Why Test Criteria for Play Structures Above 10-ft?

We are reviewing a proposed indoor play structure that is taller than 10-ft in height.

Do these structures need to be tested in accordance with ASTM E1354 and NFPA 701?

This project is under the California Building Code. Within CBC Section 424 - Children's play structures, 

• Play structures installed inside all occupancies covered by this code that exceed 10 feet (3048 mm) in height or 150 square feet (14 m2) in area shall comply with Sections 424.2 through 424.5.
  
• 424.2 Play structures shall be constructed of noncombustible materials or of combustible materials that comply with the following:...
  
• 424.2 (6) Plastic materials used to construct rigid components of soft-contained play equipment structures (such as tubes, windows, panels, junction boxes, pipes, slides and decks) exhibiting a peak rate of heat release not exceeding 400 kW/ m2 when tested in accordance with ASTM E1354 at an incident heat flux of 50 kW/m2 in the horizontal orientation at a thickness of 6 mm.

The consultant proposes the following:

• All of the combustible materials are “consumer grade” and carry test certificates stating compliance with NFPA 701 “Standard Methods of Fire Tests for Flame Propagation of Textiles and Films” as well as ASTM E84, “Standard Test Method for Surface Burning Characteristics of Building Materials”. The materials are not classified as “fire resistant” but are manufactured to the same fire safety standards as household products such as mattresses, plastic furniture, upholstery, and carpet. Unlike synthetic fibers (which contain trapped air), molded/extruded plastics and films are solid and have higher auto-ignition temperatures. The polyurethane foam is classified as “fire retardant”, and this material is likely the easiest of all the materials in this assembly to involve in a fire, however, this installation is located in a building where there are few – if any – potential sources of heat and ignition that would be robust enough to involve it in a fire. 

I don't see this proposed structure being compliant with ASTM E1354.

Is there a significant increase in fire-hazard for playground areas and structures when they are above 10-ft in height, which requires the plastics to be compliant to E1354 (and textiles and plastic foams to NFPA 701)?

Thank you all very much for your time and technical input.

​​​​​​​​​​​​​​​​​​​​​​​​​​​Sent in anonymously for discussion. Click Title to View | Submit Your Question | Subscribe