SIST-TP CEN/TR 16396:2013
(Main)Playground equipment for children - Replies to requests for interpretation of EN 1176:2008 and its parts
Playground equipment for children - Replies to requests for interpretation of EN 1176:2008 and its parts
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of all parts to EN 1176.
Alle beschlossenen Interpretationen und Antworten Spielplatzgeräte für Kinder betreffend
Der Zweck dieses CEN-Technischen-Berichtes ist, Antworten auf Anfragen für Interpretationen von allen
Teilen der EN 1176 bereitzustellen.
Équipements d'aires de jeux pour enfants - Réponses aux demandes d'interprétation aux normes EN 1176:2008 et toutes ses parties
Le présent Rapport technique du CEN vise à apporter des réponses aux demandes d’interprétation relatives à toutes les parties de la Norme EN 1176.
Oprema otroških igrišč - Odgovori na zahtevke za interpretacijo EN 1176:2008 in njegovih delov
Namen tega tehničnega poročila CEN je zagotoviti odgovore na zahteve za razlago vseh delov do standarda EN 1176.
General Information
Relations
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CEN/TR 16396:2013
01-januar-2013
2SUHPDRWURãNLKLJULãþ2GJRYRULQD]DKWHYNH]DLQWHUSUHWDFLMR(1 LQ
QMHJRYLKGHORY
Playground equipment for children - Replies to requests for interpretation of EN
1176:2008 and its parts
Alle beschlossenen Interpretationen und Antworten Spielplatzgeräte für Kinder
betreffend
Équipements d'aires de jeux pour enfants - Réponses aux demandes d'interprétation aux
normes EN 1176:2008 et toutes ses parties
Ta slovenski standard je istoveten z: CEN/TR 16396:2012
ICS:
97.200.40 ,JULãþD Playgrounds
SIST-TP CEN/TR 16396:2013 en,fr,de
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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TECHNICAL REPORT
CEN/TR 16396
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
October 2012
ICS 97.200.40
English Version
Playground equipment for children - Replies to requests for
interpretation of EN 1176:2008 and its parts
Équipements d'aires de jeux pour enfants - Réponses aux Kinderspielplatzgeräte - Antworten zu
demandes d'interprétation aux normes EN 1176:2008 et Interpretationsanfragen zur EN 1176:2008 und deren Teilen
toutes ses parties
This Technical Report was approved by CEN on 30 July 2012. 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, Former Yugoslav Republic of Macedonia, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania,
Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, Turkey and United
Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION
EUROPÄISCHES KOMITEE FÜR NORMUNG
Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2012 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 16396:2012: E
worldwide for CEN national Members.
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Contents Page
Foreword .3
Introduction .4
1 Scope .6
2 EN 1176-1:1998, Playground equipment — Part 1: General safety requirements and test
method .6
2.1 General (interpretation request 2010-09 – SII) .6
2.2 Scope (interpretation request 2010-04 SFS) .7
2.3 3.5 (interpretation request 2010-02 SFS) .7
2.4 4.2 (interpretation request 2011-02 TSI) .9
2.5 4.2.4; 4.2.4.4 (interpretation request 2011-04 SNV) . 10
2.6 4.2.4.4 (interpretation request 2010-01 SFS) . 11
2.7 4.2.7.2 a) and b) and Annex D (interpretation request 2009-09 SN) . 11
2.8 4.2.7.3 (interpretation request 2011-03 – SNV) . 13
2.9 4.2.8.1 Table 2 (interpretation request 2009-04 AFNOR). 13
2.10 4.2.8.1 Figure 14 (interpretation request 2009-05 AFNOR) . 14
2.11 4.2.8.4 (interpretation request 2009-06 DS) . 15
2.12 4.2.8.5.2 (interpretation request 2010-07 DIN) . 15
2.13 4.2.8.5.3 (interpretation request 2010-03 SFS) . 16
3 EN 1176-2:2008 - Playground equipment - Part 2: Additional specific safety requirements
and test methods for swings . 17
3.1 4.2 (interpretation request 2010-06 DS) . 17
3.2 4.10.1 (interpretation request 2010-05 DS) . 18
3.3 Annex B (interpretation request 2011-06 DS) . 18
4 EN 1176-3:2008 - Playground equipment - Part 3: Additional specific safety requirements
and test methods for slides . 20
4.1 4.2 (interpretation request 2011-05 SIS) . 20
5 EN 1176-4:2008 - Playground equipment - Part 4: Additional specific safety requirements
and test methods for cableways . 20
5.1 4.5 (interpretation request 2009-01 DS) . 20
6 EN 1176-6:2008 - Playground equipment - Part 6: Additional specific safety requirements
and test methods for rocking equipment . 21
6.1 4.6 (interpretation request 2009-07 DS) . 21
6.2 4.10 (interpretation request 2009-08 DS) . 21
6.3 Table 1 (interpretation request 2010-08 CEN/TC 136/SC 1/TG 1) . 22
7 EN 1176-10:2008 - Playground equipment - Part 10: Additional specific safety
requirements and test methods for fully enclosed play equipment . 22
7.1 4.3.7 (interpretation request 2009-02 DS) . 22
7.2 4.4.2.4 (interpretation request 2009-03 DS) . 23
8 EN 1176-11:2008 - Playground equipment and surfacing - Part 11: Additional specific
safety requirements and test methods for spatial network . 23
8.1 Scope, signage (interpretation request 2011-01 – ASI) . 23
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Foreword
This document (CEN/TR 16396:2012) 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 [and/or CENELEC] shall not be held responsible for identifying any or all such patent rights.
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Introduction
Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretations concerning the understanding of clauses
in EN 1176:2008 and its parts. 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.
Disclaimer
The interpretations have been derived by expert groups of CEN/TC 136/SC 1 and have been circulated
to National Standards Bodies for approval. The information contained herein does not reflect the full
formal approval by CEN or CEN member bodies. It should be noted that the interpretations are neither
part of any standard nor have been referenced in the Official Journal of the European Union.
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
shall be 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
This is applicable when the standard is not clear and a suitable amendment cannot be found to fully clarify the
question. Further work is needed on existing requirements or new requirements may need to be drafted.
Proposals for a revision will be progressed as a new work item proposal in accordance with CEN rules.
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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 Technical Report:
2009
2009-01 DS - Part 4 - 4.5
2009-02 DS - Part 10 - 4.3.7
2009-03 DS - Part 10 - 4.4.2.4
2009-04 AFNOR - Part 1 - 4.2.8.1 Table 2
2009-05 AFNOR - Part 1 - 4.2.8.1 Figure 14
2009-06 DS - Part 1 - 4.2.8.4
2009-07 DS - Part 6 - 4.6
2009-08 DS - Part 6 - 4.10
2009-09 SN - Part 1 - 4.2.7.2 a) and b) and Annex D
2010
2010-01 SFS - Part 1 - 4.2.4.4
2010-02 SFS - Part 1 - 3.5
2010-03 SFS - Part 1 - 4.2.8.5.3
2010-04 SFS - Part 1 – Scope
2010-05 DS - Part 2 - 4.10.1
2010-06 DS - Part 2 - 4.2
2010-07 DIN - Part 1 - 4.2.8.5.2
2010-08 CEN/TC 136/SC 1/TG 1 - Part 6 - Table 1
2010-09 SII - Part 1 gGeneral
2011
2011-01 ASI - Part 11 - Scope, signage
2011-02 TSI - Part 1 - 4.2
2011-03 SNV - Part 1 - 4.2.7.3
2011-04 SNV - Part 1 - 4.2.4; 4.2.4.4
2011-05 SIS - Part 3 - 4.2
2011-06 DS - Part 2 - Annex B
NOTE ASI – Austria, DS – Denmark, SFS – Finland, AFNOR – France, DIN – Germany, SII – Israel, SIS – Sweden,
SN – Switzerland, TSI – Turkey,
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1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of all parts to
EN 1176.
2 EN 1176-1:1998, Playground equipment — Part 1: General safety requirements
and test method
2.1 General (interpretation request 2010-09 – SII)
Question
1 We would appreciate a formal answer from the TC136/WG in relation to how to test the "rope carousel"
and to provide an explanation for the rationale for testing them only according to EN 1176-1 and not according
to EN 1176-5?
2 During that period our WG discussed the EN 1176-1:2008 standard, and now have a few questions:
a) We need to obtain the position regarding the criteria for fire resistance of playground equipment
placed mainly in open areas.
b) We need to obtain an explanation as to why the instructions for tests of playground equipment in
accordance with EN 1021 have been deleted.
c) Why are there no clear instructions besides the regulations of the countries as to where the
equipment is assembled?
3 We are also involved with musical playground equipment (see attached photographs). Would the
requirements of EN 1176 be applicable to some of them? Which types would be covered by EN 1176 and
which would not? Is there any restriction to placing them in an area together with other playground
equipment?
Reply
No action/interpretation
1) A picture of the specific product would be required to make a formal judgement.
EN 1176-1, 4.2.1 confirms; ‘Equipment where the primary play function is augmented by a secondary
motion, e.g. rocking and/or rotating, shall conform to the additional parts of EN 1176 relating to both play
functions, as appropriate, unless the equipment is specifically covered in just one of the additional parts of
EN 1176.’
EN 1176-5, scope confirms; ‘This document is not applicable to equipment where the main play function
in not rotating’.
2)
d) Contained Playground Equipment has the greatest risk and these requirements are now covered in
the new EN 1176-10. Other than this the greatest risk is from materials that produce a surface flash
effect and would not give time for users to leave the area.
e) EN 1021 was no longer thought to be necessary as a general requirement, but is still referred to in
EN 1176-10.
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f) All countries have different National Regulations, from which no universal requirements could be
identified.
3) There are no specific requirements in EN 1176 for ‘Musical’ Playground Equipment. However, EN 1176-1
provides a basis for assessing all types of Playground Equipment. The judgement of when and how much
of this specification to apply not only relates to the type of product, but also to where it is provided. In an
unsupervised/free access situation, together with other Playground Equipment items, then some
assessment to EN 1176 may be helpful.
Comments:
Question 1: Future work required to determine what is relevant for this specific type of product. This would
need to be determined by risk assessment.
Questions 2 & 3: No further action required.
2.2 Scope (interpretation request 2010-04 SFS)
Question
Question 1: How high should the fence be, if it is used as the sole means of separating the playground from
the exercise area?
Question 2: If distance alone is used as means of separating the playground from the exercise area, how
long should this distance be?
Question 3: Can you give any other example of what other means of separating these areas there could be?
Reply
No action/interpretation
The interpretation panel recommend work is started, as a priority, for exercise equipment of this type as it is
now being specified in most European countries, in association with children’s playground equipment.
The panel advises that when products of this type are installed in association with children’s playground
equipment it will get used by children, whether intentional or not, because segregating by fencing, for
example, does not work as a solution. Therefore, this type of equipment should be designed and provided
without unacceptable risks to these children, and comply with relevant requirements in EN 1176, e.g.
according to test protocols from accredited test houses, until a new standard is developed.
2.3 3.5 (interpretation request 2010-02 SFS)
Question
3.5 explains that forced movement is "e.g. sliding, swinging, rocking". Different rocking equipment provides
different types of movement. This is expressed in the table below:
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Type 1 and 6 Type 2-4 Type 5
Product example
Movement type Up-down Slow and short Rotation with vertical
horizontal movement movement
Length of movement 60 - 130 cm 20 - 40 cm infinite
Movement speed Free fall down is Slow Potentially fast
possible
It is obvious that there is a distinction between different "rocking" movements.
Question 1: Are types 2 – 4 rocking equipment intended to require free space like in 3.5?
rd
4.2.8.2.5, 3 paragraph: "In most cases there may be overlapping of falling spaces including impact areas.
Unless specified in other parts of this standard, overlapping of the falling space where forced movement exists
should not occur."
Question 2: Are types 2 – 4 rocking equipment intended to be installed without overlapping falling space as in
4.2.8.2.5?
Reply
No action/interpretation
Answer to the question 1)
The definition for Free Space in EN 1176-1:2008 point 3.5 refers to ‘Rocking Equipment’.
st
In addition, in 4.2.8.5.2, 1 paragraph, there is a clear reference to rocking equipment as having forced
movement (thus free space).
As no exceptions are given in EN 1176-6 it applies to all types of rocking items.
Additionally during the 2008 revision, changes were made to the requirements for a tested surface to be
provided. Part of these discussions assumed that small rocking items, such as type 2a, had a forced
movement/free space to ensure they were required to have an impact attenuating surface in accordance with
EN 1176-1.
Answer to the question 2)
Yes, types 2 – 4 rocking equipment are intended to be installed without overlapping falling space according to
rd
EN1176-1, 4.2.8.2.5, 3 paragraph, as there is no exception in Part 6.
However, please also see EN 1176-6, 4.10; This allows the Falling Space for rocking equipment types 1, 2, 3
and 4, to be reduced to a minimum of 1m, from the general requirements in EN 1176-1.
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Comments:
Risks associated with a closer separation/proximity of single-user rockers, such as type 2a, are much less
than for multiuser types as that single user has a far higher level of control. A closer separation distance for
Rocking Equipment, of this type, could be considered, as an exemption, as future work. This would need to be
carefully considered to the existing requirements of EN 1176-1, - 4.2.8.2.
We would recommend that specific types of Rocking Equipment complying with EN 1176-6 should be exempt
from the restriction in EN 1176-1, not to overlap Falling Spaces (should be confirmed by risk assessment).
This would still enforce that they include some forced movement, but acknowledges it to be of a small, lower
risk, amplitude.
2.4 4.2 (interpretation request 2011-02 TSI)
Question
Is the product seen in the photos suitable for 4.2 of EN 1176-1?
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Reply
No action/interpretation
EN1176-2 does not contain any specific requirements for the stiffness of swing seats.
EN 1176-1, 4.2.1 requires that: ‘The dimensions and degree of difficulty….is apparent and foreseeable by the
child’. Some of these judgements will be subjective and it is not possible for this committee to comment on
specific products and circumstances.
However, the panel is aware that ‘belt seats’ are common in some markets, for use on swings, and we
are not aware of any reason why this type of seat should not be accepted in principle.
2.5 4.2.4; 4.2.4.4 (interpretation request 2011-04 SNV)
Question
How are the requirements for protection against falling on easily accessible suspension bridges?
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Reply
Future Revision
There are no specific requirements for protection against falling on easily accessible suspension bridges
(see comments below).
Suspension bridges offer much higher levels of challenge than rigid platforms. The movement of the walkway
and the construction of the side elements will provide encouragement to users to hold on. This is different to a
‘platform’, which is defined in EN 1176-1, 3.20, where barriers or guardrails are required.
In the case of suspension bridges, which include handhold supports to the side, the free height of fall should
be measured from the walkway.
EN 1176-1, 4.2.1 states that ‘the dimensions and degree of difficulty of the equipment should be suitable for
the intended user group’. In the case of access, this would include an assessment to ensure any access
provided is not ‘easily accessible’ to those users who may not be able to cope with the expected risk factors.
Comment:
The proposal to introduce new requirements including protection against falling and limiting the height of
‘easily accessible’ suspension bridges may be helpful to allow better supervision of less able users. We
recommend that this is considered as future work.
2.6 4.2.4.4 (interpretation request 2010-01 SFS)
Question
It is not clear how the width of the opening should be measured. Text speaks about "clear opening" and even
Figure 10a indicates that opening is measured from narrowest point. Still some clarifying information in text
would be nice as well a figure showing how the width of the opening should be measured.
Reply
No action/interpretation
Agreed this could be clarified:
nd nd
Propose to amend 4.2.4.3, 2 Para., 2 sentence;
‘The width of entrance and exit opening in guardrails, with exception of stairs, ramps and bridges, shall have a
maximum clear opening of 500 mm, when measured horizontally at a position, with a height between 600 mm
to 850 mm from the platform.’
nd
Propose to amend 4.2.4.4, 2 sentence:
‘The width of entrance and exit opening in barriers shall have a clear opening of 500mm maximum, when
measured horizontally at any point, unless a guardrail is provided across the opening……’
2.7 4.2.7.2 a) and b) and Annex D (interpretation request 2009-09 SN)
Question
Is this part of the equipment, defined as a "completely bound opening", supposed to comply with the
requirements in 4.2.7.2 a) and to be tested in accordance with Annex D, D.2.1, probe a), b) and c)? Or, is this
a V-shaped opening which is supposed to comply with 4.2.7.2 b) partially bound and V-shaped openings, to
be tested in accordance to D.2.2 and the use of the test template for V-shaped openings?
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No action/interpretation
1) Yes, this entrapment situation is defined as a completely bound opening and so must comply with the
requirements in EN 1176-1, 4.2.7.2a)
2) Yes, this large completely bound opening also includes a ‘V’ shaped opening and so must comply
with the requirements in EN 1176-1, 4.2.7.2b)
2.8 4.2.7.3 (interpretation request 2011-03 – SNV)
Question
Does it make sense to test the climbing knobs by the toggle test?
Reply
No action/interpretation
The current test requirements in EN 1176-1, 4.2.7.3 ‘entrapment of clothing/hair’ are restricted to Slides,
Sliding Pole and Roofs. These were viewed to be the highest priority for this type of risk based on accident
data that was reviewed at the time of the standards publication. In all of these cases, the user is subject to
‘forced movement’ on equipment items, where no hand or foot support elements are provided.
The current standard does not view climbing as a ‘forced movement’ activity.
A climbing wall presents a different risk case, as there will generally be a number of hand and foot holds within
reach of the user, at any one time, which gives them greater opportunities to control their movements.
Should new accident data become available that suggests climbing walls are higher risk situations that require
a new standard requirement and method of test, then this should be presented to the committee for review as
‘future work’
2.9 4.2.8.1 Table 2 (interpretation request 2009-04 AFNOR)
Question
In the case of a hanging position whereupon the user cannot lift himself up to the hand support (please see
example below), what is the free height of fall to be taken into account?
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Table 2 — Free height of fall for different types of use
Hanging From hand support height to surface below
(When full body support is provided by the
hands only and the whole body can be lifted up to
the hand support, see Figure 14b)
Example:
Reply
No action/interpretation
The standard is clear.
For hanging use, the free height of fall is measured from the hand support position.
It is not always clear whether a user can lift themselves up, so it is the hand support that is referred to in
Table 2 for Hanging use.
2.10 4.2.8.1 Figure 14 (interpretation request 2009-05 AFNOR)
Question
How do we measure the free height of fall of the following:
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Reply
No action/interpretation
For the left hand example, the Free Height of Fall (h) is measured from the top, as access is encouraged to
this position.
For the right hand example the Free Height of Fall (h) is measured from the top of the climbing
panel/horizontal curved support, as it appears access is encouraged to this position.
If there are no support points for feet (climbing hold, rope, mesh,…) between the highest hands position
and this height minus 1 m, we consider playground equipment free height of fall as being the highest
hands position minus 1 m.
If there are support points for feet (climbing hold, rope, mesh,…) between the highest hands position and
this height minus 1m, we consider playground equipment free height of fall as being from the highest
hands position.
The Panel does recognise that climbing use offers the best security to the user and the measurement of Free
Height of Fall should be reviewed by SC1.
2.11 4.2.8.4 (interpretation request 2009-06 DS)
Question
It is stated in 4.2.8.4 that adjacent parts of play structures with a difference in free height of fall of less than
600 mm may be in the falling space. This leads us to ask the following questions:
From where and to where is the 600 mm measured?
What is the definition of "adjacent parts"?
In addition, we would welcome illustrations of acceptable parts of equipment or play structures in the falling
space.
Reply
No action/interpretation
1) The difference in height between adjacent parts is measured from the Free Height of Fall position of
the upper structure to the top of the structure below. (From where the user can fall to where the user
can fall on).
2) An adjacent part means a part of the same play equipment that is adjoining/near by, within the
Falling Space.
2.12 4.2.8.5.2 (interpretation request 2010-07 DIN)
Question
With reference to passage of text: "The critical fall height of the surfacing shall be equal to, or greater than the
free height of fall of the equipment."
1) Is an impact attenuating of the impact area in case of a fall height of 0 cm (slide lies directly on the
ground) required, although no minimum requirement for surface on the lateral sides of the slide
exists?
2) What about the definition of the objective in relation to the slides with fall heights below 60 cm?
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Example:
Reply
No action/interpretation
Question 1 - The Standard is clear:
EN 1176-3, 4.8 states that the surface around the run-out section shall have a critical fall height of at least
1000 mm. This is the highest risk area, as a slide designed to EN 1176-3 will ‘contain and guide’ the user until
they reach this section of the slide. (There are no specific requirements given for the sliding or starting section
of the slide).
When tested in accordance with EN 1177 a zero mm Fall Height onto any type of surface will produce a zero
HIC value. Therefore, an Impact Area for a zero Fall Height will by implication will have no test requirements,
but it must still comply with the requirements for the Falling Space given in EN 1176-1, 4.2.8.4.
Question 2 – The Panel could not understand this question.
Within the revision of EN 1176-1, 4.2.8.5 it is clear that no test is required for a surface material that is in
accordance with the r
...
SLOVENSKI STANDARD
kSIST-TP FprCEN/TR 16396:2012
01-maj-2012
2SUHPDRWURãNLKLJULãþ2GJRYRULQD]DKWHYNH]DLQWHUSUHWDFLMR(1 LQ
QMHJRYLKGHORY
Playground equipment for children - Replies to requests for interpretations to EN
1176:2008 and its parts
Ta slovenski standard je istoveten z: FprCEN/TR 16396
ICS:
97.200.40 ,JULãþD Playgrounds
kSIST-TP FprCEN/TR 16396:2012 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 16396:2012
TECHNICAL REPORT
FINAL DRAFT
FprCEN/TR 16396
RAPPORT TECHNIQUE
TECHNISCHER BERICHT
March 2012
ICS 97.200.40
English Version
Playground equipment for children - Replies to requests for
interpretation of EN 1176:2008 and its parts
Alle beschlossenen Interpretationen und Antworten
Spielplatzgeräte für Kinder betreffend
This draft Technical Report is submitted to CEN members for Technical Committee Approval. 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, Romania, 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
Management Centre: Avenue Marnix 17, B-1000 Brussels
© 2012 CEN All rights of exploitation in any form and by any means reserved Ref. No. FprCEN/TR 16396:2012: E
worldwide for CEN national Members.
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Contents Page
Foreword .3
Introduction .4
1 Scope .6
2 EN 1176-1:1998, Playground equipment Part 1: General safety requirements and test
method .6
2.1 General (interpretation request 2010-09 – SII) .6
2.2 Scope (interpretation request 2010-04 SFS) .7
2.3 3.5 (interpretation request 2010-02 SFS) .7
2.4 4.2 (interpretation request 2011-02 TSI) .9
2.5 4.2.4; 4.2.4.4 (interpretation request 2011-04 SNV) . 10
2.6 4.2.4.4 (interpretation request 2010-01 SFS) . 11
2.7 4.2.7.2 a) and b) and Annex D (interpretation request 2009-09 SN) . 11
2.8 4.2.7.3 (interpretation request 2011-03 – SNV) . 13
2.9 4.2.8.1 table 2 (interpretation request 2009-04 AFNOR) . 14
2.10 4.2.8.1 figure 14 (interpretation request 2009-05 AFNOR) . 14
2.11 4.2.8.4 (interpretation request 2009-06 DS) . 15
2.12 4.2.8.5.2 (interpretation request 2010-07 DIN) . 16
2.13 4.2.8.5.3 (interpretation request 2010-03 SFS) . 17
3 EN 1176-2:2008 - Playground equipment - Part 2: Additional specific safety requirements
and test methods for swings . 17
3.1 4.2 (interpretation request 2010-06 DS) . 17
3.2 4.10.1 (interpretation request 2010-05 DS) . 19
3.3 Annex B (interpretation request 2011-06 DS) . 19
4 EN 1176-3:2008 - Playground equipment - Part 3: Additional specific safety requirements
and test methods for slides . 21
4.1 4.2 (interpretation request 2011-05 SIS) . 21
5 EN 1176-4:2008 - Playground equipment - Part 4: Additional specific safety requirements
and test methods for cableways . 21
5.1 4.5 (interpretation request 2009-01 DS) . 21
6 EN 1176-6:2008 - Playground equipment - Part 6: Additional specific safety requirements
and test methods for rocking equipment . 22
6.1 4.6 (interpretation request 2009-07 DS) . 22
6.2 4.10 (interpretation request 2009-08 DS) . 22
6.3 Table 1 (interpretation request 2010-08 CEN/TC 136/SC 1/TG 1) . 23
7 EN 1176-10:2008 - Playground equipment - Part 10: Additional specific safety
requirements and test methods for fully enclosed play equipment . 23
7.1 4.3.7 (interpretation request 2009-02 DS) . 23
7.2 4.4.2.4 (interpretation request 2009-03 DS) . 23
8 EN 1176-11:2008 - Playground equipment and surfacing - Part 11: Additional specific
safety requirements and test methods for spatial network . 24
8.1 Scope, signage (interpretation request 2011-01 – ASI) . 24
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Foreword
This document (FprCEN/TR 16396:2012) 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 Technical Committee Approval.
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Introduction
Interpretations and no-action decisions
This Technical Report contains replies to requests for interpretations concerning the understanding of clauses
in EN 1176:2008 and its parts. 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.
Disclaimer
The interpretations have been derived by expert groups of CEN/TC 136/SC 1 and have been circulated to National
Standards Bodies for approval. The information contained herein does not reflect the full formal approval by CEN
or CEN member bodies. It should be noted that the interpretations are neither part of any standard nor have been
referenced in the Official Journal of the European Union.
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
shall be 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 xxxxx, which will be updated on a regular
basis
Proposals for amendments will be progressed as a new work item proposals in accordance with CEN rules.
c) a future revision
This is applicable when the standard is not clear and a suitable amendment can not be found to fully clarify
the question. Further work is needed on existing requirements or new requirements may need to be drafted.
Proposals for a revision will be progressed as a new work item proposal in accordance with CEN rules.
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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 Technical Report:
2009
2009-01 DS - Part 4 - 4.5
2009-02 DS - Part 10 - 4.3.7
2009-03 DS - Part 10 - 4.4.2.4
2009-04 AFNOR - Part 1 - 4.2.8.1 table 2
2009-05 AFNOR - Part 1 - 4.2.8.1 figure 14
2009-06 DS - Part 1 - 4.2.8.4
2009-07 DS - Part 6 - 4.6
2009-08 DS - Part 6 - 4.10
2009-09 SN - Part 1 - 4.2.7.2 a) and b) and Annex D
2010
2010-01 SFS - Part 1 - 4.2.4.4
2010-02 SFS - Part 1 - 3.5
2010-03 SFS - Part 1 - 4.2.8.5.3
2010-04 SFS - Part 1 - Scope
2010-05 DS - Part 2 - 4.10.1
2010-06 DS - Part 2 - 4.2
2010-07 DIN - Part 1 - 4.2.8.5.2
2010-08 CEN/TC 136/SC 1/TG 1 - Part 6 - Table 1
2010-09 SII - Part 1general
2011
2011-01 ASI - Part 11 - scope, signage
2011-02 TSI - Part 1 - 4.2
2011-03 SNV - Part 1 - 4.2.7.3
2011-04 SNV - Part 1 - 4.2.4; 4.2.4.4 - still being confirmed
2011-05 SIS - Part 3 - 4.2
2011-06 DS - Part 2 - Annex B
NOTE
ASI – Austria, DS – Denmark, SFS – Finland, AFNOR – France, DIN – Germany, SII – Israel, SIS – Sweden, SN –
Switzerland, TSI – Turkey,
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1 Scope
The purpose of this CEN Technical Report is to provide replies to requests for interpretations of all parts to
EN 1176.
2 EN 1176-1:1998, Playground equipment Part 1: General safety requirements
and test method
2.1 General (interpretation request 2010-09 – SII)
Question
1 Would appreciate and it is very important to get formal answer from the TC136 /WG in relation to how to
test the "rope carousel" an explanation for the rationale for testing them only to EN 1176-1 and not with EN
1176-5?
2 During that period our w/g discuss on the EN 1176-1:2008 standards, so they have few questions-
A) obtain their position regarding the criteria for fire resistance of playground equipment placed mainly in
open areas;
B) obtain from them an explanation why the instructions for tests of playground equipment in accordance with
EN 1021 have been deleted;
C) why are there not clear instructions besides the regulations of the countries where the equipment is
assembled?
3 We are also involved with musical playground equipment (see attached photographs). Would the
requirements of EN 1176 be applicable to some of them? Which types would be covered by EN 1176 and
which would not? Is there any restriction to placing them in an area together with other playground
equipment?
Reply
No action/interpretation
1. A picture of the specific product would be required to make a formal judgement.
EN 1176-1, clause 4.2.1 confirms; ‘Equipment where the primary play function is augmented by a
secondary motion, e.g. rocking and/or rotating, shall conform to the additional parts of EN 1176
relating to both play functions, as appropriate, unless the equipment is specifically covered in just one
of the additional parts of EN 1176.’
EN 1176-5, scope confirms; ‘This document is not applicable to equipment where the main play
function in not rotating’.
2. A) Contained Playground Equipment has the greatest risk and these requirements are now covered in
the new EN 1176-10. Other than this the greatest risk is from materials that produce a surface flash
effect and would not give time for users to leave the area.
B) EN 1021 was no longer thought to be necessary as a general requirement, but is still referred to in
EN 1176-10.
C) All countries have different National Regulations, from which no universal requirements could be
identified.
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3. There are no specific requirements in EN 1176 for ‘Musical’ Playground Equipment. However
EN 1176-1 provides a basis for assessing all types of Playground Equipment. The judgement of when
and how much of this specification to apply not only relates to the type of product, but also to where it
is provided. In an unsupervised/free access situation, together with other Playground Equipment
items, then some assessment to EN 1176 may be helpful.
Comments:
Question 1: Future work required to determine what is relevant for this specific type of product. This would
need to be determined by risk assessment.
Questions 2 & 3: No further action required.
2.2 Scope (interpretation request 2010-04 SFS)
Question
Question 1: How high should the fence be, if it is used as sole means of separating the playground from the
exercise area?
Question 2: If distance alone is used as means of separating the playground from the exercise area, how
long should this distance be?
Question 3: Can you give any other example on what other means of separating these areas there could be?
Reply
No action/interpretation
The interpretation panel recommend work is started, as a priority, for exercise equipment of this type as it is
now being specified in most European countries, in association with children’s playground equipment.
The panel advises that when products of this type are installed in association with children’s playground
equipment it will get use by children, whether intentional or not, as segregating by fencing, for example, does
not work as a solution. Therefore this type of equipment should be designed and provided without
unacceptable risks to these children, and comply with relevant requirements in EN 1176, e.g. according to test
protocols from accredited test houses, until a new standard is developed.
2.3 3.5 (interpretation request 2010-02 SFS)
Question
Clause 3.5 tells that forced movement is “e.g. sliding, swinging, rocking”. Different rocking equipment provide
different types of movement. This is expressed in the table below:
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Type 1 and 6 Type 2-4 Type 5
Product example
Movement type Up-down Slow and short Rotation with vertical
horizontal movement movement
Length of movement 60 - 130 cm 20 - 40 cm infinite
Movement speed Free fall down is Slow Potentially fast
possible
It’s obvious that there is a distinction between different “rocking” movements.
Question 1: Are type 2 – 4 rocking equipment intended to require free space like in clause 3.5?
rd
Clause 4.2.8.2.5, 3 paragraph: “In most cases there may be overlapping of falling spaces including impact
areas. Unless specified in other parts of this standard, overlapping of the falling space where forced
movement exists should not occur.”
Question 2: Are type 2 – 4 rocking equipment intended to be installed without overlapping falling space like in
clause 4.2.8.2.5?
Reply
No action/interpretation
Answer to the question 1)
The definition for Free Space in EN 1176-1:2008 point 3.5 refers to ‘Rocking Equipment’.
st
Also, in 4.2.8.5.2, 1 paragraph there is a clear reference to rocking equipment as having forced movement
(thus free space).
As no exceptions are given in EN 1176-6 it applies to all types of rocking items.
Additionally during the 2008 revision; changes were made to the requirements for a tested surface to be
provided. Part of these discussions assumed that small rocking items, such as type 2a, had a forced
movement/free space to ensure they were required to have an impact attenuating surface in accordance with
EN 1176-1.
Answer to the question 2)
Yes, types 2 – 4 rocking equipment are intended to be installed without overlapping falling space according to
rd
EN1176-1 clause 4.2.8.2.5, 3 paragraph, as there is no exception in part 6.
However, please also see EN 1176-6, clause 4.10; This allows the Falling Space for rocking equipment types
1, 2, 3 and 4, to be reduced to a minimum of 1m, from the general requirements in EN 1176-1
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Comments:
Risks associated with a closer separation/proximity of single-user rockers, such as type 2a, are much less
than for multiuser types as that single user has a far higher level of control. A closer separation distance for
Rocking Equipment, of this type, could be considered, as an exemption, as future work. This would need to be
carefully considered to the existing requirements of EN 1176-1, clauses 4.2.8.2.
We would recommend that specific types of Rocking Equipment complying with EN 1176-6 should be exempt
from the restriction in EN 1176-1, not to overlap Falling Spaces. (Should be confirmed by risk assessment).
This would still enforce that they include some forced movement, but acknowledges it to be of a small, lower
risk, amplitude.
2.4 4.2 (interpretation request 2011-02 TSI)
Question
Is the product seen in the photos suitable for Subclause 4.2 of EN 1176-1?
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Reply
No action/interpretation
EN1176-2 does not contain any specific requirements for the stiffness of swing seats.
EN 1176-1, clause 4.2.1 does require – ‘The dimensions and degree of difficulty….is apparent and
foreseeable by the child’. Some of these judgements will be subjective and it is not possible for this committee
to comment on specific products and circumstances.
However, the panel is aware that ‘belt seats’ are common in some markets, for use on swings, and we
are not aware of any reason why this type of seat should not be accepted in principle.
2.5 4.2.4; 4.2.4.4 (interpretation request 2011-04 SNV)
Question
How are the requirements for protection against falling on easily accessible suspension bridges?
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Reply
still being confirmed
2.6 4.2.4.4 (interpretation request 2010-01 SFS)
Question
It's not clear how the width of the opening should be measured. Text speaks about "clear opening" and even
figure 10a indicates that opening is measured from narrowest point. Still some clarifying information in text
would be nice as well a figure showing how the width of the opening should be measured.
Reply
No action/interpretation
Agreed this could be clarified:
nd nd
Propose to amend clause 4.2.4.3, 2 Para., 2 sentence;
‘The width of entrance and exit opening in guardrails, with exception of stairs, ramps and bridges, shall have a
maximum clear opening of 500 mm, when measured horizontally at a position, with a height between 600 mm
to 850 mm from the platform.’
nd
Propose to amend clause 4.2.4.4, 2 sentence;
‘The width of entrance and exit opening in barriers shall have a clear opening of 500mm maximum, when
measured horizontally at any point, unless a guardrail is provided across the opening……’
2.7 4.2.7.2 a) and b) and Annex D (interpretation request 2009-09 SN)
Question
Is this part of the equipment defined as a “completely bound opening” and shall comply with the requirements
in 4.2.7.2 a) and is to be tested accordance to Annex D, D.2.1, probe a), b) and c); or
is this a V-shaped opening and shall comply with 4.2.7.2 b) Partially bound and V-shaped openings and is to
be tested in accordance to D.2.2 and the use of the test template for V-shaped openings?
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Reply
No action/interpretation
1. Yes, this entrapment situation is defined as a completely bound opening and so must comply
with the requirement in EN1176-1, clause 4.2.7.2a)
2. Yes, this large completely bound opening also includes a ‘V’ shaped opening and so must
comply with the requirement in EN1176-1, clause 4.2.7.2b)
2.8 4.2.7.3 (interpretation request 2011-03 – SNV)
Question
Make it sense to test the climbing knobs by the toggle test?
Reply
No action/interpretation
The current test requirements in EN 1176-1, clause 4.2.7.3 ‘entrapment of clothing/hair’ are restricted to
Slides, Sliding Pole and Roofs. These were viewed to be the highest priority for this type of risk based on
accident data that was reviewed at the time of the standards publication. In all of these cases the user is
subject to ‘forced movement’ on equipment items, where no hand or foot support elements are provided.
The current standard does not view climbing as a ‘forced movement’ activity.
A climbing wall presents a different risk case as there will generally be a number of hand and foot holds within
reach of the user, at any one time, which gives them greater opportunities to control their movements.
Should new accident data become available that suggests climbing walls are higher risk situations that require
a new standard requirement and method of test then this should be presented to the committee for review as
‘future work’
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2.9 4.2.8.1 table 2 (interpretation request 2009-04 AFNOR)
Question
In the case of a hanging position whereupon the user cannot lift himself up to the hand support (please see
example below) what is the free height of fall to take into account?
Table 2 — Free height of fall for different types of use
Hanging From hand support height to surface below
(When full body support is provided by the
hands only and the whole body can be lifted up to
the hand support, see Figure 14b)
Example:
Reply
No action/interpretation
The standard is clear.
For Hanging use the Free Height of Fall is measured from the Hand support position.
It is not always clear whether a user can lift themselves up, so it is the Hand Support that is referred to in table
2 for Hanging use.
2.10 4.2.8.1 figure 14 (interpretation request 2009-05 AFNOR)
Question
How do we measure the free height of fall of the following:
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Reply
No action/interpretation
For the left hand example the Free Height of Fall (h) is measured from the top, as access is encouraged to
this position.
For the right hand example the Free Height of Fall (h) is measured from the top of the climbing
panel/horizontal curved support, as it appears access is encouraged to this position.
- If there are no support points for feet (climbing hold, rope, mesh,…) between the highest hands position and
this height minus 1 m, we consider playground equipment free height of fall as being the highest hands
position minus 1m.
- If there are support points for feet (climbing hold, rope, mesh,…) between the highest hands position and this
height minus 1m, we consider playground equipment free height of fall as being from the highest hands
position.
The Panel does recognise that Climbing use offers the best security to the user and the measurement of Free
Height of Fall should be reviewed by SC1.
2.11 4.2.8.4 (interpretation request 2009-06 DS)
Question
It is stated 4.2.8.4 that adjacent parts of play structures with a difference in free height of fall of less than 600
mm may be in the falling space. This induces us to ask the following questions:
- From where and to where is the 600 mm measured?
- What is the definition of "adjacent parts"?
In addition, we would welcome illustrations of acceptable parts of equipment or play structures in the falling
space.
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Reply
No action/interpretation
1) The difference in height between adjacent parts is measured from the Free Height of Fall position of
the upper structure to the top of the structure below. (From where the user can fall to where the user
can fall on).
2) An adjacent part means a part of the same play equipment that is adjoining/near by, within the
Falling Space.
2.12 4.2.8.5.2 (interpretation request 2010-07 DIN)
Question
With reference to passage of text: -The critical fall height of the surfacing shall be equal to, or greater than the
free height of fall of the equipment.
1. Is an impact attenuating of the impact area in case of a fall height of 0cm (slide lies directly on the ground)
required, although no minimum requirement for surface on the lateral sides of the slide exists?
2. What about the definition of the objective in relation to the slides with fall heights below 60cm?
Example:
Reply
No action/interpretation
Question 1 - The Standard is clear:
EN 1176-3, clause 4.8; states the surface around the run-out section shall have a critical fall height of at least
1000mm. This is the highest risk area, as a slide designed to EN 1176-3 will ‘contain and guide’ the user until
they reach this section of the slide. (There are no specific requirements given for the sliding or starting section
of the slide).
When tested in accordance with EN 1177 a zero mm Fall Height onto any type of surface will produce a zero
HIC value. Therefore an Impact Area for a zero Fall Height will by implication will have no test requirements,
but it must still comply with the requirements for the Falling Space given in EN 1176-1, clause 4.2.8.4.
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Question 2 – The Panel could not understand this question.
Within the revision of EN 1176-1 clause 4.2.8.5 it is clear that no test is required for a surface material that is
in accordance with the requirements of table 4. However, for surface materials not in accordance with table 4
and provided for equipment with forced movement, such as slides, then a test is required at all fall heights.
The Interpretation Panel understand that the surface to the side of a sliding section on an Embankment Slide
has a low risk of falling, as the structure contains and guides the user. This could be considered for an
exception from the part 1 requirements for a tested surface.
The panel would however recommend that the requirements for Falling Space in EN 1176-1, clause 4.2.8.4,
are still maintained, including the requirement that the space stall not contain any obstacles onto which a user
could fall and cause injuries.
2.13 4.2.8.5.3 (interpretation request 2010-03 SFS)
Question
Question 1: As there are no requirements for normal impact area other than “softness”, what requirements
are there for “impact area surface with no test requirement”?
Question 2: As “impact area surface with n
...
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