Safe and Accessible Play Surfaces in the Real World

Report
Safe and Accessible Play Surfaces in the
Real World
Presented to CIRSA by Geoff Ames & Glenn Staton, March 2014
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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.
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Regional Centers
800.949.4232
www.adata.org
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• Technical Assistance / ADA Information
• Referral & Networking with other
Disability Organizations
• Research
• Training
• Material Dissemination
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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
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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
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Today’s Presentation
• Play Area Scoping Requirements
• Accessible Routes
• Making Sense of Surface Materials
• New Construction and Alterations
• Conclusion: Design and Practice
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Play Area Scoping Requirements
• Elevated components
• Ground level components
• Types of components
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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
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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
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Types of Components
• “Type” is functional description,
such as:
–Swinging
–Climbing
–Sliding
–Interactive play
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Accessible Routes
• Elevated routes
–Transfer platforms and steps
–Ramps
• Ground level routes
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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
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• Transfer platforms
11 -18 inches
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Transfer Platforms
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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
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Transfer Steps
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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
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Elevated Play Structure Ramp
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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
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Ground Level Accessible Routes
• Clear ground space – 1:48 slope
maximum, 48 x 30 inches minimum
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Point of entry or seats, height: 11 inches
minimum, 24 inches maximum; 18 inches
preferred.
• Two types of accessible ground
level play components
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Special Guest Speaker
• Melissa Branson
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Making Sense of Surface Materials
• Three kinds of surfaces required
–1. Safe
–2. Accessible
–3. Safe and accessible
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Making Sense of Surface Materials
• ADA approved?
–ASTM Standards
–Impact attenuation
–Stable, firm, and slip resistant
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Pour-in-Place Surface at Transfer
Platform
• This surface is probably safe and accessible….
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Pea Gravel Over Foam Rubber
Mats at Transfer Platform…
• This surface is possibly safe but it is NOT accessible….
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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.
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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
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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]
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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
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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.
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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
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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.
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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
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§ 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.
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§ 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…
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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.
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§ 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.
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Conclusion: Design and Practice
• “ADA approved”
–Play components/structures
–Lab tested surface materials
• Inspection and maintenance
–Regular and frequent
–Ensure continued compliance
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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
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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.
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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/
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Questions?
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