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 (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 only exempts play areas from having to comply with Table (Number and Types of Ground Level Play Components Required to be on an Accessible Route). The requirements of 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,