OCFP

Office

of

Rules and

Procedures

 

Department of Children and Family Services

 

Index No: 2000.08

 

Issuance Date:  June 20, 2000

 

Origin of Request: Central Office of Licensing

 

Distribution: Licensing Staff, Administrative Staff (A,L,P)

 

Key Words: 89 IAC 407, Licensing Standards for Day Care Centers, Protective Surfaces on Playgrounds

 

Approved by:

 

Interpretation

 

Question:                    May infant and toddler outdoor play areas use wood chips, gravel, or sand as ground cover or as a protective surface under equipment?

 

Applicable To:            Licensed Day Care Centers 

 

Policy Citation:           407.380(a): Equipment and materials for both indoor and outdoor use shall be appropriate to the age and developmental needs of the children served.

 

407.380(d): Play materials shall be durable and free from hazardous characteristics, including sharp or rough edges and toxic paint. In areas where infants and toddlers play or sleep, there shall be no objects that are less than 1 1/4 inches in diameter or that have removable parts of this size.

 

407.390(h): The outdoor play area shall be arranged so that all areas are visible to staff at all times.

 

407.390(i): Protective surfaces (wood mulch, bark mulch, wood chips, sand, gravel, rubber mats, etc.) shall be provided in areas where climbing, sliding, swinging or other equipment from which a child might fall is located.

 

1)         The protective surface shall extend at least six feet beyond the perimeter of the equipment, except for swings.

 

2)         The protective surface shall have a Critical Height value of at least the height of the highest accessible part of the equipment, unless rubber mats are used which have been manufactured specifically for this purpose and which comply with the requirements established by the Consumer Products Safety Commission or the American Society for Testing Materials.  See Appendix H for Critical Height values.

 

3)         The surface material shall be properly drained to prevent the growth of molds and bacteria.

 

4)         When resilient materials become packed, they shall be raked and/or turned to restore resilience.

 

407.390(l)(11): Areas for sand play shall be distinct from the landing areas surrounding slides and other equipment.

 

407.200(i): Activity areas, equipment and materials shall be arranged so that staff can be easily aware of the child’s presence and activity at all times.

 

407.200(m): Each child shall have access to the full variety of age-appropriate equipment on a daily basis.

 


Discussion:     Subsection 407.380(d) indicates that objects in areas where infants and toddlers play or sleep shall not be less than 1¼ inches in diameter. Wood chips and mulch may have sharp and rough edges and are frequently less that 1¼ inches in diameter.    

 

Subsection 407.390(h) and subsection 407.200(i) require that activity areas and outdoor play areas shall be arranged for staff visibility at all times. With close supervision of children’s play, materials such as wood chips, mulch, gravel, and sand do not pose a great risk when used as a protective surface.  The small risk that these materials pose is greatly outweighed by their shock absorbing benefits when used as a protective covering in areas where children are likely to fall. 

 

Response:      Infant and toddler outdoor play areas may use wood chips, gravel, or sand as ground cover or as a protective surface in areas where climbing, sliding, swinging or other equipment from which a child might fall is located as provided for in 407.390(i).