What belongs on a daycare playground checklist?

A daycare is not an edge case for CPSC’s Public Playground Safety Handbook. It is the first thing on its list. §1.3 says what “public” playground equipment means by naming the places it is found, and the first bullet is “Commercial (non-residential) child care facilities”. §1.2 names the audience the handbook was written for, and the first group there is “childcare personnel”. So the answer to what belongs on a daycare playground checklist starts with the handbook’s own ready-made one, Appendix A: a single printed page of 24 checkboxes in seven groups, with NOTES, DATE OF INSPECTION and INSPECTION BY at the foot.

Two things sit beside it, and they are different in kind. Pub. 325 is guidance, and says so about itself in §1.1: it “presents safety information for public playground equipment in the form of guidelines”, and “the U.S. Consumer Product Safety Commission (CPSC) staff believes that guidelines, rather than a mandatory rule, are appropriate.” A state child care licensing code is the other kind of document. It requires, of the facilities that state licenses. We write about a state only where we have read the rule text at the primary source, and we have read two: Texas and North Carolina. They do not ask for the same thing, and on one point one of them names a form that is not CPSC’s.

Chapter 4, the maintenance chapter, names child care centers once, and it is worth knowing what that sentence is about before somebody quotes it at you as the handbook’s inspection frequency for a daycare. It is in §4.3, headed “Maintaining Loose-Fill Surfacing”: “Loose-fill surfacing materials require special maintenance. High-use public playgrounds, such as child care centers and schools, should be checked frequently to ensure surfacing has not displaced significantly, particularly in areas of the playground most subject to displacement (e.g., under swings and slide exits).” That is about whether the mulch or the sand has moved out from under the swings and away from the foot of the slide. It is not a schedule for the playground, and how often playground equipment should be inspected takes the whole question up on its own.

The handbook’s own checklist

§4.1 is where Appendix A gets its job description, and the job is narrower than the page looks: “If manufacturer-provided inspection guidelines are not available, a general checklist that may be used as a guide for frequent routine inspections of public playgrounds is included at Appendix A. This is intended to address only general maintenance concerns.” Two conditions in one sentence. It is what you reach for when the equipment came with no inspection guidelines of its own, and it is general. §4.1 also keeps a second kind of inspection separate from it — “Detailed inspections should give special attention to moving parts and other parts that can be expected to wear” — and says who walks either: “Maintenance inspections should be carried out in a systematic manner by personnel familiar with the playground, such as maintenance workers, playground supervisors, etc.”

Here are the seven groups in the order Appendix A prints them, each with the section the form itself cites:

• Surfacing (§2.4) — five boxes: adequate protective surfacing under and around the equipment; surfacing materials have not deteriorated; loose-fill has no foreign objects or debris; loose-fill is not compacted; loose-fill has not been displaced under heavy use areas such as under swings or at slide exits. The indented actions, in order, are install/replace surfacing; replace surfacing and a blank “Other maintenance:” line; remove trash and debris; rake and fluff surfacing; rake and fluff surfacing. How deep the loose fill should be is a separate question the form does not ask; the form asks whether it is still there.
• Drainage (§2.4) — one box: the entire play area has satisfactory drainage, especially in heavy use areas such as under swings and at slide exits. Actions: improve drainage, and a blank “Other maintenance:” line.
• General Hazards — six boxes, the largest group: no sharp points, corners or edges on the equipment; no missing or damaged protective caps or plugs; no hazardous protrusions; no potential clothing entanglement hazards, such as open S-hooks or protruding bolts; no crush and shearing points on exposed moving parts; no trip hazards, such as exposed footings or anchoring devices and rocks, roots, or any other obstacles in a use zone. What each of those means is set out one at a time, and the use zone the last box refers to is a measured area.
• Security of Hardware (§2.5) — two boxes: there are no loose fastening devices or worn connections; moving parts, such as swing hangers, merry-go-round bearings and track rides, are not worn. Each of the two carries an action and a blank “Other maintenance:” line: replace fasteners under the first, replace part under the second.
• Durability of Equipment (§2.5) — four boxes: no rust, rot, cracks or splinters on any equipment, checking carefully where it comes in contact with the ground; no broken or missing components on the equipment, such as handrails, guardrails, protective barriers, steps or rungs; no damaged fences, benches or signs on the playground; all equipment securely anchored.
• Leaded Paint (§2.5.4) — two boxes: paint, especially lead paint, is not peeling, cracking, chipping or chalking; there are no areas of visible leaded paint chips or accumulation of lead dust.
• General Upkeep of Playgrounds (§4) — four boxes: no user modifications to the equipment, such as strings and ropes tied to equipment or swings looped over top rails; the entire playground free from debris or litter such as tree branches, soda cans, bottles and glass; no missing trash receptacles; trash receptacles are not full.

Thirteen of the 24 boxes carry an indented action, eighteen action boxes between them; the ones not named above are mitigate lead paint hazards under Leaded Paint, and remove string or rope, correct other modification, clean playground, replace trash receptacle and empty trash under General Upkeep. General Hazards and Durability of Equipment carry no action boxes at all, which is worth knowing when you are the one deciding what to do about what you found. Appendix A also runs onto a second printed page, 44, and that page is a single box headed “Routine Inspection and Maintenance Issues” — fifteen more checkboxes, no group headings, and none of the NOTES, DATE OF INSPECTION or INSPECTION BY fields. It is the same list the handbook prints as Table 3 back in §4.1: broken equipment such as loose bolts, missing end caps and cracks; broken glass and other trash; cracks in plastics; loose anchoring; hazardous or dangerous debris; insect damage; problems with surfacing; displaced loose-fill surfacing, cross-referenced to Section 4.3; holes, flakes and/or buckling of unitary surfacing; user modifications such as ropes tied to parts or equipment rearranged; vandalism; worn, loose, damaged or missing parts; wood splitting; rusted or corroded metals; rot.

Our free playground inspection checklist is that round as a sheet you can print. It heads with Site, Date, Inspected by and Weather, and every item is marked Pass, Fail or N/A. It carries no NOTES field — that one is Appendix A’s — so write what you found beside the item that failed, sign it, date it, file it.

What the handbook asks of the people watching

§2.2.7 is the supervision section, and it is the nearest Pub. 325 comes to anything a daycare would recognise as a before-the-doors-open routine. It stops short of being one, and how it is written matters. The handbook makes supervision a matter of knowledge first — “The quality of the supervision depends on the quality of the supervisor’s knowledge of safe play behavior” — and then introduces six items with these words: “Supervisors should understand the basics of playground safety such as:”. Should understand, and such as. That is a description of what a supervisor ought to know, not a form anyone is told to sign before the children come out. The six, verbatim (Table 1 interrupts them, so the last two are printed overleaf on page 8):

• “Checking for broken equipment and making sure children don’t play on it.”
• “Checking for and removing unsafe modifications, especially ropes tied to equipment, before letting children play.”
• “Checking for properly maintained protective surfacing.”
• “Making sure children are wearing foot wear.”
• “Watching and stopping dangerous horseplay, such as children throwing protective surfacing materials, jumping from heights, etc.”
• “Watching for and stopping children from wandering away from the play area.”

The six are not all the same kind of act, and the split is the clearest evidence that this is not a pre-opening checklist. The first four are checks on things: broken equipment, modifications, surfacing, footwear. Only one of them is tied by the handbook to a moment in the day, and the words are its own — “before letting children play”, in the second. The last two are not checks at all but duties that run for as long as the children are outside: watching and stopping horseplay, and watching for children wandering off — which is the same worry §2.1 answers physically, with a method of containing children within the playground. Turning the first four into a walk somebody does each morning is a reasonable thing for a daycare to decide to do, and we are saying plainly that the arrangement would be yours, not CPSC’s — §2.2.7 does not order these six, schedule them, or call them a checklist, and the last two could not be walked through before the doors open even if it did. The same section adds a caution against leaning on any of it too hard: “Toddlers and preschool-age children require more attentive supervision than older children; however, one should not rely on supervision alone to prevent injuries.” Every other place the handbook uses the word, and what it does and does not ask of the person doing the watching, is counted out on what Pub. 325 says about playground supervision.

Fences, sun and ratios

Three things people arrive at a daycare playground page looking for. The handbook has something to say about two of them and nothing whatever about the third, and in no case is what it says the number people came for.

Fences. A fence appears in four places in Pub. 325 as we have read it, and not one of the four gives a fence a height, a dimension or a material: the site-selection table in §2.1, the listing of ASTM F2049 by designation and title in §1.4.1, a condition check on the Appendix A form, and a swing recommendation in §5.3.8.1. Only the first is a recommendation to contain children, and it lives somewhere most people never look: §2.1, “Selecting a Site”, a three-column table of site factors, questions to ask, and mitigations, introduced as “The following factors are important when selecting a site for a new playground”. One row is nearby accessible hazards — roads with traffic, lakes, ponds, streams, drop-offs and cliffs — and its questions are “Could a child inadvertently run into a nearby hazard?” and “Could younger children easily wander off toward the hazard?”. The mitigation, in full: “Provide a method to contain children within the playground. For example, a dense hedge or a fence. The method should allow for observation by supervisors. If fences are used, they should conform to local building codes and/or ASTM F-2049.”

Read what that actually commits the handbook to. A method of containment, not necessarily a fence — a dense hedge is offered in the same breath. A method you can see through, because it has to allow observation by supervisors. And a referral outward for the fence itself: to local building codes, and to the standard §1.4.1 lists as F2049, Standard Guide for Fences/Barriers for Public, Commercial, and Multi-Family Residential Use Outdoor Play Areas (§2.1 prints the designation hyphenated, as F-2049). Designation and title is all we can give you of it; we have not read F2049 and quote nothing from it, and what the ASTM playground standards are explains why the standards themselves cannot be reproduced on a page like this one. So the handbook does answer the question — contain the children, by a method that still lets supervisors see them — and then hands the height, the gaps and the latch to a document it does not reproduce and to your building code. The third of the four is on the round itself, on Appendix A under Durability of Equipment, where it is a condition check rather than a question of whether to have one: “There are no damaged fences, benches, or signs on the playground.” The fourth is not about the boundary of your yard at all. §5.3.8.1, on printed page 38, recommends that swing structures stand away from other equipment and activities, then offers a fence a second time: “Additional protection can be provided by means of a low blockade such as a fence or hedge around the perimeter of the swing area. The blockade should not be an obstacle within the use zone of a swing structure or hamper supervision by blocking visibility.” A hedge again before you get to a material, and the same test again — whoever is watching has to be able to see over it. “Low” is the only word in the four that describes the size of a fence, and it is not a number; what carries a measurement is the use zone the blockade has to stay out of, which fixes where it may stand rather than how tall it is. If a fence is required of you as a licensed facility, that requirement will be in your state’s licensing code; the two rules we have read are the playground inspection rules quoted below, neither is about fences, and we have not read the rest of either state’s code.

Sun and shade. Both are in the handbook, and shade has a subsection of its own. The same §2.1 site table has a sun exposure row, and its first question is one a daycare can ask standing in its own yard: “Is sun exposure sufficient to heat exposed bare metal slides, platforms, steps, & surfacing enough to burn children?”. Two mitigations follow: “Bare metal slides, platforms, and steps should be shaded or located out of direct sun.” and “Provide warnings that equipment and surfacing exposed to intense sun can burn.” A second question asks “Will children be exposed to the sun during the most intense part of the day?”, and the mitigation is softer: “Consider shading the playground or providing shaded areas nearby.”

§2.1.1 is headed “Shading considerations” and is given over to it: it cites the American Academy of Dermatology that “one in five Americans will develop some form of skin cancer during their lifetime, and five or more sunburns double the risk of developing skin cancer”, then names three ways to get shade — “Utilizing existing shade (e.g., trees), designing play structures as a means for providing shading (e.g., elevated platforms with shaded space below), or creating more shade (e.g., man-made structures)” — and closes with the maintenance those bring: “When trees are used for shade, additional maintenance issues arise, such as the need for cleaning up debris and trimming limbs.”

The equipment itself is covered separately, in §2.5.3 on metals: “Avoid using bare metal for platforms, slides, or steps. When exposed to direct sunlight they may reach temperatures high enough to cause serious contact burn injuries in a matter of seconds. Use other materials that may reduce the surface temperature, such as but not limited to wood, plastic, or coated metal”. And: “If bare or painted metal surfaces are used on platforms, steps, and slide beds, they should be oriented so that the surface is not exposed to direct sun year round.” Sun exposure is one of the things §1.5.3 lists as newly added in the 2008 revision, which is why so much of it sits in Chapter 2 rather than in the maintenance chapter.

Here is the line worth drawing, because it is the one that gets blurred. Shading the playground is something the handbook tells you to think about, and it says so twice: §2.1’s mitigation for children out in the middle of the day is “Consider shading the playground or providing shaded areas nearby”, and §2.1.1 names “creating more shade (e.g., man-made structures)” as one of the three ways of getting it. What no part of Pub. 325 sets is a quantity — no amount of shade, no area to be covered, no specification for a structure that provides it, and no temperature at which a surface counts as too hot. Shading bare metal, or siting it out of the sun, is put more firmly than consider — “Bare metal slides, platforms, and steps should be shaded or located out of direct sun” — but it is still a should, and it is guidance about the equipment. And the §2.1 table, with §2.1.1 under it, is written about choosing a site for a new playground — a different problem from the one you have if the structure is already up and the afternoon sun is already on it.

Staff-to-child ratios. Not in Pub. 325, anywhere. §2.2.7 discusses supervision in terms of what a supervisor should know and who supervisors tend to be, and says nothing about how many children one adult should be watching. Ratios are a licensing matter and the handbook does not address them, so nothing on this page can tell you what yours are.

One more that is genuinely specific to daycares, since it is easy to miss. §1.3 closes by sending child care facilities elsewhere for part of the job: “Child care facilities, especially indoor, should refer to ASTM F2373 — Standard Consumer Safety Performance Specification for Public Use Play Equipment for Children 6 Months Through 23 Months, for more guidance on areas unique to their facilities.” Designation and title again; we quote nothing from F2373 either.

What your state adds

A licensing code is the document that turns any of this into something you are held to, and only for the facilities that state licenses. Two states, read at the source, and they agree on almost nothing.

Texas, 26 Tex. Admin. Code § 746.4751, for licensed child-care centers, sets two intervals. The daily one: “The child-care center director or designee must inspect the active play space and equipment daily before children begin play to ensure there are no hazards present.” The monthly one, which names the form loosely: “The child-care center director or designee must conduct at least monthly inspections of the active play space and equipment, utilizing a general maintenance checklist or safety checklist that includes checking the equipment and surfacing material for normal wear and tear, broken or missing parts, debris or foreign objects, drainage problems, or other hazards.” And the rule refuses to let inspecting be the whole of the duty: “The child-care center director or designee must ensure hazards or defects identified during inspections are removed or repaired promptly, and must arrange for protection of the children or prohibit use of hazardous equipment until the hazards can be removed or repairs can be made.” The rule prescribes no particular form. Whether the sheet you walk satisfies the person who licenses you is a question for them; what we can do here is quote the rule, and we have.

North Carolina, 10A NCAC 09 .0605(q), for licensed child care centers, sets one interval and is far more specific about who walks it and on what: “Following completion of playground safety training as required by Rule .1102(e) of this Chapter, a monthly playground inspection shall be conducted by an individual trained in playground safety requirements.” Then: “A trained administrator or staff person shall make a record of each inspection using a playground inspection checklist provided by the Division.” And: “The checklist shall be signed by the person who conducts the inspection and shall be maintained for 12 months in the center’s files for review by a representative of the Division.” Read that second sentence carefully if you are in North Carolina: the licensing record goes on the Division’s own form. A CPSC round is something you do as well, not instead.

Daily plus monthly against monthly; any general maintenance checklist against the state’s own form; anyone the director designates against someone who has completed playground safety training. Both are set out in full, with their sources, on the state rules page. These two are the only codes we have read, so nothing here tells you what any other state requires of a daycare, or whether it requires anything at all. If you are licensed somewhere else, the document you need is your own state’s code, read at the source rather than in a summary of somebody else’s.

Keeping the record

§4.4 is the last section of Chapter 4 and it is four sentences long: “Records of all maintenance inspections and repairs should be retained, including the manufacturer’s maintenance instructions and any checklists used. When any inspection is performed, the person performing it should sign and date the form used. A record of any accident and injury reported to have occurred on the playground should also be retained. This will help identify potential hazards or dangerous design features that should be corrected.” Note what is being kept: not only the checklists, but the repairs and the manufacturer’s instructions alongside them. §4.2 is the reason — “Inspections alone do not constitute a comprehensive maintenance program. Any problems found during the inspection should be noted and fixed as soon as possible.”

The handbook sets no retention period, here or anywhere else in it. The two licensing rules do: Texas asks for maintenance inspection and repair records to be kept at the center for at least the previous three months and available for review during operating hours, and North Carolina for twelve months in the center’s files. What belongs in the record field by field is on what a playground maintenance record should include.

InspectPlay puts that round on a phone as 25 pass/fail items across 8 sections, at $99 per playground per year. Those are not Appendix A’s 24 boxes in seven groups item for item, so if you hold the two side by side expect the lists to differ. It runs offline, so answers queue on the phone and sync when signal returns. Failing an item asks for a priority and what you saw, then files a finding carrying the handbook’s own remedial action and section citation, and that finding stays open across rounds until somebody closes it with a repair note — which is the part a stack of paper does worst when the same loose bolt turns up on four sheets in a row. Photographs attach to play units and appear in the report; a signature is captured and appears there too. The account owner can add staff by email from the Account screen, and each person gets their own sign-in link and can run checks, read reports and close findings without reaching billing or the client and site records.

Two things to know before you choose it for a cadence a licensing rule sets. Its recurrence runs on a weekly cycle for every site, with no per-site setting, so it will not keep a daily-before-play round or a monthly one for you — nothing stops anyone filing a check whenever they walk the yard, but the schedule is not the app’s to hold. And there is no PDF file: the report is a page on the web, emailed as a link, and whoever needs paper prints it from a browser.