Notice2025-15374
Notice of Availability: Public Playground Safety Handbook Update
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
August 13, 2025
Issuing agencies
Consumer Product Safety Commission
Abstract
The U.S. Consumer Product Safety Commission (Commission or CPSC) is announcing the availability of final updates to its Public Playground Safety Handbook.
Full Text
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<title>Federal Register, Volume 90 Issue 154 (Wednesday, August 13, 2025)</title>
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[Federal Register Volume 90, Number 154 (Wednesday, August 13, 2025)]
[Notices]
[Pages 38959-38966]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-15374]
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CONSUMER PRODUCT SAFETY COMMISSION
[Docket No. CPSC-2024-0030]
Notice of Availability: Public Playground Safety Handbook Update
AGENCY: Consumer Product Safety Commission.
ACTION: Notice of availability.
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SUMMARY: The U.S. Consumer Product Safety Commission (Commission or
CPSC) is announcing the availability of final updates to its Public
Playground Safety Handbook.
ADDRESSES: Docket: For access to the docket to read background
documents
[[Page 38960]]
or comments received, go to: <a href="https://www.regulations.gov">https://www.regulations.gov</a>, and insert
the docket number, CPSC-2024-0030, into the ``Search'' box, and follow
the prompts.
FOR FURTHER INFORMATION CONTACT: Daniel Taxier, Children's Program
Manager, Division of Mechanical and Combustion Engineering, U.S.
Consumer Product Safety Commission, 5 Research Place, Rockville, MD
20850-3213; email: <a href="/cdn-cgi/l/email-protection#dfbbabbea7b6baad9fbcafacbcf1b8b0a9"><span class="__cf_email__" data-cfemail="630717021b0a061123001310004d040c15">[email protected]</span></a>; telephone: (301) 987-2211.
SUPPLEMENTARY INFORMATION:
I. Introduction and Background
CPSC's playground handbook (Handbook) is intended to provide
information about playground safety to childcare personnel, school
officials, parks and recreation personnel, equipment purchasers and
installers, playground designers, and any other members of the general
public (e.g., parents and school groups) concerned with playground
safety and interested in evaluating their respective playgrounds. The
Handbook also includes references to voluntary standards that contain
technical requirements that are primarily intended for use by equipment
designers and manufacturers, architects, and any others requiring more
technical information. The Handbook is not a rule and does not
establish legally enforceable responsibilities.
The Commission published the first Handbook for Public Playground
Safety (the Handbook) in 1981. This original document was a two-volume
set containing technical information intended to reduce deaths and
injuries to children associated with playground equipment. In 1991, the
Handbook was revised to a single volume, which contained
recommendations based on a COMSIS Corporation report to the CPSC
(COMSIS Human Factors Report).\1\ Also in 1991, the first ASTM
International (ASTM) standard for playground safety, F1292: Standard
Specification for Impact Attenuation of Surface Systems Under and
Around Playground Equipment, was published. In 1993, ASTM F1487:
Standard Consumer Safety Performance Specification for Playground
Equipment for Public Use was published. CPSC published minor revisions
to the Handbook in 1994. In 1997, the Handbook was updated based on
ASTM F1487, a playground safety roundtable meeting held in October of
1996, and comments received in response to a May 1997 CPSC request.
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\1\ The 1990 COMSIS report, Development of Human Factors
Criteria for Playground Equipment Safety, is available in six parts
on the CPSC website. Part 1 is available at: <a href="https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-1">https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-1</a>. Part 2 is available at: <a href="https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-2">https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-2</a>. Part 3 is available at: <a href="https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-3">https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-3</a>. Part 4 is available at: <a href="https://www.cpsc.gov/content/development-human-factors-criteria-playground-equipment-safety-part-4">https://www.cpsc.gov/content/development-human-factors-criteria-playground-equipment-safety-part-4</a>. Part 5 is available at: <a href="https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-5">https://www.cpsc.gov/content/Development-of-Human-Factors-Criteria-for-Playground-Equipment-Safety-Part-5</a>. Part 6 is available at: <a href="https://www.cpsc.gov/content/development-human-factors-criteria-playground-equipment-safety-part-6">https://www.cpsc.gov/content/development-human-factors-criteria-playground-equipment-safety-part-6</a>.
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Due to the lack of a Commission quorum at the time, 2008 revisions
to the Handbook were released as a draft staff document. Later in 2008,
members of ASTM's voluntary standards committee on playground equipment
and the International Play Equipment Manufacturers Association (IPEMA)
identified areas where the voluntary standards and the Handbook did not
align. In 2010, CPSC published a revised Handbook that resolved many of
these issues.
Since 2010, ASTM has published new and revised public playground
standards,\2\ and new materials and equipment have been installed in
playgrounds. Additionally, members of ASTM, the National Program for
Playground Safety (NPPS), IPEMA, and members of the general public have
requested clarifications and recommended an update to the Handbook.
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\2\ See section 1.4.1 of the Handbook for a list of relevant
standards.
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Based on the current editions of the relevant ASTM standards,
feedback from the public, and comments from ASTM and NPPS, CPSC
published a revised draft Handbook with a focus on improvements to
safety. The draft changes included updates relating to: (1) signage and
labeling; (2) common hazards for supervisor awareness; (3) new impact
attenuation testing for suspended elements in ASTM F1487; (4) an
updated warning label on potential strangulation hazards; (5) safety
recommendations concerning merry-go-rounds and other spinning
equipment, consistent with requirements in ASTM F1487; and (6) several
other minor revisions and corrections.
On October 1, 2024, CPSC published a Notice of Availability (NOA)
in the Federal Register that presented its draft updates to the
Playground Handbook. 89 FR 79901. The comment period closed on December
2, 2024. CPSC received 37 public comments.
II. Summary of the Final Updates to the Playground Handbook
The 2025 Handbook includes changes from the 2024 draft Handbook,
and additional revisions made in response to public comments on the
NOA.\3\ The staff memorandum accompanying the Handbook, available at
<a href="https://www.cpsc.gov/content/Ballot-Vote-Notice-of-Availability-Public-Playground-Safety-Handbook-Update">https://www.cpsc.gov/content/Ballot-Vote-Notice-of-Availability-Public-Playground-Safety-Handbook-Update</a>, summarizes major revisions included
in the final edition. The final edition contains the updates described
above in the 2024 draft Handbook, with revisions made in response to
public comments, which are addressed in Section III below.
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\3\ On August 5, 2025, the Commission voted (2-0) to publish
this notice.
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The updated and final Handbook is available on the Commission's
website at: <a href="https://www.cpsc.gov/safety-education/safety-guides/playgrounds/public-playground-safety-handbook">https://www.cpsc.gov/safety-education/safety-guides/playgrounds/public-playground-safety-handbook</a>, and from the
Commission's Office of the Secretary, Consumer Product Safety
Commission, 4330 East-West Highway, Bethesda, MD 20814; telephone:
(301) 504-7479.
III. Response to Public Comments
CPSC received thirty-seven public comments on the draft updates to
its Handbook, in response to the NOA. This section summarizes those
comments and provides the Commission's responses.
A. General Comments on Technical Handbook Content (Various Sections)
Comment: Blue Imp Recreational Products, IPEMA, and a safety
consultant commented that the technical information in the playground
handbook is not of value to the audience, primarily the consumer. The
commenters added that when CPSC and ASTM technical requirements are in
conflict, it causes confusion in the marketplace. Another safety
consultant stated that references to ASTM standards for technical
content on signage are not helpful because consumers must pay for
access to the standards.
Response: The Commission disagrees with the commenters that the
technical information in the Handbook is not valuable to the intended
audience. As described in section 1.2 of the Handbook, the intended
audience includes childcare personnel, school officials, parks and
recreation personnel, equipment purchasers and installers, playground
designers, and any other members of the general public (e.g., parents
and school groups)
[[Page 38961]]
concerned with public playground safety and interested in evaluating
their respective playgrounds. References to voluntary standards that
contain technical requirements are primarily intended for use by
equipment designers and manufacturers, architects, and any others
requiring more technical information. Professionals generally have the
ability to access the ASTM standards through their organizations and
therefore can benefit both from the Handbook and the ASTM standards to
see an explanation of the hazards and the steps that should be taken to
mitigate those hazards. Non-technical audiences, including the general
public, will benefit from the explanation of information in the
Handbook, but likely do not require access to the technical information
in the ASTM standards. In addition, free, read-only copies of some ASTM
standards are available for viewing on the ASTM website at <a href="https://www.astm.org/READINGLIBRARY/">https://www.astm.org/READINGLIBRARY/</a>.
The Commission acknowledges that there are some technical
requirements in the Handbook that are not consistent with the ASTM
standards. In this case, the Commission concludes that the
recommendations in the Handbook provide a greater level of safety than
a similar requirement in the ASTM standards. The Commission revisits
these differences and the available safety information during each
update process to determine whether conflicts can be resolved without
reducing safety.
Every Handbook update balances technical and non-technical safety
information, and in this instance, the Commission concludes that a
reference to ASTM standards for technical content on signage is
adequate because the general public are not responsible for designing
playground signage. The Commission also notes that the Playground
Handbook section on signage and labeling (section 2.2.6) refers to
ASTM1487, Standard Consumer Safety Performance Specification for
Playground Equipment for Public Use, and ASTM has made a free, read-
only copy of this standard available viewing at <a href="https://www.astm.org/READINGLIBRARY/">https://www.astm.org/READINGLIBRARY/</a>.
B. Photos (Various Sections)
Comment: NPPAS and IPEMA identified photographs on the front and
rear cover of the Handbook and in section 2.2.7 and noted that the
equipment shown does not follow recommendations in the Handbook or the
requirements of ASTM standards. The commenters identified that the
photographs included a slide that lacked a chute or hood at the top, an
opening in a net climber that appeared to be an entrapment hazard, and
a photo of a bucket swing that appeared to have a leg opening that is
too large. Additionally, NPPAS recommended that pictures be consistent
with having children or not having children present.
Response: The Commission thanks the commenters for their feedback
and has changed the referenced photographs in the Handbook. The
Commission intends for the Handbook to depict playground equipment both
in and out-of-use by children to allow readers to see the equipment in
various contexts, therefore, photographs were not changed to either
have children or not have children present.
C. ASTM Standards References (Section 1.4)
Comment: Three commenters, NPPAS, an ASTM standard technical
contact, and IPEMA, recommended general changes to the Handbook's
references to ASTM standards. NPPAS recommended adding a brief
description of ASTM in section 1.4 and moving all the bullet details
and listing of standards to an appendix. The technical contact for ASTM
F1292 Standard Specification for Impact Attenuation of Surfacing
Materials Within the Use Zone of Playground Equipment, stated that ASTM
F3351 Standard Test Method for Playground Surface Impact Testing in
Laboratory at Specified Test Height will be incorporated into ASTM
F1292 in 2025 and recommended not to include ASTM F3351 in the new
Handbook. IPEMA recommended providing a reference to the ASTM F1487
standard rather than the specific sections, as section numbers may
change in future revisions.
Response: The Commission lacks the resources to edit and reorganize
the references in the Handbook as requested by NPPAS at this time but
will consider them in future revisions. ASTM F3351 is only referenced
once, with respect to laboratory testing; the testing is intended to
provide more information to the manufacturer or owner/operator of the
surface, rather than to meet a performance requirement; and the
standard is likely to be incorporated into ASTM F1292. Therefore, the
Commission agrees to remove the listing of ASTM F3351 in section 1.4
and the reference in section 2.4.
The Commission agrees that referenced section numbers could change
but concludes that a simple reference to an ASTM standard would not be
appropriate in all cases. Section numbers are replaced with section
subjects, where applicable, to facilitate the public's ability to find
the appropriate section.
D. Injury Data (Section 1.7)
Comment: IPEMA and Ape Studio commented that the reported incident
data should be limited to public playgrounds only and should not
include home playgrounds because it misrepresents the hazards of public
playgrounds. IPEMA added that the reported emergency room-treated
injuries from 2021-2023 are not sourced from a CPSC published document
and are therefore difficult to verify.
Response: The Commission disagrees that the inclusion of all
playground equipment-related incidents is misrepresentative of the
hazard because home playgrounds and public playgrounds share common
hazard patterns. Furthermore, because the location categories in the
data do not delineate public playgrounds, the Commission concludes that
attempting to report only public playground data would be overly
burdensome.
The Commission confirms that the report of an average of over
190,000 estimated emergency room-treated injuries annually from 2021-
2023 includes all playground equipment, including both home playgrounds
and public playgrounds, and is based on publicly available data in the
National Electronic Injury Surveillance System (NEISS).\4\ This report
is consistent with how incident data were analyzed and reported in the
2010 Handbook and in the 2017 playground injury statistics report,
Injuries and Investigated Deaths Associated with Playground Equipment
2009-2014.\5\ Staff conducted an analysis of more recent injuries
because the most recent playground injury statistics report is based on
data that are over 10 years old. A footnote is added to the NEISS data
described in section 1.7 to clarify their source.
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\4\ NEISS is a statistically valid injury surveillance system
based on a nationally representative probability sample of hospitals
in the U.S. and its territories.
\5\ The report is available at: <a href="https://www.cpsc.gov/content/Injuries-and-Investigated-Deaths-Associated-with-Playground-Equipment-2009-to-2014">https://www.cpsc.gov/content/Injuries-and-Investigated-Deaths-Associated-with-Playground-Equipment-2009-to-2014</a>.
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E. Definitions (Section 1.8)
Comment: NPPAS recommended defining the terms ``playground,''
``play component/play structure,'' ``shock absorbing,'' ``critical
height,'' ``flangeless tube connections,'' ``impalement,'' and
``designated play surface'' to avoid ambiguity and align the Handbook
with other standards. National Recreation and Park Association (NRPA)
also recommended defining the term ``shock absorbing.''
Response: The final version of the Handbook adds descriptions of
some of
[[Page 38962]]
the recommended terms, such as ``playground,'' ``impalement,'' and
``shock absorbing,'' that serve as definitions. The terms ``critical
height'' and ``designated play surface'' are already defined in section
1.8. The terms ``flangeless tube connections'' and ``play component''
are no longer used in the Handbook, so formal definitions in section
1.8 of the Handbook are not needed. The term ``play structure'' is
self-explanatory (i.e., a structure for play) and is used contextually
in several new and existing definitions, therefore, a formal definition
is not needed.
F. Thermal Burns and Shading (Sections 2.1 and 2.5)
Comment: NPPAS and IPEMA recommended including a reference to CPSC
publication 3200, Burn Safety Awareness on Playgrounds. NPPAS
recommended emphasizing the importance of environmental hazards and the
physical design elements that can influence the safety and thermal
comfort of playgrounds. NRPA, IPEMA, and Blue Imp Recreational Products
commented that the revised recommendations for shading are not feasible
in the marketplace and will reduce access to playgrounds.
Response: The Commission agrees that including a reference to
publication 3200 will be helpful. Publication 3200, which emphasizes
the risk of thermal burns from playground equipment, was the impetus
for many of the draft changes to the Handbook regarding burns and
shading. The reference is added to section 2.1.1.
The new information on thermal burn hazards, including the
reference to publication 3200, along with the pre-existing
recommendations on shading considerations and the effects of extreme
heat or cold on surfacing, are adequate to address the request to
emphasize the importance of environmental hazards and physical design
elements.
Shading is an important consideration for safety to mitigate burn
hazards on playground equipment. The recommendations for shading allow
playground designers to best address the need for shading and are not
legally enforceable responsibilities. The phrasing of the
recommendations in section 2.1.1 is revised to address the commenters'
concerns. Additionally, section 2.5.6, which provided recommendations
for shading plastics, added no new information and is removed.
G. Fencing (Section 2.1)
Comment: IPEMA and NRPA recommended removing the year designation
that was added to ASTM F2049 for consistency with other referenced
standards and to ensure that the latest version of the standard is
reflected.
Response: The year designation (-11) was added to ASTM F2049
because of concerns that the standard would be revised to a guide,
effectively reducing the level of safety it provides; CPSC staff voted
negative on a ballot item aiming to do that.\6\ To ensure consistency
with other standards, the year designation is removed from ASTM F2049,
and instead, specific recommendations for fencing are added in a new
section, 2.1.2.
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\6\ Staff's letter is available online at: <a href="https://www.cpsc.gov/s3fs-public/2024-November-ASTM-F14-10-Playground-Fencing-Ballot-Response.pdf?VersionId=4xsADPfH7tNq2YuzY1dBTnkzVMP24wGA">https://www.cpsc.gov/s3fs-public/2024-November-ASTM-F14-10-Playground-Fencing-Ballot-Response.pdf?VersionId=4xsADPfH7tNq2YuzY1dBTnkzVMP24wGA</a>.
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H. Gates (Section 2.1)
Comment: NPPAS and the Hummingbird Alliance recommended expanding
the discussion of fence safety to include gate safety standards and to
protect consumers from the risk of vehicular accidents, drownings,
falling gates, and other adjacent hazards.
Response: The Commission agrees that gate safety is an important
topic. The Hummingbird Alliance identified 13 fatalities related to
gate incidents from September 2007 to May 2024 that would likely have
been prevented by the newest revisions to the ASTM gate voluntary
standards, including at least one incident at a playground. The
relevant gate voluntary standards, ASTM F900, ASTM F1184, and ASTM
F2200, have been updated over the past two years to protect consumers
from the unreasonable risk of being crushed by a falling gate. These
standards are now referenced in the Handbook in sections 1.4 and 2.1,
alongside recommendations for fencing to address nearby hazards, as
requested.
I. Age Recommendations (Sections 2.2 and 5.3)
Comment: IPEMA requested to remove the following sentence from
section 2.2.6 because it is unclear whether it applies to playground
design or labels: ``If the playground is used by multiple age groups,
special consideration should be made for protecting children in the
youngest age group.'' IPEMA also recommended adjusting the lowest
recommended age for horizontal ladders from 4 years old to 2 years old.
NPPAS recommended that horizontal ladders should not exceed 3-4 feet in
height for younger children and consumers should be cautious of
purchasing horizontal ladders for preschool children.
Response: The Commission agrees that the referenced sentence in
2.2.6, which was included in the draft as an update, should not be
included in the final update because age considerations are addressed
in sections 2.2.2 and 2.2.3, and the added sentence did not provide
clarity. The Commission disagrees with adjusting age or height
recommendations for horizontal ladders, as most 2-3-year-olds lack the
physical ability to use a horizontal ladder without risking injury, and
the data used to support a maximum 3-4-foot height for young children
is unclear.
J. Supervision (Section 2.2.7)
Comment: Richter Spielger[auml]te GmbH recommended adjusting
supervision recommendations to allow walking barefoot. IPEMA
recommended adding a statement to ``limit children from running on,
under, and around equipment,'' to reduce the risk of children running
into equipment.
Response: The Commission is aware of burn incidents on playgrounds
due to children being barefoot (see publication 3200). Therefore, the
Commission disagrees with revising the recommendation to make sure
children are wearing footwear. While the Commission agrees in principle
that limiting children from running on, under, and around the equipment
could reduce injuries, caregivers may not have the practical ability to
follow this recommendation, which could increase the likelihood that
this advice is dismissed. Therefore, no recommendation is added to
limit children from running on, under, and around equipment.
K. Equipment Not Recommended (Section 2.3.1)
Comment: IPEMA recommends rewriting the list of examples of heavy
swinging and rotating equipment subject to suspended element impact
attenuation testing in ASTM F1487 for the following reasons: swinging
gates and doors are not subject to suspended element impact attenuation
testing; giant strides are not subject to the testing and should still
be included on the list of equipment not recommended; and tire swings
are subject to suspended element impact attenuation testing, so should
not be excepted from the examples. APE Studio and NRPA suggested that
some multi-user swings should be allowed if they pass swing impact
testing. NRPA added that public play areas have safely incorporated
inclusive/generational swings. A safety
[[Page 38963]]
consultant questioned how a consumer or an inspector would know if a
product met the requirements in ASTM F1487, section 8.6.7.
Response: The Commission agrees that swinging gates, doors, and
giant strides are not subject to suspended element impact attenuation
testing and therefore removed this equipment from a list of examples
for that testing. Giant strides are added back to the list of equipment
not recommended because giant strides pose a unique impact and fall
hazard to children using the equipment. The Commission also removed
tire swings as an exception to suspended element impact attenuation
testing and agrees that some multi-user swings should be allowed.
However, the impact testing in ASTM F1487 does not appear to account
for the mass of users of the swing. Therefore, the Commission cautions
that because some multi-user swings, such as generational swings, are
relatively new to public playgrounds, it is unclear whether they may
pose unique hazards to users. The Commission will continue to monitor
incident data for emerging hazards related to these products.
Playground operators are expected to know whether their equipment
has been certified to meet ASTM F1487 before installation, and
consumers and inspectors should be able to contact the equipment owner
and/or manufacturer to obtain such information, if necessary.
L. Surfacing--Loose-Fill Rubber (Section 2.4)
Comment: Recycled Rubber Coalition (RRC), Recycled Materials
Association (ReMA), U.S. Tire Manufacturer's Association (USTMA), and
IPEMA commented that the discussion of rubber mulch as potentially
``toxic'' is inaccurate and is not based on scientific consensus; RRC
and USTMA referred to the EPA's Federal Research Action Plan on tire
crumb as supporting evidence for their comment. RRC added that all
references that imply recycled rubber poses a risk, a hazard, or is
toxic should be removed.
Response: The Commission has revised the short-hand for ASTM F3012
testing to accurately reflect the requirements of F3012 by stating
``loose-fill rubber testing'' instead of ``toxic/hazardous metal
testing,'' which has been deleted in sections 2.4 and 3.7. The
Commission, however, disagrees with the statement that no recycled
rubber poses a risk or a hazard. The testing in ASTM F3012 limits the
concentration of hazardous metals (such as arsenic, chromium, and lead)
and places a size limit on tramp metals to mitigate the potential
hazards posed by loose-fill rubber surfacing. Untested rubber mulch has
not been verified to mitigate these hazards and should therefore be
avoided. References to the risks or potential hazards of using such
materials are clarified but remain in place.
M. Surfacing--Recommended Surfacing Materials (Section 2.4)
Comment: IPEMA, ReMA, RRC, and USTMA commented that it is
inaccurate to single out the risks of rubber mulch compared to other
loose-fill surfacing materials. IPEMA, NRPA, and ForeverLawn explained
that the use of synthetic turf as a unitary play surface has been
rapidly growing and should be referenced in the Handbook. Richter
Spielger[auml]te GmbH and NPPAS suggested emphasizing maintenance of
loose-fill surfacing. A safety consultant, IPEMA, and NRPA offered
various edits for Figure 1 and Table 2, which they asserted conflict
with ADA or ASTM standards or with other material in the Handbook.
Response: The Commission agrees that rubber mulch should not be
singled out in comparison to other loose-fill surfacing materials, such
as engineered wood fiber. Therefore, the Handbook is revised to discuss
both ASTM F3012 and ASTM F2075, where appropriate. The Commission is
aware that synthetic turf has seen increased use as playground
surfacing in recent years and that ASTM is in the process of developing
a proposed standard for synthetic turf for playground surfacing. At
this time, CPSC does not have data on the installation and testing of
synthetic turf supporting its inclusion in the Handbook. The Commission
may consider this information in future editions, if the data becomes
available.
The Commission appreciates the identification of discrepancies with
Figure 1, Table 2, and the characterization of rubber mulch. These
issues are addressed in section 2.4.
N. Surfacing--Critical Height and Fall Height (Section 2.4)
Comment: IPEMA recommended harmonizing the definition of ``critical
height'' with ASTM F1292. NPPAS commented that there are
inconsistencies in fall heights for different pieces of equipment.
Response: The definition of ``critical height'' in the Handbook
aligns with the last sentence of the definition of ``critical fall
height'' in ASTM F1292. This alignment avoids technical descriptions of
the performance criterion in ASTM F1292 and is adequate for the
purposes of the Handbook. The fall heights, identified as being
inconsistent by NPPAS, are two different hazard scenarios for different
equipment types: one is a fall height from equipment onto the same
equipment; the other is a fall height from equipment (e.g., embankment
slides, balance beams) onto protective surfacing. In response, the
Commission clarifies, in section 5.3.9, that composite structures
should be considered one structure with a single critical height based
on the highest fall height for the structure.
O. Playground Hazards (Section 3)
Comment: IPEMA commented that the Handbook should exempt any
portions of equipment located more than 84 inches above any underlying
designated play surface from the recommendations in section 3. NPPAS
recommended adding an illustration for crush or shear hazards rather
than directing consumers to ASTM F1487 for testing criteria. IPEMA
recommended exempting partially bounded openings below 24 inches to
align with major recognized playground standards including ASTM F1487,
CSA Z614, and EN 1176. IPEMA also recommended including a reference to
the sharp points and edges requirements in 16 CFR 1500.48 and 1500.49
to align with ASTM F1487. In addition, IPEMA recommended allowing
chimes, tubes, and other musical instruments to have open ended tubes
provided there are no sharp edges. NPPAS commented that the statement,
``consider using plastic playground equipment that resembles tires,''
is unclear.
Response: The Commission disagrees that portions of equipment
located more than 84 inches above any underlying designated play
surface and that partially bounded openings below 24 inches should be
explicitly exempted from the recommendations in the Handbook. These
exemptions are a technical specification in ASTM F1487 that are based
on the ASTM playground subcommittee's assessment that children are
unlikely to reach 84 inches above play equipment and are unlikely to
become entrapped in partially bounded openings less than 24 inches from
the ground. The Handbook already refers to ASTM F1487 for technical
specifications and tests. Similarly, the Commission concludes that the
reference to ASTM F1487 testing criteria for crush/shear hazards is
adequate, as the hazard can be specific to certain pieces of moving
equipment (as discussed in section 3.1) and the reference is consistent
with existing recommendations in the Handbook.
The Commission also disagrees that the testing in 16 CFR 1500.48
and
[[Page 38964]]
1500.49 for sharp points and edges should be referenced because the
Handbook already describes practical ways that consumers can evaluate
potential sharp points and edges, rather than relying on a specific
test that most consumers will not be able to perform.
The Commission agrees that caps or plugs may not be appropriate for
chimes, tubes, or other musical equipment with no sharp edges because
caps or plugs will prevent such musical equipment from functioning.
Section 3.4 is revised to allow musical equipment to have exposed open
ends so long as the ends are rounded and are guarded from potential
impalement and entrapment hazards. Additionally, to clarify the
recommendation, the unclear statement on using ``plastic playground
equipment that resembles tires'' is revised to refer to equipment that
``simulates tires'' as stated in the 2010 Handbook.
P: Strangulation Hazards (Section 3.2)
Comment: A safety consultant commented that the strangulation
pictogram in section 3.2.1 is offensive and would be disturbing to
children. NPPAS commented to state that the pictogram is a great
addition. IPEMA recommended changing ``scarves'' to ``neck scarves'' in
the text of the strangulation warning to not discriminate against
cultures that wear head scarves.
Response: The Commission appreciates the support for the
strangulation pictogram. An additional example warning label is added
without the pictogram in section 3.2.1 for readers of the Handbook who
think the example pictogram is not appropriate. The Commission agrees
with the recommended change from ``scarves'' to ``neck scarves,'' which
more accurately conveys the strangulation hazard, and revised the text
accordingly.
Q: Suspended Component Hazards (Section 3.5)
Comment: IPEMA recommended modifying the suspended component hazard
section to add multiple suspended components to the list of equipment
to which the recommendations do not apply, and to align with the
recently balloted corresponding section in ASTM F1487 which includes
requirements for increased visibility of suspended hazards.
Response: The Commission concludes that the hazard mitigation steps
listed in section 3.5 for suspended hazards apply to both single
suspended components and multiple suspended components. This section is
further clarified to state that other features, in addition to bright
colors or contrast with the surrounding equipment and surfacing, can be
used to increase visibility of suspended hazards.
R: Transfer Systems (Section 5.1.3)
Comment: IPEMA and Richter Spielger[auml]te GmbH commented that the
draft Handbook's recommendation to label transfer points is unnecessary
because it does not increase safety.
Response: The text in section 5.1.3 is revised to clarify that
labeling of transfer points should be considered to help users identify
them.
S: Guardrails and Barriers (Section 5.1.3)
Comment: IPEMA commented that upper body equipment, entry to
stairways, and entry to ramps should be included among the equipment to
which the guardrail and barrier recommendations do not apply. IPEMA
also suggested that barriers on stairs should be treated differently
than other types of equipment and should be required on all stairs
greater than 48 inches above the protective surfacing.
Response: The Commission agrees that upper body equipment and
entryways do not require barriers or guardrails and added them to the
examples of equipment to which the recommendations do not apply in
section 5.1.3. The revisions in the draft Handbook clarified that
barriers are recommended on all elevated platforms, including stairs,
greater than 48 inches above the protective surfacing (and lower on
equipment for toddler and pre-school age children). These revisions are
included in this final update.
T. Rungs (Section 5.2.2)
Comment: IPEMA recommended removing the preference for a rung
diameter of 1.25 inches for maximal grip because the recommended grip
range is sufficient for design. IPEMA also recommended increasing the
maximum rung spacing to 18 inches (similar to the maximum step height
for adjacent platforms) in Table 6 for older children.
Response: The Handbook's recommendations for a preferred rung
diameter and rung spacing and the rationale for their inclusion is
based on the COMSIS Human Factors Report. Therefore, the Commission is
not revising this section.
U: Handrails (Section 5.2.3)
Comment: IPEMA commented that the handrail height of 22 inches to
26 inches for children ages 2 to 5 is overly restrictive and makes it
difficult to meet guardrail and handrail recommendations and to meet
entrapment space requirements. IPEMA suggested that the recommended
height range for school age children should be harmonized with ASTM (22
inches to 38 inches).
Response: The Commission continues to recommend a lower handrail
height for 2- to 5-year-old children based on the COMSIS Human Factors
report.
V. Equipment Maximum Height (Section 5.3)
Comment: NPPAS recommended providing a maximum height on different
play components for children of different ages due to a growing body of
research that connects equipment height and surfacing materials to
injury.
Response: The Commission has not analyzed data which supports
recommending specific maximum heights on different playground
equipment. Maximum height recommendations should be considered by the
ASTM playground subcommittees and could be considered in future
revisions if supported by data analysis.
W. Climbing Equipment Internal Fall Distance (Section 5.3.2)
Comment: IPEMA recommended moving an arrow in Figure 9 to show
where a child may fall.
Response: Figure 9 is updated to show arrows to measure the fall
distance in locations where a child may fall.
X. Flexible Climbers (Section 5.3.2.3)
Comment: IPEMA suggested that the Handbook should not state that
freestanding flexible climbers are not recommended for preschool
children based on their assumption that there are flexible climbers
that are functional for preschool age children. NPPAS stated that the
Handbook should tell consumers to be cautious of purchasing
freestanding flexible climbers for preschool children. Additionally,
IPEMA recommended removing the reference to the perimeter of a net
opening between 17 and 28 inches in Figure 13 asserting that it has no
bearing on whether an opening creates an entrapment.
Response: Flexible climbers are recommended for preschool age
children only if there is another method of egress from the equipment.
Freestanding flexible climbers are not recommended for preschool age
children because there is only a sole means of access to the equipment.
If young children become unable or unwilling to climb down while near
the top of the equipment, they will be more likely to jump or fall off,
increasing the risk of injury. For this reason, freestanding flexible
climbers will
[[Page 38965]]
continue to be not recommended for preschool age children.
The perimeter of net openings specified in Figure 13 is based on
the perimeters of the small torso probe and large head probe (Figures
B7 and B8, respectively) and is used to evaluate such openings to
prevent head entrapment incidents. This information is added to the
section 5.3.2.3.
Y: Track/Trolley Rides (Section 5.3.2.7)
Comment: A safety consultant and NPPAS recommended adding more
information on seated track/trolley rides instead of directing the
consumer to ASTM F1487. NPPAS recommended that equipment use zones for
trolleys and other moving equipment should be addressed in the
Handbook. IPEMA recommended clarifying that only the manufacturer's
intended parts should ever be tied or attached to any moving part of
the ride, rather than ``nothing.''
Response: The Commission concludes that the reference to ASTM F1487
is appropriate due to the many technical considerations included
therein for the safety of seated track/trolley rides. The topic of
equipment use zones and clearance zones or areas around the equipment
that should remain clear of people or other equipment while in use
spans multiple types of playground equipment which could span multiple
sections of the Handbook, if addressed. These topics could be addressed
in future editions of the Handbook, as the balance between technical
and non-technical safety information is reconsidered. The Commission
agrees with IPEMA's suggested clarification regarding manufacturer's
intended parts and has removed ``nothing'' and replaced it with ``only
the intended equipment.'' The Commission, however, cautions that
manufacturer's intended parts should not be hazardous, as described in
section 3 of the Handbook and elsewhere in ASTM F1487.
Z: Merry-Go-Rounds and Other Spinning Equipment (Section 5.3.4)
Comment: NRPA and IPEMA recommended changing ``Merry-go-rounds/
Spinners'' to ``Rotating Equipment'' for consistency with ASTM
standards. Richter Spielger[auml]te GmbH and IPEMA stated that maximum
requirements for platform heights in section 5.3.4 should not be
required because there are design types that allow access for both
preschool and school age children. These commenters also said that hand
supports are not required for seat designs where the seating adequately
secures children. Both commenters also asserted that the rotation speed
formula in the draft Handbook may not be accurate for all rotating
equipment. In addition, IPEMA recommended removing the term ``clearance
zone'' because it lacks a clear definition in the Handbook and has a
specific use in ASTM F1487.
Response: Most consumers colloquially understand or use the terms
``merry-go-round'' and ``spinner.'' Therefore, for ease of use, those
terms will continue to be used in the Handbook. The Commission will
retain the platform height recommendations because the platform height
can affect both child access and fall height. The Commission agrees
that some seat designs, such as sufficiently concave or contained
seating, can be used without hand supports because such seats are
designed to contain children's bodies at the maximum rotational speed
of the equipment, and has revised section 5.3.4 of the Handbook
accordingly. The Commission also agrees that the rotation speed formula
added in the draft Handbook is not accurate for all rotating playground
equipment. Therefore, the formula is removed in section 5.3.4.1. The
maximum recommended rotation speed, however, is retained. The
Commission agrees to remove the term ``clearance zone'' because
clearance zones are not currently defined in the Handbook.
AA. Seesaws (Section 5.3.5)
Comment: IPEMA recommended that designers should determine whether
footrests are necessary to include on spring-centered seesaws.
Response: The Commission agrees with the commenter. Some spring
seesaws will move horizontally, like spring rockers and unlike fulcrum
seesaws, and therefore should have footrests to assist users to stay on
the equipment. Other spring seesaws will swing up and down like a
fulcrum seesaw, in which case a footrest would be a potential crush
hazard. This distinction is clarified in section 5.3.5.2.
AB. Slides (Section 5.3.6)
Comment: NPPAS requested an illustration for safety signage or
labels and an illustration for embankment slides to clarify the
recommended maximum height of 12 inches above the underlying ground
surface. IPEMA recommended that the slide exit slope be harmonized with
ASTM (0-10 degrees below horizontal) to get proper drainage. A safety
consultant agreed with the existing slope recommendation (0-4 degrees
below horizontal). IPEMA suggested harmonizing the recommendations for
slide exit clearance zones with ASTM F1487. The safety consultant
recommended that the entanglement hazard on slides in section 5.3.6.7
should be described as a ``narrowing gap'' because ``that is where a
drawstring gets hung up.''
Response: Generally, signage and labeling recommendations are
addressed in the Signage and/or Labeling section, 2.2.6, and example
strangulation warnings are addressed in the Strings, Straps, and Ropes
section 3.2.1, which includes an illustration with a slide. The
recommendations for embankment slides to have a maximum height of 12
inches above the underlying ground surface are clearly expressed and
therefore the Commission finds that an additional illustration is
unnecessary.
The Handbook's existing slide exit slope recommendation of 0-4
degrees below horizontal reduces the risk of injury from falls related
to children exiting the slide too fast. CPSC is unaware of incident
data which demonstrates that water at slide exits poses a risk of
injury, and the Handbook's slide exit slope recommendations overlap
with ASTM F1487's slide exit slope requirements. Therefore, the slide
exit slope recommendations remain unchanged.
As described in other comment responses, ``clearance zones'' are
not currently addressed as a specific topic in the Handbook. However,
Figure B13 in the appendix describes recommended areas to test for
slide entanglement protrusions and may address the commenter's
concerns.
The Commission concludes that gaps at the tops of slides where the
slide chute connects with the platform do not need to be ``narrowing''
to pose a strangulation hazard on slides, and that the recommendation
to remove gaps that can entangle clothing or strings is adequate;
therefore, the entanglement hazard description remains unchanged.
AC. Swings (Section 5.3.8)
Comment: IPEMA recommended that all swing seats should be impact
tested per ASTM F1487, the use of the term ``belt seats'' should be
changed to be ``swing seats'' in section 5.3.8.3., general to-fro swing
seats should be allowed to be multi-user, bucket swing pivot point
height recommendations should only apply to swings intended for
toddlers, and a play area with only a single swing bay be allowed to
have a full bucket seat with other seat types in the same bay. A safety
consultant recommended that section 5.3.8.4 on multi-axis swings
include other types of dish or saucer swings, not just tire swings.
Response: The Commission agrees that all swing seats should be
impact tested in accordance with ASTM F1487
[[Page 38966]]
to reduce the severity of injury from swings impacting people on their
paths; this is added in section 5.3.8.
The Commission concludes that the suggested change from ``belt
seat'' to ``swing seats'' would require additional changes throughout
the Handbook to adequately address safety issues. For instance, the
examples of age-appropriate equipment in Table 1 describe the
appropriateness of belt swings; Table 7 describes minimum clearance
dimensions for belt swings; and the use zone for belt swings is
described in section 5.3.8.3.3. Removing specific recommendations for
belt swings in section 5.3.8.3.1 would raise a question about the
specific mention of belt swings in these sections. Generalizing the
recommendations in these other sections is not always logical.
Therefore, the change will not be made. The Commission also rejects the
recommendation to allow general to-fro swing seats to be multi-user
because section 5.3.8.3.1 addresses belt seats only, and belt seats can
only accommodate a single user safely.
In addition, the Commission will maintain the current pivot point
height recommendations for bucket seats to ensure toddlers are
protected from potentially hazardous falls because caregivers are
unlikely to distinguish full bucket seats intended for toddlers from
full bucket seats intended for older pre-school age children.
The Commission agrees that small playgrounds with only a single
swing bay may include different types of swings in the same bay with
reduced risk, the corresponding change is made in section 5.3.8.3.2 to
state that ``when possible,'' full bucket seat swings should be in
separate structures or bays. Section 5.3.8.4 on multi-axis swings is
also revised to include all types of multi-axis swings, including tire
swings.
Abioye Mosheim Oyewole,
Acting Secretary, Consumer Product Safety Commission.
[FR Doc. 2025-15374 Filed 8-12-25; 8:45 am]
BILLING CODE 6355-01-P
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