Playground Surfaces: ADA Compliance vs. Safety vs. Cost
Submitted by Marc Dunker, Senior Loss Control Consultant

What materials are safe and ADA-compliant for playground surfaces? With so much conflicting information out there, it can be hard to know what to trust.
According to the U.S. Access Board, the following playground surfacing materials are acceptable for both ADA accessibility and fall safety:
Poured-in-Place Rubber (PIP)
Tiles (TIL)
Engineered Wood Fiber (EWF)
Hybrid Surface Systems (HYB)
Shredded rubber or rubber mulch – These may be acceptable, but it depends on the source. Mulch made from used tires is inexpensive but potentially toxic. While not currently banned, Minnesota discussed a ban in 2019, and future restrictions are possible. When in doubt, avoid tire-derived rubber.
No matter which product you choose, always purchase from a reputable playground engineer or contractor who can certify that the material meets ASTM F1951 standards for accessibility.
ADA Compliance is Not the Same as Safety
It’s important not to confuse ADA compliance with safety. For example, sand is technically considered a safe fall attenuation surface for very short fall heights (four feet or less), but it’s not ADA accessible—wheelchairs can’t roll through it. So, while sand might be safe in certain limited applications, it’s never ADA compliant.
Here’s a quick list of surfaces that are either unsafe, not ADA compliant, or both:
Sand – allowed for falls under four feet, but not ADA compliant
Pea gravel
Landscaping wood chips (not to be confused with Engineered Wood Fiber, which is compliant)
Concrete
Asphalt/tar
Grass
Shredded tires (especially from unknown sources)
Carpet
For detailed information, visit the U.S. Access Board’s play surfaces guide.
Protect Your City and Residents
When it comes to playground surfacing, the best approach is to work with trusted experts. Vendors should offer consultation and certify that their products meet safety and accessibility standards.
Cities should also protect themselves with:
A strong contract that outlines compliance requirements
A certificate of liability insurance
Provisions for reimbursement or correction if standards aren’t met
These steps help ensure your city isn’t left vulnerable if the product fails or the installation falls short. If you have further questions, please contact your League of Minnesota Cities Insurance Trust Loss Control Consultant.

