my address

delivery signature Sion Davies - hand delivered on 31/7/2019

Suzy Davies - AM for South West Wales,
Cornhill Chambers,
8 Christina Street,
Swansea 
SA1 4EW

30/7/2019

Dear Mrs Davies,

My wife and I took the Level 2 Award in Playwork Practice course hosted by Swansea Council in July 2018 and provided by Adult Learning Wales. We were both disturbed by the content of the course to the extent that we both refused to complete the course because we believed the content dangerous to children, even though my job depended on gaining the qualification. Some of things that concerned us are as follows:

A film where children chased each other with fire, a child received burns from unsupervised play with fire. Children fighting over the use of hammers, children playing with dangerous tools. Bullying and children enclosed in a zoo type environment, some attempting to escape from the bullies.

A film in which the course tutor acted inappropriately in a sexual manner towards a young child.

A system of deliberate delay in rescuing a child from a dangerous or life threatening situation.

Deliberate mis-representation of UNCRC Article 31, UNCRC General Comment 17 on Article 31 and Wales - a Play Friendly Country (2014). 

No effective risk management strategy.

Elevation of the importance of play above the safety of children.

That children should resolve conflict themselves through any means including fighting.

The course tutor a 60 year old woman constantly used the word "fuc*' and her catch phrase during the course was "if in doubt use fuc**** loose parts". Loose parts is a form of play using rubbish as play equipment based on a Landscape and Architecture magazine article dated 1972, the author who had no background in children's play later died of alcohol poisoning.

The only forms of play taught were: loose parts, playing with fire and placing children at risk during play where the playworker decides whether or not the child should be placed in a situation where they could die.

 

********

Subsequent research into the L2APP course has shown that the organisations Play Wales and Adult Learning Wales are responsible for the course content. The majority of the material is based on the teachings of Bob Hughes, author of "The First Claim" and an evolutionary playworker. Mr Hughes believes that children are a different species and should play wild, he believes they will benefit from the learning process that wild play without adults brings. For example he believes that every child should burn their fingers and that bullying is a form of hierarchy in the playground, he finds it entertaining that people find it difficult to cope with bullying. Bob Hughes idea of an ideal play area is an adventure playground built by the children themselves where the fittest reign supreme and everyone else is literally fighting for survival. He has introduced into the Welsh play curriculum 'deep play' which is children playing in life endangering situations such as playing in traffic and riding a bike on a parapet of a bridge or through fire. This, believe it or not, has been part of the WAG's play policy since its inception in 2002. 

You will note from the attached sheets that Bob Hughes source for 'deep play' is a 1972 article by C Geertz. We have researched the complete article "Deep Play: Notes on the Balinese Cockfight" which about the Indonesian obsession with gambling on cockfights. Geertz learned about this illegal pastime during a study visit to Bali in 1958. 'Deep play' refers to adult male gamblers who bet far higher stakes than they can afford to loose in cockfights. Geertz goes on to describe these gamblers as "irrational - addicts, fetishists, children, fools, savages who need only to be protected against themselves" (CGEE1972DPN015). Geertz uses the term 'children' to identify these adults as immature and unable to make rational decisions.  

The phrase 'deep play' was coined by Jeremy Bentham 1748-1832 in his "The Theory of Legislation" originally published in French and translated into English by Richard Hildreth in 1840 (source Stanford University website ). 

On page 15, paragraph's 4 and 5 of the 'Deep Play article' we see that both Bentham and Geertz find 'deep play' irrational as does Hughes, however both Geertz and Bentham suggest that it should be stopped, Bentham states it should be made illegal and Geertz that those partaking in 'deep play' need to be protected from themselves, meaning they should not take part in 'deep play'. Hughes on the other hand has introduced it into the Welsh play curriculum endangering the lives of Welsh children.

The article does not make reference to children taking 'high stakes' physical risks. The article is about adult males taking 'financial risks'. There is no correlation with child's play or 'children' taking 'life threatening' risks during play.

Even if it is good idea to place Welsh children in life endangering situations (which it is not). The Welsh Assembly Government funded publication "The First Claim" has deliberately mis-represented the term 'deep play' and we find that it is the WAG's play policy to place children's lives in danger based on this mis-representation.  

I am including evidence of this 'deep play' on the next few pages and I would ask whether or not you support 'deep play' as part of the playwork framework for Welsh children and whether or not you agree that children 'playing with fire' should be number one on the play curriculum? Please reply to the address above if you do, but if not I would hope that as an elected AM you would do something about it.

 

67-first-claim.jpg (479461 bytes)

42-edif-TFC.jpg (333266 bytes)

The organisation Play Wales is a Welsh Assembly Government (WAG) funded charity who advise the WAG on play policies.

In 2001 they published the "The First Claim" which is aimed at providing Welsh playworkers with a framework on which to judge their performance.

80-fire-top.jpg (121694 bytes) This framework included 'playing with fire as the number one play choice on the basic playworker curriculum. Playworkers are encouraged to offer children the opportunity to play with fire daily because nobody has been "prosecuted 

" for allowing children to burn?

75-deep-03.jpg (65435 bytes)  and 'deep play' as a choice on the intermediate framework. The framework has a scoring system from 1 to 4. If you always include a play type such as 'deep play' in your play sessions then you score 4 points. The more points you score, the better the playworker you are. 
41-wag-2002.jpg (317800 bytes) In 2002 the WAG stated:

"The Welsh Assembly Government recognises the significance and the value of play in children’s development and that children have an innate desire to seek out opportunities to take increasing risks. This is an essential part of their play and learning." - WGOV2002PPO004-06

They followed this statement with 

"The Welsh Assembly Government is committed to ensuring that all children have access to rich stimulating environments, free from inappropriate risk, and full of challenge, thereby offering them the opportunity to explore through freely chosen play both themselves and the world." - WGOV2002PPO004-07

The WAG state that "that children have an innate desire to seek out opportunities to take increasing risks" and If deep play is already on the play curriculum then it must be considered an appropriate risk that is "full of challenge". 

This means that since 2001 the Welsh Assembly Government's play policy has included 'deep play' and fire as the number one play opportunity.

40-deep-play.jpg (384911 bytes) If we look at the text within "The First Claim" Booklet we will see that the author believes that 'deep play'

"... is essential for a child's personal development"

The author is actually quoting and earlier (Hughes 1996a) work of his to provide this information.

he later describes 'deep play' as

CHILDREN PLAYING IN FRONT OF TRAFFIC

RIDING A BIKE ON A PARAPET OF A BRIDGE

RIDING A BIKE THROUGH A FIRE

HIGH TREE CLIMBING, ESPECIALLY OVER RIVERS OR THE SEA

PLAY IN WHICH THE STAKES ARE SO HIGH, THAT IS.. IRRATIONAL .. TO ENGAGE IN IT AT ALL

The source for this information is referenced as:

Geertz, C (1972) 'Deep Play : a Description of a Balinese Coackfight'. Daedalus, No 101

39-deep-play.jpg (622657 bytes) On checking the original artice by Geertz in 1972 we find that the conclusion reached by Bob Hughes in his 1996 publication has mis-represented the original work by Geertz:

In the original article "Deep Play: Notes on the Balinese Cockfight" is about the Indonesian obsession with gambling on cockfights. Geertz learned about this illegal pastime during a study visit to Bali in 1958. 'Deep play' refers to adult male gamblers who bet far higher stakes than they can afford to loose in cockfights. Geertz goes on to describe these gamblers as "irrational - addicts, fetishists, children, fools, savages who need only to be protected against themselves" (CGEE1972DPN015). Geertz uses the term children to identify these adults as immature.  

The phrase 'deep play' was coined by Jeremy Bentham 1748-1832 in his "The Theory of Legislation" originally published in French and translated into English by Richard Hildreth in 1840 (source Stanford University website ). 

Both Bentham and Geertz find 'deep play' irrational as does Hughes, however both suggest that it should be stopped, Bentham sates it should be made illegal and Geertz that those partaking in 'deep play' need to be protected from themselves, meaning they should not take part in 'deep play'. 

The article does not make reference to children taking 'high stakes' physical risks. The article is about adult males taking 'financial risks' 

There is no correlation with child's play or 'children' taking 'life threatening' risks during play.

"The First Claim" has deliberately mis-represented the term 'deep play' to place Welsh children in life threatening situations. 

 

As mentioned previously the content of the L2APP course was a deliberate mis-representation of UNCRC Article 31, UNCRC General Comment 17 on Article 31 and the statutory guidance Wales - a Play Friendly Country (2014). I have enclosed an analysis of this. It should be noted that the play as defined in L2APP is not voluntary play as defined by UNCRC and WAG. The L2APP play is playing with fire and loose parts, basically it is 'survival play' which is only a suitable form of play for a minority of children, for the rest it is confinement and survival. As you are on the 'children and young people committee,  I would ask that you please investigate my concerns please. If it helps you I have prepared a presentation which would provide information about how the L2APP course failed to meet the WAG & UNCRC guidelines through methods of manipulation and deception.

My initial contact with the WAG was with the Minister for Children in 2018 who refused to answer questions relating to the L2APP course, more recently I have been in touch with the AM for Neath Jeremy Miles who has deliberately manipulated information to protect the Minister for Children rather than investigating my concerns. I have included this information for your records.

yours faithfully

 

 

Dai Richards ( a concerned grandparent)  

 

 

 

 

current UNCRC deception info added

OVERVIEW

The Level 2 Award in Playwork Practice (L2APP) course is the entry level educational course required for workers in the play industry. It should follow the guidelines for children's play detailed in the following three documents. 

1. Wales - a Play Friendly Country - Statutory Guidance 38 pages published by Welsh Assembly Government - LINK TO THE DOCUMENT WALES - "A PLAY FRIENDLY COUNTRY" 2014 - (source code WGOV2014PFC)

2. United Nations Convention on the Rights of the Child - published by the United Nations 1989 - LINK TO THE DOCUMENT UNCRC RIGHTS OF THE CHILD - (source code UNAT1989CRC)

3. United Nations - General Comment 17 on Article 31 - published by the United Nations 2013 - LINK TO THE DOCUMENT UNCRC - GENERAL COMMENT 17 ON ARTICLE 31 (source code UNAT2013GCO) 

However, the L2APP course has a different agenda to and it uses methods of deception to avoid both Welsh Assembly Government and the United Nations guidelines. A link to the course booklet can be found below.  

 

L2APP Learner Resources - course booklet - 48 pages published by Play Wales 2018 -  LINK TO L2APP COURSE BOOKLET - (source code PWAL2018LAP)

 

 

ANALYSIS

The opening paragraph of the L2APP learner resources booklet begins: 

"The Level 2 Award in Playwork Practice (L2APP) has been developed to respond to the needs of the play and playwork workforce as defined in Welsh Government's statutory guidance, Wales - a Play Friendly Country (2014)." PWAL2018LAP001

Essentially the L2APP course needs to follow the guidelines of this document. If we look at the document Wales - a Play Friendly Country (2014) and it's introduction we will see that it aligns itself with the United Nations Convention on the Rights of the Child Articles 31, 15 and 12). From this document we can see that the Welsh Assembly Government have agreed to follow the UNCRC charter:

"Children’s right to play is enshrined in Article 31 of the United Nations Convention on the Rights of the Child (UNCRC). The Welsh Government formally adopted the United Nations Convention on the Rights of the Child in 2004, and we are committed to making the principles of the UNCRC a reality for all children and young people. There are three articles
which particularly relate to this duty: 

• Article 31 (Leisure, play and culture): Children have the right to relax and play, and to join in a wide range of cultural, artistic and other recreational activities, which must be read in combination with the General Comment No17 on the right of the child to rest, leisure, play, recreational activities, cultural life and the arts (art. 31): “The general comment seeks to enhance the understanding of the importance of article 31 for children’s well-being and development; to ensure respect for and strengthen the application of the rights under article 31”

• Article 15 (Freedom of association): Children have the right to meet together and to join groups and organisations.

• Article 12 (Respect for the views of the child): When adults are making decisions that affect children, children have the right to say what they think should happen and have their opinions taken into account.

In Wales play is established as one of children’s rights under Core Aim 4 – Play, Sport, Leisure and Culture, of the Welsh Government’s 7 Core Aims for Children, set out in Children & Young People: Rights to Action, 2004."
WGOV2014PFC002

Both the United Nations Article 31, General Comment 17 and Wales - a Play Friendly Country documents are quite clear in their definition of childrens' rights and those of the government; 

Article 31 states: "Children have the right to relax and play and to join in a wide range of cultural, artistic and other recreational activites" - UNAT1989CRC003

General Comment 17 confirms the Welsh Assembly Government's obligations: 

"(h) Training and capacity - building: All professionals working with or for children, or whose work impacts on children
(Government officials, educators, health professionals, social workers, early years and care workers, planners and architects,etc.), should receive systematic and ongoing training on the human rights of children, including the rights embodied in article 31. Such training should include guidance on how to create and sustain environments in which the rights under article 31 can be most effectively realized by all children" -
UNAT2013GCO003

(g)Participate freely: The right of children to participate freely in cultural life and the arts requires that States parties respect and abstain from interfering in the child’s access to, choice of and engagement in such activities, subject to the obligation to ensure the protection of the child and the promotion of the child’s best interests. States parties must also ensure that others do not restrict that right. The child’s decision to exercise or not exercise this right is his or her choice and, as such, should be recognized, respected and protected. - UNAT2013GCO008

"Wales - a Play Friendly Country" defines play as 

"Play is defined for the purposes of the measure as including “any recreational activity” (Section 11(6) Measure). The definition of play includes but is not limited to “any recreational activity”. This recognises that children enjoy and benefit from taking part in a wide range of activities that are, in the main, organised by adults for children. These can include junior and youth clubs; leisure centre and sporting activities; cultural and arts activities; indoor play centres, play buses and events organised for children and their families. These recreational activities may offer a combination of adult led organised activities, and opportunities for freely chosen and child led play. In any of these situations children should have the choice of taking part and a voice in what opportunities are offered and how they are organised. We see the range of play opportunities for children that are covered under the Measure as being:–

• Freely chosen Play – With or without adult supervision/facilitation.

• Structured recreational activities – in the main led by adults, with predefined rules.

These opportunities can be available in a range of spaces and settings and any setting may afford both opportunities for freely chosen play and structured recreational activities" -
WGOV2014PFC014-05

The definition of play quoted here in the 2014 is the legal definition taken from the Children and families (Wales) measure 2010. In a nutshell both the United Nations and the Welsh Assembly Government's policies indicate that a child is entitled to play, leisure, rest, recreation, the arts and cultural activities and the term 'play' covers all these. If we refer again to the first paragraph of the L2APP course.

"The Level 2 Award in Playwork Practice (L2APP) has been developed to respond to the needs of the play and playwork workforce as defined in Welsh Government's statutory guidance, Wales - a Play Friendly Country (2014)." -  PWAL2018LAP003

This being the case we would expect the L2APP course to follow the United Nations and Welsh Assembly Government's policies with regards to play covering the whole spectrum of play, recreational activities and rest. However it does not. If we refer to the very first paragraph of the course under the heading "Unit 1 - Understanding a Playwork Approach" immediately the course begins to follow its own agenda, the Playwork Principles. 

"Playworkers work according to the Playwork Principles. These are values and beliefs that playworkers have agreed are central to what we do. they describe what is special about play and playwork. They help to explain the role of the playworker and establish a professional and ethical framework for the playwork profession" - PWAL2018LAP006

The Playwork Principles are a collection of play related statements that were agreed by the Playwork Principles Scrutiny Group 2005. The Playwork Principles Scrutiny Group were a number of people who were invited by Play Wales to form a 'play focus' group. Play Wales motives in the formation of this group are questionable. 

CLICK HERE FOR MORE ABOUT THE PLAYWORK PRINCIPLES

The 'Playwork Principles' view of play is defined in the Playwork Principle 2:

2 - "Play is a process that is freely chosen, personally directed and intrinsically motivated. That is, children and young people determine and control the content and intent of their play, by following their own instincts, ideas and interests, in their own way for their own reasons" PWAL2018LAP007

Playwork principles 3, 4 and 5 state that the playworker should support this process and no other: 

"3 - The prime focus and essence of playwork is to support and facilitate the play process and this should inform the development of play policy, strategy, training and education."

"4 - For playworkers, the play process takes precedence and playworkers act as advocates for play when engaging with adult led agendas."

"5 - The role of the playworker is to support all children and young people in the creation of a space in which they can play."

Adult led agendas in playwork principle 4 is everything that is not instinctive play. - PWAL2018LAP012-07 - PWAL2018LAP012-07

This is the reason why on page 10 of the course booklet we find a major case of deception and manipulation by the L2APP course booklet author. The booklet author wants students to believe that the course follows the guidelines of United Nations Article 31 and General Comment 17 so rather than include the United Nations information alongside Wales - a Play Friendly Country in the background to the qualification, prior to the course start, which is its natural position, he has hidden it amongst the Playwork Principles, between numbers two and three. If we look at the wording of article 31 

"Article 31: 

1. States Parties recognize the right of the child to rest and leisure, to engage in play and recreational activities appropriate to the age of the child and to participate freely in cultural life and the arts. 

2. States Parties shall respect and promote the right of the child to participate fully in cultural and artistic life and shall encourage the provision of appropriate and equal opportunities for cultural, artistic, recreational and leisure activity." -
PWAL2018LAP010-08to09


We see that it suggests a broad range of interests for children including "cultural, artistic, recreational and leisure activity" then look at how Article 31 is represented by Play Wales:

"In effect, Article 31 says that children have a right to play and that governments should provide opportunities for children to play" - PWAL2018LAP010-10

If we refer again to the Play Wales definition of play which is:

"Play is a process that is freely chosen, personally directed and intrinsically motivated. That is, children and young people determine and control the content and intent of their play, by following their own instincts, ideas and interests, in their own way for their own reasons" 

We can see that the author here is attempting to mis-represent article 31. The author has just spent four pages drilling it into students what his definition of play is. To the author play is not rest, it is not recreation or leisure, and it certainly is not cultural activities, sport or the arts it is not even the Welsh Assembly Government definition of play which is:

"Play is defined for the purposes of the measure as including “any recreational activity” 

The author states that play is:

"......a process that is freely chosen, personally directed and intrinsically motivated. That is, children and young people determine and control the content and intent of their play, by following their own instincts, ideas and interests, in their own way for their own reasons"

...... and nothing else. Adults have no place in Play Wales definition of 'play. 

"Typically most professional people deal with outcome orientated aspects of the child's life, for instance education or health, and the outcomes are usually part of an adult agenda. Playwork however, deals with the child's agenda - play. Play is a process not an outcome, and is driven by the child for the child." PWAL2018LAP012-01202 - PWAL2018LAP012-02

"... children's innate drive to play, can be manipulated and used to determine outcomes determined by adults, examples include sport and education". We must be careful not to be distracted from our role as playworkers, fitness, crime reduction and education are agendas set by adults.... PWAL2018LAP012-p07

However General Comment 17 on Article 31 has a totally contrasting view of the role of adults in children's play.

Both play and recreation can take place when children are on their own, together with their peers or with supportive adults. Children’s development can be supported by loving and caring adults as they relate to children through play. Participation with children in play provides adults with unique insights and understanding into the child’s perspectives. It builds respect between generations, contributes to effective understanding and communication between children and adults and affords opportunities to provide guidance and stimulus. Children benefit from recreational activities involving adults, including voluntary participation in organized sports, games and other recreational activities." - UNAT2013GCO002-P03

Another form of deception can be found when Play Wales make an attempt to associate the Playwork Principles and Article 31 by placing Playwork Principle 1 on the UNCRC page without relevance. There is no text leading into or out of it, Playwork Principle 1 mysteriously appears for no known reason. A search of the documents Wales - a Play Friendly Country, UNCRC Rights of the Child and General Comment 17 will show that these documents do not mention the Playwork Principles. The reason for this is that the way L2APP wishes the way the Playwork Principles to be interpreted contradict the aims of both the United Nations and Welsh Assembly Government publications. This method of deception is repeated on page 40 where the author gives priority to the Playwork Principles above the health of children. 

Further to mis-representing Article 31 the document author has on page 11 completely glossed over the General Comment 17 content with a summary of the document. General Comment 17 is an extensive document which almost always partners 'play and recreation' together. 

"Play and recreation are essential to the health and well-being of children and promote the development of creativity, imagination, self-confidence, self-efficacy, as well as physical, social, cognitive and emotional strength and skills. They contribute to all aspects of learning; they are a form of participation in everyday life and are of intrinsic value to the child, purely in terms of the enjoyment and pleasure they afford. Research evidence highlights that playing is also central to children’s spontaneous drive for development, and that it performs a significant role in the development of the brain, particularly in the early years. Play and recreation facilitate children’s capacities to negotiate, regain emotional balance, resolve conflicts and make decisions. Through their involvement in play and recreation, children learn by doing; they explore and experience the world around them; experiment with new ideas, roles and experiences and in so doing, learn to understand and construct their social position within the world.  - UNAT2013GCO002-09

The only time we find the 'Play Wales' definition of play in the document is when it has to separated from recreation so that a legal definition of 'play' can be given. Here 'play' can be found alongside and is given parity with rest, leisure, recreational activities, cultural life and the arts. Recreation according to the UNCRC is any activity chosen voluntarily by a child. 

"Recreation is an umbrella term used to describe a very broad range of activities, including, inter alia,
participation in music, art, crafts, community engagement, clubs, sports, games, hiking and camping, pursuing hobbies."

The objective of L2APP is to remove the above structured play options and replace them with instinctive play only along with 'playing with fire', loose parts (playing with rubbish) and play through taking physical risks. 

The author is deceiving students so that he can promote the Playwork Principles and his definition of 'play' as opposed to the correct definition of 'play' which appears in the documents on which the course should be based "Wales a Play Friendly Country 2014" (“any recreational activity”), the UNCRC Article 31 ("Children have the right to relax and play, and to join in a wide range of cultural, artistic and other recreational activities") and General Comment 17 on this charter (rest, leisure, play, recreational activities, cultural life and the arts). 

This is deception which has no place in an educational publication or a government funded organistaion.

CONCLUSION

The L2APP course fails to meet its intended purpose which is. 

"The Level 2 Award in Playwork Practice (L2APP) has been developed to respond to the needs of the play and playwork workforce as defined in Welsh Government's statutory guidance, Wales - a Play Friendly Country (2014)." - PWAL2018LAP003 

WHAT IS THE PURPOSE OF THIS DECEPTION?

The deception employed by the Play Wales Organisation provides evidence that this organisation lacks integrity. A children's charity that's lacks integrity is a cause for concern. Initially one would think that the purpose of the deception employed is to secure funding ahead of other children's organisations such as sport, culture, arts, education, leisure etc. I would suggest that this is the case, however the course content is also dangerous to children and subversive. The focus on 'loose parts' and 'fearsome fire'  may point to additional motives of a more sinister nature. 

The objective of the course is to develop a workforce that deliberately places children in harm's way and creates vulnerable children through encouraging conflict and risk taking.