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Rubber Mulch Safety And Fall Zone
Specifications
Playgrounds can be a source of great happiness and joy for children. However, they can also be a
source of injury. To minimize injuries from trips and falls, especially falls from equipment, playgrounds
are being equipped with shock absorbing surfaces under and around equipment. While various materials
provide shock protection, some of the most protective surfaces are being provided by scrap rubber derived
materials. There have been questions or concerns raised about tire derived materials being used for
playground cover. This Briefing Sheet is intended to provide answers to these questions. The information
provided below is taken from a variety of sources, including State & Federal agencies, laboratories contracted
by State agencies, research hospitals, licensed testing companies and rubber manufacturers. Two types of rubber playground surfacing material are on the market today: loose fill and solid mats. Loose
fill generally consists of chips of rubber ranging from one half inch to three quarters inch in size. All non-rubber
materials are removed, and the chips are washed before being placed on the play ground. Rubber, does not
contain asbestos nor fiberglass as reinforcement fibers. Safety Value of Scrap Rubber Material as a Playground Cover: According to the Mayo Clinic (Mayo Health O@sis, May, 1998), about 70 percent of playground injuries are a
result of falls. The Consumers Product Safety Commission recommends that "hard surfacing materials, such
as asphalt or concrete, are unsuitable for use under and around playground equipment of any height unless
they are required as a base of for a shock absorbing unitary material such as a rubber mat." (CPSC document
1005). The CPSC defines unitary materials as "...generally rubber mats or a combination of rubber-like
materials held in place by a binder that may be pour in place at the playground site and cures to form a
unitary shock absorbing surface." (CPSC document 1005). Shock Attenuation: The Mayo Clinic recommendation is to use playground mating/flooring that "gives", such as rubber. The
State of Illinois conducted a direct comparison between scrap tire rubber and other loose fill playground
surfacing materials at a depth of six inches. It is reported that wire-free scrap tire chips have roughly twice
the cushioning effect of other material. (Report to the Illinois Department of Commerce and Community
Affairs, January 1994). Critical Heights for a 6 Inch Uncompressed Layer* Wood Mulch 5 feet Fine Sand 5 feet Medium Gravel 7 feet Rubber Chips 12 feet Rubber shreds/chip data from the Illinois Department of Energy & Natural Resources. Measured in
accordance with ASTM F12-93 and ASTM F355-86. Data on other materials from U.S. Consumer
Product Safety Commission, CPSC Document 1005. *According to the testing criteria, the higher the height, the safer the material. Flammability: Rubber chips were tested in 1995 in accordance with the Federal Hazardous Substance Act (16 CFR 1500.44)
to determine whether this material would be considered "flammable" (a material is considered flammable
if it ignites and burns with a self-sustained flame at a rate greater than 0.1 inches per second along its major
axis). From the test results it was concluded that scrap rubber material is considered non-flammable. Other Advantages of Wire-Free Scrap Rubber Chips: Clean and non-toxic Does not produce toxic leachate Resilient Does not attract or maintain moisture Economical, lasts for years Reduces dust and mud around playing area Does not attract cats, dogs, rodents or insects Will not rot or decay Not susceptible to reduced performance due to rainy weather or freezing temperatures What if a Child Swallows a Rubber Chip? In 1994 the Maryland Environmental Services (MES) put this question to a series of tests. At the MES
request, a testing laboratory subjected 3/4 inch pieces of rubber chips to hydrochloric acid (stomach
acid). "Visual examination of insoluble residue appeared to indicate only fibrous reinforcing strands
were dissolved by the hydrochloric acid. The tire rubber did not appear to be affected in any way; i.e.
chalking, cracking, spauling, fracturing, etc." (PSI report No. 486-40013-001). What does this mean? If a
piece of rubber is swallowed, it should not cause any acute or chronic problems. Short-term issues,
such as an upset stomach will be a function of the amount of rubber swallowed. As to the fate of the
rubber chips swallowed, they are eventually evacuated from the body, just like any other non-digestible
material. Additional Information: For further information on playground safety, contact the Consumers Product Safety Commission,
Washington. DC 20207; http://www.cpsc.gov. We suggest obtaining their publication on Playground
Surfacing Materials, CPSC Document #1005. The STMC is not-for-profit, advocacy organization, founded
and supported by the United States based rubber manufacturers. The Council is part of the Rubber
Manufacturers Association, the trade association representing the United States rubber industry.
The Council’s primary function is to assist in the promotion and development of environmental sound
and cost efficient markets for the scrap rubber generated in the United States.
Playground Installation
Specifications
Proper Playground Equipment
Placement
The use zone for each piece of equipment is made up of two
parts:
- The Fall Zone: an area under and around the equipment
where protective surfacing is required, and,
- The No-Encroachment Zone: an additional area beyond the fall
zone where children using the equipment can be expected to
move about and should have no encroaching obstacles.
With the exception of spring rocking equipment, equipment under
24 inches in height, and the zone between adjacent swings (see
below), the fall zones of adjacent pieces of equipment should
not overlap. However, adjacent pieces of equipment may share a
single no-encroachment zone.
Regardless of the type of equipment, the use zone should be free
of obstacles that children could run into or fall on top of and
thus be injured. For example, there should not be any vertical
posts or other objects protruding from the ground onto which a
child may fall.
Recommendations for Fall Zone
Stationary Equipment
The fall zone should extend a minimum of 6 feet in all
directions from the perimeter of the equipment.
Slides
The fall zone in front of the access and to the sides of a slide
shall extend a minimum of 6 feet from the perimeter of the
equipment. Note: This does not apply to embankment slides.
The fall zone in front of the exit of a slide shall extend a
minimum distance of 6 feet from the end of the slide chute or
for a distance of H + 4 feet whichever is the greater. H is the
height of the slide platform and the H + 4 foot measurement is
made from a point on the slide chute where the gradient has been
reduced to 5o from the horizontal (see Figure 16).

Shaded Area Denotes Fall Zone with Protective Surfacing

Figure 16 Fall Zone for Slides
Single Axis Swings
Because children may deliberately attempt to exit from a single
axis swing while it is in motion, the fall zone in front of and
behind the swing should be greater than to the sides of such a
swing. It is recommended that the fall zone extend to the front
and rear of a single axis swing a minimum distance of 2 times
the height of the pivot point above the surfacing material
measured from a point directly beneath the pivot on the
supporting structure (see Figure 17). The fall zone to the sides
of a single axis swing should follow the general recommendation
and extend a minimum of 6 feet from the perimeter of the swing
structure in accordance with the general recommendation for fall
zones. This 6 foot zone may overlap that of an adjacent swing
structure.

Shaded Area Denotes Fall Zone with Protective Surfacing

Figure 17 Fall Zone for Single Axis Swings
Multi Axis Swings
The fall zone should extend in any direction from a point
directly beneath the pivot point for a minimum distance of 6
feet + the length of the suspending members (see Figure 18). In
addition, the fall zone shall extend a minimum of 6 feet from
the perimeter of the supporting structure. This 6 foot zone may
overlap that of an adjacent swing structure.
Merry-Go-Rounds
The fall zone should extend 6 feet beyond the perimeter of the
platform.
Spring Rocking Equipment
The fall zone should extend a minimum of 6 feet from the
"at rest" perimeter of the equipment but adjacent
spring rockers with a maximum seat height of 24 inches may share
the same fall zone.
Composite Equipment
The above recommendations for individual pieces of equipment
should be used as a guide in establishing the fall zones around
pieces of composite playground equipment. Note that in Section
9.2.2 it was recommended that single axis swings not be a part
of a composite structure.

Shaded Area Denotes Fall Zone with Protective

Figure 18 Fall Zone for Multi Axis Tire Swings
Recommendations for No-Encroachment Zone
No specific dimensions can be recommended for the noencroachment
zone around individual pieces of playground equipment. These
dimensions will vary according to the types of adjacent pieces
of equipment and their orientation with respect to one another.
For example, the recommended fall zone at the side of both a
slide and a swing is 6 feet. Since fall zones should not overlap
(with the exception of certain adjacent spring rockers), a slide
could be placed with its side no closer than 12 feet to the side
of a swing. Therefore, there may be no need to add an additional
no-encroachment zone. Conversely, it would not be desirable to
have a slide exit facing the front or rear of single axis swing.
No-encroachment zones extending beyond the fall zones are
recommended for moving equipment or equipment from which the
child is in motion as he or she exits. This allows more space
for children to regain their balance upon exiting the equipment
and also provides added protection against other children
running into a moving part.
For a single axis swing, it is recommended that there be a
barrier beyond the fall zone in front of the swing if it is
located in a playground facing other pieces of equipment.
Information Source:
http://www.cpsc.gov/cpscpub/pubs/327.html
visit the CPSC site at this link for more information.
This article is a excerpt from the "Handbook for Public
Playground Safety", Pub. No. 325
U.S. Consumer Product Safety Commission, Washington, DC 20207.
Toxicity
Rubber mulch is considered
non-toxic. MSDS Sheets for key
components available upon request.
Based on Toxicity Characteristic Leaching Procedure (TCLP) conducted on
scrap tire chips (method 1311 of USEPA), the following trace metal elements were
determined to be significantly lower than regulatory threshold limits:
Arsenic (As), Cadmium (Cd), Chromium (Cr), Lead (Lb), Selenium (Sc), and
Silver (Ag). Source:
Criteria of Selecting Toxicity Characteristic Leaching Procedure (TCLP)
and Synthetic Precipitation Leaching Procedure (SPLP) Tests to Characterize
Special Wastes, Dr. Chih-Shin Shieh, Florida Institute of Technology,
June 30, 2001
.Oral ingestion is deemed to be low in overall hazard because ingestion of tire
crumb on the ground is not likely, and the gastrointestinal tract is unlikely to
be efficient in extracting toxic chemicals from tire crumb.
Tire crumb does not contain chemicals with high vapor pressures; thus,
exposure via inhalation is deemed inconsequential and the resulting hazard
negligible. Dermal exposure is
deemed to be unlikely and therefore to present low overall hazard.
A carrier solvent more efficient than water would be needed to extract
toxic chemicals from tire crumb in quantity, and a suitable non-polar vehicle
would be required to penetrate protective skin layers for significant
absorption. This was deemed
implausible in a playground situation. Cancer
hazard as measured by relevant in vitro predictive assays, was deemed negative.
Ingestion of small amounts of tire crumb by small children will not
result in an unacceptable hazard of contracting cancer.
Source: Toxicological
Evaluation for the Hazard Assessment of Tire Crumb for Use in Public
Playgrounds, Journal of the Air & Waste Management Association, 2003.In 1994
the Maryland Environmental Services (MES) sent 3/4 inch pieces of tire chips to
a testing laboratory to be tested with hydrochloric acid (stomach acid).
"Visual examination of insoluble residue appeared to indicate only fibrous
reinforcing strands were dissolved by the hydrochloric acid.
The tire rubber did not appear to be affected in any way; i.e. chalking,
cracking, spauling, fracturing, etc." (PSI report No. 486-40013-001).
Therefore, if a piece of rubber is swallowed, it should not cause any
acute or chronic problems. Short-term issues, such as an upset stomach will be a
function of the amount of rubber swallowed. As to the fate of the rubber chips
swallowed, they are eventually evacuated from the body, just like any other
non-digestible material. Source:
RubberManufacturers Association www.rma.org/scrap_tires/scrap_tire_markets/playgrounduse.cfm
D. Leaching:A number of
studies have been done to determine the potential for leaching from recycled
scrap tires and recycled tire products. Increased levels of zinc and iron were
found in soil tilled with raw crumb rubber particles (1/4” and less) when
tested annually for 4 years. The
amounts detected were below levels of concern and posed no hazards to water
quality. Additionally no toxicity to
turf grass was observed in these studies. Source:
Top Dressing with Crumb Rubber on Athletic Fields, Dr. J.N. Rogers, III
and J.T. Vanini, Department of Crop and Soil Sciences,
Michigan
State
University
, 1994.Zinc that had leached from scrap tires was determined not to pose any
potential harm to the environment. Source:
Identification of Tire Leachate Toxicants and A Risk Assessment of Water
Quality Effects Using Tire Reefs in Canals, Bulletin of Environmental
Contamination and Toxicology, 578-581, Environmental Canada, 1994.Some volatile
and semi-volatile organic compounds were identified in scrap tire leachates
using the TCLP test. Reported levels
are far below regulatory limits:
Reported Value ug/L
Regulatory Limit ug/L
Carbon disulfide
67
14,400
Methyl ethyl ketone
21
7,200
Toluene
190
14,000
Phenol
46
14,400
Source:
A Report on the Use of Shredded Scrap Tires in On-Site Sewage Disposal
Systems, Department of Environmental Conservation, State of Vermont,
Brattleboro, VT, Envirologic, Inc. 1990.Chemicals leaching from relative fresh
tire crumb may present a moderate toxic threat to aquatic species if the runoff
is not diluted. However, this toxic
activity is quickly degraded by natural processes, presumably by conversion of
the chemicals responsible to nontoxic products.
Conditions likely to produce runoff, such as rain and snowmelt, are also
likely to dilute the runoff in receiving sewers, bodies of water, and
groundwater by considerable volumes. Given
that undiluted runoff is not likely and that 3 months is an outside estimate of
the duration of toxicity, it is doubtful that tire crumb would present a
significant risk of contamination in receiving surface waters or groundwater.
Source: Toxicological
Evaluation for the Hazard Assessment of Tire Crumb for Use in Public
Playgrounds, Journal of the Air & Waste ManagementAssociation, 2003.
E.
Flammability:
Scrap tire material is
considered non-flammable based on test results from 1995 in accordance with the
Federal Hazardous Substance Act (16 CFR 1500.44). A
material is considered flammable if it ignites and burns with a self sustaining
flame greater than 0.1 inches per second along its major axis.
F.
Colorfastness:
Colorfastness of product has
been tested under extreme circumstances and is considered by manufacturer to be
fade resistant.
G. Safety Ratings:
Rubber Bark complies with
ASTM F1292-99 as was tested by Northwest Laboratories of Seattle, Incorporated
–
May 26, 2004
Product
Install Depth
Critical Fall Height
Rubber
Mulch
4” (Four inches)
9’ (Nine feet)
With proper installation and
maintenance, Rubber mulch will reduce fall injuries in playgrounds.
However, PRM Enterprises, LLC and any of its affiliates or subsidiaries
make no warranty of the safety and colorfastness of this product.
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