SIST-TP CEN/TR 17842-1:2023
(Main)Playground equipment for children - Part 1: Replies to requests for interpretation of EN 1176:2017 and its parts (2018-2019)
Playground equipment for children - Part 1: Replies to requests for interpretation of EN 1176:2017 and its parts (2018-2019)
The purpose of this document is to publish replies to requests for interpretations, to all parts of EN 1176, which have been drafted by the interpretation panel and confirmed by CEN/TC136/SC1.
Kinderspielplatzgeräte - Teil 1: Antworten zu Interpretationsanfragen der Jahre 2018 und 2019 zur EN 1176:2017 und deren Teilen
Équipements d'aires de jeux pour enfants - Partie 1: Réponses aux demandes d'interprétation de l'EN 1176:2017 et de ses parties (2018-2019)
L’objectif du présent Rapport technique du CEN est de publier les réponses aux demandes d’interprétation concernant toutes les parties de l’EN 1176, qui ont été formulées par le panel d’interprétation et validées par le CEN/TC 136/SC 1.
Oprema otroških igrišč - 1. del: Odgovori na zahteve za razlago EN 1176:2017 in njegovih delov (2018-2019)
Namen tega dokumenta je objaviti odgovore na zahteve za razlago vseh delov standarda EN 1176, ki jih je pripravila komisija za interpretacijo in potrdil tehnični odbor CEN/TC136/SC1.
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CEN/TR 17842-1:2023
01-marec-2023
Oprema otroških igrišč - 1. del: Odgovori na zahteve za razlago EN 1176:2017 in
njegovih delov (2018-2019)
Playground equipment for children - Part 1: Replies to requests for interpretation of EN
1176:2017 and its parts (2018-2019)
Kinderspielplatzgeräte - Teil 1: Antworten zu Interpretationsanfragen der Jahre 2018 und
2019 zur EN 1176:2017 und deren Teilen
Équipements d'aires de jeux pour enfants - Partie 1: Réponses aux demandes
d'interprétation de l'EN 1176:2017 et de ses parties (2018-2019)
Ta slovenski standard je istoveten z: CEN/TR 17842-1:2022
ICS:
97.200.40 Igrišča Playgrounds
SIST-TP CEN/TR 17842-1:2023 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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CEN/TR 17842-1
TECHNICAL REPORT
RAPPORT TECHNIQUE
November 2022
TECHNISCHER REPORT
ICS 97.200.40
English Version
Playground equipment for children - Part 1: Replies to
requests for interpretation of EN 1176:2017 and its parts
(2018-2019)
Équipements d'aires de jeux pour enfants - Partie 1: Kinderspielplatzgeräte - Teil 1: Antworten zu
Réponses aux demandes d'interprétation de l'EN Interpretationsanfragen der Jahre 2018 und 2019 zur
1176:2017 et de ses parties (2018-2019) EN 1176:2017 und deren Teilen
This Technical Report was approved by CEN on 9 October 2022. It has been drawn up by the Technical Committee CEN/TC 136.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2022 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 17842-1:2022 E
worldwide for CEN national Members.
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Contents Page
European foreword . 3
Introduction . 4
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 6
4 EN 1176-1:2017, Playground equipment and surfacing — Part 1: General safety
requirements and test methods . 6
5 EN 1176-2:2017+AC:2019, Playground equipment and surfacing — Part 2: Additional
specific safety requirements and test methods for swings . 30
6 EN 1176-3:2017, Playground equipment and surfacing — Part 3: Additional specific
safety requirements and test methods for slides . 34
7 EN 1176-5:2019, Playground equipment and surfacing — Part 5: Additional specific
safety requirements and test methods for carousels . 36
8 EN 1176-6:2017+AC:2019, Playground equipment and surfacing — Part 6: Additional
specific safety requirements and test methods for rocking equipment . 37
9 EN 1176-11:2014, Playground equipment and surfacing — Part 11: Additional
specific safety requirements and test methods for spatial network . 41
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European foreword
This document (CEN/TR 17842-1:2022) has been prepared by Technical Committee CEN/TC 136
“Sports, playground and other recreational facilities and equipment”, the secretariat of which is held by
DIN.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN shall not be held responsible for identifying any or all such patent rights.
Any feedback and questions on this document should be directed to the users’ national standards body.
A complete listing of these bodies can be found on the CEN website.
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Introduction
Interpretations and no-action decisions
This document contains all interpretations since CEN/TR 16396 to the end of 2019. It should bring a
close to all interpretations made to the 2020 version of the EN 1176 series and all of its specific parts
that were also revised in 2020. It contains replies to requests for interpretations concerning the
understanding of clauses in the parts of the EN 1176 series. The replies concern those requests that
have resulted in an interpretation or a decision that no action is required as the standard is sufficiently
clear.
An interpretation does not have the same status as the text of the standard. However, following an
interpretation gives assurance that the relevant clause of the standard has been correctly applied.
An interpretation is a clarification of the meaning of the standard. This document covers requests from
2018 to the end of 2019.
Disclaimer
The interpretations have been prepared by the interpretation panel of CEN/TC 136/SC1 committee
according to an agreed process and finally confirmed by the whole SC1 committee prior to responding
back to the enquiring National Standard Body. The information contained herein should always be
considered in association with the original EN 1176 series published in 2017.
Requests for interpretations may be submitted by a CEN member body through its national committee
or by a CEN/TC 136 liaison (but not directly by an individual or a company) – in accordance with the
interpretation protocols agreed by CEN/TC 136/SC 1. The requests are then channelled to the CEN/TC
136/SC 1 interpretation panel, which will then deal with the request.
A request for an interpretation may lead to:
a) an interpretation of the standard with no action to the standard (no revision and no amendment)
This should reflect a reasonable interpretation of how the standard should be used, taking into
account:
1) the wording of the standard;
2) the rationale of the standard;
3) the history of the standard.
This is also applicable when it is agreed that the standard appropriately specifies how playground
equipment is assessed.
b) a proposal for an amendment of the standard
This is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretation and no-action decisions are published in CEN/TR 16396 which will be updated on a
regular basis. Proposals for amendments will be progressed as new work item proposals in accordance with
CEN rules.
c) a future revision
It is not within the interpretation protocol to carry out new work that was not previously covered
within the published EN 1176 series parts and clauses. Future work requests should always be
raised by National Standard Bodies using the “Future work request template” to ensure full
consideration is given to the necessity and possible consequences, before starting any new work on
the EN 1176 series.
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Answers to requests for interpretations
Since requests for interpretations are submitted through a CEN member body, it is assumed that the
member body will keep itself informed about decisions concerning the request and its progress and will
itself inform the originator of the request, as appropriate.
The following information requests have been included in this document:
2018
2018-01 NO — Part 1 — 3.5, 3.20, 3.34-3, 4.2.8.2.3 General, 4.2.16.1 2nd Paragraph after Figure 26
2018-02 NO — Part 1— 4.2
2018-03 NO — Part 1 — 4.2.7.2
2018-04 NO — Part 1 — 4.2.7.2 part b and D.2.2
2018-05 DK — Part 2 — 3.13 and 4.6.3 in part 2:2017
2018-06 DS — Part 1 — 4.7 Hand support
2018-07 DS — Part 1 — 4.2.4.4 and Figure 10
2018-08 NO — Part 2 — Figure 6
2018-09 DE — Part 3 — 4.4.1 and Annex B
2018-10 NEN Part 1 — Figure D.7
2018-11 NEN—Part 1 — Figure D.13
2018-13 NO — Part 1 —4.2.7.3 Entrapment of clothing/hair
2018-15 NEN—Part 1 —4.2.16.1 General
2018-16 NEN—Part 1 —4.2.16
2019
2019-01 UNI Part 3 — 4.5, 4.7, 4.9.2
2019-09 LTL — Part 1 — 4.9 Entrapment
2019-10 LTL— Part 1 — 4.2.4.4 Barriers
2019-11 SIS — Part 1 — 6.2.16 Bouncing facilities
2019-12 HUN—Part 1 — 4.2.8.1
2019-13 DIN —Part 1 — 4.2.13 Chains
2019-14 UK — Part 2 — 3.13
2019-15 DIN— Part 1 — 4.2.16.1
2019-16 SIS — Part 2 — 3.13, 4.6.3 and 4.9
2019-17 SFS — Part 1 — 4.2.7.2
2019-18 SFS —Part 5 — 5.2.3
NOTE ASI — Austria, DS — Denmark, SFS — Finland, AFNOR — France, DIN — Germany, HUN – Hungary, SII
— Israel, — LVS — Latvia, LTL – Lithuania, NBN— Belgium, NEN — Netherlands, SN — Norway, SIS — Sweden,
SIST — Slovakia, SN — Switzerland, TSI — Türkiye, GB — United Kingdom.
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1 Scope
The purpose of this document is to publish replies to requests for interpretations, to all parts of the
EN 1176 series, which have been drafted by the interpretation panel and confirmed by
CEN/TC136/SC1.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp
— IEC Electropedia: available at https://www.electropedia.org/
4 EN 1176-1:2017, Playground equipment and surfacing — Part 1: General safety
requirements and test methods
4.1 General (interpretation request 2018-01 — Norway)
Question
2
1) The standard allows placing several small bouncing facilities – each approximately between 1 m to
2
1,44 m as for single users – together in a cluster, or in a row as part of a jump/stepping-trail thus
letting each bouncing equipment's free space of 1 500 mm overlap each other's free space, or other
equipment's falling space.
See Figure 1 below for example.
NB – We do appreciate that bouncing facilities demand free space/have forced movement as described
in 3.6 and, therefore, our opinion is that this is not allowed. Due to several installations that we do see
are in conflict with this, as others understand the standard differently, we therefore would like it to be
clarified.
We also appreciate that equipment in a cluster – 3.20 – is allowed for equipment not involving free
space/forced movement. A central and relevant question is therefore if one can deviate from the
demands related to free space if one places several equipment’s with or without forced movement in a
cluster?
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Figure 1
MB Proposal:
To exclude any misunderstanding or “use” of the cluster clause, this definition could be more precise:
That 3.20 includes information if a cluster is allowed or not for equipment with forced movement and in
need of free space.
Reply
No action/interpretation
Regarding Free Space:
From EN 1176-1:2017:
clause 3.6 free space; Space in, on or around the equipment that can be occupied by a user undergoing
a movement forced by the equipment.
NOTE 1 Examples for this is sliding, swinging, rocking, jumping in bouncing facility for several users…
clause 4.2.16.1 Bouncing facilities, general.
For a bouncing facility the extent of the free space shall be 1 500 mm measured horizontally from any
point at the perimeter and 3 500 mm above the suspension bed.
All bouncing facilities do have Free Space, however ‘Small’ bouncing facilities are allowed to have
overlapping Free Spaces in clusters.
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Regarding Clusters:
From EN 1176-1:2017:
clause 3.20 cluster;
two or more separate pieces of equipment designed to be installed in close proximity to each other
to provide continuity in a sequence that is needed for the play activity
NOTE An example for a cluster is a trail of stepping stones.
clause 4.2.8.3 Protection against injuries in the free space for users undergoing a movement that is
forced by the equipment
Unless stated otherwise, there shall be no overlapping of adjacent free spaces, or of free space and
falling space of two different pieces of equipment.
NOTE 1 This requirement does not apply to the common space between pieces of equipment in a cluster.
For information:
The current EN 1176 series definition of a cluster requires ‘continuity in a sequence that is needed for
the play activity’. This allows the user to focus on the cluster activities in a way that will allow them to
judge the risks of transferring from one part to the next. In the case of clusters, it is also highlighted in
4.2.8.3, NOTE 1 of EN 1176-1:2017, that overlapping of Free/Falling Space is permitted.
The example shown above, with ‘small’ bouncing suspension beds, is a typical equipment cluster,
therefore the free spaces may overlap, however the standard does not currently include any additional
specific requirements for clusters. This is purposely the case, to allow for flexibility in design. In the
case of bouncing facilities, as with other equipment clusters, a risk assessment should always be carried
out by the supplier to confirm any risks are suitably controlled, in providing this ‘continuity in a
sequence that is needed for the play activity’.
We would recommend that a future work request is made by the NSB if they feel there is a strong safety
case to start future work on products of the type shown, following the procedure agreed by SC1 (see
template in document SC1 N9002). This is to encourage the use of the template / matrix, and to avoid
duplication of work.
4.2 Scope (interpretation request 2018-02 Norway)
Clause 4.2
Question
This is regarding double tyre swing seats. These seats consist of one big car-tyre that has a smaller tyre
(often called security tyre) hanging under it – see Figure 2 below.
The new standard does not include information on ground clearance for tyre seats as in the previous
edition. Instead there is a description for single user seat with ground clearance 35 and group swing
seat with clearance demand 40.
What seat type does the standard define, a single tyre seat or a double tyre seat as shown in Figure 2
below; single user seat or group swing seat?
In the case of double tyre seat – see Figure 2 below, is the ground clearance demand applicable only for
the main top tyre or for the lower tyre as well?
NB – we often observe children standing on the lower tyre having the upper tyre supporting their body.
This has the effect that the lower tyre will not easily deflect if it hits or squeezes another child under it
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against the impact attenuating surface (IAS) under the swing as many seem to argue so that they can
justify that the ground clearance should only be measured from the top tyre.
Sentence 2 in the clause does not define where this measure is to be taken, and one presumes that this
is where the seat is closest to the IAS. Is this correct?
Sentence 3 deviates from sentence 2 for the part of swings being flexible. Is this to be seen in
conjunction with sentence 2 so that IF a part of a seat is flexible this part shall not be included for
measurement of ground clearance? (This would be easier to understand and see if both sentences were
included in the same sentence or paragraph.)
NB! – Here also we do see that flexible lower parts of seats, often with many children inside will not
necessarily deflect or prevent a child falling off the seat in the possibility to be squeezed under the seat
against the IAS.
Figure 2
Reply
No action/interpretation
This type of swing seat is not specifically covered in the EN 1176 series.
We would recommend that a future work request is made by the NSB if they feel there is a strong
requirement to start future work on products of the type shown following the procedure agreed by SC1
(see template in document SC1 N9002). This is to encourage the use of the template / matrix, and to
avoid duplication of work.
For information we can confirm that:
This type of seat is special as it has a top section that provides a general sitting position and also has a
lower flexible part that would only provide a sitting position to very young children, who had their body
positioned within the top section. Prior to publication of the EN 1176 series, swing seat ground
clearances were referenced in DIN 7926-2. This publication required a ground clearance of 250 mm for
seats less than 1 000 g in weight. Although this old standard is no longer valid, the information could be
used as part of a risk assessment on the lower seat part.
In addition to the specific requirements of the EN 1176 series, it is always recommended that a risk
assessment is carried out should unusual situations be identified.
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4.3 Clause 3.5 (interpretation request 2018-03 Norway)
EN 1176-1:2017, clause 4.2.7.2
MB Question:
This is regarding openings between 8,9 and 23 or within angles defined for v-shaped openings, all with
lowest part being above 60 over standing position and all with what we see as obvious possibility for
entrapment of head/neck that we cannot see described in the standard that we do think the standard
should address.
Or do these cases possibly lie within the descriptions that exist in any way?
We want to draw the committee’s attention to:
1) Partially bound rigid openings that consist of parallel or close to parallel sides that are
between 8,9 to 23 apart – see Figure 3 and Figure 4.
2) Flexible V-shaped openings with a lower edge above 60 between two flexible sides or one
flexible side and one rigid side – see Figure 5.
3) Partially bound rigid Horizontal opening – in what we here call “arm-walk”.
See Figures 3 to 5 and texts that should explain this.
If we – for the case of further easing our argument - may be so bold as to assume that the committee
agrees with our examples in that they do in fact represent obvious hazards the standard should
include / address we would like the following to be clarified for each situation:
1) Is there any clause in the existing standard that covers this situation?
2) If no in question 1; if the committee agrees with our view that this is a hazard that should be
abolished – how do we go about it?
3) If the committee does NOT agree with our view that this is a hazard we would very much
appreciate an explanation / reason for this.
1) Opening with parallel sides - between ledge and back side of ladder. A child wanting to pass through
the ladder or out the play house can get caught between the step in the ladder - the one just above the
blue opposite edge - and the blue edge of the play house. The ledges being paralleled for more than
50 cm gives the child little but no possibility to escape. This is per definition NOT a completely bound
opening and not a partially bound opening that deviates from D.2.2 test.
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Figure 3
Figure 4
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1) Opening with parallel sides / ledges - here between climbing ladder and platform. A child falling or
wanting to climb down getting their head caught in the opening is not necessarily “lucky” enough to get
freed from entrapment to one of the sides. We do see that this has a lower risk than a rigid closed
opening and also at the same time see the possible hazard. The ledges are parallel for approximately
30 cm. This is per definition NOT a completely bound opening and not a partially bound opening that
deviates from D.2.2 test.
a) b)
Figure 5
MB Proposal
Include these situations in the standards descriptions using the same templates that are used for other
openings.
PROPOSED TRACK: No action
Comments/proposal for an answer:
1) With reference to EN 1176-1:2017, 4.2.7.2 a) the situations shown are not ‘completely bound’ and
therefore do not require a test to comply with the EN 1176 series.
2) & 3) In addition to the specific requirements of the EN 1176 series, it is always recommended that a
risk assessment is carried out should unusual situations, not covered by the EN 1176 series, be
identified. (For example, situations that are not completely bound but where entrapment risk
could occur). It is not within the terms of the interpretation panel to make judgements about
risks relating to specific pieces of equipment. It can very problematic to make judgements from
photographs alone.
The IP recommends that a proposal for amendment or future work is made by the NSB if they want to
present a “safety case”, following the procedure agreed by SC1 (see template in document SC1 N9002).
4.4 Clause 4.2.7.2 Part b and D.2.2 (interpretation request 2018-04 Norway)
MB Question
This is regarding:
1) Clarification of test method for range 2 and D.2.2; and
2) Clarification of need of template apex to contact base of the opening” in regards to angles.
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Clause D.2.2.2 first paragraph describes the first step in testing and refers to Figure D.3. Figure D.3 only
shows examples where the opening is in range 1 thus making it possible to (mis)understand that this
first procedure only is to be done for openings in this range 1. We ask for a clarification on this.
Question 1) Does the first paragraph in D.2.2.2 apply and is to be executed as a first step of testing in
both range 1 and range 2?
(See examples in Figure 6 a) and b).)
Question 2) 4.2.7.2 part b) “Partially bound and V-shaped openings” does in its description under list
item 2) use the term(s) “When the templates apex contacts the base of the opening…” and by this laying
down that this has to be met when testing if the opening shall be able to pass the test.
(NB – “apex” is here understood as the 4,5 cm wide part in the tip of the template’s part A.)
This is very seldom the case – that the apex gets in contact with the base of the angle/opening - because
angles most often have “angle sides” that continue further “in” and meet in a sharp “tip” thus will not
allow this to be the case - see Figure 7 a) and b) where the angle is narrower than 60° and Figure 8
where the angle is over 60° – all where the apex of the template does not come in contact with the base
of the opening.
As many angles do not comply with the mentioned descriptions in 4.2.7.2 part b), this makes it possible
to (mis)understand this text so that if an angle or opening does not allow the apex to contact the base,
because there is no base – it is a fail, even though the angle is within what the standard demands in
D.2.2.2 – being above 60°. This resulting in that angles that do comply with D.2.2.2 but does not allow
the template apex to contact the base can be interpreted as failing to comply with the standards
description in 4.2.7.2 part b) – see Figure 8.
A very strict understanding could be that angles that are accessible and do comply with D.2.2.2 when
tested, still will fail if the apex does not contact the base – because there is no base! And it just might be
that the standard intends it to be so. We think this needs to be clarified.
NB - We have been informed from a manufacturer that in fact one should use two D2 apparatuses – first
introducing one as in Question 1 – placing the neck part in the tip of the angle – and then testing the
above angle with the second apparatus on top/outside of this one. But we can find nothing to support
this.
And we do appreciate that 4.2.7.2 part b) is for describing how an angle should be in order to comply
with the standard, and that D.2.2.2, and specifically paragraph 4 under this clause, takes care of the test
procedure which is normally the case. This does still not solve the case.
We ask for a clarification that undoubtedly addresses the terms that apply for testing. If one by the
term “apex contacts the base of the opening” rather means that it is “the tips/corners of the apex on the
template where the apex “line” meets the angle sides - in the templates corners” we think this should be
clarified.
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a) b)
Figure 6
a) b)
Figure 7
Figure 8
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PROPOSED TRACK: No action
Comments/proposal for an answer:
1) Yes.
2) “Apex” includes front edges of the template. If the leading face or edges meet the opening’s edges,
the test passes.
For additional information we can confirm that:
The test requirements for partially bound openings are given in EN 1176-1:2017, 4.2.7.2 b) and are
dependent on the template insertion angle range. The closer the probe is to the horizontal (or below)
the lower the risk. As it can often be difficult to orientate the probe to be ‘in line with the opening’ the
angle of the lower edge can also be used as a reference point to determine what range should be
considered.
It is not within the terms of the interpretation panel to make judgements about compliance or
noncompliance of specific pieces of equipment. It can very problematic to make test interpretations
from photographs alone.
4.5 Clause 4.7 of EN 1176-6:2017+AC:2019, Hand support (interpretation request 2018-
06 Denmark)
MB Question:
The text in 4.7 of EN 1176-6:2017+AC:2019 regarding hand support, has been added with the word
“cross section”.
This could indicate an acceptance that the possibility to get “hand support” by a grip on the edge of the
equipment, could be sufficient support.
See Figure 9 a) and b). This product is TüV certified to Part 6 See-saw.
a) b)
Figure 9
MB Proposal
IP to provide an indication of the intent of the addition “/cross section” in 4.7 of
EN 1176-6:2017+AC:2019.
PROPOSED TRACK: No Action
Comments/proposal for an answer:
I think it’s obvious that we have equipment for balancing, but where the user would choose to start
sitting and thus “see-sawing” while gaining courage to stand up.
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I consider a grip on the edge as sufficient, and I think that the heading “Hand Support” is open enough,
but realize that if the added “cross section” is not intended to indicate this, a future revision may be
necessary.
4.6 Clause 4.2.4.4 and Figure 10 (interpretation request 2018-07 Denmark)
MB Question:
The text for Figure 10 c) of EN 1176-1:2017 has a reference to: ‘steep play elements wider than the
opening’.
Does this mean openings for steep play elements cannot be wider than the activity?
Compared with the 2008 version, the text for 4.2.4.4 is not modified and does not specify such a
requirement.
MB proposal
As texts for pictures are intended to be explanatory only and support the requirements in the text – not
specify additional requirements.
The below sketch (Figure 10) of a product with a net access with an angle α >60° and a width, w, less
than the total width of the opening is regarded as compliant.
Figure 10
PROPOSED TRACK: No action
Comments/proposal for an answer:
EN 1176-1:2017, 4.2.4.4 has not changed from the 2008 version.
For steep play elements, there is no specific requirement for the width of the exit opening to be
restricted to be no greater than the width of the activity.
(This is only the case for stairs, ramps, bridges, etc. that have additional barriers as part of their
structure.)
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4.7 Figure D.7 (Interpretation request 2018-10 — NEN)
MB Question:
a) b)
Figure 11 — Figure D.7 a) and b) of EN 1176-1:2017
During the inspection of indoor playgrounds, the test device as depicted in Figure D.7 a) of
EN 1176-1:2017 (see above Figure 11 a)) is requir
...
SLOVENSKI STANDARD
kSIST-TP FprCEN/TR 17842-1:2022
01-september-2022
Oprema otroških igrišč - Odgovori na zahteve za razlago EN 1176:2017 in njegovih
delov (2018-2019)
Playground equipment for children - Part 1: Replies to requests for interpretation of EN
1176:2017 and its parts (2018-2019)
Kinderspielplatzgeräte - Teil 1: Antworten zu Interpretationsanfragen der Jahre 2018 und
2019 zur EN 1176:2017 und deren Teilen
Équipements d'aires de jeux pour enfants - Partie 1: Réponses aux demandes
d'interprétation de l'EN 1176:2017 et de ses parties (2018-2019)
Ta slovenski standard je istoveten z: FprCEN/TR 17842-1
ICS:
97.200.40 Igrišča Playgrounds
kSIST-TP FprCEN/TR 17842-1:2022 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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kSIST-TP FprCEN/TR 17842-1:2022
FINAL DRAFT
TECHNICAL REPORT
FprCEN/TR 17842-1
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
June 2022
ICS
English Version
Playground equipment for children - Part 1: Replies to
requests for interpretation of EN 1176:2017 and its parts
(2018-2019)
Équipements d'aires de jeux pour enfants - Partie 1: Kinderspielplatzgeräte - Teil 1: Antworten zu
Réponses aux demandes d'interprétation aux normes Interpretationsanfragen der Jahre 2018 und 2019 zur
EN 1176:2017 et toutes ses parties (2018-2019) EN 1176:2017 und deren Teilen
This draft Technical Report is submitted to CEN members for Vote. It has been drawn up by the Technical Committee CEN/TC
136.
CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and
United Kingdom.
Recipients of this draft are invited to submit, with their comments, notification of any relevant patent rights of which they are
aware and to provide supporting documentation.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to change without
notice and shall not be referred to as a Technical Report.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2022 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TR 17842-1:2022 E
worldwide for CEN national Members.
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Contents Page
European foreword . 3
Introduction . 4
1 Scope . 6
2 Normative references . 6
3 Terms and definitions . 6
4 EN 1176-1:2017, Playground equipment and surfacing — Part 1: General safety
requirements and test methods . 6
5 EN 1176-2:2017, Playground equipment and surfacing — Part 2: Additional specific
safety requirements and test methods for swings . 28
6 EN 1176-3:2017, Playground equipment — Part 3: Additional specific safety
requirements and test methods for slides . 32
7 EN 1176-5:2019 - Playground equipment and surfacing — Part 5: Additional specific
safety requirements and test methods for carousels . 34
8 EN 1176-6:2017+AC:2019, Playground equipment — Part 6: Additional specific safety
requirements and test methods for rocking equipment . 35
9 EN 1176-11:2014, Playground equipment and surfacing — Part 11: Additional
specific safety requirements and test methods for spatial network . 38
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European foreword
This document (FprCEN/TR 17842-1:2022) has been prepared by Technical Committee CEN/TC 136
“Sports, playground and other recreational facilities and equipment”, the secretariat of which is held by
DIN.
This document is currently submitted to the Vote on TR.
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Introduction
Interpretations and no-action decisions
This document contains all interpretations since CEN/TR 16396 to the end of 2019. It should bring a
close to all interpretations made to the 2020 version of EN 1176 and all of its specific parts that were
also revised in 2020. It contains replies to requests for interpretations concerning the understanding of
clauses in the parts of EN 1176. The replies concern those requests that have resulted in an
interpretation or a decision that no action is required as the standard is sufficiently clear.
An interpretation does not have the same status as the text of the standard. However, following an
interpretation gives assurance that the relevant clause of the standard has been correctly applied.
An interpretation is a clarification of the meaning of the standard. This document covers requests from
2018 to the end of 2019.
Disclaimer
The interpretations have been prepared by the interpretation panel of CEN/TC 136/SC1 committee
according to an agreed process and finally confirmed by the whole SC1 committee prior to responding
back to the enquiring National Standard Body. The information contained herein should always be
considered in association with the original EN 1176:2017 published text.
Requests for interpretations may be submitted by a CEN member body through its national committee
or by a CEN/TC 136 liaison (but not directly by an individual or a company) – in accordance with the
interpretation protocols agreed by CEN/TC 136/SC 1. The requests are then channelled to the CEN/TC
136/SC 1 interpretation panel, which will then deal with the request.
A request for an interpretation may lead to:
a) an interpretation of the standard with no action to the standard (no revision and no amendment)
This should reflect a reasonable interpretation of how the standard should be used, taking into
account:
1) the wording of the standard;
2) the rationale of the standard;
3) the history of the standard.
This is also applicable when it is agreed that the standard appropriately specifies how playground
equipment is assessed.
b) a proposal for an amendment of the standard
This is applicable when it is agreed that the standard is deficient in some way.
NOTE Interpretation and no-action decisions are published in CEN/TR 16396 which will be updated on a
regular basis. Proposals for amendments will be progressed as new work item proposals in accordance with
CEN rules.
c) a future revision
It is not within the interpretation protocol to carry out new work that was not previously covered
within the published EN 1176 parts and clauses. Future work requests should always be raised by
National Standard Bodies using the “Future work request template” to ensure full consideration is
given to the necessity and possible consequences, before starting any new work on EN 1176.
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Answers to requests for interpretations
Since requests for interpretations are submitted through a CEN member body, it is assumed that the
member body will keep itself informed about decisions concerning the request and its progress and will
itself inform the originator of the request, as appropriate.
The following information requests have been included in this document:
2018
2018-01 NO — Part 1 — 3.5, 3.20, 3.34-3, 4.2.8.2.3 General, 4.2.16.1 2nd Paragraph after Figure 26
2018-02 NO — Part 1— 4.2
2018-03 NO — Part 1 — 4.2.7.2
2018-04 NO — Part 1 — 4.2.7.2 part b and D.2.2
2018-05 DK — Part 2 — 3.13 and 4.6.3 in part 2:2017
2018-06 DS — Part 1 — 4.7 Hand support
2018-07 DS — Part 1 — 4.2.4.4 and Figure 10
2018-08 NO — Part 2 — Figure 6
2018-09 DE — Part 3 — 4.4.1 and Annex B
2018-10 NEN Part 1 — Figure D.7
2018-11 NEN—Part 1 — Figure D.13
2018-13 NO — Part 1 —4.2.7.3 Entrapment of clothing/hair
2018-15 NEN—Part 1 —4.2.16.1 General
2018-16 NEN—Part 1 —4.2.16
2019
2019-01 UNI Part 3 — 4.5, 4.7, 4.9.2
2019-09 LTL — Part 1 — 4.9 Entrapment
2019-10 LTL— Part 1 — 4.2.4.4 Barriers
2019-11 SIS — Part 1 — 6.2.16 Bouncing facilities
2019-12 HUN—Part 1 — 4.2.8.1
2019-13 DIN —Part 1 — 4.2.13 Chains
2019-14 UK — Part 2 — 3.13
2019-15 DIN— Part 1 — 4.2.16.1
2019-16 SIS — Part 2 — 3.13, 4.6.3 and 4.9
2019-17 SFS — Part 1 — 4.2.7.2
2019-18 SFS —Part 5 — 5.2.3
NOTE ASI — Austria, DS — Denmark, SFS — Finland, AFNOR — France, DIN — Germany, HUN – Hungary, SII
— Israel, — LVS — Latvia, LTL – Lithuania, NBN— Belgium, NEN — Netherlands, SN — Norway, SIS — Sweden,
SIST — Slovakia, SN — Switzerland, TSI — Turkey, GB — United Kingdom
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1 Scope
The purpose of this document is to publish replies to requests for interpretations, to all parts of
EN 1176, which have been drafted by the interpretation panel and confirmed by CEN/TC136/SC1.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
4 EN 1176-1:2017, Playground equipment and surfacing — Part 1: General safety
requirements and test methods
4.1 General (interpretation request 2018-01 — Norway)
Question
2
1. The standard allows placing several small bouncing facilities – each approximately between 1 m
2
to 1,44 m as for single users – together in a cluster, or in a row as part of a jump/stepping-trail
thus letting each bouncing equipment's free space of 1 500 mm overlap each other's free space, or
other equipment's falling space.
See Figure 1 below for example.
NB - We do appreciate that bouncing facilities demand free space/have forced movement as described
in 3.6 and, therefore, our opinion is that this is not allowed. Due to several installations that we do see
are in conflict with this, as others understand the standard differently, we therefore would like it to be
clarified.
We also appreciate that equipment in a cluster – 3.20 - is allowed for equipment not involving free
space/forced movement. A central and relevant question is therefore if one can deviate from the
demands related to free space if one places several equipment’s with or without forced movement in a
cluster?
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Figure 1
MB Proposal:
To exclude any misunderstanding or “use” of the cluster clause, this definition could be more precise:
That 3.20 includes information if a cluster is allowed or not for equipment with forced movement and in
need of free space.
Reply
No action/interpretation
Regarding Free Space:
From EN 1176-1:2017:
clause 3.6 free space; Space in, on or around the equipment that can be occupied by a user undergoing
a movement forced by the equipment.
NOTE 1 Examples for this is sliding, swinging, rocking, jumping in bouncing facility for several users…
clause 4.2.16.1 Bouncing facilities, general
For a bouncing facility the extent of the free space shall be 1 500 mm measured horizontally from any
point at the perimeter and 3 500 mm above the suspension bed
All bouncing facilities do have Free Space, however ‘Small’ bouncing facilities are allowed to have
overlapping Free Spaces in clusters.
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Regarding Clusters:
From EN 1176-1:2017:
clause 3.20 cluster;
two or more separate pieces of equipment designed to be installed in close proximity to each other
to provide continuity in a sequence that is needed for the play activity
NOTE An example for a cluster is a trail of stepping stones.
clause 4.2.8.3 Protection against injuries in the free space for users undergoing a movement that is
forced by the equipment
Unless stated otherwise, there shall be no overlapping of adjacent free spaces, or of free space and
falling space of two different pieces of equipment.
NOTE 1 This requirement does not apply to the common space between pieces of equipment in a cluster.
For information:
The current EN 1176 definition of a cluster requires ‘continuity in a sequence that is needed for the play
activity’. This allows the user to focus on the cluster activities in a way that will allow them to judge the
risks of transferring from one part to the next. In the case of clusters, it is also highlighted in 4.2.8.3,
NOTE 1 of EN 1176-1:2017, that overlapping of Free/Falling Space is permitted.
The example shown above, with ‘small’ bouncing suspension beds, is a typical equipment cluster,
therefore the free spaces may overlap, however the standard does not currently include any additional
specific requirements for clusters. This is purposely the case, to allow for flexibility in design. In the
case of bouncing facilities, as with other equipment clusters, a risk assessment should always be carried
out by the supplier to confirm any risks are suitably controlled, in providing this ‘continuity in a
sequence that is needed for the play activity’.
We would recommend that a future work request is made by the NSB if they feel there is a strong safety
case to start future work on products of the type shown, following the procedure agreed by SC1 (see
template in document SC1 N9002). This is to encourage the use of the template / matrix, and to avoid
duplication of work.
4.2 Scope (interpretation request 2018-02 Norway)
Clause 4.2
Question
This is regarding double tyre swing seats. These seats consist of one big car-tyre that has a smaller tyre
(often called security tyre) hanging under it – see Figure 2 below.
The new standard does not include information on ground clearance for tyre seats as in the previous
edition. Instead there is a description for single user seat with ground clearance 35 and group swing
seat with clearance demand 40.
What seat type does the standard define, a single tyre seat or a double tyre seat as shown in Figure 2
below; single user seat or group swing seat?
In the case of double tyre seat – see Figure 2 below, is the ground clearance demand applicable only for
the main top tyre or for the lower tyre as well?
NB – we often observe children standing on the lower tyre having the upper tyre supporting their body.
This has the effect that the lower tyre will not easily deflect if it hits or squeezes another child under it
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against the impact attenuating surface (IAS) under the swing as many seem to argue so that they can
justify that the ground clearance should only be measured from the top tyre.
Sentence 2 in the clause does not define where this measure is to be taken, and one presumes that this
is where the seat is closest to the IAS. Is this correct?
Sentence 3 deviates from sentence 2 for the part of swings being flexible. Is this to be seen in
conjunction with sentence 2 so that IF a part of a seat is flexible this part shall not be included for
measurement of ground clearance? (This would be easier to understand and see if both sentences were
included in the same sentence or paragraph.)
NB! – Here also we do see that flexible lower parts of seats, often with many children inside will not
necessarily deflect or prevent a child falling off the seat in the possibility to be squeezed under the seat
against the IAS.
Figure 2
Reply
No action/interpretation
This type of swing seat is not specifically covered in EN 1176.
We would recommend that a future work request is made by the NSB if they feel there is a strong
requirement to start future work on products of the type shown following the procedure agreed by SC1
(see template in document SC1 N9002). This is to encourage the use of the template / matrix, and to
avoid duplication of work.
For information we can confirm that:
This type of seat is special as it has a top section that provides a general sitting position and also has a
lower flexible part that would only provide a sitting position to very young children, who had their body
positioned within the top section. Prior to publication of EN 1176 swing seat ground clearances were
referenced in DIN 7926-2. This publication required a ground clearance of 250 mm for seats less than
1 000 g in weight. Although this old standard is no longer valid, the information could be used as part of
a risk assessment on the lower seat part.
In addition to the specific requirements of EN 1176, it is always recommended that a risk assessment is
carried out should unusual situations be identified.
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4.3 Clause 3.5 (interpretation request 2018-03 Norway)
EN 1176-1:2017, clause 4.2.7.2
MB Question:
This is regarding openings between 8,9 and 23 or within angles defined for v-shaped openings, all with
lowest part being above 60 over standing position and all with what we see as obvious possibility for
entrapment of head/neck that we cannot see described in the standard that we do think the standard
should address.
Or do these cases possibly lie within the descriptions that exist in any way?
We want to draw the committee’s attention to:
1. Partially bound rigid openings that consist of parallel or close to parallel sides that are
between 8,9 to 23 apart – see Figure 3 and Figure 4.
2. Flexible V-shaped openings with a lower edge above 60 between two flexible sides or one
flexible side and one rigid side – see Figure 5.
3. Partially bound rigid Horizontal opening - in what we here call “arm-walk”.
See Figures 3 to 5 and texts that should explain this.
If we – for the case of further easing our argument - may be so bold as to assume that the committee
agrees with our examples in that they do in fact represent obvious hazards the standard should include
/ address we would like the following to be clarified for each situation:
1. Is there any clause in the existing standard that covers this situation?
2. If no in question 1; if the committee agrees with our view that this is a hazard that should be
abolished – how do we go about it?
3. If the committee does NOT agree with our view that this is a hazard we would very much appreciate
an explanation / reason for this.
1) Opening with parallel sides - between ledge and back side of ladder. A child wanting to pass through
the ladder or out the play house can get caught between the step in the ladder - the one just above the
blue opposite edge - and the blue edge of the play house. The ledges being paralleled for more than
50 cm gives the child little but no possibility to escape. This is per definition NOT a completely bound
opening and not a partially bound opening that deviates from D.2.2 test.
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Figure 3
Figure 4
1) Opening with parallel sides / ledges - here between climbing ladder and platform. A child falling or
wanting to climb down getting their head caught in the opening is not necessarily “lucky” enough to get
freed from entrapment to one of the sides. We do see that this has a lower risk than a rigid closed
opening and also at the same time see the possible hazard. The ledges are parallel for approximately
30 cm. This is per definition NOT a completely bound opening and not a partially bound opening that
deviates from D.2.2 test.
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a) b)
Figure 5
MB Proposal
Include these situations in the standards descriptions using the same templates that are used for other
openings.
PROPOSED TRACK: No action
Comments/proposal for an answer:
1. With reference to EN 1176-1:2017, 4.2.7.2 a) the situations shown are not ‘completely bound’ and
therefore do not require a test to comply with EN 1176.
2. & 3. In addition to the specific requirements of EN 1176, it is always recommended that a risk
assessment is carried out should unusual situations, not covered by EN 1176, be identified. (For
example, situations that are not completely bound but where entrapment risk could occur). It is
not within the terms of the interpretation panel to make judgements about risks relating to
specific pieces of equipment. It can very problematic to make judgements from photographs
alone.
The IP recommends that a proposal for amendment or future work is made by the NSB if they want to
present a “safety case”, following the procedure agreed by SC1 (see template in document SC1 N9002).
4.4 Clause 4.2.7.2 Part b and D.2.2 (interpretation request 2018-04 Norway)
MB Question
This is regarding:
1) Clarification of test method for range 2 and D.2.2; and
2) Clarification of need of template apex to contact base of the opening” in regards to angles.
Clause D.2.2.2 first paragraph describes the first step in testing and refers to Figure D.3. Figure D.3 only
shows examples where the opening is in range 1 thus making it possible to (mis)understand that this
first procedure only is to be done for openings in this range 1. We ask for a clarification on this.
Question 1) Does the first paragraph in D.2.2.2 apply and is to be executed as a first step of testing in
both range 1 and range 2?
(See examples in Figure 6 a) and b)
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Question 2) 4.2.7.2 part b) “Partially bound and V-shaped openings” does in its description under list
item 2) use the term(s) “When the templates apex contacts the base of the opening…” and by this laying
down that this has to be met when testing if the opening shall be able to pass the test.
(NB – “apex” is here understood as the 4,5 cm wide part in the tip of the template’s part A)
This is very seldom the case – that the apex gets in contact with the base of the angle/opening - because
angles most often have “angle sides” that continue further “in” and meet in a sharp “tip” thus will not
allow this to be the case - see Figure 7 a) and b) where the angle is narrower than 60° and Figure 8
where the angle is over 60° – all where the apex of the template does not come in contact with the base
of the opening.
As many angles do not comply with the mentioned descriptions in 4.2.7.2 part b), this makes it possible
to (mis)understand this text so that if an angle or opening does not allow the apex to contact the base,
because there is no base – it is a fail, even though the angle is within what the standard demands in
D.2.2.2 – being above 60°. This resulting in that angles that do comply with D.2.2.2 but does not allow
the template apex to contact the base can be interpreted as failing to comply with the standards
description in 4.2.7.2 part b) – see Figure 8.
A very strict understanding could be that angles that are accessible and do comply with D.2.2.2 when
tested, still will fail if the apex does not contact the base – because there is no base! And it just might be
that the standard intends it to be so. We think this needs to be clarified.
NB - We have been informed from a manufacturer that in fact one should use two D2 apparatuses – first
introducing one as in Question 1 – placing the neck part in the tip of the angle – and then testing the
above angle with the second apparatus on top/outside of this one. But we can find nothing to support
this.
And we do appreciate that 4.2.7.2 part b) is for describing how an angle should be in order to comply
with the standard, and that D.2.2.2, and specifically paragraph 4 under this clause, takes care of the test
procedure which is normally the case. This does still not solve the case.
We ask for a clarification that undoubtedly addresses the terms that apply for testing. If one by the
term “apex contacts the base of the opening” rather means that it is “the tips/corners of the apex on the
template where the apex “line” meets the angle sides - in the templates corners” we think this should be
clarified.
a) b)
Figure 6
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a) b)
Figure 7
Figure 8
PROPOSED TRACK: No action
Comments/proposal for an answer:
1. Yes
2. “Apex” includes front edges of the template. If the leading face or edges meet the opening’s edges,
the test passes.
For additional information we can confirm that:
The test requirements for partially bound openings are given in EN 1176-1:2017, 4.2.7.2 b) and are
dependent on the template insertion angle range. The closer the probe is to the horizontal (or below)
the lower the risk. As it can often be difficult to orientate the probe to be ‘in line with the opening’ the
angle of the lower edge can also be used as a reference point to determine what range should be
considered.
It is not within the terms of the interpretation panel to make judgements about compliance or
noncompliance of specific pieces of equipment. It can very problematic to make test interpretations
from photographs alone.
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4.5 Clause 4.7 of EN 1176-6:2017, Hand support (interpretation request 2018-06
Denmark)
MB Question:
The text in 4.7 of EN 1176-6:2017 regarding hand support, has been added with the word “cross
section”.
This could indicate an acceptance that the possibility to get “hand support” by a grip on the edge of the
equipment, could be sufficient support.
See Figure 9 a) and b). This product is TüV certified to Part 6 See-saw.
a) b)
Figure 9
MB Proposal
IP to provide an indication of the intent of the addition “/cross section” in 4.7 of EN 1176-6:2017.
PROPOSED TRACK : No Action
Comments/proposal for an answer:
I think it’s obvious that we have equipment for balancing, but where the user would choose to start
sitting and thus “see-sawing” while gaining courage to stand up.
I consider a grip on the edge as sufficient, and I think that the heading “Hand Support” is open enough,
but realize that if the added “cross section” is not intended to indicate this, a future revision may be
necessary.
4.6 Clause 4.2.4.4 and Figure 10 (interpretation request 2018-07 Denmark)
MB Question:
The text for Figure 10 c) of EN 1176-1:2017 has a reference to: ‘steep play elements wider than the
opening’.
Does this mean openings for steep play elements cannot be wider than the activity?
Compared with the 2008 version, the text for 4.2.4.4 is not modified and does not specify such a
requirement.
MB proposal
As texts for pictures are intended to be explanatory only and support the requirements in the text – not
specify additional requirements.
The below sketch (Figure 10) of a product with a net access with an angle α >60° and a width, w, less
than the total width of the opening is regarded as compliant.
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Figure 10
PROPOSED TRACK: No action
Comments/proposal for an answer:
EN 1176-1:2017, 4.2.4.4 has not changed from the 2008 version.
For steep play elements, there is no specific requirement for the width of the exit opening to be
restricted to be no greater than the width of the activity.
(This is only the case for stairs, ramps, bridges, etc. that have additional barriers as part of their
structure.)
4.7 Figure D.7 (Interpretation request 2018-10 — NEN)
MB Question:
a) b)
Figure 11 — Figure D.7 a) and b) of EN 1176-1:2017
During the inspection of indoor playgrounds, the test device as depicted in Figure D.7 a) of
EN 1176-1:2017 (see above Figure 11 a)) is required in order to inspect slides according to the
standard. However, it is unclear what the size, or to be more precise the height of the foot of this test
device should be. The standard refers to "20, 10" (see above, zoomed in). What should the exact height
of the foot be?
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Questions, Comments and Discussion
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