Examining Water-Play Surfacing Compliance
An opinion on NSF50 (S26) and ASTM F2461 as they develop
By Rolf Huber
Owners of children’s water features run a full gambit of risks. One of those risks should not have to be contending with apparent mandates to purchase and install surfacing systems that are certified. Owners today are faced with understanding new standards being developed at ISO, revised at ASTM, and terms added to NSF50 in Section 26 (S26). Currently, there are two competing standards—ASTM F2461 and NSF50 Section 26—that are held up for compliance and they are incomplete and under revision. However, that will not stop them from being used when an injury and lawsuit occurs. Designers, specifiers, and owners must be aware of their choices and make intelligent decisions.
Weighing The Risks
At the top of the pyramid are ISO standards that are used worldwide. In the area of sports, recreation, and play, there are standards for drowning prevention in commercial pools, floating inflatables, and benefit/risk assessment. The basis of these standards is to identify intended users and reasonably foreseeable behaviors, as well as to understand there are certain injuries that are an acceptable outcome for an activity, product, or service. In the evaluation process, activities and potential outcomes are evaluated against the probability of a selected injury-severity occurring. In a separate exercise, the benefits of the activity, product, or services are listed, noting that, for some activities, risk taking is a benefit. The key is to determine whether the benefits outweigh the risks, and to move the activity forward. Obviously, regulatory prohibitions stop any project.
On The Horizon
The NSF50 (S26) and ASTM F2461 are tools in understanding and evaluating surfacing options for a water play or water feature, whether in a public setting or a pay-for-play venue. These tools help the owner/operator prevent the specific harm that can occur, such as skinned knees, fractures, concussions, or worse. The owner must prioritize these accidents and prepare to accept and defend as a legitimate outcome of an activity. The NSF50 (S26) and ASTM F2461 consider slip-fall and impact with the surface, while NSF50 (S26) also considers impermeability to water, removal of microorganisms, and a warranty associated with a surfacing system. NSF50 even offers product suppliers the opportunity to participate in an expensive certification program, while ASTM does not certify products. Effectively, both standards offer tests and procedures a supplier can have performed in a laboratory, and test results can be delivered to the designer or owner to confirm compliance for the installed surface system. Slip resistance (ASTM E303) and impact attenuation (ASTM F3313) can be performed in the field, at the time of installation, and seasonally.
Time Will Tell
The ISO benefit/risk-assessment standard is in the development stage, but the principles still apply. The ASTM F2461 is in revision, but the hope is that surfaces must first and foremost be slip-resistant to prevent falls and only if the surface is considered slippery; the surface must be impact-attenuating, the same as a playground surface, with ASTM F1292 and ASTM F3313. NSF50 (S26) is being revised to allow broom-finished concrete as a general surface, with synthetic surfaces as an option. The larger problem is that many of the laboratory tests and compliance requirements as written in NSF50 (S26) are not realistic or cannot be performed. It does deal with slip and impact equally. If an owner chooses to adopt compliance with NSF50 (S26), the owner will have to consider how to adopt an incomplete standard or how to defend that choice should an injury occur.
Each designer, specifier, and owner will have to decide on the standards that best meet their needs. Public health or state regulations might mandate all or part of NSF50 compliance locally. Designers, specifiers, and owners need to take a page from the ISO benefit/risk work and document their decisions. Accidents will happen and injuries will occur. A well-documented benefit/risk assessment, based on an educated understanding of relevant standards, and re-evaluation from time to time, will form a first line of defense should an injury occur, and the injured party decides it is outside their tolerance for risk.
Rolf Huber is President of the Canadian Playground Advisory, Inc. Reach him at rolf@playgroundadvisory.com.