Since the nationwide SunSmart Early Childhood Program was introduced in 1998, more than 3500 childcare centres across Australia have been certified SunSmart. The program is voluntary and provides sun protection guidelines for participating centres to follow, including identification and use of shaded areas for outdoor activities.
The Cancer Council recommends centres conduct their own shade audits to ensure shade protection is adequate. However, Cancer Council Australia does not itself inspect or carry out shade audits as part of its SunSmart certification. According to a spokesperson: “Regulation is the responsibility of state governments, each of which has its own recommendations or guidelines for sun protection, shade in outdoor spaces and duty of care.”
With responsibility falling across different organisations – many with stretched resources to adequately police the sun protection policies of so many childcare centres – accountability is hard to pin down.
NSW under the microscope
Centres come under the responsibility of the Department of Community Services (DoCS), whose regulations specify that they must provide “adequate shade” based on Cancer Council NSW and NSW Health Department's Shade Guidelines for Childcare Services.
A DoCS spokesperson told CHOICE that departmental officers carry out “comprehensive inspections” of the physical environment of childcare centres to ensure they have an appropriate sun protection policy in place. However, what actually constitutes adequate shade is only broadly described in the official regulations.
Cancer Council NSW’s guidelines recommend that shadecloths have at least 94% UVR block (essentially a measurement of the amount of UV blocked out). But in NSW, using a shadecloth rated lower than the recommended 94% is not necessarily grounds for non-compliance.
“A shadecloth is but one of the physical aspects of outdoor play space that contributes to it being an adequately shaded area,” says the DoCS spokesperson. “It is unlikely that a children's service would be deemed non-compliant merely for not having a shadecloth with a minimum of 94% UVR block.”
She also says officers conduct unannounced and random checks on centres to check compliance with all regulations, including the centre’s sun protection policy and practice. One preschool in Macquarie Fields had its licence revoked in January 2008 for several breaches, including failure to provide adequate shade for outdoor play areas.
Archicentre, the building advisory service of the Australian Institute of Architects, voiced its concerns with the lack of understanding of what “adequate shade” means. “The regulation is in place, and self-regulation in part is already in place – the real problem is that people do not understand the regulation, much less comply,” says Angus Kell, Archicentre’s NSW/ACT state manager.
Between January 2007 and November 2008, WebShade, a professional shade auditing company, conducted audits of seven childcare centres and found none complied fully with regulations, despite two being SunSmart certified.
“The three key areas of non-compliance were inadequate UV protection levels of shadecloths, poor shade design and ineffective shading in open play areas. The managers of the centres also did not know how much UVR protection their shadecloths provided,” according to WebShade’s director, architect John Greenwood.