The following article begins by reviewing when play areas are required to comply with the 2010 ADA Standards for Accessible Design and then discusses the scoping and technical requirements for play areas found in the 2010 ADA Standards.

When are Play Areas Required to Comply with the New Standards?

Under the 2010 ADA Standards for Accessible Design, newly designed, constructed and altered play areas have enforceable accessibility requirements effective March 15, 2012 which include a requirement to provide at least one accessible route to each type of play component provided in a play area.

Accessibility Services staff have received numerous requests from owners/operators of facilities that contain play areas to clarify how these new standards apply to existing play areas (i.e. constructed prior to March 15, 2012). Below is a summary of compliance dates and information on how existing play areas are affected for both Title II (state & local government facilities) and Title III (places of public accommodation) entities.

For newly constructed and altered play areas, as well as existing play areas undergoing barrier removal to comply with the new regulations, Section 240 of the 2010 ADA Standards contains the scoping for accessibility requirements. The technical requirements for the design of these required accessibility features in play areas are found in Section 1008. Both the scoping and technical requirements can be accessed via:
http://www.ada.gov/regs2010/2010ADAStandards/2010ADAstandards.htm.

Application of the 2010 Design Standards to Existing Play Areas (not undergoing alterations)

-Title II Entities:

Title II of the ADA covers all activities of State and local governments regardless of the government entity’s size or receipt of Federal funding. For Title II entities, March 15, 2012 is the compliance date for using the 2010 Standards for new construction, alterations, program accessibility, and barrier removal. On or after March 15, 2012, public entities must consider the supplemental requirements (such as those for play areas) in the 2010 Standards to assess their compliance with program accessibility.

Program Access is a term unique to Title II entities. Essentially, a public entity’s services, programs, or activities, when viewed in their entirety, must be readily accessible to and usable by individuals with disabilities. “Program Accessibility,” applies to all existing facilities of a public entity. Public entities are not necessarily required to make each of their existing facilities accessible. Public entities may achieve program accessibility by a number of methods. In many situations, providing access to facilities through structural methods, such as alteration of existing facilities and acquisition or construction of additional facilities, may be the most efficient method of providing program accessibility. The public entity may, however, pursue alternatives to structural changes in order to achieve program accessibility. Nonstructural methods include acquisition or redesign of equipment, assignment of aides to beneficiaries, and provision of services at alternate accessible sites. A public entity may not deny the benefits of its programs, activities, and services to individuals with disabilities because its facilities are inaccessible.

-Title III Entities:

Title III of the ADA covers places of public accommodations- private entities who own, lease, lease to, or operate facilities such as restaurants, retail stores, hotels, movie theaters, private schools, convention centers, doctors’ offices, homeless shelters, transportation depots, zoos, day care centers, and recreation facilities including sports stadiums and fitness clubs.

For Title III entities March 15, 2012 is the compliance date for the 2010 Standards, including the supplemental requirements for which there are no technical or scoping requirements in the 1991 Standards (such as play areas). Public accommodations must comply with the 2010 Standards’ supplemental requirements in existing facilities to the extent readily achievable.

The standard applied to Title III entities in existing facilities is known as “readily achievable barrier removal” – which is different than the standard applied to Title II entities (program accessibility) as explained above.

Essentially, physical barriers to entering and using existing places of public accommodation facilities must be removed when “readily achievable.” Readily achievable means “easily accomplishable and able to be carried out without much difficulty or expense.” It is important to note that what is readily achievable will be determined on a case-by-case basis in light of the resources (including financial resources) available. Some examples of barrier removal include: installing ramps, making curb ramps at sidewalks and entrances, rearranging tables, chairs, vending machines, display racks, and other furniture, widening doorways, installing grab bars in toilet stalls, and adding raised letters or braille to elevator control buttons. First priority should be given to measures that will enable individuals with disabilities to “get in the front door,” followed by measures to provide access to areas providing goods and services.

Alterations to Existing Play Areas:

When play areas are altered, those alterations are covered under section 202.3 of the 2010 Standards and the definition of “alteration” is provided in section 106.5. A physical change to a play area which affects, or could affect, the usability of the play area is considered to be an alteration. Maintenance of equipment however, does not necessitate compliance with all of the new requirements for play areas. For instance, if a railing is in disrepair and replaced as part of maintenance efforts, that does not mean that the entire play area now must comply with the 2010 ADA Standards for Accessible Design. Exception 2 to section 202.3 permits an altered play area to comply with applicable requirements to the maximum extent feasible, if full compliance is technically infeasible. “Technically infeasible” is also defined in section 106.5 of the 2010 Standards. There are also several Exceptions for alterations to play areas as compared to newly constructed play areas in Section 1008.

Overview of Play Area Scoping Requirements & Definitions:

A play area is a site that:

  • Contains play components
  • Designed & constructed for children
  • Where play areas are separated on a site, each area must be evaluated separately for accessibility compliance.
  • Each of the age specific areas must be evaluated separately for accessibility

There are several instances when the 2010 ADA Standards requirements for Play Areas do not apply, including: Play areas designed for children under 2 years old; Family childcare facilities where the proprietor resides; Amusement attractions; Religious entities; and, where play components are altered and the ground surface is not altered, the ground surface shall not be required to comply with 1008.2.6 unless required by 202.4. Also, 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 240.

What is a Play Component?

A Play Component is 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, i.e. swings, slides, rockers, and see-saws.

What is a Ground Level Play Component?

A ground level play component is a play component that is approached and exited at the ground level.

  • Where Ground level play components are provided, one of each type must be accessible
  • Where elevated play components are provided, ground level must equal at least 50% of the total number of elevated elements – Except when there is a ramp to each elevated play area
  • Ground level play components must be integrated in the play area to allow for socialization.
  • At least one of each type of play component provided at ground level in a play area must be on an accessible route and comply with 1008.4. Different “types” of play components are based on the general experience provided by the play component i.e. rocking, swinging, climbing, spinning, and sliding.
  • Additionally, 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 1008.4. There is an Exception to this requirement 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 240.2.1.2.

Table 240.2.1.2 Number and Types of Ground Level Play Components Required to be on Accessible Routes

Number of Elevated Play Components Provided

Minimum Number of Ground Level Play Components Required to be on an Accessible Route

Minimum Number of Different Types of Ground Level Play Components Required to be on an Accessible Route

1 Not applicable Not applicable
2 to 4 1 1
5 to 7 2 2
8 to 10 3 3
11 to 13 4 3
14 to 16 5 3
17 to 19 6 3
20 to 22 7 4
23 to 25 8 4
26 and over 8, plus 1 for each additional 3,
or fraction thereof, over 25
5

 

  • 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.

What is an Elevated Play Component?

An elevated play component is 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.

  • Where elevated play components are provided, at least 50 percent shall be on an accessible route and shall comply with 1008.4.

What is a Soft Contained Play Component?

A Soft Contained Play Component is a play structure made up of one or more play components where the user enters a fully enclosed play environment that utilizes pliable materials, such as plastic, netting, or fabric (i.e. the type of play area you may find at the local fast food restaurant).

  • Soft Contained play components must provide at least one entry point on an accessible route when three or fewer entry points are provided and where four or more entry points are provided, at least two entry points must be located on an accessible route.

What is a Use Zone?

A Use Zone is the ground level area beneath and immediately adjacent to a play structure or play equipment that is designated by ASTM F 1487* for unrestricted circulation around the play equipment and where it is predicted that a user would land when falling from or exiting the play equipment.

*ASTM F 1487 – safety specifications for various types of playground equipment for children ages 2-12 not including soft contained play equipment.

Accessible Routes within Play Areas

At least one accessible route shall be provided within the play area serving Ground Level and Elevated Play Components. The accessible route shall connect ground level play components required to comply with 240.2.1 and elevated play components required to comply with 240.2.2, including entry and exit points of the play components (206.2.17.1).

Accessible routes serving play areas shall comply with Chapter 4 and 1008.2 and shall be permitted to use the exceptions in 1008.2.1 through 1008.2.3. Where accessible routes serve ground level play components, the vertical clearance shall be 80 inches high minimum.

1008.2.1 – Accessible routes serving ground level play components and elevated play components shall be permitted to use the exceptions in 1008.2.1.

EXCEPTION 1:

Transfer systems complying with 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.

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.

Play Areas Accessible Route Width

1008.2.4.1 Ground Level. At ground level, the clear width of accessible routes shall be 60 inches minimum.

EXCEPTION 1: In play areas less than 1000 square feet the clear width of accessible routes shall be permitted to be 44 inches minimum, if at least one turning space complying with 304.3 is provided where the restricted accessible route exceeds 30 feet in length.

EXCEPTION 2: The clear width of accessible routes shall be permitted to be 36 inches minimum for a distance of 60 inches maximum provided that multiple reduced width segments are separated by segments that are 60 inches wide minimum and 60 inches long minimum.

1008.2.4.2 Elevated. The clear width of accessible routes connecting elevated play components shall be 36 inches minimum.

EXCEPTION 1: The clear width of accessible routes connecting elevated play components shall be permitted to be reduced to 32 inches minimum for a distance of 24 inches maximum provided that reduced width segments are separated by segments that are 48 inches long minimum and 36 inches wide minimum.

EXCEPTION 2: The clear width of transfer systems connecting elevated play components shall be permitted to be 24 inches minimum.

Ramps

Within play areas, ramps connecting ground level play components and ramps connecting elevated play components shall comply with 1008.2.5.

1008.2.5.1 Ground Level. Ramp runs connecting ground level play components shall have a running slope not steeper than 1:16.

1008.2.5.2 Elevated. The rise for any ramp run connecting elevated play components shall be 12 inches maximum.

Ramp Handrails

Where required on ramps serving play components, the handrails shall comply with 505 except as modified by 1008.2.5.3.

EXCEPTIONS:

1. Handrails shall not be required on ramps located within ground level use zones.

2. Handrail extensions shall not be required.

1008.2.5.3.1 Handrail Gripping Surfaces. Handrail gripping surfaces with a circular cross section shall have an outside diameter of 0.95 inch minimum and 1.55 inches maximum. Where the shape of the gripping surface is non-circular, the handrail shall provide an equivalent gripping surface.

1008.2.5.3.2 Handrail Height. The top of handrail gripping surfaces shall be 20 inches minimum and 28 inches maximum above the ramp surface.

Play Components:

Ground level play components on accessible routes and elevated play components connected by ramps shall comply with 1008.4.

1008.4.1 Turning Space. At least one turning space complying with 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.

1008.4.2 Clear Floor or Ground Space. Clear floor or ground space complying with 305.2 and 305.3 shall be provided at play components. See the Advisory below for additional information:

1008.4.3 Play Tables. Where play tables are provided, knee clearance 24 inches high minimum, 17 inches deep minimum, and 30 inches wide minimum shall be provided. The tops of rims, curbs, or other obstructions shall be 31 inches high maximum.

EXCEPTION: Play tables designed and constructed primarily for children 5 years and younger shall not be required to provide knee clearance where the clear floor or ground space required by 1008.4.2 is arranged for a parallel approach.

1008.4.4 Entry Points and Seats. Where play components require transfer to entry points or seats, the entry points or seats shall be 11 inches minimum and 24 inches maximum from the clear floor or ground space.

EXCEPTION: Entry points of slides shall not be required to comply with 1008.4.4.

1008.4.5 Transfer Supports. Where play components require transfer to entry points or seats, at least one means of support for transferring shall be provided.

Play Area Ground Surface Material

Ground surface materials used on accessible routes, clear floor spaces and turning spaces must comply with ASTM F 1951 (2010 ADA) and Use Zones must comply with ASTM F 1292 and generally must be stable, firm and slip resistant.

Exception: Where play components are altered but the ground surface is not altered, the ground surface is not required to comply with 1008.2.6, unless required by 202.4 (Alterations to a Primary Function Area).

ASTM 1951-99 assesses the accessibility of a surface by measuring the work an individual must exert to propel a wheelchair across the surface. The standard includes tests of effort for both straight-ahead and turning movements, using a force wheel on a rehabilitation wheelchair as the measuring device.

Remember that there is no “one size fits all” surface material.

Items to consider when selecting ground surface material include the following: The location of the playground; drainage; average grade of the area; cost of installation and maintenance; life expectancy of the surface and infill materials; accessible routes to the playground; temperature; amount of use; ages of the users; height of equipment; and amount of and dispersion of accessible elements.

There are essentially 2 options for ground surface material: loose fill materials or synthetic materials

When choosing the type of surfacing material there are two important criteria to apply:

  1. What is the force of impact from a fall in a use zone, in and around playground equipment? (Established by ASTM Standard 1292-99 and ASTM F 1292-04).

    These standards provide a uniform means to measure and compare characteristics of surfacing materials to determine whether materials provide a safe surface under and around playground equipment.

  2. What are the surface characteristics of playground surfaces that allow for compaction, propulsion and turning capabilities for mobility devices on playground surfaces?

    These standards are addressed in ASTM F 1951-99. ASTM F 1951-99 establishes a uniform means to measure the characteristics of surface systems in order to provide performance specifications to be used when selecting materials for use as an accessible surface under and around playground equipment. Surface materials that comply with this standard and are located in the use zone must also comply with ASTM F 1292.

Review of Accessible Ground Surfaces

-Pea gravel, sand and wood chips

These materials do meet compliance standards for impact attenuating surfaces, but they seldom meet the standard for propulsion and turning requirements in the ASTM standards and are thus not recognized as ADA-approved materials. Other surfacing materials can be used to create paths to the entry point of the play equipment and render playgrounds compliant.

-Shredded Rubber and Engineered Wood Fiber

Both are ADA compliant for both mobility and impact attenuation (they meet the minimum requirements of ASTM F 1292). Shredded Rubber and Engineered Wood Fiber can be used for play structures with a fall height up to 10 feet.

-Pour-in-Place, Rubber Mats/Tiles

These artificial surfacing materials exceed ADA standards and are deemed universally accessible for children with disabilities and they are low maintenance.

-Artificial Grass with Rubber in-fill

Properly certified turf should also have a soft, consistent surface that is ADA wheelchair accessible. Since the grass won’t displace like loose fill, such as sand, rubber chips, or wood chips, the safety rating is easy to maintain, even under play equipment. (Generally more cost effective than Pour-in-Place tiles).

Transfer Systems

Where transfer systems are provided to connect to elevated play components, transfer systems shall comply with 1008.3.

Advisory 1008.3 Transfer Systems. Moving between a transfer platform and a series of transfer steps requires extensive exertion for some children. Designers should minimize the distance between the points where a child transfers from a wheelchair or mobility device and where the elevated play components are located.

Transfer platforms shall be provided where transfer is intended from wheelchairs or other mobility aids. Transfer platforms shall comply with 1008.3.1.

1008.3.1.1 Size. Transfer platforms shall have level surfaces 14 inch deep minimum and 24 inch wide minimum.

1008.3.1.2 Height. The height of transfer platforms shall be 11 inch minimum and 18 inch maximum measured to the top of the surface from the ground or floor surface.

1008.3.1.3 Transfer Space. A transfer space complying with 305.2 and 305.3 shall be provided adjacent to the transfer platform. The 48 inch long minimum dimension of the transfer space shall be centered on and parallel to the 24 inch long minimum side of the transfer platform. The side of the transfer platform serving the transfer space shall be unobstructed.

1008.3.1.4 Transfer Supports. At least one means of support for transferring shall be provided.

1008.3.2 Transfer steps. Transfer steps shall be provided where movement is intended from transfer platforms to levels with elevated play components required to be on accessible routes. Transfer steps shall comply with 1008.3.2.

1008.3.2.1 Size. Transfer steps shall have level surfaces 14 inches deep minimum and 24 inches wide minimum.

1008.3.2.2 Height. Each transfer step shall be 8 inches high maximum.

1008.3.2.3 Transfer Supports. At least one means of support for transferring shall be provided.

Advisory 1008.3.2.3 Transfer Supports. Transfer supports are required on transfer platforms and transfer steps to assist children when transferring. Some examples of supports include a rope loop, a loop type handle, a slot in the edge of a flat horizontal or vertical member, poles or bars, or D rings on the corner posts.

Other Accessible Elements to Consider:

If play areas are part of a multi-use facility, designers and operators must also comply with ADA and all applicable requirements for recreation facilities.

NOTE: There is a safe harbor in place for those elements at facilities constructed in compliance with the 1991 ADA Accessibility Guidelines that applies until those spaces/elements are altered (then 2010 ADA Standards apply). These areas include, but are not limited to, toilet rooms and dressing, fitting, and locker rooms.

Conclusion:

The application of play area accessibility requirements is impacted by the new 2010 ADA Standards for Accessible Design and the extent to which existing play areas must be modified to comply with these new standards varies from entity to entity based on the “Program Access” and “Barrier Removal” standards. Accessibility Services is here to assist you as you work to improve the accessibility of your existing and newly constructed and/or altered play areas. We can help you apply the ADA requirements reviewed above as well as any state building code requirements that may be applicable to play areas.

Should you have questions about the accessibility of play areas, feel free to contact Jennifer Perry, Accessibility Services, at 718.803.3782 #7504 or jperry@accessibility-services.com.