The Australian Construction Safety Journal Autumn 2012 digital eMagazine has been released, view here: http://t.co/6qniRFQj
In my capacity as the chair of several Australian standards committees I am frequently approached to provide guidance and interpretation of play and adventure standards.
One commonly asked question relates to compliance and certification of playground equipment.
Certification refers to the confirmation of certain characteristics of a product, person, or organisation. This confirmation is often, but not always, provided by some form of external review or training and/or assessment. One of the most common types of certification is professional certification, where a person is certified as being able to competently complete a job or task, usually by passing an examination for example, a certified professional engineer must successfully complete a Bachelor of Engineering degree followed by several years of supervised professional practice.
The other most common type of certification is product certification. This refers to processes intended to determine if a product meets minimum standards. Product certification is the process of certifying that a certain product has passed performance and quality assurance tests stipulated in regulations such as a building code and standards, or that it complies with quality and minimum performance requirements. Product certification is the certification that is required for playground equipment. This short article discusses how certification and compliance relate to the manufacture, supply and installation of playground equipment.
The AS 4685:2004 mandates that all equipment shall be marked legibly and permanently with the name and address of the manufacturer and the number of the standard i.e. AS 4685:2004. It also warns that manufacturers making a statement of compliance with this Australian standard on a product, packaging or promotional material related to that product are advised to ensure that compliance is capable of being verified. Verification is demonstrated by documentation confirming appropriate design and testing has been performed to AS 4685:2004.
If the manufacturers and/or suppliers do not label the playground equipment, then by definition, they cannot comply with the standard as they have not labelled the equipment in accordance with a mandatory clause within the standard.
The Australian Standard AS4685:2004 Playground equipment specifies the method for determining the loads on playground equipment and structural integrity of playground equipment.
The standard uses a loading system that considers both permanent and variable loads. The permanent loads include: the mass of the playground structure and components; any prestressing loads such as those associated with the flying fox main cable or a large space net structure; and the mass of water or sand if permanent or semi-permanent water or sand storage are incorporated within the play structure.
The variable loads include: user loads both static and dynamic; snow and hail loads; wind loads; temperature loads such as those on the main cable of a flying fox; and other specifi c loads such as swinging and rotating loads.
Independent testing and certification of conformity
The Australian Standard AS4685:2004 Playground equipment states that manufacturers and/or suppliers shall provide certification of conformity with this standard. They shall also supply copies of test reports upon request.
In the first instance it is recommended that you start by requesting copies of the certification of conformity and the supporting test reports. The standard states that the manufacturers and/ or suppliers must provide this so you are not asking for anything extraordinary by making this request. Should the manufacturers and/or suppliers be unable or unwilling, by definition they are no longer complying with the playground equipment standard.
Why does the playground designer (and owner) need to obtain a copy of the manufacturers and/or suppliers pre-information and certification of conformity? Among other things, playground designers need this documentation to enable them to design the playground in accordance with the standard. It is also important to have an independent appraisal before you purchase or install the equipment to ensure that the equipment you are about to specify or purchase is fit to be used for its intended purpose. The playground designer needs to know that the playground equipment will be manufactured consistently within dimensional tolerances to a minimum standard. The playground designer also needs to know that the equipment has been assessed for the target user group and indirectly answers the question does the play equipment have sufficient play value for the intended age range? Have all the hazards been removed, particularly the hazards that are not obvious to children at play. Have all the whole body, head, neck, torso, hair, clothing strangulation, leg, foot, hand and finger entrapments been removed? Is the free space sufficient? Is there any unintended access? What is the free height of fall and extent of the falling surface? Are all the hazard reduction mechanisms sufficient? Is the structural integrity of the playground equipment adequate? What is the availability of spare parts? What are the finished levels of the various components of the equipment? How can the playground designer determine the placement and configuration of fencing, gates, trees, shade structures, landscaping, benches, tables, water features and other services; ensure the equipment footings suit ground conditions; the choice of a suitable and adequate impact attenuating surface; ensure that the equipment will fit within the space provided and that the equipment is suitable for the site topography.
When you purchase playground equipment you are generally protected by two types of warranties, namely: expressed warranties; and statutory warranties.
Express warranties are offered by the supplier and should be in writing. Some are given unconditionally while others may be subject to time limits or conditions such as ‘regular maintenance’. Suppliers must stand by their warranties or guarantees, whether the product is sold directly or through an agent. If they do not, then you may seek redress.
Manufacturers must also ensure a reasonable supply of spare parts and repair facilities. However, they do not have to do so if they take reasonable action to advise at the time of sale that parts or facilities will not be available at all after a specified time.
Statutory warranties are provided by two Australian laws, namely: the Trade Practices Act; and the Sale of Goods Act. These operate in addition to any express warranty.
Independent verification of the ‘as installed’ playground
Prior to opening the playground to the public when the playground installation is complete and the manufacturers and/or suppliers have commissioned all the playground elements, an independent inspection is performed to verify compliance against the relevant Australian playground standards. AS/NZS 4486.1:1997 calls this process the post-installation inspection. This standard states that the manufacturers and/or suppliers shall supply an inspection checklist for the post-installation inspection. This is important to check that no non-conformities have been inadvertently introduced during the assembly of the equipment and also to verify the manufacturer’s certification.
For reasons of impartiality it is also important to ensure that the post-installation inspection is at arms length from the equipment manufacturers and/or suppliers. This is commonly referred to as ‘third party’ or ‘independent certification’. Using an independent post-installation inspector reduces the likelihood of any conflict of interest. As a general rule you should never use a post-installation inspector who has a relationship with the equipment manufacturers and/or suppliers or installer as there will always be a conflict of interest whether real or perceived. An equipment inspector who has issued the certificate of conformity should not be signing off any playground that contains equipment previously certified by this inspector on behalf of the equipment supplier.
To obtain and maintain confidence, it is essential that the decisions of persons or organisations conducting the certification are based on objective evidence of conformity (or non-conformity) obtained by the certifying person or organisation, and that these decisions are not influenced by other interests or by other parties. Familiarity by equipment inspectors with the equipment or the manufacturers and/or suppliers can also result in their impartiality being compromised.
Resolving conflict between supplier and independent verifier
The most commonly reported conflict is where suppliers and/or manufacturers claim that on-site verification is not necessary as they have a certificate of conformity to the European Standard for playground equipment EN 1176, that this certificate is fr om a large and respected European testing authority, and that they have a letter stating that it also complies with AS4685:2004. They insist that on-site testing and/or inspection is not necessary although an independent site inspection has reported one or more non-conformities. If you have not experienced this problem it is only a matter of time before you do.
In an attempt to resolved this circular argument I contacted my colleagues in Europe requesting clarification. To my surprise I was advised that this is also a problem in Europe even where the equipment is tested and installed to EN 1176:2008.
In France there is a statutory requirement for certification if the manufacturer deviates from EN 1176. Nevertheless on-site inspectors still experience problems with certificates from a large and respected European testing authority and complain about the additional work involved with clarification.
In other European countries where, as in Australia, there is no statutory requirement to comply with the playground standard, the problem is similar but more complex. I have been advised that nonconformity to EN 1176 happens because the manufactured product deviates from the certified product or the certificate is not correct – on-site inspectors experience both. They also advised that this is why the post-installation inspection and not the certificate of conformity is relevant for the compliance. They advise the best way to resolve this difficulty is to address the problem in advance and disseminate information of known deviations to importers, designers and owners of playground equipment.
The Australian Standard for Playground Equipment requires playground manufacturers and/or suppliers to label all playground equipment. If manufacturers and/or suppliers are unprepared or unwilling to do this you should ask the question ‘why are they unwilling to perform what on the surface is a very simple task?’
You should be asking for a copy of the manufacturer’s certificate of conformity and copies of the test reports to AS 4685:2004. If they unable or unwilling do provide this documentation you should be asking the question ‘why are they unwilling to provide this documentation?’