Rules and



Department of Children and Family Services


Index No: 99-13


Issuance Date: April 21, 1999


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, Utilization of Alternative Materials in a Sand Box


Approved by:




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(l)(10): Sand boxes, if smaller than 100 square feet, shall be covered when not in use. Larger sand play areas shall be covered, or there shall be a written plan for the daily raking and cleaning of animal fecal matter, if present.


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.


Question:        Can alternative materials such as beans, macaroni, etc. be used in sand boxes?


Discussion:     Subsection 407.380(d) indicates that objects in areas where infants and toddlers play or sleep shall not be less than 1 1/4 inches in diameter. Such objects as beans and uncooked macaroni that may be utilized in a sandbox as an alternative to sand are smaller in diameter and may cause more of a choking hazard to infants and toddlers than sand. Sand box play is not recommended for infants and only for toddlers when closely supervised to prevent throwing or eating of the sand.


89 IAC 407, Licensing Standards for Day Care Centers is silent on measurements of objects for any child older than an infant or toddler. 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, alternative materials in a sand box do not pose more of a risk to a preschool child than sand.


Alternative items that are used in place of sand in a sand box shall be covered and cleaned in the same fashion as sand (see subsection 407.390(l)(10)). Food items such as beans, corn meal and macaroni that are substituted for sand shall only be used to fill indoor sand boxes to prevent deterioration from poor weather and shall be changed on at least a weekly basis or more often if needed to prevent drawing of insects and other pests.


Response:      Dried beans, macaroni and other small articles (under 1 1/4 inches in diameter) shall not be used in the sand box for infants and toddlers. Substituting materials in a sand box for preschool age children can be approved provided subsection 407.390(1)(10) (cleaning of the sand box), subsection 407.390(h) and subsection 407.200(i) (supervision of the children) are followed.