Child Safety Through Communication

Seven days before Christmas, another little girl died after falling out of a spinning amusement ride with a fixed lap bar restraint system. This 9-year-old was killed by a Wisdom Sizzler at a carnival in Texas, one of the many states without a ride inspection or accident investigation program. The U.S. Consumer Product Safety Commission (CPSC) has authority to investigate thrill ride fatalities as long as they happen to occur outside the sovereign grounds of an amusement park. I don't yet know whether the CPSC will elect to investigate this accident and, if so, how long it will take before the results of the investigation can be revealed to the general public. Little matter, really. This particular story plays out on a regular basis; the report on rideaccidents.com follows a sadly predictable format: "The [carnival's] owner says that the girl exceeded the ride's minimum height requirement for passengers. He says that the girl probably either slipped or slid underneath the safety bar and fell only a few feet, and that she may have been hit in the head by another car."

The child ejection hazard on older rides with fixed lap bars is well documented within the industry and regulatory community at this point. The child's grieving parents are the only people involved who could have been surprised by this outcome. Ride manufacturers have been circulating safety bulletins to owner/operators for at least ten years describing this hazard and suggesting - although not requiring - that operators do something about it. The suggestions offered include adding seatbelts or enforcing a "no single rider" policy. Operators who don't like either of those suggestions are instructed to 1) not allow children to misbehave during the ride cycle and 2) stop the ride immediately if a child moves into an unsafe position while the ride is whirling.

How, exactly, does a ride operator control the movements of a child who's riding unrestrained dozens of feet away on a rapidly spinning machine? How, exactly, does a ride operator "immediately stop" a seventeen-ton machine that takes several revolutions to wind down? The two mitigations that are possible for an owner/operator to accomplish with any certainty do not have the force of mandatory requirement (i.e, adding seatbelts or refusing to start the machine if a child is riding alone). And the two mandatory requirements in the bulletin (i.e., not allowing children to move into unsafe positions and stopping the machine immediately if they do) are impossible for an operator to reliably perform.

These safety bulletins describe a known hazard with the potential to kill children. The hazard has not been mitigated by mandatory design change, machine guarding, procedural guarding, or ANSI-standard safety warnings to parents. The bulletins provide nothing more than a few optional suggestions and an implausible requirement that ride operators develop super-human capabilities to stop the next child from falling out mid-cycle. Is it any wonder that children continue to be crushed by thrill rides?

Whirling rides like the Sizzler have been crushing small children for years. Not too many, of course. Otherwise the problem would've been fixed by now. Simply put, it's more profitable to let a few kids be killed than it is to install effective restraints or keep young children off the ride. Think of it as the Ford Pinto gas tank business model translated to children's entertainment. According to the Intended Use section of the Sizzler manual, which happened to be included in the CPSC's report on the Colorado Sizzler fatality earlier this year, the Sizzler was never intended to safely restrain children:

"The SIZZLER is designed to be a teen-age adult thrill ride. It is not recommended that small children, 11 or younger ride by themselves. They must be accompanied by a responsible adult."

According to the Colorado report, the intended use recommendation was not included in the posted warnings made available to paying customers who had to judge whether the ride is safe for their child. The posted minimum height limits (52" for a child riding alone and 36" for a child riding accompanied) clearly conflict with the intended use recommendation. Children in the 95th percentile for height reach 36" before their second birthday, and are tall enough to ride a Sizzler alone when they're six. That means the operating limits on the Deluxe Sizzler encourage parents to let their six-year-olds ride alone on a whirling thrill ride with a containment system designed for adults and teens, and encourage parents to bring their toddlers on board a major thrill ride. And if something goes wrong, the industry places the blame squarely on the stunned parents who should've known better.

Where operational limits don't screen out at-risk riders, consumers need to see all recommendations from the manufacturer so that they can make an informed choice.

In the case of the Sizzler, parents need the intended use information as well as the minimum allowable height limits in order to accurately weigh the benefits and risks. They're still likely to be confused by the wide gap between intended use and allowable use, but at least parents have a fighting chance to make a safe choice. Without the extra piece of information, parents will most likely assume that the ride's containment system has been designed to protect 6-year-olds riding alone and 2-year-olds riding with a parent, when in reality, the owner/operator is counting on the parent to restrain the 2-year-old and is counting on the 6-year-old to keep him/herself from slipping or deliberately moving into a dangerous posture.

Children interpret and interact with machinery differently than adults and teens do. Affordance analysis is a human factors discipline commonly used in accident prevention that looks at how features of the product invite or suggest (i.e., afford) different kinds of behavior. In a child's world, horizontal metal bars are perceived as climbing equipment (this is intended in some cases, such as jungle gyms; unintentional in others, such as gates and fences). The adults and teenage users for whom the Sizzler was designed are likely to perceive a solid metal lap bar as safety equipment and a psychological incentive to stay seated, but a child may have the opposite perception, especially when something that looks like a monkey bar is positioned across the opening in front of her.

The industry standards committee has formed a task group to modernize the design requirements for new amusement rides used by children. I hope concepts such as affordance analysis, child retention testing, and ANSI-standard warnings designed for end-users will be included in our discussions and incorporated into the design standard. I believe the industry is committed to making new rides safer for children. However, the problem of existing rides with known child safety hazards will persist.

Ride designs that rely on one-size-fits-all lap bars continue to sell well to park and carnival owners because the simple lap bar systems are cheaper to produce, quicker to load and unload, and have fewer parts to fail. Those factors can make them more profitable to operate and more attractive to buy, even with a higher rate of kiddie ejection. Manufacturers sell to owner/operators, not parents. Those with the most to lose aren't informed about the potential danger, and those who know about the potential danger can manage their financial risk through increased volume, insurance policies, and a prepared legal response to limit liability.

Patrons suffer more than financial loss in the event of a serious accident. The death or maiming of a beloved child can never be managed or mitigated. Lost human parts cannot be replaced. The manufacturer and the owner/operator of the Sizzler ride that crushed the little girl in Austin are, no doubt, saddened and worried, but they didn't have to wake up on Christmas morning grieving the fresh and permanent loss of their own child.

Children are uniquely vulnerable to injury around thrill ride machinery. Parents have the right and the responsibility to make fully informed decisions about which rides are safe for their own kids. Current industry standards do not support the end-user's right to full disclosure. Safety bulletins and ride manuals are distributed only to owner/operators. Owner/operators are required to familiarize themselves with the documentation, but are only required to post whatever they feel is pertinent. In the case of the Sizzler, owner/operators can elect to share only the information that will encourage broader ticket sales (i.e., low height limits), but not the safety recommendation that warns against letting children under 12 ride alone.

Owner/operators have told me that they won't post safety information like the Sizzler's intended use recommendation because regulatory officials might hold them accountable for enforcing general recommendations. Yet as things stand now, critical safety information is being withheld from consumers - in this case, parents - to protect owner/operators from unreasonable enforcement actions. That is neither fair nor safe. If owner/operators are able to post warnings about health-related interactions, then it should be possible to post warnings about age-related interactions. Children's lives are at stake here. Surely we can figure out a way to communicate safety recommendations to parents. Here are my suggestions:

• Define a standard category of information called "Recommendations to Patrons (RTPs)" that can be included in the manufacturer's documentation delivered with the ride and must be included in the warnings posted for patrons. RTPs are intended to provide general and/or specific guidance to help consumers in determining whether a particular ride is a safe choice for a particular person, but aren't to be interpreted by as regulators as operational restrictions. Explicitly defining RTPs as conduits of information to aid consumer choice, as opposed to operational restrictions, should address the needs of both owner/operators and patrons. In concept this isn't any different than posting recommendations regarding medical conditions that can create negative interactions on particular rides. Owner/operators aren't held responsible for keeping people with high blood pressure off rides. They post recommendations to patrons and leave the rest up to consumer choice.
• Require ride owner/operators to publicly post all manufacturers' recommendations pertaining to the safety of children. Parents should be fully informed of the risks and recommendations before they choose to put their child on any thrill ride.
• Require manufacturers to notify the CPSC about known hazards that have not been mitigated by mandatory design changes or guarding so that the CPSC can help consumers understand and avoid those hazards. The CPSC is the primary source of information, advice, and warnings about product safety interactions for U.S. consumers. The agency is trusted by parents and has an established communication network to effectively disseminate warnings and other safety information. Congress chose to exempt the amusement park industry from compliance with product safety rules, but that political favor shouldn't prohibit consumers (aka tax-payers) from using the public resources of the CPSC to help them keep their children safe from thrill ride dangers.
• Create a national ride registry so that parents can comparison shop for rides with child safety features. Consumers should be able to easily identify and patronize parks and carnivals that choose to provide reliable and safe containment systems for children. Saferparks is developing a production version of the Ride Information Depository and Exchange System to work toward this goal.

Nobody wants to see children hurt or killed by amusement rides. Accidents like this will continue to dog the amusement ride industry, damaging families and businesses, until manufacturers, owner/operators, and regulators collectively agree to change the dynamic. Children will continue to act like children no matter how lengthy and detailed the Rider Responsibility laws get. Older rides originally designed for teens and adults will continue to provide inadequate protection for children no matter how much moral outrage the industry whips up over these tragedies. The only responsible answer is to raise the height limits, revise the containment systems, or make sure parents know exactly what the industry knows about the safety records of those rides.

Let's solve this problem now for sake of the children. Please.

Epilogue - Part 1:  On February 6, 2006 Wisdom Industries issued a Safety Bulletin instructing customers who own Sizzler amusement rides to install a spreader tube and step plate in the lapbar immediately. The modification reduces the opportunity for a child to slide into an unsafe position while the ride is spinning. On January 31, 2006 Eli Bridge issued a Notification reminding customers that seat belts are strongly recommended, although not required, on Scramblers and Big Eli wheels.

Epilogue - Part 2: On February 4, 2006, two days prior to Wisdom's bulletin, a 5-year-old girl was forcefully ejected from a carnival Sizzler in California. The girl, who escaped serious injury, was riding with a 6-yo and 7-yo. Investigators determined that the child moved into an ejectable position while trying to reposition herself so she wouldn't squish her seatmates. California safety officials required an engineering review and design modifications to eliminate the ejection hazard for young children. The changes were only mandated in California, however. The ride is allowed to operate elsewhere despite the potentially lethal hazard.