Saferparks Proposal:
National Child Safety Standards for Amusement Rides

• There are no standardized criteria for minimum height limits or containment systems for amusement rides approved for use by young children. Child safety standards defined in ASTM F2291 for kiddie rides do not apply to rides designed before 2003, and no child safety standards have been developed for full-sized amusement rides.
• Two thirds of all available government accident reports on falls and ejections from amusement rides involve children under 10.
• No government approval process exists to audit child safety protections before or after a thrill ride is put into service.
  • Amusement park rides are exempt from federal safety oversight, which is generally where product design issues like child safety standards are regulated.
  • Only 28 states have government inspection and accident investigation programs for amusement rides. Many of those states do not investigate accidents stemming from human error or require mitigation of chronic child safety hazards.

Proposed National Standards would ideally be passed as federal legislation, but could be introduced in each individual state/local jurisidiction.

1. Child Safety Containment and Supervision Analysis (CSCSA) aka "Child Safety Plan"

1. Each owner/operator shall produce a Child Safety Containment and Supervision Analysis (CSCSA) for any amusement ride that carries children under ten years of age, explaining their plan for keeping children safe during the ride cycle.
2. The CSCSA shall include:
   1. A photo of the ride and a photo of the containment system
   2. Patron boarding restrictions related to size, age, and/or weight
   3. Any requirements for companion or chaperone riders
   4. A narrative description of the restraint and containment features
   5. A list of any significant child safety hazards that have not been mitigated by design or guarding (i.e., those hazards that must mitigated by child riders and/or their companions).
3. If companion or chaperone riders are required for smaller children, the analysis shall specify the minimum recommended age and abilities of the chaperone, and the reason why a chaperone is considered necessary for safety (e.g., to comfort/reassure the child; to take up physical space on a bench seat so the child is more closely contained; to block access to open sides; to physically restrain children on rides designed without close-fitting restraints).
4. The CSCSA for each ride shall be made available for patron review at each carnival, amusement park, or private event where children under ten years of age are allowed onto the ride.

2. Minimum Standards for Containment on Amusement Rides (MSCAR)

• Amusement rides approved for use by unaccompanied children four years of age or younger shall have restraining systems that meet or exceed the retention requirements for shopping carts described in Section 6.2 of ASTM F2372, unless the CSCSA shows that children who stand up on the ride cannot fall far enough to inflict serious injury, be hit or run over by the ride, entrap body parts in the machinery, or encounter any other hazard that can reasonably be foreseen to cause serious injury.
• Amusement rides approved for use by children under ten years of age shall provide fall protection equivalent to that provided in the workplace under OSHA rules.
  • Owner/operators shall develop, document, and implement a Fall Protection Plan (FPP) for each amusement ride on which child riders are six feet or more above a lower level or are exposed to the hazard of falling into dangerous equipment.
  • The owner/operator's Fall Protection Plan shall address both the human and equipment-related issues in protecting child patrons from fall hazards.
  • Owner/operators may select fall protection measures compatible with the type of ride and range of patrons allowed on board.
• Where significant hazards have not been mitigated by design or guarding, a warning sign complying with ANSI Z535.4 shall be prominently posted at the entrance to the queue and at the entrance to the ride, on or near the sign listing patron rules and restrictions.
  • The warning sign's message shall alert viewers to the nature of the hazard(s), the consequences of interaction with the hazard(s), and how to avoid the hazard(s).
  • Where the CSCSA indicates that small children must ride with a chaperone or companion in order to protect the child from exposure to significant hazards, a sign as described in section (2)(c) shall be posted warning patrons that 1) the ride's containment system is not designed to sufficiently protect small children and 2) the companion rider is wholly responsible for keeping the child safely contained throughout the entire ride cycle.

Federal government provides support to and incentive for state/local agencies that monitor and enforce compliance with National Child Safety Standards for Amusement Rides.

• State and local agencies with government-led inspection programs can modify their regulations to require that the Child Safety Containment and Supervision Analysis be submitted and approved as a part of the ride approval/permitting process. Regulatory approval may be withheld in cases where the CSCSA relies on equipment or policies that have a documented history of containment failure involving young children.
• During operational inspections, ride inspectors should check to make sure that the CSCSAs have been made easily available to the public, and verify that the operator/attendants are following the plan outlined in the CSCSA.
• If an accident occurs in which a child falls or is ejected during the ride cycle, the CSCSA can act as a blueprint to help investigators (public or private sector) identify which element(s) of the safety plan failed, and whether additions or changes to the CSCSA are necessary to prevent a recurrence - on that ride or others that rely on similar child safety plans.
• The Federal government could offer supplemental funding to states that actively enforce compliance with the National Child Safety Standards for Amusement Rides.

• The proposed National Child Safety Standards for Amusement Rides offer uniform protection to all children under ten who use amusement rides, without regard to arbitrary divisions in public/commercial policy. Protection is child-centered rather than machine-centered. Children are protected on rides operated by amusement park companies and carnival companies. Children are protected on machines designed in the 1800s, the 1900s, and the current century. Children are protected on kiddie rides and on full-sized rides.
• The National Child Safety Standards for Amusement Rides represent a flexible, risk-based approach to child safety. They do not conflict with existing industry standards, but simply expand the risk analysis approach into the area of child safety. The NCSSAR complement the current industry standards for amusement rides and the ASTM F-24 committee's plan for reorganization.
• The cost of compliance would be minimal for rides that are designed to safely contain the full range of riders allowed on board. This creates market incentives for child-safe design of kiddie and family rides, and child-protective minimum height limits on wilder rides with older, less-secure containment systems.
• Parents would have a way to review the manufacturer's or owner/operator's child safety plan for a ride before entrusting their child's life to it. Conflicting assumptions/expectations between industry and consumers are a major contributing factor in serious child safety accidents involving amusement rides. Providing consumers access to the child safety plan gives parents the opportunity to make informed decisions and better protect their children from hazardous situations. It also establishes market incentives for child safe design of amusement rides used by children.
• Serious thrill seekers (adults and teens) should be largely unaffected by the requirements of NCSSAR. Extreme rides, particular the newer designs, are more likely to have containment systems that closely and reliably contain each individual rider and, therefore, provide riders of all ages with an OSHA-equivalent level of fall protection. NCSSAR is intended to target child safety. It respects the difference between older riders seeking serious thrills with a hint of danger, and parents who want their small children to experience a pleasant day of novel-yet-safe entertainment.
• NCSSAR does not interfere with or threaten existing regulatory laws or exemptions. Rides operated in venues that are currently exempt from regulatory oversight will not be subject to any additional enforcement. State and local governments can decide on their own whether to monitor/enforce compliance with the National Child Safety Standards for Amusement Rides.
• Proposed Federal incentives would reward state and local regulatory programs that choose to actively oversee children's safety on amusement rides. The extra funds could be used by existing programs to allow regulatory officials to participate in industry standards development, attend safety seminars, improve data collection and communication between agencies, fund ride-safety public education campaigns, or hire additional inspectors. Federal incentives could also make it easier to initiate government inspection programs in the 22 U.S. states that do not yet have one.
• The NCSSAR would be most useful if implemented as federal law, but the proposed standard requirements could be incorporated into state and local laws and regulations. Click here to view Saferparks' proposed addition of NCSSAR requirements into New Jersey's amusement ride regulations.

• Saferparks Report on Falls/Ejections (July 2006)
• Government Records - All Ages
• News Reports of Falls/Ejections Involving Children