below is representative. In this photo the white line separates the area inside the play area from the area outside the play area.
Accessible Routes Inside and Outside a Play Area
All accessible routes have requirements for surface conditions, clear width, clear width reductions, changes in level, running slope, cross slope, openings, and protruding objects.
Outside the play area the route walking surface is typically sloped less than 5% in the run direction [2010 ADA Standard 403.3]. If the route outside the play area is sloped greater than 5% that surface would need to be installed as a ramp and typically is sloped not steeper than 1:12, or 8.33% [2010 ADA Standard 405.1]. Also, outside the play area the width of the accessible route must be 36 inches, minimum, with some exceptions [2010 ADA Standard 403.5.1].
Inside the play area the requirements for an accessible route are modified when compared to outside the play area. 2010 ADA Standard 1008.2, [Play Areas] Accessible Routes, states, “Accessible routes serving play areas shall comply with [2010 ADA] Chapter 4 and [Standard] 1008.2 and shall be permitted to use the exceptions in [Standards] 1008.2.1 through 1008.2.3. Where accessible routes serve ground level play components, the vertical clearance shall be 80 inches high (2030 mm) minimum.”
2010 ADA Standard 1008.2.4.1, [Play Areas] Ground Level, “At ground level, the clear width of accessible routes shall be 60 inches (1525 mm) minimum.” The intent here is to provide increased width because the surface beyond the accessible route at a play area may not be usable. Plus, this wider accessible route allows individuals to turn at any point, perhaps to chase another individual or otherwise continue to play. Remember, the accessible route inside the play area is also part of the play structure. There are two exceptions to this Standard.
Small Play Area Accessible Routes
1. In play areas less than 1000 square feet (93 m2), the clear width of accessible routes shall be permitted to be 44 inches (1120 mm) minimum, if at least one turning space complying with [Standard] 304.3 is provided where the restricted accessible route exceeds 30 feet (9145 mm) in length. The graphic on the right is representative of this exception.
2. The clear width of accessible routes shall be permitted to be 36 inches (915 mm) minimum for a distance of 60 inches (1525 mm) maximum provided that multiple reduced width segments are separated by segments that are 60 inches (1525 mm) wide minimum and 60 inches (1525 mm) long minimum. The graphic below is representative of this exception.
Accessible Route Width Reduction Inside a Play Area
2010 ADA Standard 1008.2.4.2, [Play Area, Accessible Route, Clear Width] Elevated, states, “The clear width of accessible routes connecting elevated play components shall be 36 inches (915 mm) minimum.” Wider is preferred and recommended, but only 36 inches width is required for routes connecting elevated play components. The photo on the left is representative of an accessible route connecting elevated play components. Note that the wider route width (5 feet in the photo above) allows two people in wheelchairs to pass. There are some exceptions to this Standard to allow for more narrow widths for a short distance on the route and a narrow width for transfer systems. Note that an elevated play component can also serve as an elevated route connecting two play components.
Ramps within play areas are limited compared to ramps that are not in play areas. 2010 ADA Standard 1008.2.5.1, [Ramps] Ground Level, states, “Ramp runs connecting ground level play components shall have a running slope not steeper than 1:16.” The photo below is representative of this Standard where the slope of the route between the exit and entry point of this play component should not exceed 1:16, or 6.25%.
2010 ADA Standard 1008.2.5.2, [Ramps] Elevated, “The rise for any ramp run connecting elevated play components shall be 12 inches (305 mm) maximum.” So when the elevated ramp rise reaches 12 inches vertical change there must be a landing, at the top and bottom of the ramp, to allow for resting. The photo below is representative of this Standard and showing a landing at the bottom of an elevated ramp.
Maximum Elevated Ramp Rise is 12 Inches
Play Area Ramp Handrail
Handrails for ramps in play areas must comply with 2010 ADA Standard 505 except as modified by Standard 1008.2.5.3, which includes:
Handrails shall not be required on ramps located within ground level use zones.
Handrail extensions shall not be required.
Handrail gripping surfaces with a circular cross section shall have an outside diameter of 0.95 inch (24 mm) minimum and 1.55 inches (39 mm) maximum. Where the shape of the gripping surface is non-circular, the handrail shall provide an equivalent gripping surface.
The top of handrail gripping surfaces shall be 20 inches (510 mm) minimum and 28 inches (710 mm) maximum above the ramp surface.
The photo above is representative of play area ramp handrails. Also note the edge protection at the bottom of the railing.
The maximum cross slope of an accessible route inside a play area is the same as for accessible routes outside the play area. This measurement must not be steeper than 1:48, or 2.08%. Cross slope is measured perpendicular to the direction of travel. The graphic below is representative of cross slope.
Measurement of Cross Slope on an Accessible Route
Maximum Openings on an Accessible Route
The maximum openings in floor or ground surfaces for accessible routes inside a play area are the same as for accessible routes outside a play area. 2010 ADA Standard 302.3, [Floor and Ground Surfaces] Openings, states, “Openings in floor or ground surfaces shall not allow passage of a sphere more than ½ inch (13 mm) diameter except as allowed in [Standards] 407.4.3, 409.4.3, 410.4, 810.5.3 and 810.10. Elongated openings shall be placed so that the long dimension is perpendicular to the dominant direction of travel.” The graphic on the right is representative of this Standard. A common installation to find excessive openings in the surface of a walkway is where two sections of concrete join, or where two different types of surface material join, such as concrete and asphalt. The photo below is representative.
Excessive Surface Gap Where Concrete Sections of Accessible Route Join
According to the US Access Board, for elevated accessible routes, the requirement for maximum openings only applies if the route is wheelchair accessible (ramped).
Maximum Abrupt Change in Level for Floor or Ground Surface
Requirements for ADA compliance regarding changes in level along an accessible route are the same inside play areas as they are outside of play areas. 2010 ADA Standard 303.2, [Floor and Ground Surfaces, Change in Level] Vertical, states, “Changes in level of ¼ inch (6.4 mm) high maximum shall be permitted to be vertical.” The graphic on the right is representative of this Standard.
2010 ADA Standard 303.3 [Floor and Ground Surfaces, Change in Level] Beveled, states, “Changes in level between ¼ inch (6.4 mm) high minimum and ½ inch (13 mm) high maximum shall be beveled with a slope not steeper than 1:2.” In other words, a change in level of ½ inch (13 mm) is permitted to be ¼ inch (6.4 mm) vertical plus ¼ inch (6.4 mm) beveled. However, in no case may the combined change in level exceed ½ inch (13 mm). Changes in level exceeding ½ inch (13 mm) must comply with 405 (Ramps) or 406 (Curb Ramps). The graphic below is representative of a beveled change of elevation.
Maximum Beveled Change in Level of Floor or Ground Surface
Maximum Carpet Pile Height
Carpeted surfaces of accessible routes in play areas must comply with the same ADA requirements as accessible routes not in play areas. 2010 ADA Standard 302.2, [Floor and Ground Surfaces] Carpet, states, “Carpet or carpet tile shall be securely attached and shall have a firm cushion, pad, or backing or no cushion or pad. Carpet or carpet tile shall have a level loop, textured loop, level cut pile, or level cut/uncut pile texture. Pile height shall be ½ inch (13 mm) maximum. Exposed edges of carpet shall be fastened to floor surfaces and shall have trim on the entire length of the exposed edge. Carpet edge trim shall comply with [Standard] 303.” The graphic on the right is representative of carpet pile maximum height. This Standard applies to synthetic turf as well.
The requirements for protruding objects along accessible routes in play areas is the same as for protruding objects for accessible routes that are not in play areas. Protruding objects are covered primarily in 2010 ADA Standards 204 and 307. 2010 ADA Standard 307.2, [Protruding Objects] Protrusion Limits, states, “Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path.” The graphic below is representative of this Standard. Although shown in an interior corridor, the same principles apply to exterior routes at play areas.
Protruding Object Limitations Along an Accessible Route
Play Components
Play Area Sand Digger and Young Girl
As was mentioned earlier, a play component is defined in the 2010 ADA Standards as “an element intended to generate specific opportunities for play, socialization, or learning. Play components are manufactured or natural; and are stand-alone or part of a composite play structure.” Play components can include swings, slides, climbers, rockers, sand diggers, hand rings, play tables and panels, etc. The photo on the right shows a young girl using a manufactured stand-alone sand digger.
Play Area Slide and Tunnel Installed on Berm
Natural feature play components can include logs, rocks, and berms, etc. The photo on the left is a berm that is used to provide a slide with a tunnel underneath. Issues that may be more challenging for natural features include proximity of entry and exit points, especially for individuals using mobility devices, and seats at the entry point. Berms or sculpted dirt may be used to provide elevation and may be part of an accessible route to composite play structures.
Elements in a play area that are not considered a play component include:
Transfer Systems - installations that allow a disabled individual to transfer from a mobility device to a play component
Steps
Decks
Roofs
Benches
Ramps
Although socialization and pretend play can occur on these elements, they are not primarily intended for play. Benches in play areas are not regulated by the ADA Standards in any way.
Ground Level Adaptive Swing Set Play Component
There are two general types of play components, ground level and elevated. Ground level play components are approached and exited at the ground level. Examples include adaptive swings, stand-alone slides, and sand surface play equipment. The photo on the right is representative of a ground level swing set play component. The photo below is also a ground level play component because it is approached and exited from the ground, even though at times the participant(s) is/are in an elevated position.
Ground Level Climbing Play Component
Ground level play components accessed by children with disabilities must be integrated into the play area. Designers should consider the optimal layout of ground level play components accessed by children with disabilities to foster interaction and socialization among all children. Grouping all ground level play components accessed by children with disabilities in one location is not considered integrated.
Where a stand-alone slide is provided, an accessible route must connect the base of the stairs at the entry point to the exit point of the slide. A ramp or transfer system to the top of the slide is not required. Where a sand box is provided, an accessible route must connect to the border of the sand box. Accessibility to the sand box would be enhanced by providing a transfer system into the sand or by providing a raised sand table with knee clearance complying with Standard 1008.4.3.
Ramps are preferred over transfer systems since not all children who use wheelchairs or other mobility devices may be able to use, or may choose not to use, transfer systems. Where ramps connect elevated play components, the maximum rise of any ramp run is limited to 12 inches (305 mm). Where possible, designers and operators are encouraged to provide ramps with a slope less than the 1:12 maximum.
Platform lifts are permitted as a part of an accessible route. Because lifts must be independently operable, operators should carefully consider the appropriateness of their use in unsupervised settings.
When designing or inspecting a play area, it is important to know how many ground-level and elevated play components will be part of the play area. The requirements for the minimum number of ground-level and elevated play components, their location (dispersion), and the accessible routes within the play area will depend on this information.
Accessible Sand Pit with Diggers
2010 ADA Standard 240.2.1.1, [Play Components, Ground Level] Minimum Number and Types, states, “Where ground level play components are provided, at least one of each type shall be on an accessible route and shall comply with [Standard] 1008.4.” The photo on the right is where the accessible route approaches the sand pit in a play area and at least one of the sand diggers is accessible without having to enter the sand. Remember, loose sand is not an accessible route because it is not firm, stable and slip resistant.
The “type” of each component is not defined by the ADA Standards but the intent is for the function of the play component to define the type. Functions can include sliding, rocking, swinging, climbing, drawing, digging, etc.
2010 ADA Standard 240.2.1.2, [Play Components, Ground Level] Additional Number and Types, states, “Where elevated play components are provided, ground level play components shall be provided in accordance with Table 240.2.1.2 and shall comply with [Standard] 1008.4.” The exception to this Standard is if at least 50 percent of the elevated play components are connected by a ramp and at least 3 of the elevated play components connected by the ramp are different types of play components, the play area shall not be required to comply with [Standard] 240.2.1.2. Table 240.2.1.2 is shown below.
Table 240.2.1.2, Number and Types of Ground Level Play Components Required
Using the chart above, if the number of elevated play components is 12, then at least 4 ground level play components are required to be on an accessible route, and of these 4, at least 3 would be of different types (functions). And of course these should be dispersed and integrated.
Where a large play area includes two or more composite play structures designed for the same age group, the total number of elevated play components on all the composite play structures must be added to determine the additional number and types of ground level play components that must be provided on an accessible route.
Elevated Play Components at Play Area
An elevated play component is defined in the 2010 ADA Standards as “a play component that is approached above or below grade and that is part of a composite play structure consisting of two or more play components attached or functionally linked to create an integrated unit providing more than one play activity.” The photo on the right is representative of elevated play components.
Play components that are attached to a composite play structure and can be approached from a platform or deck (e.g., climbers and overhead play components) are considered elevated play components. These play components are not considered ground level play components and do not count toward the requirements in Standard 240.2.1.2 regarding the number of ground level play components that must be located on an accessible route.
2010 ADA Standard 240.2.2, [Play Components] Elevated Play Components, states, “Where elevated play components are provided, at least 50 percent [50%] shall be on an accessible route and shall comply with [Standard] 1008.4.”
All playground components must comply with ADA Standard 1008.4 regarding turning space, clear floor or ground space, entry points and seats, and transfer supports, as applicable.
2010 ADA Standard 1008.4.1, [Play Areas, Play Components] Turning Space, states, “At least one turning space complying with [Standard] 304 shall be provided on the same level as play components. Where swings are provided, the turning space shall be located immediately adjacent to the swing.” For additional information please see Turning Space.
2010 ADA Standard 1008.4.2, [Play Areas, Play Components] Clear Floor or Ground Space, states, “Clear floor or ground space complying with [Standards] 305.2 and 305.3 shall be provided at play components.” For additional information please see Accessible Clear Space.
The photo below is representative of these Standards where the turning space is shown in black and the clear space is shown in green.
Play Component with Turning Space and Clear Space
Note that the clear floor or ground spaces, turning spaces, and accessible routes are permitted to overlap within play areas. The exact/specific location for these clear floor or ground spaces and the turning space is not defined in the ADA Standards, except for swings.
2010 ADA Standard 1008.2.1, [Play Areas, Accessible Routes] Ground Level and Elevated Play Components, states, “Accessible routes serving ground level play components and elevated play components shall be permitted to use the exceptions in [Standard] 1008.2.1.”
Exception 1: Transfer systems complying with [Standard] 1008.3 shall be permitted to connect elevated play components except where 20 or more elevated play components are provided no more than 25 percent of the elevated play components shall be permitted to be connected by transfer systems. In other words, if the play area has less than 20 elevated play components, a ramp and/or transfer system must connect to 50%. If the play area has 20 or more elevated play components, 25% must be connected by ramp and the other 25% must be connected by ramp and/or transfer system.
Exception 2: Where transfer systems are provided, an elevated play component shall be permitted to connect to another elevated play component as part of an accessible route.
Transfer Systems
Play Area Transfer System
Play Area transfer systems are covered in 2010 ADA Standard 1008.3. The purpose of a play area transfer system is to facilitate the transfer of a person from a wheelchair or other mobility aid to the play equipment. Transfer Systems consist of the following components.
Transfer platforms
Transfer steps
Transfer supports
Clear floor or ground space
The photo on the right is representative of a play area transfer system. For additional information please see Transfer System.
Play Area Ground Surfaces
Accessible play area surfaces are difficult to design and install because they must meet impact attenuation criteria and also maintain accessible route criteria for firmness, slip resistance, stability, and wheelchair maneuverability.
2010 ADA Standard 1008.2.6, [Play Areas] Ground Surfaces, states, “Ground surfaces on accessible routes, clear floor or ground spaces, and turning spaces shall comply with [Standard] 1008.2.6.”
ASTM Logo
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 1292- 99 or 04 - Standard Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment.
ASTM F 1951-99 - Standard Specification for Determination of Accessibility [Wheelchair Maneuverability] of Surface Systems Under and Around Playground Equipment.
The principle of Equivalent Facilitation allows for more recently published versions of these ASTM standards to be used if those versions provide equal to or greater provisions.
ASTM F 1487-01
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. This zone is the area where an individual using the play component may reasonably expect to fall or exit the equipment, based on the height of the component.
TRIAX Surface Impact Tester
ASTM F 1292-99 or 04 provides for measurement of impact attenuation (shock absorption). The graphic on the left is representative of a TRIAX Surface Impact Tester (SIT) which is a portable, free-fall playground surface impact tester with three supports designed like a teepee. A single ball is attached to the center portion of the supports. The ball is dropped from the height of equipment and measures G forces, Head Injury Criteria (HIC), and impact velocity. When operated, no values shall exceed 200 Gs or 1000 HIC to comply with the ADA Standards.
Wheelchair Maneuverability Test on Incline
ASTM F 1951-99 is the standard for wheelchair maneuverability. This standard uses the wheelchair Work Test Method in a lab controlled environment two ways using a manual wheelchair to measure the work required for straight propulsion and for a turn:
to push up a 7% ramp for about 6.5 feet, as a baseline test work level
then a 90 degree turning test on a flat surface is accomplished to verify the work required is not greater than that required on the straight baseline test.