Who Should Commission Level 3 Playground Audits?

Rethinking Independence, Governance, and Risk in Urban Councils

Playground audits play a critical role in managing safety, compliance, and risk across public open spaces. As playground assets age and expectations around child safety, governance, and accountability increase, many councils are reviewing not just how audits are undertaken, but how they are commissioned.

In particular, there is growing discussion around the appropriate role of facilities management contractors (FMCs) versus asset owners when commissioning Level 3 playground audits.

This article explores the issue from a governance perspective and outlines common audit commissioning models currently in use across New Zealand.

What is a Level 3 Playground Audit?

A Level 3 playground audit is generally understood to be a comprehensive, technical assessment of playground safety and compliance. Unlike routine operational inspections,

Level 3 audits typically include:

• assessment of free height of fall and spatial relationships

• review of impact attenuating surfacing performance

• structural integrity evaluation

• identification of inherited compliance and design risk

• prioritisation of findings based on injury potential

Because of this scope, Level 3 audits are often relied upon for:

• governance assurance,

• liability management,

• insurer confidence,

• and post-incident scrutiny.

This distinction is important when considering who should commission and control the audit process.

The Current Landscape: How Audits Are Commissioned

Across New Zealand, two broad approaches are commonly observed.

Provincial and Regional Councils

Many provincial councils engage independent playground auditors directly, recognising Level 3 audits as a governance and risk-assurance function. Audit findings are then provided to maintenance contractors for response and rectification.

Large Urban Councils

In larger urban environments, Level 3 audits are often commissioned via the primary facilities management contractor as part of broader parks and open-space delivery contracts.

Both approaches are functional. However, they carry different implications for independence and governance.

Independence and Perceived Conflict

A recurring consideration in audit commissioning is independence — not just actual independence, but perceived independence.

Where the party commissioning the audit is also:

• responsible for rectifying findings,

• exposed to cost and performance KPIs,

• or managing asset condition outcomes,

there can be an inherent tension between:

• comprehensive risk identification, and

• commercial efficiency.

  
  

This does not imply poor intent or practice. Rather, it reflects a structural incentive that is common across many asset management environments.

For high-risk assets such as playgrounds, councils are increasingly asking whether this model provides sufficient separation between:

• independent risk identification, and

• contract delivery responsibilities.

  
  

Why This Matters for Playground Assets

Playgrounds are unique within council asset portfolios. They are:

• used primarily by children,

• highly visible to the public,

• subject to injury and coronial scrutiny,

• and often assessed retrospectively following incidents.

In these contexts, the key question is not:

“Was the audit efficient?”

but rather:

“Was the audit independent, comprehensive, and defensible?”

Councils are increasingly expected to demonstrate that safety risks were not only inspected, but appropriately escalated and documented, regardless of cost or inconvenience.

Common Audit Commissioning Models

Across the sector, three models are typically observed:

Model A – FMC-Commissioned Audits

The facilities management contractor commissions and manages the audit process.

Advantages

• operational efficiency

• minimal administrative overhead

Considerations

• perceived conflict of interest

• audit scope may be influenced by delivery incentives

Model B – Council-Approved Audit Panels

Council establishes an approved panel of independent Level 3 auditors. Auditors are engaged either directly by Council or selected by the FMC from the approved panel.

Advantages

• improved independence

• resilience in delivery

• clear scope control by the asset owner

This model is increasingly viewed as a pragmatic balance between governance and operational delivery.

Model C – Council-Direct Audit Commissioning

Council commissions the Level 3 audit directly as a governance function. Findings are then provided to the FMC for pricing and rectification.

Advantages

• maximum independence

• strong governance alignment

• clear audit ownership

This model mirrors approaches used for financial audit, health and safety assurance, and structural peer review.

A Shift in Thinking

Rather than viewing Level 3 playground audits as a maintenance activity, many councils are beginning to frame them as a risk-assurance function.

This shift aligns with broader public-sector trends:

• separation of assurance from delivery,

• increased scrutiny of perceived conflicts,

• and stronger expectations around defensibility.

Importantly, this is not about criticising existing arrangements, but about future-proofing governance models as playgrounds age and expectations rise.

Final Thoughts

There is no single “correct” audit commissioning model. However, for urban councils managing large and complex playground portfolios, it is timely to consider whether current arrangements adequately support:

• independence,

• transparency,

• and long-term risk management.

As expectations continue to evolve, the question may become less about who can deliver audits most efficiently, and more about who should own the assurance process.

By Adam Stride