Guide to the ABA Accessibility Standards

A Summary of Accessibility Guidelines for Play Areas

January 2007

The products shown in this guide are only intended to serve as examples to illustrate the accessibility guidelines, and are not intended as endorsements of the products. Other products may be available. The Access Board does not evaluate or certify products for compliance with the accessibility guidelines. Users are advised to obtain and review product specifications for compliance with the accessibility guidelines.

Introduction

The Americans with Disabilities Act (ADA) is a comprehensive civil rights law that prohibits discrimination on the basis of disability. The ADA requires that newly constructed and altered state and local government facilities, places of public accommodation, and commercial facilities be readily accessible to, and usable by, individuals with disabilities. Recreational facilities, including play areas, are among the facilities required to comply with the ADA.

The Architectural and Transportation Barriers Compliance Board - often referred to as the “Access Board” - has developed accessibility guidelines for newly constructed and altered play areas. The play area guidelines are a supplement to the Americans with Disabilities Act Accessibility Guidelines (ADAAG). Once these guidelines are adopted as enforceable standards by the Department of Justice, all newly constructed and altered play areas covered by the ADA will be required to comply. These guidelines also apply to play areas covered by the Architectural Barriers Act (ABA).

This guide is designed to assist in using the play area accessibility guidelines and is divided into the following sections:

• Summary
• Defined Terms
• Where Do the Play Area Guidelines Apply?
• What is a Play Component?
• How Many Play Components Must Be on an Accessible Route?
• What Are the Requirements for Accessible Routes?
• What Other Accessibility Requirements Apply to Play Components? Soft Contained Play Structures

Acknowledgments

The Access Board would like to thank the following manufacturers for their generous assistance: Bob Leathers, Columbia Cascade, GameTime, KOMPAN, Landscape Structures, Little Tikes, Miracle, Olympic Recreation, Playworld Systems, and Recreation Creations. This manual was developed in part through a contract with KOMPAN, Inc., 50 Commercial Drive, Johnson City, New York 13790.

---

Play Area Terms

Many terms are used throughout this guide to describe the play area guidelines. Familiarity with these terms is important when applying the guidelines. Other definitions are provided in the ADA and ABA Accessibility Guidelines.

ABA

Architectural Barriers Act.

Access Board

An independent Federal agency that develops accessibility guidelines under the ADA and other laws. The Access Board is also known as the Architectural and Transportation Barriers Compliance Board.

Accessible

Describes a site, building, facility, or portion thereof that complies with the play area guidelines.

Accessible Route

A continuous unobstructed path connecting all accessible elements and spaces of a building or facility. Inside the boundary of the play area, accessible routes may include platforms, ramps, elevators, and lifts. Outside the boundary of the play area, accessible routes may also include parking access aisles, curb ramps, crosswalks at vehicular ways, walks, ramps, and lifts.

ADA

Americans with Disabilities Act.

Alteration

An alteration is a change to a building or facility that affects or could affect the usability of the building or facility or part thereof. Alterations include, but are not limited to, remodeling, renovation, rehabilitation, reconstruction, historic restoration, resurfacing of circulation paths or vehicular ways, changes or rearrangement of structural parts or elements, and changes or rearrangement in the plan configuration of walls and full-height partitions. Normal maintenance is not an alteration unless it affects the usability of the facility (see section on alterations for more details).

Amusement Attraction

Any facility, or portion of a facility, located within an amusement park or theme park, that provides amusement without the use of an amusement device. Examples include, but are not limited to, fun houses, barrels, and other attractions without seats.

ASTM

American Society for Testing and Materials.

Berm

A sloped surface at ground level designed to ascend or descend in elevation.

Clear

Unobstructed.

Composite Play Structure

Two or more play structures attached or functionally linked, to create one integral unit that provides more than one play activity (ASTM F 1487-01).

Cross Slope

The slope that is perpendicular to the direction of travel (see running slope).

Facility

All or any portion of buildings, structures, site improvements, elements, and pedestrian routes or vehicle ways located on a site.

Ground Level Play Component

A play component that is approached and exited at the ground level.

Play Area

A portion of a site containing play components designed and constructed for children.

Play Component

An element intended to generate specific opportunities for play, socialization, or learning. Play components may be manufactured or natural, and may be stand alone or part of a composite play structure.

Ramp

A walking surface that has a running slope of greater than 1:20.

Running Slope

The slope that is parallel to the direction of travel (see cross slope).

Site

A parcel of land bounded by a property line or a designated portion of a public right-of-way.

Soft Contained Play Structure

A play structure made up of one or more components where the user enters a fully enclosed play environment that utilizes pliable materials (e.g., plastic, netting, fabric).

Use Zone

The ground level area beneath and immediately adjacent to a play structure or piece of equipment that is designated by ASTM F 1487 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use for unrestricted circulation. This is the play surface upon which it is predicted a user would land when falling from or exiting the equipment.

---

Application - Where do the play area guides apply?

New Construction

The play area guidelines in this guide apply to all newly designed or constructed play areas for children ages 2 and older. This includes play areas located in a variety of settings: parks, schools, childcare facilities, shopping centers, and public gathering areas. Owners or operators of newly constructed play areas are responsible for complying with these guidelines.

The play area guidelines do not apply to:

• Family childcare facilities where the proprietor resides
• Amusement attractions
• Religious entities

Alterations

The play area guidelines apply to alterations made to existing play areas that affect, or could affect, the usability of the play area. Examples include removing a climbing play component and replacing it with a spring rocker, or changing the ground surfacing.

Alterations provide an opportunity to improve access to existing play areas. Where play components are altered and the ground surface is not, the ground surface does not have to comply with the ASTM F 1951-99 standard for accessible surfaces unless the cost of providing an accessible surface is less than 20 percent of the cost of the alterations to the play components.

If the entire ground surface of an existing play area is replaced, the new ground surface must provide an accessible route to connect the required number and types of play components. Normal maintenance activities such as replacing worn ropes or topping off ground surfaces are not considered alterations.

If play components are relocated in an existing play area to create safe use zones, the guidelines do not apply, provided that the ground surface is not changed or extended for more than one use zone. Replacing the entire ground surface does not require the addition of more play components.

Equivalent Facilitation

Designs, products, or technologies can be used as alternatives to those prescribed, provided they result in substantially equivalent or greater accessibility or usability.

Equivalent facilitation is the concept of utilizing innovative solutions and new technology, design, or materials in order to satisfy the guidelines. These alternative solutions provide equal access and take advantage of new developments, but may differ technically from specific guidelines.

Phasing in Play Areas

When play areas are constructed in phases, they must continue to meet the play area guidelines throughout construction. The initial phase area must meet the guidelines, and then at each successive phase the whole play area must be reassessed to assure compliance. “Phased Designs” are play areas developed to be installed in different stages, allowing the play area to grow in a planned manner while accommodating budgets, fund raising, or community approval processes. The play area shown below will be installed in twp phases. As each phase is completed, the entire play area must be reevaluated for compliance.

Play Areas Separated by Age

To reduce the risk of injury, safety guidelines recommend separate play areas for different age groups. In applying the guidelines, play areas designed for different age groups should be considered separately. A play area designed for 2 to 5 year-olds is considered separate from one for 5 to 12 year-olds. Therefore, compliance with the guidelines must be considered for each individual play area.

Geographically Separated Play Areas

Large geographical spaces may contain several play areas within one park setting. Where play areas are geographically separated on a site, they are considered separate play areas. The accessibility guidelines apply to each play area.

---

What is a Play Component?

A play component is an element designed to generate specific opportunities for play, socialization, and learning. Play components may be manufactured or natural, and may be stand alone or part of a composite play structure. Swings, spring riders (below), water tables, playhouses, slides, and climbers (right) are among the many different play components.

For the purpose of the guidelines, ramps, transfer systems, steps, decks, and roofs are not considered play components. These elements are generally used to link other elements on a composite play structure. Although socialization and pretend play can occur on these elements, they are not primarily intended for play.

When applying the play area guidelines, it is important to identify the different play experiences play components can provide.

Different "Types"

At least one of each type of play component provided at ground level in a play area must be on the accessible route. Different "types" of play components are based on the general experience provided by the play component. Different types include, but are not limited to, experiences such as rocking, swinging, climbing, spinning, and sliding.

"Rocking" is an example of horizontal movement that can be backwards, forwards, sideways or even circular in nature. "Sliding" is an example of rapid descent that utilizes the force of gravity.

The number of individuals who can play on a play component at once does not determine the quantity of play components provided in a play area. A play component can hold many children but is considered one type of play experience - or one play component - in the play area.

Examples of Sliding Types

Elevated Play Components

An elevated play component is a play component that is approached above or below grade and is part of a composite play structure. Play components that are attached to a composite play structure and that can be approached from a platform or deck area are considered elevated play components.

Ground-Level Play Components

Ground-level play components are items that can be approached and exited at ground level. For example, a child approaches a spring rider at ground level via the accessible route. The child may ride then exit directly back onto the accessible route. The activity is considered ground level because the child approaches and exits it from the ground-level route.

"Ground-level components" are approached and exited at ground level. Ground-level play components may include items such as swings, spring riders, and panels. Freestanding slides are considered ground-level components for the purpose of these guidelines. An accessible route must connect to the ladder or steps, and to the exit of the slide. While this solution does not provide access for all children, it gives many individuals the opportunity to access play components.

When more than one ground-level play component is required on an accessible route, the play components must be integrated. Designers should consider the optimal layout of ground-level play components to foster interaction and socialization among all children. Grouping all ground-level play components accessed by children with disabilities in one location does not constitute integration.

---

Components and Accessible Routes

Ground-Level Play Components

There are two requirements addressing how many ground-level play components must be on an accessible route:

• One of Each Type
• Ground-Level Requirements based on the number of Elevated Play Components

One of Each Type

At least one of each type of ground-level play component that is present in the play area must be on an accessible route.

Ground Level Requirements Based on Elevated Play Components

The number and variety of ground-level play components required to be on an accessible route is also determined by the number of elevated components provided in the play area. The intent of this requirement is to provide a variety of experiences for individuals who choose to remain with their mobility devices, or choose not to transfer to elevated play components.

Table 240.2.1.2

Number of elevated play components provided	Minimum number of ground-level play components required to be on accessible route	Minimum number of different types of ground-level play components required to be on accessible route
1	Not applicable	Not applicable
2 to 4	1	1
5 to 7	2	2
8 to 10	3	3
11 to 13	4	3
14 to 16	5	3
17 to 19	6	3
20 to 22	7	4
23 to 25	8	4
More than 25	8 plus 1 for each additional 3 over 25, or fraction thereof	5

If ramps provide access to at least 50 percent of the elevated play components – which must include at least three different play types – then additional ground-level components are not required. An example: the composite structure of a play area has four elevated play components (bubble panel, slide, steering wheel, and tic-tac-toe panel). According to the table, a minimum of one ground level play component must be provided, and a minimum of one different type. The spring rider or swing can be used to meet the “one of each type” requirement and can also be used to meet the minimum number determined by Table 240.2.1.2. The number of ground-level components determined by “one of each type” can also fulfill the minimum ground level requirement that is indicated by the elevated play components table.

Elevated Play Components

At least 50 percent of the elevated play components must be on an accessible route. An “elevated play component” is a play component reached from above or below grade, and is part of a composite play structure.

Step-by-Step Guide

The following step-by-step guide has been provided to assist in evaluating a play area for meeting the minimum requirements of these guidelines. The guide has been arranged in four steps and provides spaces to fill in numeric values of play components for evaluating a specific play area design.

STEP 1 Assess your play area design
This step identifies the number and different types of ground level play components provided in a play area design. The number of elevated play components is also identified.

STEP 2 Determine what is needed
In some cases, the accessibility guidelines will require additional play components to be provided to meet the minimum requirements. Step 2 begins identifying what is needed by reading Table 240.2.1.2. Table 240.2.1.2 establishes a minimum level of ground level play components required to be on an accessible route, based on the number of elevated play components provided.

STEP 3 Compare which is greater
Step 3 compares your results in identifying the number and different types of ground level play components with those required by Table 240.2.1.2. The greater number is considered to be the minimum number of ground level play components required to be on an accessible route.

STEP 4 Assess how to get there
Step 4 examines the number of elevated play components provided, beginning with the number established in step 1. Once the number of elevated play components provided is identified, step 4 defines the type of route to be provided to connect to these elevated play components. Where 20 or more elevated play components are provided, ramps must connect to a minimum of 25% of the elevated play components. Ramp or transfer systems must connect to the remaining 25%. If 19 or fewer elevated play components are provided, transfer systems must connect to a minimum of 50% of the elevated play components.

This step-by-step guide is applied using the proposed play area design.

STEP 1 Number of ground level play components: 3

• 1 spring rider
• 2 swings

Number of different types of ground level play components provided: 2

• spring rider
• swing

STEP 2 Determining what is needed based on Table 240.2.1.2:

Table 240.2.1.2

Number of elevated play components provided	Minimum number of ground-level play componentsi required to be on accessible route	Minimum number of different types of ground-level play components required to be on accessible route
1	Not applicable	Not applicable
2 to 4	1	1
5 to 7	2	2

STEP 3 Determining the greater number: 2

In this case, 2 types were provided. Table 240.2.1.2 requires a minimum of 1.

STEP 4 Assessing how to get there:

Number of elevated = 4 (1 triple slide, 1 interactive panel, 1 overhead curved ladder, 1 banister bars)
50% = 2
Transfer access required to 2 elevated play components as a minimum

---

Accessible Routes Requirements

ADAAG Section 4.3 addresses accessible routes that connect the play area to the school, parking lot, or facility that it serves. Operators or owners of play areas are subject to all the other requirements of the ADA, including the obligation to provide individuals with disabilities an equal opportunity to enjoy the play area provided by that facility.

This section describes the various features of accessible routes within a play area, including location, clear width, slope, and accessible surfaces.

Accessible Routes

An accessible route is a pathway specifically designed to provide access for individuals with disabilities, including those using wheelchairs or mobility devices.

The accessible route must connect all entry and exit points of accessible play components. Clear floor space required at play components and maneuvering space can overlap the accessible route. Incorporating additional circulation space around high-use play components creates extra room for movement and accessibility for everyone using the play area.

There are two types of accessible routes:

• Ground-level
• Elevated

Ground-Level Accessible Routes

A ground-level accessible route connects play components at ground level.

• 60 inches (1525 mm) minimum clear width
• 1:16 maximum slope

Smaller play areas - those that are less than 1,000 square feet (93 square meters) - may have ground-level accessible routes that are 44 inches (1120 mm) clear width. A wheelchair turning space must be provided where the route exceeds 30 feet (9.14 mm) in length.

At ground level, objects may not protrude into the 60-inch wide space of an accessible route up to or below the height of 80 inches (2030 mm), measured above the accessible route surface. The 80-inch clearance applies only to the 60-inch accessible route, and is not required for the entire play area. The 80-inch vertical clearance applies to ground-level routes only, and not elevated routes. This allows features like protective roofs and sun shelters to be present.

Maximum Slope at Ground Level

The maximum allowable slope for a ground-level accessible route is 1:16.

Berms are sometimes used to provide access to elevated play areas. A berm may be a natural sloped surface that is present in a hilly play area site, or a ground-level route built with slopes.

Designers are encouraged to consider edge protection and handrails on berms where there may be a drop-off. Remember the maximum slope of this “ground-level accessible route” is 1:16.

However, handrails are not required on ground-level accessible routes. This is permitted since the handrails may become a safety hazard in the “use zone.”

Accessible Ground Surfaces

Ground surfaces along accessible routes, clear floor or ground spaces, and maneuvering spaces, must comply with the American Society for Testing and Materials (ASTM) F 1951-99 Standard Specification for Determination of Accessibility to Surface Systems Under and Around Playground Equipment. This standard assesses the accessibility of a surface by measuring the work an individual must exert to propel a wheelchair across the surface. The standard includes tests of effort for both straight-ahead and turning movements, using a force wheel on a rehabilitation wheelchair as the measuring device. To meet the standard, the force required must be less than that which is required to propel the wheelchair up a ramp with a slope of 1:14.

When selecting ground surfaces, operators should request information about compliance with the ASTM F 1951-99 standard.

The American Society for Testing and Materials (ASTM) has established safety standards for play areas, including resilient surfaces. For further information or to purchase these standards, contact ASTM, 100 Barr Harbor Drive, West Conshohocken, PA 19428-2959, www.astm.org.

Accessible Surfaces Located In The Use Zone

If located within the use zone, accessible ground surfaces must also be impact attenuating and meet ASTM F 1292-04 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment. The “use zone” is a ground level area beneath and immediately adjacent to a play structure or piece of equipment that is designated for unrestricted circulation around the equipment. It is predicted that a user would fall and land or exit the equipment on the surface of the use zone.

Ground surfaces must be inspected and maintained regularly and frequently to ensure continued compliance with the ASTM F 1951-99 standard. The frequency of maintenance and inspection of resilient surfacing depends on the amount of use and the type of surfacing installed.

Engineered wood fiber surfaces will require frequent maintenance to comply with the ASTM F 1951-99 standard because of surface displacement due to user activity or other factors. Designers and operators are likely to choose materials that best serve the needs of each play area. The type of material selected will affect the frequency and cost of maintenance.

At the time of this publication, rubber surfacing and some engineered wood fiber products meet the ASTM F 1951-99 standard. The fact that a specific product meets the ASTM 1951-99 standard does not necessarily mean that all other similar products will meet the standard. Operators interested in selecting surfaces to comply with the play area guidelines should consult individual product manufacturers to determine compliance with ASTM F 1951-99.

Elevated Accessible Routes

An elevated accessible route is the path used for connecting elevated play components. Elevated accessible routes must connect the entry and exit points of at least 50 percent of the elevated play components provided in the play area. Two common methods for providing access to elevated play components are ramps and transfer systems. Ramps are the preferred method since not all children who use wheelchairs or other mobility devices may be able to use - or may choose not to use - transfer systems.

A typical elevated accessible route might include the following:

• 36-inch (915 mm) clear width
• 32-inch (815 mm) narrowed width permitted for 24-inch (610 mm) length to accommodate features in the composite structure
• 12-inch (305 mm) rise maximum per ramp run
• Top of handrail gripping surfaces shall be 20 inches (510 mm) minimum to 28 inches (710 mm) maximum above the ramp surface

When Ramps Are Required

Ramps are required on composite structures with 20 or more elevated play components and must connect to at least 25 percent of the elevated play components. Ramps allow individuals who use wheelchairs and mobility devices to access elevated play components in composite play structures without transferring.

Rise of a ramp is the amount of vertical distance the inclined or slanted surface ascends or descends. A ramp run is a length of a continuous sloped surface that is ascending or descending. For example, to reach a 12-inch high deck or platform, a designer could use a 12-foot ramp with the maximum 1:12 slope, or a 14-foot ramp with a less-steep 1:14 slope.

Platform lifts, also known as “wheelchair lifts,” may be considered for providing access to elevated play components when appropriate. Where applicable, platform lifts complying with ADAAG section 4.11 and applicable state and local codes are permitted as a part of an accessible route. Because lifts must be independently operable, owners and operators should carefully consider the appropriateness of their use in unsupervised settings.

Ramps

Ramps serve as a continuation of the accessible route from the ground allowing individuals who use mobility devices to access elevated components. For each elevated ramp run:

• 12-inch (305 mm) maximum rise

• 1:12 maximum slope

• 36-inch (915 mm) minimum clear width

Maneuvering Space Where Ramps are Provided

At least one maneuvering space must be provided on the same level as the play component. The space must have a slope no steeper than 1:48 in all directions. The ADA and ABA Accessibility Guidelines address additional requirements for ramps and landings including edge protection, cross slope, surfaces, and outdoor conditions.

Handrails

Handrails are required on both sides of ramps connecting elevated play components. Handrails must comply with the following:

• Clearance between handrail gripping surfaces and adjacent surfaces shall be 1 1/2 inches (38 mm) minimum.

• Handrail gripping surfaces shall be continuous along their length and shall not be obstructed along their tops and sides. The bottoms of handrail gripping surfaces shall not be obstructed for more than 20 percent of their length. Where provided, horizontal projections shall occur 1 1/2 inches (38 mm) minimum below the bottom of the handrail gripping surface.

Handrails are required to comply with ADAAG 4.8.5. However, extensions on handrails in the play area are not required. This is to prevent children running into protruding rails in the play area.

When Transfer Systems Are Used

A transfer system provides access to elevated play components within a composite system by connecting different levels with transfer platforms and steps. A transfer system provides access to elevated play components without the use of a wheelchair or mobility devices. At least 50 percent of the elevated play components can be connected by a transfer system in play areas with fewer than 20 elevated components. In play areas with 20 or more elevated play components, transfer systems may be used to connect up to 25 percent of the elevated play components and the rest of the elevated play components required to be on an accessible route must be connected by a ramp.

**A transfer system typically consists of a transfer platform, transfer steps, and transfer supports. **

Where a transfer system is provided, such a combination of transfer platforms and transfer steps provides a continuous accessible route to elevated play components. A transfer system provides individuals the space necessary to physically transfer up or down in a composite play structure. Where provided, a 24-inch (610 mm) minimum width is necessary for individuals moving around a structure.

Consider the distance someone must travel to reach play components accessed by transfer systems. When a transfer system is placed directly next to a slide, for example, access to the elevated play component must be carefully designed to minimize the distance someone must transfer to reach it.

Transfer Platforms

A transfer platform is a platform or landing that an individual who uses a wheelchair or mobility device can use to lift or transfer onto the play structure and leave the wheelchair or mobility device behind at ground level.

• 11 inches (280 mm) to 18 inches (455 mm) height of top surface

• Minimum 24 inches (610 mm) wide

• Minimum 14 inches (355 mm) deep

• Unobstructed side

Adding a transfer step that leads to the ground’s surface increases access for children exiting components at the ground level.

Clear floor or ground space - used for parking wheelchair or mobility devices (commonly called “wheelchair parking”) - is required at the transfer platform. The 48-inch long side (1220 mm) of the “wheelchair parking” space must be parallel to the 24-inch (610 mm) side of the transfer platform.

Transfer Steps

Transfer steps are level surfaces in a composite structure that can be used for transferring from different levels to access play components.

• Minimum 24 inches (610 mm) wide

• Minimum 14 inches (355 mm) deep

• 8 inches (205 mm) maximum height

Transfer steps in a play area are not required to satisfy the general ADAAG stair requirements. Maneuvering space and clear space is not required on elevated structures or at elevated play components reached by a transfer system.

Transfer Supports

A means of support is required when transferring into the entry or seat of a play component. Transfer supports assist individuals with transferring and general mobility. They include handrails, handgrips, or custom designed handholds. Transfer supports must be provided on transfer platforms and transfer steps at each level where transferring is the intended method of access.

Consideration must be given to the distance between the transfer system and the elevated play components it is intended to facilitate. Designers should minimize the distance between the points where a child transfers from a wheelchair or mobility device and the elevated play destination.

Connected Elevated Components

When transfer systems are used, an elevated play component may connect to other elevated play components, providing an innovative, accessible route.

Consideration should be given to how a play component is utilized when it is selected to connect to other elevated play events. When a transfer system is provided, children move through a play component (such as a crawling tube) using their own strength without a mobility device. Providing variety and excitement through elevated play spaces benefits all children. Tunnels and tubes make “getting there” an activity in itself.

Elevated play components that are connected to other play components count toward fulfilling the requirement for the number of elevated components on an accessible route where transfer systems are used.

---

Other Accessibility Requirements

The play area guidelines address accessible routes connecting play components along with certain spaces that are crucial to making a play area usable for children with disabilities. The other requirements for play components are provided to promote general usability, with application to a variety of play components. Additional features will assist in making play components more accessible to more children. Designers are encouraged to consider components with back support, increased space for maneuvering adjacent to the play component, and other features that promote independent use.

Clear Floor or Ground Space

Clear floor space - also known as ground space - provides unobstructed room to accommodate a single stationary wheelchair and its occupant at a play component on an accessible route. Clear floor or ground space is also sometimes called “wheelchair parking space.”

• 30-inch (760 mm) by 48-inch (1220 mm) minimum area
• May overlap accessible routes and maneuvering spaces
• Slope not steeper than 1:48 in all directions

Play components come in a variety of shapes and sizes facilitating a broad range of experiences. A specific location for clear floor or ground space has not been designated. Each play component is unique and the spaces must be placed in the best location for the situation.

The minimum clear floor or ground space on a composite structure may be positioned for a forward or parallel approach. It may overlap accessible routes and maneuvering spaces. Elevated play components accessed by transfer systems do not require maneuvering or clear floor spaces, since mobility devices are left at ground level.

Maneuvering Space

Maneuvering space is defined as the space required for a wheelchair to make a 180-degree turn. At least one maneuvering space must be provided on the same level as elevated play components.

When providing access to ground level and elevated play components by ramps, space allowances to accommodate wheelchairs and mobility devices are required.

• A 60-inch (1525 mm) turning circle permits individuals with mobility devices to turn around
• A 60-inch (1525 mm) T-Shaped turn allows an individual to change directions by making a series of multi-point turns
• Slope not steeper than 1:48 in all directions

As an example, maneuvering space is required for swings and may be located behind or in front, as long as it is immediately adjacent to the swing. Objects are not permitted to protrude into ground level maneuvering spaces at or below 80 inches (2030 mm) above the ground or floor surface.

Entry Points and Seats

Entry points and seats are features of play components where individuals would transfer, sit, or gain access. When play components are located on an accessible route, the height required to transfer directly to the entry point or seat of a play component has a minimum of 11 inches (280 mm) and a maximum of 24 inches (610 mm). A mid-level height of 18 inches (455 mm) is recommended. The height of the entry point of a slide is not specified.

Examples of entry points and seats include swing seats, spring rocker seats, and crawl-tube openings (left). Consider design features like open sides, back supports, and hand supports (right) to help facilitate easy transfer and access.

Play Tables

Play tables are surfaces, boards, slabs, or counters that are created for play. This includes tables designed for sand and water play, gathering areas, and other activities. Where play tables are located on an accessible route, the wheelchair knee clearance minimums are:

• 24 inches (610 mm) high minimum
• 30 inches (760 mm) wide minimum
• 17 inches (430 mm) deep minimum

Play tables designed primarily for children under 5 years old may provide a parallel approach instead of knee clearance if the rim is a maximum of 31 inches (785 mm) high. The tops of rims, curbs, or other obstructions that would prevent access to a table surface should be 31 inches (785 mm) maximum in height.

Play tables may be located at a ground or elevated level in a composite play structure. Consider the route, clear floor space and maneuvering spaces for tables intended to be accessible to individuals who use wheelchairs.

Reach Ranges (Advisory)

The play area guidelines include advisory information on recommended reach ranges. Reach ranges are the recommended designated regions of space that a person seated in a wheelchair can reasonably extend their arm or hand to touch, manipulate, move, or interact with an object or play component.

Reach ranges should be considered when providing play components with manipulative or interactive features for children who use wheelchairs. Recommended forward or side reach ranges are:

• 20 to 36 inches for 3 to 4 year-olds
• 18 to 40 inches for 5 to 8 year-olds
• 16 to 44 inches for 9 to 12 year-olds

The reach ranges appropriate for use by children who use wheelchairs to access play components are intended for ground-level components, and elevated components accessed by ramps. Reach ranges are not appropriate for play components reached by transfer systems. Appropriate reach range heights will vary depending on how the play component is accessed. This interactive panel (right) is mounted at a height appropriate for a child who uses a wheelchair.

The reach ranges in this guide are recommendations that should be considered when designing play components with manipulative features intended for use by individuals who use wheelchairs.

---

---

Frequently Asked Questions

This document answers frequently asked questions concerning requirements for accessible play areas in standards issued under the Americans with Disabilities Act (ADA) and the Architectural Barriers Act (ABA). The ADA Standards, as issued by the Department of Justice and the Department of Transportation, apply to places of public accommodation, commercial facilities, and state and local government facilities, including transportation facilities. The ABA Standards, which are very similar to the ADA Standards, apply to facilities designed, built, altered, or leased with federal funds.

1. What is considered an “accessible” play component?

Section 240 of the ADA Standards (F240 in the ABA Standards) establishes the scoping requirements for “accessible” play components. An “accessible” play component is one that is located on an accessible route and meets the technical provisions of Section 1008.4. Remember, the standards are only minimums. There are additional designs and features that can be added to further enhance accessibility.

2. Are play components that have multiple stations or which can include more than one person using them at one time considered one or two play components?

Play components such as a fire truck or other play vehicles, a playhouse, train, or a storefront that have multiple stations or can include more than one person using them at one time are considered one play component. If required to be accessible, a play component must be on an accessible route, have clear floor or ground space and maneuvering space, and have entry points and seats at the required heights if they are ground level play components or elevated play components accessed by ramp.

3. Are ramps, transfer systems, and stairs permitted to be counted as play components?

No. The Standards do not permit steps, ramps, transfer systems, decks, or roofs to be counted as play components.

4. Is a talk tube where two children talk to each other simultaneously considered one or two play components? If one end of the talk tube is at ground level and the other is on an elevated deck, is it considered a ground level or elevated play component?

Generally, a talk tube is considered one play component. A talk tube with one end located at ground level and another on an elevated deck or platform would be considered an elevated play component. If both ends were located at ground level, it would be considered a ground level play component.

5. Where multiple swings in a swing bay are provided, Section 240.2.1.1 (one of each type) requires one swing to be located on an accessible route. If an accessible route is provided to more than one swing, can each swing be counted as an accessible ground level play component? If one is an infant seat and another a sling seat, are those considered two different types?

Swing bays that provide an accessible route, clear floor or ground space, maneuvering space, and the seat at a height between 11 to 24 inches to more than one swing, can count each swing as an accessible ground level play component. However, they are considered only one type of play component. An infant seat and a sling seat are not considered two different types. Designers and play area operators may choose to provide these different types of swing seats to provide additional play opportunities to children of different ages, but the type is the same.

6. Should overhead play components such as track riders, ring ladders, monkey bars, and chin up bars be lowered to the recommended reach ranges?

Overhead play components that are required to have their entry and exit points connected by an accessible route are not required to be lowered to be considered accessible. It is recommended that, where possible, providing one component or element of a component at a lower height, or multiple overhead components at varied heights, would better accommodate more children, especially those with disabilities.

7. Can an elevated crawl tube be used to connect to a play component required to be accessible? Can that crawl tube also be considered an accessible play component?

Yes, where transfer access is provided on a composite play structure elevated play components such as a crawl tube are permitted to connect to other play components. The crawl tube may also be considered an accessible play component.

8. When ramp access is provided to one side of a crawl tube and the other side is only entered by transfer access, how is it counted (ramp or transfer access play component)?

A crawl tube that provides ramp access to one end and transfer access to the other end can be counted either as an accessible play component reached by ramp access or transfer access, but cannot be counted as both.

9. Can a transfer platform be an irregular shape as long as it incorporates the minimum rectangle of 14 by 24 inches?

Yes. While permitted, providing odd shaped or textured transfer platforms may decrease the usability by some persons with disabilities. It is recommended that the clear edge provided for transfer be a straight edge. The 24 inch side of the transfer platform must be free from obstructions to allow a person to transfer.

10. When a composite play structure provides more than 20 elevated play components and ramp access to at least 25% of the elevated play components is provided, do the elevated play components need to be of different types as well?

No. The Standards do not require accessible elevated play components to be of different types regardless of the method of access provided (ramp or transfer). At least 50% of the elevated play components must be accessible. Providing diversity of types among the elevated play components is recommended and is likely to occur given the number of play components that are required to be accessible.

11. If ramp access is provided to at least 50% of elevated play components and 3 different types of elevated play components can be accessed by a ramp, do any additional ground level accessible play components need to be provided?

No. The exception to Section 240.2.1.2 only exempts play areas from having to comply with Table 240.2.1.2 (Number and Types of Ground Level Play Components Required to be on an Accessible Route). The requirements of 240.2.1.1 would apply to any ground level play components otherwise provided. This requires a minimum of one of each type of ground level play components provided to be accessible.

12. Do the provisions for openings in floor and ground surfaces in Section 302.3 apply to walking surfaces in play areas?

Yes. Section 302.3 applies to accessible routes that connect to ground level play components and that provide ramp access to elevated play components. Section 302.3 requires gratings or openings located along walking surfaces to have openings or spaces no greater than ½ inch wide. If gratings or openings have elongated openings, they must be placed so the long dimension is perpendicular to the dominant direction of travel. This applies to elevated platforms and decks on composite play structures where ramp access is provided on the structure. Decking or platform surfaces that are part of a transfer system connecting accessible elevated play components are not required to comply with Section 302.3.

13. If an alteration is being made to part of a play area, does the entire play area need to be upgraded with accessible components and surfacing?

Generally only those areas that are being altered must comply with the Standards, unless “path of travel” obligations are triggered. See question 15 for more on “path of travel.”

14. When are “path of travel” obligations triggered?

Section 202.4 requires that if alterations are made to areas containing a primary function, an accessible “path of travel” must be provided to the altered area unless it is “disproportionate” to the overall alterations in terms of cost and scope as determined under criteria established by the Department of Justice. An accessible “path of travel” is a continuous route connecting the altered areas to an entrance and other elements (i.e., toilet rooms, drinking fountains, and public telephones) that serve the altered area. For example, an alteration is planned for a portion of an existing composite play structure. Alterations to any play components or structures in the play area would be considered a “primary function” since “play” is the primary function of the area. In this example, the “path of travel” obligation requires an accessible route to be provided from an exterior approach (e.g., sidewalks, street, parking area) to the portion of the composite play structure being altered, unless the cost is “disproportionate” to the overall alterations in terms of cost and scope.

Under the Department of Justice rules (28 C.F.R. 36.403), the cost of providing an accessible “path of travel” to the altered area is considered “disproportionate” when the cost exceeds 20% of the costs of the overall alterations. When the cost of providing an accessible “path of travel” is “disproportionate,” the “path of travel” must be made accessible to the extent that it can be done without incurring “disproportionate” costs. If a primary function area is altered without providing an accessible “path of travel” due to “disproportionate” costs and additional alterations are made to the play area within three years of the original alteration, the total cost of the alterations to the play area during the preceding three year period are considered in determining whether the cost of making the “path of travel” accessible is “disproportionate”. Specific questions about “path of travel” obligations should be directed to the Department of Justice.

Not all alterations to a site that contains a play area would trigger “path of travel” obligations. Alterations to a toilet room or a drinking fountain located on a site that includes a play area would not trigger the “path of travel” obligations. In this case, the toilet room and drinking fountain are not considered primary function areas.

15. If a play surface is replaced with an accessible surface and the existing ground level play components are not accessible, do the components need to be replaced?

No. The rule of thumb is–that what you touch must be brought into compliance. If the alteration to the play area only involves the surfacing, only the surface along accessible routes, clear floor or ground spaces, and maneuvering spaces must comply with the ASTM F 1951-99 (wheelchair maneuverability) standard. Where the surface is within the “use zone” defined by the ASTM F 1487-98 (safety) standard, the surface must also meet the ASTM F 1292-99 (impact attenuation) standard. In this case, existing ground level play components are not required to meet the technical provisions of Section 1008.4.

16. Can broken or older ground level play components be replaced without changing the surface?

Yes. Section 240.1 Exception 4 permits broken or older play components to be replaced without requiring changes to the play surface. Changes to the surface are only required when the existing play surface is being replaced or when “path of travel” obligations are triggered. See question 15 for more on “path of travel”.

17. Where an existing ground level play component is replaced, should the new component comply with the technical provisions of Section 1008.4 even if there is not an accessible route to it?

Yes. Unless the required number of accessible ground level play components are provided, the new play component would be required to be accessible. For example, a spring rocker is replaced and no other spring rockers are accessible. In this case, the spring rocker being replaced would need to have the rocker seat height between 11 and 24 inches and clear floor or ground space and maneuvering space provided adjacent to the spring rocker. An accessible route to the replaced play components may be triggered under “path of travel” obligations. See question 14 for more on “path of travel”.

18. Are new play components added to an existing play area required to comply with the Standards even if there is not an accessible route from parking or the street to the play area?

Yes. Where new play components are added to an existing play area, the new play components are required to comply with the Standards. It is anticipated that many play areas will be updated and altered in phases. Through the series of alterations, additional access to the total play area and accessible routes from parking or the street will be added.

19. Does topping off a play surface trigger its replacement with an accessible surface?

No. Topping off a surface is routine maintenance and does not trigger replacement of the existing play surface with an accessible surface. Changing the surface type or replacement of the surface would require an accessible surface along accessible routes located within the boundary of the play area, including the entry and exit points of the ground level play components required to be accessible, as well as at clear floor or ground spaces and maneuvering spaces.

20. Are play areas on military bases subject to the “standards”?

Yes. Most facilities constructed on military bases are covered by the ABA Standards. The ABA Standards include scoping and technical provisions for play areas, including those provided on military bases.

21. How can I get copies of the ASTM standards that apply to play areas?

Copies of the following referenced standards may be obtained from the American Society for Testing and Materials, 100 Bar Harbor Drive, West Conshohocken, Pennsylvania 19428, www.astm.org:

• ASTM F 1292-99 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment
• ASTM F 1292-04 Standard Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment
• ASTM F 1487-01 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use
• ASTM F 1951-99 Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment

---

Provision Index

These tables highlight the sections of the ADA and ABA Accessibility Standards discussed in the play areas guide.

* The guide uses the term ADAAG (Americans with Disabilities Act Accessibility Guidelines) as the basis of the requirements discussed. The recreational provisions of these guidelines were adopted into the 2010 ADA Standards without changes, so the ADAAG section numbers correspond to the same section numbers in the ADA Standards (as well as the Architectural Barriers Act (ABA) Accessibility Standards).

Definitions

	ADA Standards*	ABA Standards
Definitions	106.5	F106.5
Addition	106.5	F106.5
Alteration	106.5	F106.5
Cross Slope	106.5	F106.5
Curb Ramp	106.5	F106.5
Elevated Play Component	106.5	F106.5
Facility	106.5	F106.5
Ground Level Play Component	106.5	F106.5
Play Area	106.5	F106.5
Play Component	106.5	F106.5
Ramp	106.5	F106.5
Running Slope	106.5	F106.5
Soft Contained Play Structure	106.5	F106.5
Use Zone (see also referenced standards below)	106.5	F106.5

Play Areas (where provided) - Additions

	ADA Standards*	ABA Standards
Play Areas (where provided)	240	F240
Additions	202.2 & 240.1.1	F202.2 & F240.1.1
Elevated Play Components	240.2.2	F240.2.2
Ground Level Play Components	240.2.1	F240.2.1
Additional Number and Types of Ground Level	240.2.1.2	F240.2.1.2
Minimum Number and Types of Ground Level	240.2.1.1	F240.2.1.1

Play Areas (where provided) - Exceptions

	ADA Standards*	ABA Standards
Exceptions	240.1	F240.1
EX 1 - family child care facilities	240.1 EX 1	F240.1 EX 1
EX 2 - existing play areas	240.1 EX 2	F240.1 EX 2
EX 3 - amusement attractions	240.1 EX 3	F240.1 EX 3
EX 4 - alterations	240.1 EX 4	F240.1 EX 4

Play Areas (where provided) - Exceptions

	ADA Standards*	ABA Standards
Accessible Routes (where required)	206	F206
Play Areas (specific provision)	206.2.17	F206.2.17
Soft Contained Play Structures (specific provision)	206.2.17.2	F206.2.17.2
Transfer System for Play Areas (exceptions)	1008.2.1 EXs	1008.2.1 EXs
Transfer System for Soft Contained (exception)	1008.2.2 EX	1008.2.2 EX
Platform Lift (new construction use)	206.7.8	F206.7.8

Accessible Routes Compontents (typically used)

	ADA Standards*	ABA Standards
Curb Ramps	406	406
Doors and Gates	404	404
Ramps	405	405
Ramps (slope exception)	1002.2 EX 1	1002.2 EX 1
Walking Surfaces with Running Slopes of 5% or less	403	403
Modifications to Accessible Routes	1008.2	1008.2
Clear Width Modifications	1008.2.4	1008.2.4
Ground Surfaces Modifications (see referenced stands.)	1008.2.6	1008.2.6
Ramp Modifications	1008.2.5	1008.2.5
Elevated Components to Elev. Components (exception)	1008.2.1 EX2	1008.2.1 EX2
Transfer Systems	1008.3	1008.3
Water Play Components (exceptions)	1008.2.3 EXs	1008.2.3 EXs

Technical Requirements for Accessible Play Components

	ADA Standards*	ABA Standards
Technical Requirements for Accessible Play Components	1008.4	1008.4
Clear Floor or Ground Space	1008.4.2	1008.4.2
Entry Points and Seats	1008.4.4	1008.4.4
Play Tables	1008.4.3	1008.4.3
Transfer Supports	1008.4.5	1008.4.5
Turning Space	1008.4.1	1008.4.1

Other Typical Scoping Requirements at Play Areas

	ADA Standards*	ABA Standards
Parking	208	F208
Signage	216	F216
Toilet and Bathing	213	F213

Other Exceptions

	ADA Standards*	ABA Standards
Protruding Objects	204.1 EX 2	F204.1 EX 2

Reference Standards

	ADA Standards*	ABA Standards
Reference Standards	105.2.3	F105.2.3

• ASTM F 1292-99 Standard Specification for Impact Attenuation of Surface Systems Under and Around Playground Equipment (see 1008.2.6.2)
• ASTM F 1292-04 Standard Specification for Impact Attenuation of Surfacing Materials Within the Use Zone of Playground Equipment (see 1008.2.6.2)
• ASTM F 1487-01 Standard Consumer Safety Performance Specification for Playground Equipment for Public Use (see 106.5 or F106.5 for “Use Zone”, and 1008.2.6.2).
• ASTM F 1951-99 Standard Specification for Determination of Accessibility of Surface Systems Under and Around Playground Equipment (see 1008.2.6.1).