SIST-TP CEN/TR 17842-2:2024

SLOVENSKI STANDARD
01-december-2024
Oprema otroških igrišč - 2. del: Odgovori na zahteve za razlago standarda EN
1176:2017 in njegovih delov (2020 - 2022)
Playground equipment for children ­ Part 2: Replies to requests for interpretation of EN
1176:2017 and its parts (2020 ­­ 2022)
Kinderspielplatzgeräte ­ Teil 2: Antworten zu Interpretationsanfragen der Jahre 2020 ­­
2022 zur EN 1176:2017 und deren Teilen
Équipements d'aires de jeux pour enfants ­ Partie 2: Réponses aux demandes
d'interprétation de l'EN 1176:2017 et de ses parties (2020 ­ ­2022)
Ta slovenski standard je istoveten z: CEN/TR 17842-2:2024
ICS:
97.200.40 Igrišča Playgrounds
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

CEN/TR 17842-2
TECHNICAL REPORT
RAPPORT TECHNIQUE
September 2024
TECHNISCHER REPORT
ICS 97.200.40
English Version
Playground equipment for children - Part 2: Replies to
requests for interpretation of EN 1176:2017 and its parts
(2020 - 2022)
Équipements d'aires de jeux pour enfants - Partie 2: Kinderspielplatzgeräte - Teil 2: Antworten zu
Réponses aux demandes d'interprétation de l'EN Interpretationsanfragen der Jahre 2020 - 2022 zur EN
1176:2017 et de ses parties (2020 - 2022) 1176:2017 und deren Teilen

This Technical Report was approved by CEN on 19 August 2024. It has been drawn up by the Technical Committee CEN/TC 136.

CEN members are the national standards bodies of Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Norway,
Poland, Portugal, Republic of North Macedonia, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, Switzerland, Türkiye and
United Kingdom.
EUROPEAN COMMITTEE FOR STANDARDIZATION
COMITÉ EUROPÉEN DE NORMALISATION

EUROPÄISCHES KOMITEE FÜR NORMUNG

CEN-CENELEC Management Centre: Rue de la Science 23, B-1040 Brussels
© 2024 CEN All rights of exploitation in any form and by any means reserved Ref. No. CEN/TR 17842-2:2024 E
worldwide for CEN national Members.

Contents Page
European foreword . 5
Introduction . 6
1 Scope . 8
2 Normative references . 8
3 Terms and definitions . 8
4 EN 1176-1:2017+A1:2023, Playground equipment and surfacing — Part 1: General
safety requirements and test methods . 8
4.1 Interpretation request 2022-05 – Finland: 4.2.4.3 Guardrails . 8
4.1.1 Member body question . 8
4.1.2 Member body proposal . 9
4.1.3 Interpretation Panel . 9
4.1.4 Comments/proposal for an answer . 9
4.2 Interpretation request 2021-02 – Sweden: 4.2.7.2 b) – Entrapment, partially bound
test probe . 9
4.2.1 Member body question . 9
4.2.2 Member body proposal . 10
4.2.3 Interpretation Panel . 10
4.2.4 Comments/proposal for an answer . 10
4.3 Interpretation request 2022-02 – Sweden: 4.2.7.2 b) – Entrapment, partially bound
test probe . 10
4.3.1 Member body question . 10
4.3.2 Member body proposal . 11
4.3.3 Interpretation Panel . 11
4.3.4 Comments/proposal for an answer . 11
4.4 Interpretation request 2021-01 – Sweden: 4.2.8.2.4, Table 4 – Bark, woodchip,
particle size . 11
4.4.1 Member body question . 11
4.4.2 Questions: . 11
4.4.3 Member body proposal . 12
4.4.4 Interpretation Panel . 12
4.4.5 Comments/proposal for an answer . 12
4.5 Interpretation request 2020-09 – Netherlands: EN 1176-1 – 4.2.8.2.4 and EN 1176-2
– 4.10.2.2 – Width, Impact area, Group swing seat . 14
4.5.1 Member body question . 14
4.5.2 Member body proposal . 14
4.5.3 Interpretation Panel . 16
4.5.4 Comments/proposal for an answer . 16
4.6 Interpretation request 2022-04 – Finland: 4.2.8.4 Protection against injuries in the
falling space . 16
4.6.1 Member body question . 16
4.6.2 Member body proposal . 16
4.6.3 Interpretation Panel . 16
4.6.4 Comments/proposal for an answer . 16
4.7 Interpretation request 2020-14 – Finland: 4.2.8.5.4 . 17
4.7.1 Member body question . 17
4.7.2 Member body proposal . 18
4.7.3 Interpretation Panel . 18
4.7.4 Comments/proposal for an answer . 18
4.8 Interpretation request 2020-01 – Norway: 4.2.12.2 – Sand cranes, ropes fixed at both
ends. 18
4.8.1 Member body question . 18
4.8.2 Member body proposal . 20
4.8.3 Interpretation Panel . 20
4.8.4 Comments/proposal for an answer . 20
4.9 Interpretation request 2020-06 – Denmark: A.2.6.1, a) and b) – Definition of
“traditional” and “gondola” . 20
4.9.1 Member body question . 20
4.9.2 Member body proposal . 20
4.9.3 Interpretation Panel . 20
4.9.4 Comments/proposal for an answer . 21
4.10 Interpretation request 2020-07 – Lithuania: Annex H confirming the adequate level
of impact attenuation after installation of impact attenuating surfacing . 21
4.10.1 Member body question . 21
4.10.2 Member body proposal . 21
4.10.3 Interpretation Panel . 21
4.10.4 Comments/proposal for an answer . 21
5 EN 1176-2:2017+AC:2019, Playground equipment and surfacing — Part 2:
Additional specific safety requirements and test methods for swings . 23
5.1 Interpretation request 2020-02 – Netherlands: 4.5, 4.6.3 and Annex B – Parent-child
swing . 23
5.1.1 Member body question . 23
5.1.2 Member body proposal . 23
5.1.3 Interpretation Panel . 25
5.1.4 Comments/proposal for an answer . 26
5.2 Interpretation request 2020-05 – Denmark: 3.13 – Group swing seat . 26
5.2.1 Member body question . 26
5.2.2 Member body proposal . 26
5.2.3 Interpretation Panel . 26
5.2.4 Comments/proposal for an answer . 26
6 EN 1176-3:2017, Playground equipment — Part 3: Additional specific safety
requirements and test methods for slides . 27
6.1 Interpretation request 2022-03 – Finland: 4.8 – Impact area and Figure 9 . 27
6.1.1 Member body question . 27
6.1.2 Member body proposal . 27
6.1.3 Interpretation Panel . 27
6.1.4 Comments/proposal for an answer . 27
7 EN 1176-4:2017+AC:2019, Playground equipment and surfacing - Part 4: Additional
specific safety requirements and test methods for cableways . 28
7.1 Interpretation request 2020-13 – Türkiye: 4.9, acceleration, seat test, Annex C,
Annex B . 28
7.1.1 Member body question . 28
7.1.2 Member body proposal . 28
7.1.3 Interpretation Panel . 28
7.1.4 Comments/proposal for an answer . 28
8 EN 1176-5:2019, Playground equipment and surfacing — Part 5: Additional specific
safety requirements and test methods for carousels . 29
8.1 Interpretation request 2020-03 – Finland: 5.2.3 Ground clearance – rotating
platform not flush with the ground . 29
8.1.1 Member body question . 29
8.1.2 Member body proposal . 29
8.1.3 Interpretation Panel . 29
8.1.4 Comments/proposal for an answer . 29
8.2 Interpretation request 2020-12 – Sweden: Table 1, 4.3 + 4.5 – User stations/Annex E . 30
8.2.1 Member body question . 30
8.2.2 Member body proposal . 30
8.2.3 Interpretation Panel . 31
8.2.4 Comments/proposal for an answer . 31
9 EN 1176-6:2017+AC:2019, Playground equipment — Part 6: Additional specific
safety requirements and test methods for rocking equipment . 31
9.1 Interpretation request 2020-04 – Denmark: 3.11, 4.5 – Restraint of Motion, Damping . 31
9.1.1 Member body question . 31
9.1.2 Member body proposal . 32
9.1.3 Interpretation Panel . 32
9.1.4 Comments/proposal for an answer . 32
10 EN 1176-7:2020, Playground equipment and surfacing — Part 7: Guidance on
installation, inspection, maintenance and operation . 32
10.1 Interpretation request 2020-08 – Lithuania: Scope . 32
10.1.1 Member body question . 32
10.1.2 Member body proposal . 33
10.1.3 Interpretation Panel . 33
10.1.4 Comments/proposal for an answer . 33
Bibliography . 34

European foreword
This document (CEN/TR 17842-2:2024) has been prepared by Technical Committee CEN/TC 136
“Sports, playground and other recreational facilities and equipment”, the secretariat of which is held by
DIN.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN shall not be held responsible for identifying any or all such patent rights.
CEN/TR 1784 consists of the following parts, under the general title Playground equipment for children
— Replies to requests for interpretation of EN 1176:2017 and its parts:
— Part 1: Replies to requests for interpretation of EN 1176:2017 and its parts (2018-2019)
— Part 2: Replies to requests for interpretation of EN 1176:2017 and its parts (2020-2022)
Any feedback and questions on this document should be directed to the users’ national standards body.
A complete listing of these bodies can be found on the CEN website.
Introduction
Interpretations and no-action decisions
This document contains all agreed responses to interpretation requests of the years 2020 to 2022
concerning the understanding of clauses and requirements in EN 1176 and its parts. The responses
concern those requests that have resulted in an interpretation or a decision that no action is required as
the standard is sufficiently clear. It should bring a close to all interpretations made to EN 1176 and its
parts.
An interpretation does not have the same status as the text of the standard. However, following an
interpretation gives assurance that the relevant clause of the standard has been applied correctly.
An interpretation is a clarification of the meaning of the standard.
Disclaimer
The interpretations have been prepared by the interpretation panel of CEN/TC 136/SC 1 in accordance
with an agreed process and finally confirmed by the whole CEN/TC 136/SC 1 prior to responding back
to the enquiring National Standardization Body. The information contained herein should always be
considered in association with the original published text contained in the EN 1176 standard series.
Requests for interpretations can be submitted by a CEN member body through its national mirror
committee or by a CEN/TC 136 liaison organization (but not directly by an individual or a company) –
in accordance with the interpretation panel process agreed by CEN/TC 136/SC 1. The requests are
channelled to the CEN/TC 136/SC 1 interpretation panel, which will then deal with the request.
A request for an interpretation may lead to:
a) an interpretation of the standard with no action to the standard (no revision and no amendment)
This should reflect a reasonable interpretation of how the standard should be used, taking into
account:
1) the wording of the standard;
2) the rationale of the standard;
3) the history of the standard.
This is also applicable when it is agreed that the standard appropriately specifies how playground
equipment is assessed.
b) a proposal for an amendment of the standard
This is applicable when it is agreed that the existing standard clauses need urgent update, for
example, if the interpretation identifies a serious conflict that compromises safety.
NOTE All replies to interpretation requests received since 2017 are published in the CEN/TR 17842 series.
As required, additional parts of this TR are published to include any new interpretations that have been agreed
since the publication of the previous TR part. Proposals for amendments will be progressed as new work item
proposals in accordance with CEN rules.
c) a future revision
It is not part of the interpretation panel process to carry out new work that was not previously
covered within the published EN 1176 parts and clauses. Future work requests should always be
raised by National Standard Bodies using the “Future work request template” to ensure full
consideration is given to the necessity and possible consequences, before starting any new work on
EN 1176 and its parts.
Responses to interpretation requests
Since requests for interpretations are submitted through a CEN member body, it is assumed that the
member body will keep itself informed about decisions concerning the request and its progress and will
itself inform the originator of the request, as appropriate.
The following information requests have been included in this document:
Table 1
Request Standard Submitting
Clause Key words
Number reference country
2020-01 EN 1176-1 4.2.12.2 Sweden Sand cranes
2020-02 EN 1176-2 4.5, 3.13, 4.6.3 & Netherlands Parent-child swing
Annex B
2020-03 EN 1176-5 5.2.3 Finland Ground clearance, tapered
underside
2020-04 EN 1176-6 3.11, 4.5 Denmark Restraint of motion, damping
2020-05 EN 1176-2 3.13 Denmark Group swing seat, parent-child
swing
2020-06 EN 1176-1 A.2.6.1 Denmark Swing seats, gondola, traditional
2020-07 EN 1176-1 Annex H Lithuania adequate level of impact
attenuating surfacing
2020-08 EN 1176-7 scope Lithuania Scope
2020-09 EN 1176-2 Impact Area, Group Netherlands Impact area, group swing
swing seat
2020-12 EN 1176-5 4.3 and 4.5, Table 1 Sweden Type D, user stations, Annex E
2020-13 EN 1176-4 4.9 Türkiye Impact test method
2020-14 EN 1176-1 4.2.8.5.4 Finland Adjacent platforms
Table 2
Request Standard Submitting
Clause Key words
Number reference country
2021-01 1176-1 4.2.8.2.4, table 4 Sweden Bark, woodchip, particle size
2021-02 1176-1 4.2.7.2b Sweden Entrapment, partially bound test
probe
Table 3
Request Standard Submitting
Clause Key words
Number reference country
2022-02 EN 1176-1 7.2.7.2 Sweden Partially bound openings
2022-03 EN 1176-3 4.8 Finland Impact areas, slides, falling spaces
2022-04 EN 1176-1 4.2.8.4 Finland Falling space, obstacles, climbing, risk
assessment
2022-05 EN 1176-1 4.2.4.3 Finland Guardrails, falling height, climbing
1 Scope
The purpose of this document is to publish replies to requests for interpretations to all parts of EN 1176
which have been drafted by the interpretation panel and confirmed by CEN/TC 136/SC 1.
2 Normative references
There are no normative references in this document.
3 Terms and definitions
No terms and definitions are listed in this document.
ISO and IEC maintain terminology databases for use in standardization at the following addresses:
— ISO Online browsing platform: available at https://www.iso.org/obp/
— IEC Electropedia: available at https://www.electropedia.org/
4 EN 1176-1:2017+A1:2023, Playground equipment and surfacing — Part 1:
General safety requirements and test methods
4.1 Interpretation request 2022-05 – Finland: 4.2.4.3 Guardrails
4.1.1 Member body question
1. Is the underside of a guardrail (A) allowed to have elements or geometries (B) that could be used
for climbing? See Figure 1.
2. If geometries that could be used for climbing do exist, should the guard rail be included to falling
height?
Figure 1
4.1.2 Member body proposal
1. Yes. The requirement to discourage climbing is given only for barriers and not for the guard rails.
2. In line with interpretation 2011-04, only if the guardrail allows access to higher locations, the
guard rail is considered a climbing element and should be included to the falling height.
4.1.3 Interpretation Panel
Proposed track: No action
4.1.4 Comments/proposal for an answer
A Guardrail’ is defined in EN 1176-1:2017+A1:2023, clause 3.23, as ‘rail intended to prevent a user from
falling’.
Requirements for ‘Guardrails’ are given in EN 1176-1:2017+A1:2023, clause 4.2.4.3, which do not
require them to discourage climbing.
To answer the specific MB Questions:
1. Yes. The requirement to discourage climbing is given only for barriers and not for the guardrails.
2. Yes. Any elements that encourage climbing to higher sections of the equipment should be included
in the ‘Free Height of Fall’. (EN 1176-1:2017+A1:2023, clause 4.2.8.1, includes examples of what
features could encourage climbing ‘for roofs, or other features not intended for play’. Guardrails are
not specifically mentioned although they would generally be expected as a ‘feature not intended for
play’.)
The Interpretation Panel also noted that when considering a fall onto a platform that is more than 1m
high, the surface of the lower platform shall present the necessary impact attenuating properties, in line
with EN 1176-1:2017+A1:2023, clause 4.2.8.5.4.
4.2 Interpretation request 2021-02 – Sweden: 4.2.7.2 b) – Entrapment, partially bound
test probe
4.2.1 Member body question
Our questions relate to paragraph 4.2.7.2 b) and the connected test method D2.2. This works perfectly
fine for rectangular openings. However, for angular/V-shaped openings in range 2, you get totally
different minimum angle depending on whether you use the shoulder part or the test template D.
See also separate document for further illustrations and explanation of the problem.
Based on the findings in the separate document, should we:
— Use only the shoulder portion, approving angles >75 degrees?
— Use only the test template D, approving angles >60 degrees?
4.2.2 Member body proposal
Either change the clause and the test method to use ONLY one of the following:
— Shoulder portion of the template
— Test probe D
4.2.3 Interpretation Panel
Proposed track: No action
4.2.4 Comments/proposal for an answer
EN 1176-1:2017+A1:2023, 4.2.7.2, b), 2) states:
‘Range 2: (template centre line from horizontal to + 45°); when the template apex contacts the base of
the opening, the depth of the opening shall be less than the ‘A’ portion of the template. If the depth of
the opening is greater than the ‘A’ portion of the template all parts of the opening above the ‘A’ portion
shall also allow insertion of the shoulder section of the template or probe D.’
The two test methods given in EN 1176-1:2017+A1:2023, 4.2.7.2, b),2) produce different results, for the
same angular openings, when tested with either the shoulder section of the template or probe D.
Because of that, use of probe D is labelled in Figure D.6 ‘pass but not the minimum requirement’.
The intention of EN 1176, when alternative tests are given, is based on whether the test requirements
are published as an ‘and’ or ‘or’:
— If the requirement says ‘and,’ then both tests must pass, and it is worst case situation that is taken.
— If the requirement says ‘or,’ then only one test must pass, and it is not worst case.
The example we are considering in EN 1176-1, 4.2.7.2, b),2) is ‘or’, so not worst case.
Both of the methods (shoulder section and probe D) are shown in Figure D.6. As the requirement is an
or, the opening can be considered to pass if either method gives the pass result.
4.3 Interpretation request 2022-02 – Sweden: 4.2.7.2 b) – Entrapment, partially bound
test probe
4.3.1 Member body question
We appreciate the clarification given to our previous request about this paragraph. We have an
additional request regarding the same paragraph, 4.2.7.2 b) and exactly how the probe D should be
used.
The standard states ‘all parts of the opening above the ‘A’ portion shall also allow insertion of the …
probe D.’
The test procedure connected to above is shown in Figure D.6.
In the annex attached to this document, we illustrate two different ways of performing this test,
Example A and Example B. Should the probe be used with its EDGE (example A) or its centre (example
B) in tangent with depth A?
Using example B, the test will not pass any angles less than 90 degrees given the relationship between
the radius of the probe and the depth of the A-portion.
Using example A will pass angles from around 60 degrees and upwards.
4.3.2 Member body proposal
The result when testing according to example A is in line with both clause 4.2.7.1 (60 degrees) and the
text description given under 4.2.7.2 b (‘…all parts above…). Hence our proposal is that the procedure
should be performed with the edge of probe D in tangent with depth A.
To avoid confusion:
— Figure D.6 should be revised accordingly.
— Add an illustration of how the test should be performed in a V-shaped opening for interval 2.
— Change the text in the clause to the following (or similar): “If the depth of the opening is greater
than the ‘A’ portion of the template all parts of the opening above the ‘A’ portion shall also allow
insertion of the shoulder section of the template or the edge of probe D.”
4.3.3 Interpretation Panel
Proposed track: Future revision
4.3.4 Comments/proposal for an answer
It was noted that this question was similar to interpretation request 2016-01. In general the
Interpretation panel was concerned about making strict assessments, based on Hypothetical ‘paper
based’ situations only. The guidance in the standard is intended to be used as a tool to assess real life
situations, with the 3D probes and provide a criteria for their evaluation of how a child’s head and neck
could come to rest in an opening. We are concerned that trying to treat this test in an over scientific
way, will move the process away from assessing real life situations in an informed and realistic way.
The interpretation panel feel the requirements in EN 1176 and their intension, could be made clearer,
with a greater understanding of the rationales behind them. A new Working Group is being established
within SC1 to progress this work.
It was also noted that some helpful guidance was previously published in SC1 document N1604.
4.4 Interpretation request 2021-01 – Sweden: 4.2.8.2.4, Table 4 – Bark, woodchip,
particle size
4.4.1 Member body question
How should the wood shavings size be interpreted, and witch dimensions are table 4 referring to?
The question is referring to Wood chips 5-30mm and Bark 20-80mm.
See Figure 2.
4.4.2 Questions:
1. Is there a rationale behind table 4; and why there is no deviation for grain and particle size?
2. Is there a maximum length of the woodchip or bark grain?
3. How much of the material may deviate from the grain size 5-30 mm or 20-80mm?
4. How will the size be interpreted according to table 4
5. Which dimensions of a woodchip or bark grain is the dimension in table 4 referring to, length,
width or thickness?
a) b)
c) d)
Figure 2
4.4.3 Member body proposal
Add information into Table 4:
e) maximum length of wood chip and bark and that at least 70% of the material should be within 5-
30mm or 20-80mm.
4.4.4 Interpretation Panel
Proposed track: No action
4.4.5 Comments/proposal for an answer
EN 1176-1:2017+A1:2023, clause 3.32 adequate level of impact attenuation
property of a surface having the necessary impact attenuation for a given free height of fall, which is in
compliance with:
a) Table 4, including sieve test in accordance with EN 933-1;
b) EN 1177;
c) other appropriate means of verification e.g., value-based judgement for turf/topsoil.
EN 1176-1:2017+A1:2023, clause 4.2.8.5.1
The surface of the impact area shall be free from sharp edged parts or projections and shall be installed
without creating any entrapment situation (see 4.2.7).
If loose particulate material is used it shall be installed to a layer thickness of 100 mm more than that
determined in Table 4 or by testing to EN 1177.
NOTE This is to allow for displacement of loose particulate material through use.
EN 1176-1:2017+A1:2023, clause 4.2.8.5.2
Examples for commonly used impact attenuating materials are given in Table 4 with the related
maximum free heights of fall, tested in accordance with EN 1177 and measured partly on site and partly
in the laboratory with different test conditions. Where the installed surfacing can be verified as being in
accordance with Table 4, no additional testing is required.
EN 1176-1:2017+A1:2023, table 4
Where the installed surfacing is verified (e.g., sieve test) as being in accordance with this table or carries
a test report according to EN 1177, no additional testing is required.
NOTE 4 Loose fill material specifications in Table 4 are examples that can be accepted without further testing
in accordance with EN 1177.
Summary answer:
Table 4 only gives example particle sizes with known HIC performance that can be used without need of
a specific HIC test to EN 1177. All other particles sizes are also possible, although will require a HIC test
to EN 1177.
Table 4 is only referencing HIC performance of known materials. Other requirements such as sharp
edges or projections are referenced in other EN 1176 clauses. See above extract, EN 1176-
1:2017+A1:2023, clause 4.2.8.5.1.
Specific Q1 answer:
These requirements have been published since 1998. Unfortunately, the rationale for these precise
dimensions is not published, other than they have known HIC test performance.
Specific Q2 answer:
No measurement is published, however there is a general requirement for the surface to be free from
sharp edged parts or projections. This should be judged by risk assessment, depending on the particle
type.
Specific Q3 answer:
The Standard recommends that the particle size is verified by sieve test and does not give any tolerance
limits for non-conforming particle sizes.
Specific Q4 & Q5 answers:
The sieve test will filter particles, mainly by their cross-section dimensions.
4.5 Interpretation request 2020-09 – Netherlands: EN 1176-1 – 4.2.8.2.4 and EN 1176-2 –
4.10.2.2 – Width, Impact area, Group swing seat
4.5.1 Member body question
NOTE The length of the impact area of swings is depending on the free height of fall. The width of the falling
space is NOT depending on the free height of fall.
Regarding “normal” swings (type 1, 2 and 4), the swing suspension members (ropes or chains) reduce
the likelihood of a user falling to the side. With most group swing seats this is also valid. Where the
swing suspension members do not provide a similar protection, (for instance the family swing shown),
where users can fall to the side, the width of the impact zone does not seem to be sufficient.
See Figure 3.
The presumption of the protection against a fall to the side is not described in EN 1176-2. Thus, also no
additional requirement has been set when the presumption of this additional protection is not met.
1. Should the requirements for the width of the impact area be supplemented with a note where it is
made clear that these requirements are only valid for swing seats with a certain protection against
falling to the side?
2. Should there be additional requirements for the width of the impact area of swings without any
protection of falling to the side?

Figure 3
4.5.2 Member body proposal
1. Yes.
2. Yes. The additional requirements for the width of the impact area could be defined as follows
(definitions cf. EN 1176-1), see Figure 4.
Figure 4
Rationales for this answer: See figure 17 from EN 1176-1 (corrected for scale) and the similar figure if
EN 1176-2:2017+AC:2019, 4.10.2.2 would be put into a figure.
NOTE the first is from the SIZE of an elevated surface, the second from the centre of a swing seat).

a) b)
Figure 5
The minimum width of the impact zone is chosen between the requirements of EN 1176-1 and those of
EN 1176-2. The intended impact zone is 1 m from the side of the swing seat. And from a FHF of 1,5 m
the zone has to be increased: for every 3 mm additional FHF, an increase of 2 mm.
See Figure 5.
4.5.3 Interpretation Panel
Proposed track: No action
4.5.4 Comments/proposal for an answer
The current EN 1176-2 does not give any specific requirements for standing use, even though it is
generally accepted that users will stand on many swing seat types. This has been the case since the
Standard was first published. It is understood that the particular seat type referred in the question
above has been on the market for over 10 years.
Should the NSB be of the opinion that addition safety requirements are necessary the IP recommends
that a proposal for amendment or future work is made by the NSB following the procedure agreed by
SC1 (see template in document SC 1 N9002). Following this procedure allows a full safety case to be
presented, together with an evaluation of any consequences that a possible Standard change could
bring.
4.6 Interpretation request 2022-04 – Finland: 4.2.8.4 Protection against injuries in the
falling space
4.6.1 Member body question
The requirement says: “The falling space shall not contain any obstacles onto which a user could fall and
cause injuries.” As the minimum extent of the falling space is 1500 mm, almost all climbing equipment
fail this requirement. Even common inclined ladders.
Should risk assessment be preferred instead of pass/fail judgment? See Figure 6.

Figure 6
4.6.2 Member body proposal
Yes. In line with interpretation 2010-03, elements outside the most obvious falling direction will
require a risk assessment to determine whether it could cause injuries to the user.
4.6.3 Interpretation Panel
Proposed track: No action
4.6.4 Comments/proposal for an answer
Requirements and guidance on assessing which equipment parts are accepted in the equipment Falling
Space is given in EN 1176-1:2017+A1:2023, 4.2.8.4
4.2.8.4 Protection against injuries in the falling space
The falling space shall not contain any obstacles onto which a user could fall and cause injuries, e.g.
posts not flush with adjacent parts or exposed foundations (see 4.2.14).
NOTE 1 The intention of this requirement is not to protect the user from minor knocks or bumps, that might
lead to a bruise or sprain etc., as these types of injuries are possible in all situations.
The following parts of play structures may be in the falling space:
a) adjacent parts of play structures with a difference in free height of fall of less than 600 mm;
b) parts of the equipment bearing or containing the user, or helping the user to keep balance;
c) parts of the equipment with an inclination of 60° or more from the horizontal.
NOTE 2 In this case a falling user would only make a glancing contact with the equipment part
A definition of ‘Obstacle’ is also given in EN 1176-1:2017+A1:2023, clause 3.19.
To answer the specific MB question:
Yes, it is accepted that Risk Assessment will be required, for specific situations, to determine whether
equipment parts are ‘obstacles’ that could cause injuries to the user, as defined in the clauses EN 1176-
1:2017+A1:2023, clause 4.2.8.4 and 3.19.
4.7 Interpretation request 2020-14 – Finland: 4.2.8.5.4
4.7.1 Member body question
EN 1176-1:2017+A1:2023, clause 4.2.8.5.4 says about adjacent platforms: “If the free height of fall
between adjacent platforms is more than 1 m, the surface of the lower platform shall present the
necessary impact attenuating properties.”
The requirement in effect says that the falling height up to 1 000 mm from a platform onto an adjacent
platform is allowed.
Could this requirement be extended to cover also play elements such as climbing nets and seats?
In other words, what is the maximum allowed falling height from a climbing net onto a wooden
platform that is part of the play structure; 600 mm or 1000 mm?
Example to clarify the question. Not a real product.
See Figure 7.
CEN/T
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