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EWF Playground Surface

Sep 2016

On NRPA Connect, Phillip in Franklin, Kentucky asks about EWF, he says: “We have engineered wood fiber (EWF) in all but two of our playgrounds. We currently have a parent challenging that EWF is ADA accessible for children in our early childhood development program.  The smaller children in wheel chairs have trouble traversing the EWF because the front caster wheels on their little wheel chairs are small and catch on the EWF.

We installed a product called "Mobi-Mat" over the EWF for the child to be able to self-propel her chair and socialize with the other children in the playground (it is outside of all use zones).  The parent has stated that since we don't have unitary surfacing like two of our schools, her child cannot access the playground or the equipment.

Have the ADA playground accessibility standards for playgrounds changed in the last three years?  Anyone have any experience or input on our situation?

RAC is keen on EWF questions.  We said: There has been no change, and I wouldn't just say in the last three years.  The US Access Board published a Final Guideline on play areas in the year 2000.  US DOJ published the 2010 Standards and used the exact same language.  Engineered Wood Fiber (EWF) is only accessible and therefore ADA compliant under two circumstances.

First, it must pass both the ASTM F1292 and ASTM F1951 tests.  As you know, 1292 measures impact attenuation and 1951 measures accessibility characteristics.  I am sure you have the independent lab testing certificates for the EWF surfaces.

Second, per the title II regulation at section 35.133, which governs public school districts and other state and local government entities, requires the school district to maintain accessible features.  Additionally, the 2010 Standards for Accessible Design, in section 1008.2.6.1, imposes a requirement regarding maintenance on the school district.  It says "Ground surfaces shall be inspected and maintained regularly and frequently to ensure continued compliance with ASTM F1951."

It is September, so I imagine your EWF playgrounds are crawling with kids. All those footfalls have undoubtedly created uneven surfaces and divots in the EWF.  No one knows how to quantify "regularly and frequently". Is it daily? Hourly? Every two days? Once a week?  In our experience evaluating playgrounds, we rarely find once a week.  It is usually less frequently than that. And in those circumstances, the EWF surface almost always fails to be accessible.

IPEMA says that an EWF surface, to be accessible, must be replenished and then raked, levelled, watered, and compacted.  Are your school district maintenance teams taking that approach?

Others on this forum will give you some helpful technical advice. But to me this boils down to maintenance…think of it as maintenance-PLUS!

Candidly, in our experience, school districts do not make maintenance a priority.

Disclaimer: Nothing in this newsletter is legal advice. It is instead a relaying of decisions and information about the application of the Americans with Disabilities Act to public parks and recreation. Readers interested in legal advice should seek an attorney licensed in your state that knows the ADA and can apply it to parks and recreation.