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April | 2020

This fact sheet provides clear guidance to people building new services or undertaking major upgrades of existing services. In particular it covers many safety aspects required at a service.

As an approved provider, you must ensure that ‘every reasonable precaution is taken to protect children being educated and cared for by the service from harm and hazard likely to cause injury’. This is a requirement of s. 167 of the Education and Care Services National Law.

This fact sheet provides information about what the Education Standards Board (ESB) considers to be ‘reasonable precaution’ required by approved providers to protect children from harm.

The following applies to all new service approvals from 1 November 2019.

New or existing building?

There are different options for setting up a new education and care service. One is building a new purpose-built premises. Another is refurbishing an existing building to convert it into an education and care service.

With either option, the building must meet certain requirements of the National Construction Code, including the Building Code of Australia (BCA) for a class 9b building It must also meet requirements of the Education and Care Services National Law (South Australia) (the National Law) and the Education and Care Services National Regulations (the National Regulations).

If you are intending to establish a new education and care service, you could consider designing and building a new centre-based education and care premises. This avoids the potential difficulties and constraints of working with existing buildings.

Certification is required to be submitted to the ESB clearly stating that the premises complies with building code requirements. In particular, it must have convenient access to:

  • toilets
  • hand washing
  • nappy change and bath facilities
  • natural light and window requirements.

The location

It is important to consider the suitability of a location for a new education and care service. Each local government area has its own planning controls and approval processes.

As part of the service approval application, you may need to conduct soil testing or provide a statement that, to the best of your knowledge, the site does not indicate it is likely to be contaminated in a way that poses an unacceptable risk to children.

In Australia, there is a national guidance document for the assessment of site contamination called the National Environment Protection (Assessment of Site Contamination) Measure 1999. It outlines the process for the assessment of site contamination.

Further information and advice about conducting soil assessments can be obtained from the Environmental Protection Agency.

Concept design

Before submitting an Application for service approval, you may wish to show us a concept or preliminary plan for feedback. This process is useful for identifying issues before any building work commences.

Facilities and physical environment

Information required with an application for service approval include:

  • site and floor plans prepared by a building practitioner showing the location of all buildings (including entries and exits), structures, outdoor play areas, shaded areas and boundary fencing, gates and elevation plans of the premises
  • detailed floor plan indicating all encumbrances and facilities provided, such as toilet and hand-washing facilities, nappy-changing bench and bath, food-preparation areas, including details of how the rooms will be used
  • calculations carried out by a building practitioner of the unencumbered indoor and outdoor space
  • plans of the outdoor learning environment specifying the landscaping and natural environments that will be provided.

The relationship of rooms and the interaction between the indoor and outdoor environments is an important factor in the design. The design of the building should:

  • facilitate effective supervision
  • allow children to easily move between spaces
  • provide convenient access to toilet and hand-washing facilities.

The National Quality Standard outlines characteristics of service facilities.

The pre-approval inspection

Before service approval is granted, the ESB will conduct a visit to the service premises to assess whether the premises is safe for the education and care of children. This visit is to reassure us that the provider has taken every reasonable precaution to protect children being educated and cared for by the service from any harm and hazard likely to cause injury. At this stage of the approval process, the education and care service should be ready to commence operation. All building works, fit-out and development of outdoor play spaces should be finalised before the pre-approval visit.

The following physical items relating to health and safety are inspected during a pre-approval visit:


Door finger guards

Severe injuries to children’s fingers can occur in education and care services. This can include amputations and crushing injuries.

These can be prevented by fitting finger guards to the hinge edges of doors that may be accessed by children. This includes both sides of the door or gate if each side is accessible to children.

Door finger guards must be fitted on new buildings and when undertaking renovations.

Common rooms where door finger guards are applicable include doors to:

  • children’s activity rooms
  • toilet areas
  • front entrances
  • offices or store rooms
  • staff preparation rooms
  • laundries
  • staff rooms.

This also includes children’s toilet cubicle doors, doors or gates to kitchens and reception areas. In some cases these doors may lead directly from children’s activity rooms or they may lead from corridors or passageways.

We have also seen an alternative hinge arrangement used on children’s toilet doors, creating a larger gap to prevent fingers being caught in the hinge side.

Cushioning devices

Doors that children may access must be self-closing, adjusted to a slow close using a cushioning device. This allows children time to react.

In high-traffic areas, doors should be able to be fixed in an open position by use of mechanical means, for example a cabin hook or drop bolt.

Doors that rely on the cushioning device to hold the door open can be blown shut by a strong breeze.

Cushioning devices alleviate crush injuries, and the self-closing and self-latching function ensures children do not have an opportunity to access unintended areas. 

Sliding doors can be fitted with stoppers that prevent the door being shut on a hand.

Bi-fold doors and foldable walls

Room dividers, such as bi-fold doors or foldable walls, should be effectively secured for adult operation only.

Secure doors in open position

For doors located in high-traffic areas for children, it is recommended the doors are able to be secured in an open position, when required. For example internal and external toilet doors and doors leading from children’s activity rooms to outside play spaces. The recommended securing position is preferably out of children’s reach, for example a high cabin hook located at 1500 mm may be used.

For high-traffic areas, in particular to toilet and hand-washing areas and to outside play spaces, door handles should be located at children’s height to:

  • provide easy access
  • avoid reliance on adult assistance
  • foster children’s independence with toileting and handwashing.

All sliding doors throughout the centre should be able to be secured in an open position and fitted with devices that prevent crushing of fingers.

Door handles

Door handles are to be fitted at approximately 1500 mm from the finished floor level to doors leading from corridor areas to children’s activity rooms and to areas not to be accessed by children. For example, doors leading to:

  • offices
  • staff rooms
  • storerooms
  • kitchens
  • staff preparation rooms
  • staff toilets (except disabled)
  • laundries
  • front entrance doors.

Trip hazards

There should be no trip hazards where different flooring surfaces meet.

Hot water

To ensure children’s safety, hot water delivered in areas accessible to children must be tempered to not exceed 45°C, with a recommended setting at approximately 40-42°C. For example, hand wash basins, bath taps, sinks, troughs and showers.


As per the Building Code, any glazing less than 1 m above floor height must be of safety glass standard in all areas accessible to children. For existing glazing, a qualified glazier may apply an approved film to achieve the same purpose.

Power points

In children’s areas, all unused power points should be covered with safety plugs at all times. Residual-current device (RCD) protection must also be installed and connected to all power points as per Building Code requirements.

Stairs and stairways

Stairs to nappy-change benches must be secured in a manner that is not accessible by children. The stair treads are to be non-slip. Hand rails should be provided for children where possible, to assist with children’s access. The Building Code of Australia may specify appropriate stair dimensions.

Additionally, stairways should be fitted with a childproof gate to prevent free access by children to upper levels.

Children’s hygiene

Soap dispensers and hygienic hand-drying facilities must be provided in children’s toilet areas. Foaming-type dispensers are recommended as their use presents less of a slip hazard than other liquid-type dispensers, which often drip.

Hygienic nappy-changing facilities must be provided. If a service accommodates children younger than three years, a properly constructed nappy-change bench is required with a bench-type baby bath and separate adult hand-washing facilities located within 1 m.

Emergency evacuation plan

Emergency evacuation plans with clear and concise procedures must be displayed in each children’s activity room. These must be adjacent to the exits that show the specific location and emergency evacuation routes to be taken to the nominated assembly point.

Blind cords

Blind cords pose a strangulation hazard and must be made inaccessible to children at all times. Cords should be secured in a position that is out of children’s reach, which ordinarily is at approximately 1500 mm above floor level, but may be higher if adjacent to cots or other play equipment.

Unobstructed viewing windows

Unobstructed viewing windows are to be provided to children’s toilet areas, nappy-change areas and sleep rooms to assist staff with effective supervision.


Fridges accessible to children must have childproof latches on them. Freezers are generally not placed in areas accessible to children.

Indoor space

Regulation 107 of the Education and Care Services National Regulations prescribes that, for each child being educated and cared for by the service, there must be at least 3.25 m2 of unencumbered indoor space.

When calculating unencumbered indoor space, the following areas are excluded, any:

  • passageway or thoroughfare (including door swings)
  • toilet and hygiene facilities  
  • nappy-changing area or area for preparing bottles
  • area permanently set aside for the use or storage of cots
  • area permanently set aside for storage
  • area or room for staff or administration
  • other space that is not suitable for children.

The area of a kitchen is also to be excluded unless the kitchen is primarily to be used by children as part of the educational program of the service.

If you want to include a verandah as indoor space, you need written approval. Please see our fact sheet on verandah areas counted as indoor space for further information.

Thoroughfare areas

Passageway or thoroughfare areas, including door swings, are not included as countable play spaces for capacity purposes, as they are not considered to be usable unencumbered space for children. These areas are determined to be used for the purposes of ingress and egress and, therefore, must allow for the safe movement of children and adults.

In these circumstances, 1 m2 for a single thoroughfare opening and 2 m2 for a double thoroughfare opening is deducted in each countable room along with the appropriate square metre deductions for built-in cupboards, sinks etc. that also present as encumbrances. This applies to all thoroughfare areas in and between children’s rooms regardless of where the thoroughfare areas are located or how doors are configured.

The resulting unencumbered play space is used to calculate the maximum number of children permitted at the service. (Consideration is also given to the amount of unencumbered outdoor space provided and number of children’s toilets and hand wash basins available.)

Children under three and small objects

Children under three should not have access to small objects (of a size that presents a choking hazard). This includes mulch and stones.

Kidsafe and ACECQA both publish information sheets on the value of outside play spaces and safety considerations. The ACECQA information sheet on babies and outdoor play recommends that anything smaller than a D-size battery is a choking risk.

The Australian Competition and Consumer Commission also provides guidance on buying safe toys and making a DIY safety tool for checking the size of small objects.


Fences and gates

Fences and gates must be of a height and design that prevent children preschool age or under from going under, over or through. It is important to ensure effective fence heights are maintained at all times by not locating objects or structures close by. A minimum 1.2 m clearance should be provided. Any gaps in fences or gates are not to exceed 100 mm, including gaps under or adjacent to structures or between vertical bars.

Self-closing and self-latching mechanisms on all perimeter gates should also be operating effectively. This can be tested by opening the gate to a variety of positions, such as approximately 25 mm open, half open and full open positions. In all circumstances, upon release, the gate should subsequently close and latch properly.

If kept locked, emergency access gates must have a key readily available and accessible to all staff for use in the event of an emergency.

Carparks and double gates for vehicle access

If a service has a double gate to allow for vehicle access, the double gate must be effectively secured at all times children are in attendance—with no gaps greater than 100 mm.

Where carparks are near main entrances, a suitably sized fenced holding area is recommended with self-closing, self-latching mechanisms fitted to gates.

Stormwater grates/drains

The diameter of grate holes of stormwater drainage should not be between 5-25 mm, as they could trap a child’s finger.

Surfaces under play equipment

A suitable impact-absorbing surface must be provided in the impact (fall-zone) area where free height of fall is 600 mm or greater to meet current Australian standards. For example if wood chips are used, a minimum depth of 300 mm is to be maintained at all times (installed at 400 mm).

A suitable impact-absorbing surface must also be provided for fall heights less than 600 mm where equipment causes a forced movement on the body of the user, e.g. swings, slides and rocking equipment.

An appropriate fall space clearance is also required. To meet current Australian standards, the impact area clearances provided around play equipment require a minimum impact zone of 1.5 m.

For example a fall height of 600 mm requires a minimum impact-attenuating zone of 1.5 m. This can increase proportionally as the free height of fall height increases, noting that the maximum fall height for an education and care service is 1.8 m. For such a height the fall zone area must be a minimum of 1.7 m. KidsafeSA has a useful information sheet on impact areas for further guidance.

The maximum free height of fall for moveable play equipment is limited to 1.5 m.

It is not recommended to include woodchip softfall in outdoor play areas for children under three years of age, as this is a potential choking hazard. (See also 'Children under three and small objects', below.)

If a rubber impact-attenuating surface is used, attention must be given to the temperature of the surface on hot days. This product absorbs heat readily and can cause burns to children.

A simple test is for an educator to hold their hand on the surface. If they can do so comfortably for five seconds, it is fine.

Seek guidance from KidsafeSA or a qualified landscape designer to meet the current Australian standards for playground safety.

Sharp corners, edges and rocks

Sharp corners and sharp edges on rocks and timbers must be made well rounded and smooth, e.g. sharp corners or edges on garden beds and borders, decking and boardwalks, balancing beams and sandpits.

Timbers on structures, posts, equipment and garden beds may require sanding to make them smooth. Otherwise they may be rough and likely to contain splinters.

Timbers used in the outside play areas are to be certified safe and free from any copper chrome arsenate (CCA) products.

Any large rocks that may be unstable are to be secured. Any stones located in the under-three outside play area must not be too small, as they may present a choking hazard to children. (See also 'Children under three and small objects', below.)

Protruding small branches with sharp ends are to be only above children’s head height.

Swings and fixed play structures

Swings and fixed-play structures must be suitable for the ages of children, meet current Australian standards and be installed strictly in accordance with the manufacturer’s instructions.

Hot-water services and air-conditioning units

Hot-water services and air-conditioning units are to be inaccessible to children at all times.

Tripping hazards

Tripping hazards in the outdoor play environment should not be evident, in particular on walkways and paved areas. However, the natural environment should include some uneven surfaces to provide a level of challenge and controlled risk-taking.

Outdoor supervision

The design and configuration of the outdoor play area should ensure that children can be actively supervised at all times. Children should not have free access to areas behind structures, such as storage sheds, cubby houses and water tanks.

Adequate outdoor shade

Adequate shade must be provided in all children’s outdoor play areas. This can be achieved through the use of shade structures, verandahs and plantings, such as trees and large shrubs.

Outdoor space

For each child, there must be at least 7 m2 of unencumbered outdoor space.

When calculating unencumbered outdoor space the following areas are excluded, any:

  • pathway or thoroughfare, except where used by children as part of the education and care program
  • car parking area
  • storage shed or other storage area
  • other space that is not suitable for children.

Similar to the calculation of indoor play space, either 1 m2 or 2 m2 is deducted per single or double thoroughfare opening to determine the total unencumbered play space. For example gates, doors leading from indoor areas and storage sheds, etc. are considered as encumbrances.

Children under three and small objects

See this topic, above under 'Indoors'.

Service approval

The ESB will normally only approve an application for service approval for a centre-based service once a site inspection has been conducted. This inspection is to verify that all the physical environment requirements have been met and that the premises is considered to be safe and suitable for children. At the time of the inspection, all building work must be fully completed.

Please note that a service approval will only be granted once the ESB is satisfied that all other matters as outlined in the National Law and Regulations in determining an application for service approval have been addressed.

Contact details

Education Standards Board
Phone: (08) 8226 0077 or 1800 882 413
Email: educationstandardsboard [at] sa.gov.au 

This fact sheet provides guidance for approved providers of education and care services to help them operate in line with the National Quality Framework. We also recommend referring directly to the legislation: