Safe and Accessible Play Surfaces in the
Real World
Presented to CIRSA by Geoff Ames & Glenn Staton, March 2014
OPERATED BY
Disclaimer
• Information, materials, and/or technical assistance
are intended solely as informal guidance, and are
neither a determination of your legal rights or
responsibilities under the ADA, nor binding on any
agency with enforcement responsibility under the
ADA.
• ADA Center authorized by NIDRR to provide
information, materials, and technical assistance to
individuals and entities that are covered by the ADA.
OPERATED BY
Regional Centers
800.949.4232
www.adata.org
OPERATED BY
ADA Center Functions
• Technical Assistance / ADA Information
• Referral & Networking with other
Disability Organizations
• Research
• Training
• Material Dissemination
OPERATED BY
Newsletter
Keep up to date!
• Monthly E-newsletter
• Quarterly Hardcopy Newsletter
Sign up:
http://adainformation.org/forms/newsletter
Free!
Facebook page:
https://www.facebook.com/RMADACenter
OPERATED BY
Meeting the Challenge, Inc.
• Operates the Rocky Mountain ADA Center
project
• Generates materials and products that
support accessibility
• Offers customized implementation services
• Provides training on various disability rights
laws
OPERATED BY
MTC Implementation Services
Providing customized solutions for:
• Municipal Self -evaluations and Transition Plans
– Public buildings
– Public parks & recreation facilities
– Pedestrian facilities in public right-of-way
• Municipal and County Facility and Program
Accessibility
• Commercial Facility Accessibility
OPERATED BY
Today’s Presentation
• Play Area Scoping Requirements
• Accessible Routes
• Making Sense of Surface Materials
• New Construction and Alterations
• Conclusion: Design and Practice
OPERATED BY
8
Play Area Scoping Requirements
• Elevated components
• Ground level components
• Types of components
OPERATED BY
9
Elevated Play Components
• 50 percent on an accessible route
• If 20 or more 25 percent must be
accessible by means other than
transfer systems (level or ramped
access)
• If 50% of not < 3 types connected by
ramps additional GLPCs not required
OPERATED BY
10
Ground Level Play Components
• At least one of each type present
• Per scoping based on number of
elevated components see Table
240.2.1.2
OPERATED BY
11
Types of Components
• “Type” is functional description,
such as:
–Swinging
–Climbing
–Sliding
–Interactive play
OPERATED BY
12
Accessible Routes
• Elevated routes
–Transfer platforms and steps
–Ramps
• Ground level routes
OPERATED BY
13
Elevated Accessible Routes
•
•
•
•
Clear width 36 inches minimum
At transfer systems 24 inches minimum
Ramp run 12-inch rise maximum
Transfer platforms
–14 inches deep x 24 inches wide
minimum
–Height 11 inches minimum, 18 inches
maximum
OPERATED BY
14
• Transfer platforms
11 -18 inches
OPERATED BY
15
Transfer Platforms
OPERATED BY
16
Elevated Accessible Routes
• Transfer platforms (cont.)
–Transfer space with 48-inch side centered
on 24-inch dimension of platform
–At least 1 transfer support provided
• Transfer steps
–14 inches deep x 24 inches wide
minimum
–Height 8 inches maximum
OPERATED BY
17
Transfer Steps
OPERATED BY
18
Elevated Accessible Routes
• Transfer steps (cont.)
–At least 1 transfer support provided
• Elevated play components connected
by ramps
–At least turning space provided
–Clear floor space required
OPERATED BY
19
Elevated Play Structure Ramp
OPERATED BY
20
Ground Level Accessible Routes
• Clear width 60 inches minimum
• Vertical clearance 80 inches minimum
• Ramps 1:16 (6.25%) running slope
maximum
• Surfaces must meet ASTM F 1951 (&
ASTM F 1292 within Use Zones)
• Turning space must be provided
OPERATED BY
21
Ground Level Accessible Routes
• Clear ground space – 1:48 slope
maximum, 48 x 30 inches minimum
OPERATED BY
22
Point of entry or seats, height: 11 inches
minimum, 24 inches maximum; 18 inches
preferred.
• Two types of accessible ground
level play components
OPERATED BY
23
Special Guest Speaker
• Melissa Branson
OPERATED BY
24
Making Sense of Surface Materials
• Three kinds of surfaces required
–1. Safe
–2. Accessible
–3. Safe and accessible
OPERATED BY
25
Making Sense of Surface Materials
• ADA approved?
–ASTM Standards
–Impact attenuation
–Stable, firm, and slip resistant
OPERATED BY
26
Pour-in-Place Surface at Transfer
Platform
• This surface is probably safe and accessible….
OPERATED BY
27
Pea Gravel Over Foam Rubber
Mats at Transfer Platform…
• This surface is possibly safe but it is NOT accessible….
OPERATED BY
28
Making Sense of Surface Materials
• Ground surfaces must be inspected and
maintained regularly to ensure continued
compliance with the ASTM F 1951 standard.
• § 35.133 Maintenance of accessible features
– (a) A public entity shall maintain in operable
working condition those features of facilities
and equipment that are required to be readily
accessible to and usable by persons with
disabilities by the Act or this part.
OPERATED BY
29
Making Sense of Surface Materials
• Synthesis: Regulation, Research, and
Real World
– U.S. Access Board
– U.S. Departments of Justice and Interior
– National Center on Accessibility
– Play areas in the real world
OPERATED BY
30
Stable Surface?
Stability - the degree to which a surface resists change
from contaminants or applied force, so that when the
contaminant or force is removed, the surface returns to
its original condition [U.S. Access Board]
OPERATED BY
Play Surfaces in the Real World
• Concrete, asphalt, other paved surfaces,
compacted gravel, etc. – can probably be
accessible (stable, firm, & slip-resistant) but
are not possibly safe
• Loose fill: wood chips, mulch, shredded
rubber, pea gravel, sawdust, etc. – can
probably be safe (fall-attenuating) but are not
possibly accessible
OPERATED BY
32
Play Surfaces in the Real World
• Stabilized Engineered Wood Fiber, rubber
mats over air pillows, pour-in-place (PIP), geofabric hybrids, etc. – can possibly be safe and
accessible.
• No surface material is perfect.
• All surfaces are not required to be BOTH safe
and accessible.
• Inspect & maintain ground surfaces regularly
& frequently to ensure continued accessibility.
OPERATED BY
33
Play Surfaces in the Real World
• Meeting the Challenge has inspected over 400
play areas since October 2011
• In our observations:
– No loose fill surface – even those newly-installed –
has met the stability requirement
– Loose fill surfaces consistently demonstrate
undulation that exceeds maximum slopes
– Dish-out under swings, at transfer platforms, & at
slide outlets present failure w/o measurement
OPERATED BY
34
Play Surfaces in the Real World
• Conclusion: We are not saying
that EWF surfaces cannot be
made stable – but in our
experience they are not made
and are not maintained in a
stable condition.
OPERATED BY
35
New Construction and Alterations
• Program access
– Public parks
– School playgrounds
• Readily achievable barrier removal
– McDonald’s
– HOAs
– Other places of public accommodation
• No Safe Harbor
OPERATED BY
36
§ 35.130 General Prohibitions
Against Discrimination
• No qualified individual with a disability
shall, on the basis of disability, be
excluded from participation in or be
denied the benefits of the services,
programs, or activities of a public
entity, or be subjected to
discrimination by any public entity.
OPERATED BY
37
§ 35.151 New Construction and
Alterations
• Each facility or part of a facility
constructed by, on behalf of, or for the
use of a public entity shall be designed
and constructed in such manner that the
facility or part of the facility is readily
accessible to and usable by individuals
with disabilities…
OPERATED BY
38
Commentary on Play Areas
• DOJ: it is preferable for public entities to
try to achieve compliance with the
design standards established in the 2010
Standards. If this is not possible to
achieve… requirements for program
accessibility provide enough flexibility to
permit the covered entity to pursue
alternative approaches to provide
accessibility.
OPERATED BY
39
§ 35.150(b)(2)(ii) Safe Harbor
• Does not apply to those elements in
existing facilities that are subject to
supplemental requirements
• Elements in the 2010 Standards not
eligible for the element-by-element safe
harbor are identified as follows––
–Play areas, sections 240 and 1008; 206.2.17.
OPERATED BY
40
Conclusion: Design and Practice
• “ADA approved”
–Play components/structures
–Lab tested surface materials
• Inspection and maintenance
–Regular and frequent
–Ensure continued compliance
OPERATED BY
41
Real World Conclusion
• “ADA approved” is meaningless
–Lab tests v. actual in-place surfaces
• Without a ramped entrance,
accessible surface to elevated
structures and GLPCs is prerequisite
to scoping compliance
• Must monitor & maintain
OPERATED BY
42
Dept. of Justice Guidance:
• The Department would caution covered entities
selecting among the ground surfacing materials
that comply with the ASTM requirements that
they must anticipate the maintenance costs that
will be associated with some of the products.
• Permitting a surface to deteriorate so that it
does not meet the 2010 Standards would be an
independent violation of the Department´s
ADA regulations.
OPERATED BY
43
Resources
• U.S. Department of Justice, 2010 Standards
http://www.ada.gov/regs2010/2010ADAStandard
s/2010ADAstandards.htm#2004
• U.S. Access Board recreational facility guides
http://www.accessboard.gov/recreation/guides/index.htm
• National Center on Accessibility
http://www.ncaonline.org/
• Rocky Mountain ADA Center 800.949.4232,
http://adainformation.org/
OPERATED BY
44
Questions?
OPERATED BY
45