THE AMERICANS WITH DISABILITIES ACT INSURES THE RIGHT OF EVERY CHILD TO PLAY.

An accessible route of travel must be provided to the perimeter of the play area.

A young father sitting in his wheelchair holding his squirming toddler is frustrated because he cannot get close enough to the park's swing set to be able to push his daughter in a swing. A child wearing braces and pushing a walker stands outside the playground watching her friends play, unable to walk across the sandy surfacing to join in the fun. An energetic teenager volunteering at a camp for physically challenged children takes one of her campers to the playground only to realize there is not one thing the child using a wheelchair can play with because the playground is not accessible. Mahatma Ghandi said, "The rudiments of knowledge imbibed through play are an essential part of education." The United Nations Declaration of the Rights of the Child suggested that "the child shall have full opportunity for play and recreation which should be directed to the same purposes as education: society and the public authorities shall endeavor to promote the enjoyment of this right." It is the right of every child to play.

Ten years after President Bush signed into law The Americans with Disabilities Act, recreation providers still argue about accessibility. One of the most frequently asked questions during the National Playground Safety Institute's training is "Do I have to make all my playgrounds accessible?" It is time that as a society we realized that by making our playgrounds and recreation areas accessible to persons with disabilities, we are making them more enjoyable for people of all ages and abilities.

The Americans with Disabilities Act (ADA) prohibits discrimination on the basis of disability in the provision of services and facilities such as playgrounds. The Architectural and Transportation Barriers Compliance Board (U.S. Access Board) was responsible for developing accessibility guidelines for new construction and alterations of existing facilities. The Americans with Disabilities Act Accessibility Guidelines (ADAAG), issued in 1991, did not yet address recreation facilities such as sports facilities, outdoor recreation areas, parks, and playgrounds. For almost ten years recreation providers have not been sure of what the law required them to do. In October of 2000, the U.S. Access Board issued the Final Rule for playgrounds (36 CFR Part 1191). A modification was published on November 20, 2000 that amended the definition of elevated component found in the October release.

The "Final Rule" modified the existing accessibility guidelines (ADAAG) by providing guidance to public entities specifically about playground components and surfaces. Newly designed and newly constructed play areas for children ages two and over, and altered portions of existing play areas, shall comply with this final rule.

Bottom line, it is about providing play for everyone! Persons with disabilities must be able to approach, enter, and use the playground and its components.

Approach, Enter and Use

The original accessibility guidelines set forth recommendations for accessible routes of travel by providing guidance as to the necessary width, length, and slope of these routes of travel. The "Final Rule" amends ADAAG by adding a new section that provides requirements for ground level and elevated play components, accessible routes, ramps and transfer systems, ground surfaces, and soft contained play structures.

Accessible Route (Approach)

The purpose of the "Final Rule" is to enable us to provide play areas that a person with a disability can approach, enter, and use. The accessible route allows the user to approach the play area. An accessible route must be provided to the perimeter of the playground area connecting the play area entrance to accessible buildings, facilities, elements and spaces that are on the same site. The route must be a minimum of 36 inches wide. If an accessible route has less than 60 inches of clear width, then passing spaces at least 60 inches by 60 inches must be provided at intervals not to exceed 200 feet. A "T" intersection of two accessible routes is considered an acceptable passing space. The slope of an accessible route should not exceed a one-foot rise over a run of twenty feet. If the 1:20 slope is exceeded the route is considered a ramp and must comply with the section on ramps

Accessible Routes Within the Playground Area (Enter)

The "Final Rule" provides specific requirements for the accessible route within the perimeter of the playground area. Typically this is the area where there is protective surfacing material. There must be a transition provided that allows the person to move from the accessible route or walkway into the play area. At least one accessible route must be provided within the play area connecting accessible play components, including their entrance and exit points. This is important to remember because if a child is given an accessible route to the entrance of an activity such as a slide, but no accessible route is provided from the exit of the slide back to the entry point then the play apparatus is not accessible. Nor is it fun ... how can the child get back to his or her assistive device?

Accessible routes can be either elevated (ramps and transfer systems) or on the ground. Ground level accessible routes within the play area must be 60 inches minimum clear width with a few exceptions. A small playground with less than 1000 square feet of play area is permitted to have an accessible route that is a minimum of 44 inches wide. A ground level accessible route that is connecting other ground level play events may have a slope that does not exceed 1:16. Handrails would not be required on this route of travel.

An elevated accessible route such as a ramp must have a clear width of 36 inches, with the exception of 32-inch minimum width for a distance of not more than 24 inches. Ramps may not exceed a rise of one foot per twelve feet. There is not a maximum length imposed on the ramp such as there is in the ASTM 1487 standard for public playground equipment. The Access Board wanted to encourage the use of longer ramps with a more gradual rise. Ramps must have handrails and edge protection. Transfer systems, which allow a child to transfer from a wheelchair to the equipment, are also considered part of the accessible route within the playground area. Specific requirements for the height, width, and depth of transfer platforms are found in the "Final Rule."

In order for a person with a disability to enter the play area there cannot be any barrier along the accessible route. A change in elevation of as little as 1/2 of an inch can present a barrier to a person using a wheelchair. It is imperative that abrupt changes in elevation be avoided. This is especially important when transitioning from a paved hard surface to a rubber surface or loose fill surface, such as regularly maintained and compacted engineered wood fiber. Any Change in elevation greater than half an inch would require the use of a beveled surface to ease the transition. The bevel should have a slope that does not exceed 1:12 feet.

When the accessible route crosses into the fall zone or use zone of the playground equipment, the surfacing material must meet the requirements for protective surfacing materials used under and around playground equipment. Refer to the Consumer Product Safety Commission's Handbook for Public Playground Safety for protective surfacing requirements. The playground surfacing material used on the accessible route of travel must meet the requirements of ASTM F1951-99 Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment. Generally most unitary rubber surfacing materials are considered accessible. Some engineered wood fibers milled specifically for use as playground surfacing materials have been found to be accessible per the F1951 Standard. However, the Access Board included a requirement in the "Final Rule" that owners and operators of playgrounds must insure that playgrounds be "maintained regularly and frequently." No one knows exactly how to quantify these two terms. If an agency chooses engineered wood fiber, it must commit to a higher standard of inspection and maintenance than in prior years with this surface.

It is the owner's responsibility to request proof of testing to insure that they are purchasing an accessible surfacing material. All surfaces must be maintained in order to remain accessible.

Technical Requirements for Equipment (Use)

In the eyes of the law, it is not enough to simply provide barrier free access to the play area and equipment. The child with a physical challenge should be able to use the equipment to the best of his/her ability. This means that within every playground area, a certain number of play opportunities must be accessible. The guidelines look at play areas as collections of individual components. A play component is an element intended to generate specific opportunities for play, socialization or learning. Play components may be manufactured or natural, and may be stand alone or as part of a composite play structure. Play components are distinguished as being either ground level or elevated. The number of elevated play components determines the number of ground level components that are to be provided for each play area. A chart is provided that illustrates the number of elevated components and the corresponding number of ground level components along with the type of components required.

Ground Level Play Component

A ground level play component is defined as a play component that is "approached and exited from the ground level." Where ground level components are provided, at least one of each type provided must be located on an accessible route. Rocking devices, freestanding climbers, overhead events, spinning devices and swings are examples of ground level play components.

Elevated Play Component

The October 20, 2000 release of the "Final Rule" incorrectly defined elevated play components. A month later an amendment was released that redefined an elevated play component as "a play component that is approached above and 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." A horizontal ladder that is free standing with no platform access is considered a ground level play component. The same horizontal ladder attached to a platform as part of a composite play structure is then considered an elevated play component, and not a ground level component, even though it can be reached and used from the ground.

Not every element on a play structure is considered to be a component. "Elements not specifically intended for play, socialization, or learning such as ramps, decks, steps, transfer systems and roofs are not play components." Think of structural items such as building walls and floors to help understand the difference. A protective barrier or guardrail such as a vertical pipe rail enclosure, that has no interactive play component is not considered to be a play component. If you add a steering wheel to the enclosure, it is now counted as a play component.

The type of access to the play structure that is required is directly related to the number of elevated play events that are present on the playground. If a play structure has less than 20 elevated play components then access to the structure may be provided by a transfer system. The transfer system must provide access to at least 50% of the elevated play components. If there are 20 or more elevated play components then ramp access must be provided to at least 25% of the elevated components and an additional 25% must be accessible via either a ramp or a transfer system. At least 50% of the elevated play components must always be accessible. For example, a play area with 24 elevated play components would have a ramp from the ground to at least six components, and a transfer system to at least six additional components.

Elevated Components Trigger Number and Type of Ground Level Components

A chart is provided in the guidelines that illustrates the number of elevated play components and the corresponding requirements for ground level components, including the number of different types of components. These requirements do not apply if there are no elevated components, or if access to the play structure is by ramp and the ramp provides access to at least 50% of the play components and there are at least three different types of play components provided.

Unfortunately, the guidelines do not give much information on how the different types are determined. When trying to determine the "type" of play, think of the experience that is occurring. An overhead play event that requires upper body strength would be one type of activity. A climber is another type of component. A to-fro swing (moves back and forth) is distinguished from a tire swing, which is a rotating, swinging motion. Therefore they are two types of swinging. A rocking device is different from a spinning or rotating device.

A play panel that contains a game would be a different play experience from one that encourages fantasy play such as a steering wheel. They are both manipulative play, but encourage a different experience. A chinning bar is a different type of activity from a parallel bar even though both might be considered fitness types of equipment. A double or triple wide slide with separate but connected bedways is considered one slide. (Please note that these interpretations of "types" of play are that of the author in the absence of direction from the U.S. Access Board).

If a play area has 12 elevated play components, six of those components must be accessible via a transfer system or ramp. There are four additional ground level components that must be placed on an accessible route of travel, and of the four ground level events, there must be three different types of play provided.

There has been much discussion over the past five years regarding whether or not multiple play structures within the same playground area must all be accessible. The answer is not a simple one. If there are two separate play structures within the same play area and one structure is intended for 2-5 year olds and the other structure is for 5-12 year olds then each structure is dealt with separately. The need for ramping and number of ground level components required would be based on each separate structure. In essence, you are creating two separate playground areas for each age group.

If there are multiple play structures within the same play area and they are not designated to a specific age group, or they are all for the same age group, then the total number of elevated play components that are in the area are to be counted. For example, assume a playground has a composite structure with 13 elevated play events and a separate structure with eight elevated play events, for a total of 21 elevated play events. The two structures are counted as one, therefore requiring that 25% of the elevated components be accessible via ramp and at least 25% accessible via a transfer system. Seven ground level components would be required and at least four of the ground level components would have to be of different types.

A school or park that has multiple playgrounds within the grounds of that facility may treat them separately as long as they are in separate areas of the school or park or are intended for different user groups.

Technical Requirements for Play Components

The guidelines give very specific requirements for individual components such as:

* Forward and side reach ranges for various age groups

* Space required for wheelchairs to maneuver to, from and at the play component

* Height requirements for entry points such as transfer platforms

* Height requirements for items such as sand or water tables

Compliance Does Not Automatically Provide for a Good "User Friendly" Design!

Simple compliance with the ADA Guidelines for playgrounds may make the playground accessible but may not truly provide much play for children with physical challenges. The playground planning efforts must consider activities that a child with mobility difficulties can enjoy. Placing interactive game panels at ground level may satisfy the ADA but not the child. Research has shown that children spend little time playing with the wide variety of play panels that are on the market today. How often do we really see kids playing tic-tac-toe on a playground? Choose your panels wisely. Children do love to look through panels that distort their view of the world, such as bug eye panels. All kids love to see themselves in mirror panels, especially the wavy ones. Panels that encourage fantasy play such as door, house, and storefront panels are valuable. Panels on which a child can manipulate an object and is rewarded with a reaction or sound, such as gear or chime panels, have value. Think of other alternatives for providing ground level play opportunities such as low chinning bars, trapeze rings, crawl tunnels, and talk tubes.

When locating accessible elevated play events, take care to make sure that there is direct access from the exit of a play event back to the entry. A slide exit that provides no means for a child using a wheelchair to get back to their chair would not be accessible to that child. When designing a playground area or composite play structure, always pay close attention to the path of travel that a child will take to move within the play area or structure. Too many slides with too few means of returning to the platforms may meet standards and guidelines, but may create a conflict of traffic patterns for all children.

Also consider access to other elements within the play environment. When providing sand play it is important to provide it at both elevated and ground levels where possible. Not every child wants to sit in the sand. An elevated sand table provides opportunity for the wheelchair user and also allows an ambulatory child to stand and play. It is also important to provide an opportunity for a child to transfer from his or her wheelchair into the sandbox. By providing sand play that is both elevated and at ground level you are giving all children the choice of where to play.

When designing play environments for children, remember that all children, regardless of ability, need the same things to develop into fully functioning adults.

By providing accessible play opportunities that encourage fantasy play, that provide balancing opportunities and movement, that give children the opportunity to develop physically, socially and emotionally, we are setting the stage for "free play." We must recognize the importance that free play has in our lives and as the United Nations Declaration states, it is the right of every child to play. The Accessibility Guidelines for Play Areas enable us to provide play opportunities for all children. Embrace them!

ELEVATED PLAY COMPONENTS VS. GROUND LEVEL COMPONENTS

Number of elevated    Minimum number of      Minimum number of
play components       ground level play     different types of
provided             components to be on    ground level play
                       accessible route     components required

1                             na                    na
2 to 4                        1                      1
5 to 7                        2                      2
8 to 10                       3                      3
11 to 13                      4                      3
14 to i6                      5                      3
17 to 19                      6                      3
20 to 22                      7                      4
23 to 25                      8                      4
More than 25                  8                      5
                       plus 1 for each
                     additional 3 over 25

ELEVATED PLAY COMPONENTS

Total provided           Ramp access        Ramp or transfer system
                                            access
Less than 20             Not required       50% minimum
20 or more               25% minimum        25% minimum

References

Americans With Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Play Areas; Final Rule. Available on the internet at www.access-board.gov

Consumer Product Safety Commission's Handbook for Public Playground Safety Public Affairs office: 301-504-0580 Available on the internet at www.cpsc.gov

American Society for Testing and Materials 100 Barr Harbor Drive West Conshohocken, PA 19428 610-832-9500 website www.astm.org

F1951-99 Standard for accessibility of surfacing materials

F1487- 98 Standard for public playground equipment

Teri Hendy is president of Site Masters, Inc., a Cincinnati, Ohio, design and safety consulting company serving the school, park, and recreation industry. For the past 18 years, she has been actively involved in all aspects of the playground industry from designing equipment to the layout of the playground area. Hendy employs a knowledge of equipment design, risk management, child development, and an understanding of the guidelines and standards that affect this industry in her article "The Americans with Disabilities Act Insures the Right of Every Child to Play" on page 108.