Analysis Of The Proposed Standarts (Appendix A) - Summary Of The Major Substantive Changes Proposed For The Scoping And Technical Requirements Page 58

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A commenter noted that the proposed standards allow for the provision of transfer steps
to elevated play structures based on the number of elevated play activities, but asserted
that transfer steps have not been documented as effective means of access.
The guidelines recognize that play structures are designed to provide unique experiences
and opportunities for children. The proposed rule provides for play components that are
accessible to children who cannot transfer from their wheelchair, but it also provides
opportunities for children who are able to transfer. Child
ren often interact with their
e
nvironment in ways that would be considered inappropriate for adults. Crawling and
climbing, for example, are integral parts of the play experience for young children.
Permitting the use of transfer platforms in play structures provides some flexibility for
creative playground design.
ccessible Play Components. Play components (including ground level, elevated, and
A
soft contained play structures) will be req
uired to be on an accessible route, including
e
levated play components that are required to be connected by ramps, and will
themselves have to comply with accessibility requirements (including specificatio
ns for
turning space and clear floor space and for play tables and transfer entry points and
supports).
A commenter expressed concerns that the general requirements of section 240.2.
1, Play
A
reas, and the advisory accompanying section 240.2.1, General, conflict. The comment
asserts that section 240.2.1 provides that the only requirement for integration of
equipment is where there are two or more required ground level play components, whil
e
the advisory appears to suggest that all accessible com
ponents must be integrated.
The commenter misinterpr
ets the requirement. The ADA mandates that people with
d
isabilities be able to participate in programs or activities in the most integrated setting
appropriate to their needs. Therefore, all accessible playground equipment must be
integrated into the general playground setting. Section 240.2.1 specifies that where
there
is more than one accessible ground level play component, the components must be b
oth
dispersed and integrated.
Ground Surfaces. Section 1008.2.6, Ground Surfaces, provides that ground surfaces on
accessible routes must comply with ASTM requirements.
A commenter recommended that the Department closely examine the requirements for
ground surfaces at play areas. The Department is aware that there is an ongoing
controversy about ground surfaces arising from a concern that some surfaces that meet
the ASTM requirements at the time of installation will become inaccessible if they d
o not
receive constant maintenance. The Access Board is also aware of this issue and is
undertaking research to explore solutions to the problems. The Department would
caution covered entities selecting among the ground surfacing materials
that comply with
th
e ASTM requirements, that they must anticipate the maintenance costs that will be
associated with some of the products. Permitting a surface to deteriorate so that it does
58

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