New standards requirement for the onsite testing of playground surfaces
The Play Safety Forum disagrees with the proposal currently being made by European and British Standards bodies to introduce a requirement for onsite testing of playground surfaces. Robin Sutcliffe, the Chairman of the Forum has written to the British Standards committee as part of the consultation process. His letter follows:
To: Matthew Marshall
I am writing on behalf of the UK Play Safety Forum to express our deep concern about the proposed amendments to EN 1176 specifically in relation to the requirement for site testing of impact absorbing surfaces.
The forum believe that the case for surfacing itself is controversial and that the level of serious injuries sustained from impacts resulting from falls within playgrounds is not significant and could therefore not be significantly reduced by this measure. The increased costs will either reduce levels of investment in play or see policies of play spaces being removed, or, more probably, both. It therefore follows that if this measure is implemented it will have a serious impact on the wellbeing of children across Europe.
The Forum feel very strongly about this and would be willing to attend a meeting of CEN to argue our case if that would be helpful.
Play Safety Forum Chairman
The Forum would like to encourage you to write with your comments as soon as possible so that they can be considered by the relevant European Committee. The reference for the document concerned is:
EN 1176 part 1 – CEN* 2nd Enquiry
As discussed at the recent CEN/TC136/SC1 meetings in Cyprus and Warsaw, we are working to a very tight deadline with this second Enquiry. Due to this work programme constraint and no availability of meeting rooms it is not possible to change the date of the next meeting. Therefore, after a decision with CCMC* we would like to ask members to kindly submit all comments by 29 July 2016 and when submitting their comments to please also send a copy to the secretary
This is to ensure that all comments can be passed to WG13* as soon as possible and not have to wait until the official closing date of 2 September 2016.
The official closing date for all comments is 2 September 2016. After that there is a period of seven weeks for the comments to be addressed and a revised draft sent to DIN*. The Formal Vote will then be opened on 13 December 2016. There is a two month translation period for CEN between 27 October and 13 December 2016.
- CEN – the European body responsible for producing European Standards ‘Committee European Normalisation’. It extends beyond EU membership and hence would not be affected by BREXIT. CEN is managed by CCMC – see below.
- CCMC – the CEN-CENELEC Management Centre (CCMC), located in Brussels, is in charge of the daily operations, coordination and promotion of all CEN and CENELEC activities. Our sector of children’s play sits under the CEN side of their activities, within SC1 – see below. (CENELEC, relates specifically to ‘electrical’ focused products and services).
- SC1 – European Standards ‘Sub-committee 1’ and has specific responsibility for Children’s Playground Equipment. SC1 reports back to CCMC, via an intermediate group.
- WG13 – a Working Group for the European Standards committee SC1. WG13 is specifically responsible for the revision of EN 1176, part 1.
- DIN – the German standards body Deutches Institute for Normalisation