Perspectives on lightning safety risk management in sport and recreational activities

Transcription

1 WORLD LEISURE No O Coovrioht bv the authors Perspectives on lightning safety risk management in sport and recreational activities JOHN 0. SPENGLER, DANIEL F! CONNAUGHTON, JEFF EARNSHAW University of Florida Abstract Lightning is typically considered the most dangerous weather hazard for those who engage in outdoor sport and recreational activities. It is estimated that lightning strikes somewhere in the world about 100 times every second and kills approximately 1,000 people a year worldwide (Long, 1999). The risk associated with lightning is both a safety concern and a liability concern for sport and recreation managers. Management is often faced with difficult decisions regarding the implementation of lightning safety policies and procedures. The purpose of this article is to address the issue of implementing lightning safety policies and procedures through an analysis and discussion of legal concerns relevant to lightning safety, emerging technology for predicting and monitoring lightning, current recommendations and guidelines for lightning safety policies and procedures, and lightning-related research. Professional associations that have published and/or adopted specific management directed lightning safety policies and procedures are (I) the National Athletic Trainers Association (NATA), (2) the American Meteorological Society (AMS), (3) the National Federation of State High Schools' Association (NFSHSA), (4) the National Collegiate Athletic Association (NCAA), and (5) the United States Golf Association (USGA). Recommendations from these groups are summarized and implications for lightning safety education are provided. Keywords: risk, policy, procedures, legal, lightning, safety, recreation, sport. Much of the appeal of sport and recreational activities is that they provide an opportunity for outdoor activities. These activities, however, also have the potential to place participants in harm's way if severe weather arises. Therefore, weather is a key concern for those who manage and program outdoor sport and recreational activities. Of all weather hazards, lightning is typically considered the most dangerous. Given the relevance of lightning as a safety hazard to sport and recreation managers, the purpose of this article is to address the dangers associated with lightning and the importance of lightning safety, and to identify the associated legal concerns for managers. Legal concerns are addressed by a discussion of case law, and issues potentially influencing the standard of care such as emerging technology, lightning safety guidelines and recommendations, and a review of the research as it pertains to sport and recreation risk management and severe weather. Importance of Lightning Safety At any given instance, there are approxi- t mately 2,000 thunderstorms in progress

2 SI- The World's Leading This material has been copied under license from the Publisher. Sgo" Rrsrarrh Inldlllcncc rsonlrr Sport Resource Centre &- Any resale for profit or further copying is strictly prohibited. Perspectives on lightning safety risk management in sport and recreational activities somewhere on the earth (Kithil, 1998). This amounts to approximately 16 million thunderstorms every year (Franklin, 2002). Worldwide, almost 50,000 thunderstorms and 8 million lightning flashes occur every day (Fahmy, Brinsden, Smith, & Frame, 1999). It is estimated that lightning strikes somewhere in the world about 100 times every second. Using advanced satellites, NASA scientists have recently been able to map the global distribution of lightning. The frequency of lightning strikes increases in the lower latitudes (nearer to the equator) and in the higher altitudes (mountainous terrain). In the United States, central Florida experiences an unusually high number of strikes ( strikes per sq. kmlyr.). Central Africa, areas in Southeast Asia, and the mountain regions in Latin America may experience two to three times as many lightning strikes as central Florida (Kithil, 1998; Price, Barry, & Phillips, 2001). Worldwide, lightning kills approximately 1,000 people each year (Long, 1999). However, many authorities report that the number of lightning-related deaths is underreported (Cwinn & Cantrill, 1985; Fahmy et al., 1999; Holle & Lopez, 1999; Long, 1999). Lightning strikes throughout the world have been responsible for many notable tragedies involving sport and recreational activities. For example, in 1998, lightning killed 1 1 soccer players in Congo, Africa. In 2001, in Mexico City, 6 teenagers were killed when lightning struck during a soccer game. Also, in 2001 and perhaps most notably, lightning killed 5 and injured over 100 people at a soccer game in Malawi, Africa (National Weather Service, 2002). In the United States, lightning ranks second only to floods as the leading cause of death from weather-related hazards (Holle & Lopez, 1999). It is estimated that 100 people are killed and 1,000 more are injured by lightning each year (Cherington, 2001). Additionally, the majority of deaths and injuries from lightning occur to individuals involved in sport and recreational activities. Aquatic activities, golf, baseball, and camping have been identified as those most prominent in lightning-related injuries and deaths among sport and recreational activities (Alexander, 1999). For example, in 1990, there were 147 people injured and 32 killed in lightning-related injuries related to golf alone (Alexander, 1999). Lightning safety issues are very important to sport and recreation managers who plan and supervise organized outdoor sports activities. There are several reasons why an understanding of lightning safety is important. The reasons are related to the timing of lightning strikes and when most outdoor sports and recreational activities occur. Research indicates that approximately 70% of all lightning deaths and injuries occur outside and in the afternoon (Bennett, 1997). Specifically, "the greatest number of lightning casualties occur between the hours of 10 a.m. and 7 p.m., with the greatest risk concentrated between 2 p.m. and 6 p.m." (Schultz, Zinder, & Valovich, 2001, p. 16). Additionally, the time of year is also a factor in the probability of lightning strikes. Lightning strikes are most likely to occur between late Spring and early Fall, the most popular seasons for outdoor sport and recreational activities. (Walsh et al., 2000). Legal Concerns There are legal risks associated with lightning where sports or recreational activities are supervised or managed. Lightning-related injuries and deaths in the United States have resulted in negligence claims brought against managed sport and recreation facilities such as golf courses, recreation and park departments, and aquatic facilities. In the United States, negligence lawsuits are common in sport and recreation settings. Negligence is defined as conduct that falls below the legal standard that has been established to protect people from an unreasonable risk of harm (Black, 1979). For injured persons to recover monetary damages for negligence, they must prove (1) a standard of care (duty) which a sport or recreation manager must meet, (2) a failure to meet the standard of care, (3) a connection between the failure to conform to the standard of care and the injury, and (4) some actual physical or psychological injury (Presser, 1980). The following cases provide examples of United States case law where negligence was claimed due to an alleged

3 SI- Sgo" Rrsrarrh The World's Leading Sport Resource Centre This material has been copied under license from the Publisher. &- Any resale for profit or further copying is strictly prohibited. Inldlllcncc rsonlrr John 0. Spengler, Daniel F! Connaughton, Jeff Earnshaw failure to meet the standard of care in providing reasonable protection from lightning. United States Case Law and Legal Issues The following case provides an example of a negligence lawsuit where several people were injured and killed from a lightning strike in a city park. In the case of Bier v. City of New Philadelphia (1984), a group was enjoying a picnic at a city pork when a thunderstorm approached. The group was under the cover of a metal-roofed picnic shelter packing up their supplies, when a bolt of lightning stuck the shelter, resulting in the death of Mr. Bier and injury to the remaining group members. It was shown that the metal roof attracted the lightning to the structure, and there were no lightning protection measures in place. A key issue in the case was whether the defendants failure to install a lightning protection system on the metal-roofed picnic shelter was a cause of the injuries and death. The Ohio Supreme Court reversed the ruling of the lower court that had found in favor of the defendant. The case was sent back to the trial court for a jury to determine whether the unprotected shelter was a concurrent cause of the plaintiff's injuries and death. Numerous United States legal cases exist where lightning strike victims or their families have sued golf course management for negligence (Tonner, Sawyer, & Hypes, 1999). The following cases are provided for illustration. In Hames v. State (1991), Phillip Hames was killed by a lightning strike that occurred during a round of golf at a course owned and operated by the State of Tennessee. When Hames and two other golfers began to play the weather was overcast, but there were no signs of an imminent thunderstorm. There were no weather shelters on the course, nor were there any signs instructing players of what should be done in case of severe weather. After a thunderstorm had passed, the three players were found unconscious on the course, about 800 yards from the clubhouse. The course professional testified that it would have taken less than two minutes to reach the clubhouse by golf cart. The widow of Phillip Hames sued for wrongful death because there were no weather shelters, warning systems, or signs that indicated what to do in case of severe weather. At trial, there was testimony from experts that there were no recognized standards that stipulated golf courses be equipped with shelters or warning devices. The Court ruled that because lightning is so highly unpredictable, it is not reasonable to require management to anticipate when and where it will strike (Hames v. State, 1991). The Court further noted that it was significant that there were no industry standards regarding lightning detection and prevention. In a more recent case, Maussner v. Atlantic Citv Country Club, Inc. (1 997), the Court also examined the issue of whether golf course owners owe a duty of care to protect players from lightning. The case was brought after Spencer Van Maussner was struck by lightning while playing golf at the Atlantic City Country Club where he was a member. A snowstorm was predicted for that day, but after Spencer's group had played two holes, it began to rain heavily. One of the players noticed a lighting bolt and the players began making their way back to the clubhouse that was about one-half mile away. There were no weather shelters along the way to the clubhouse for the players to use. While crossing one of the fairways on the way back to the clubhouse, Maussner was struck by lightning, causing him substantial injuries. The Club generally monitored the weather by listening to the weather advisory channel and calling the National Aviation Facilities Experimental Center. That morning there were no warnings of lightning, although inclement weather was predicted. The Club did not possess any lightning detectors or a warning system. The Club did however, have an evacuation plan where employees would remove golfers from the course when there were signs of lightning. The Club also encouraged golfers to take refuge in private homes along the course during severe weather. The Club claimed to have United States Golf Association (USGA) posters on lightning safety in the locker room on the day of the incident, but Maussner claimed that they were posted after the incident. Maussner also stated that it was not

4 SI- The World's Leading This material has been copied under license from the Publisher. Sgo" Rrsrarrh Inldlllcncc rsonlrr Sport Resource Centre &- Any resale for profit or further copying is strictly prohibited. Perspectives on lightning safety risk management in sport and recreational activities communicated that they would be able to seek shelter in private homes. The Court recognized that new technology can allow golf course management to detect the existence of lightning. Although the Court did not rule that golf courses have an absolute duty to protect golfers from lightning strikes (a factor being cost), it did say that when a golf course has procedures in place to protect golfers from lightning strikes, it owes the golfers a duty of reasonable care to implement those lightning safety procedures properly. A traditional defense to negligence lawsuits in the United States involving lightning-related injures was the argument that lightning strikes were unforeseeable acts referred to as "Acts of God." The legal implications were that the recreation and sport manager was afforded protection from negligence liability when a patron was struck by lightning on their property since they had no duty or responsibility to individuals for situations such as severe weather conditions that were unforeseeable and beyond their control. Today, however, there are increased expectations that sport and recreation managers will protect their participants and users from lightning (Shadiack, 1998). These expectations have arisen from advances in technology, and a better understanding of the nature and potential occurrence of lightning strikes which has had the effect of making lightning strikes a more predictable force and, arguably, more foreseeable (Shadiack, 1 998). Emerging Technology As noted, the ability to predict severe weather and lightning has been and will be influenced by emerging and future advances in technology. This in turn should make lightning strikes a more predictable force, and subsequently more foreseeable. The legal implications are that a hazard that is foreseeable raises the standard of care imposed on managers to protect patrons from that hazard. Ethically, emerging technology that allows management to better predict and prepare for lightning strikes is favorable since it has the potential to decrease injuries and save lives. Legally, however, the ability to predict lightning might have negative consequences for the sport and recreation manager given that the standard of care for lightning safety is likely to increase along with potential liability. Advances in technology are likely to continue and it is incumbent upon sport and recreation managers to understand the technology that is available and the possible legal consequences of using or not using this technology. Technology in the area of preventing lightning injuries and fatalities has progressed rapidly over the past several years. Three common technologies include lightning detectors, lightning predictors, and lightning monitors. The first of these systems, lightning detectors, are local devices that detect when lightning has occurred within a certain limited range. These detectors can be hand-held and are relatively easy to operate. Lightning predictors, unlike lightning detectors, measure atmospheric conditions that are most favorable for lightning strikes. An example of a prediction system is the "Thor Guard '"" system used by the Professional Golfer's Association (PGA) during tournaments. This system claims to predict the probability of lightning within a twenty-five mile radius and sounds loud horns if conditions are threatening. However, this system is expensive, costing over $50,000 ( 2002). Lighting monitors use various weather networks to track storms. This may range from sophisticated systems to weather radios that will sound alerts from the National Weather Service. The most basic of these radios can cost as little as $20 and are portable (Kithil, 2000). The lnternet has also become a useful tool for tracking storms. Online tools can help sport and recreation managers access weather alerts, forecasts, and even real-time information on storm systems that will help them to better understand when lightning may become a threat. Some systems use a combination of approaches (Kithil, 2000). For example, a system operated by Global Atmospherics, Inc. uses information that is displayed on the lnternet from sensors throughout North America. This system maps where lightning is located and where it is heading. This information is dis-

5 SI- Sgo" Rrsrarrh The World's Leading Sport Resource Centre This material has been copied under license from the Publisher. &- Any resale for profit or further copying is strictly prohibited. Inldlllcncc rsonlrr John 0. Spengler, Daniel F! Connaughton, Jeff Eornshaw played on a detailed map that shows lightning strikes as they happen. In this way, officials can determine if lightning is heading toward a sport or recreational event, how quickly it is approaching, and then communicate with the appropriate supervisors on the scene (Keen, 2001). The system1 can be used for a variety of sport and recreational events. If the system calls for the stoppage of play during an organized sports event, such as a football game, spectators will be notified and allowed to leave the stadium. They may return later when conditions are safe and play has resumed (Keen, 2001 ). As new technologies continue to improve and become less expensive, the use of detection, prediction, or monitoring devices may become a standard practice for sport and recreation managers. This would have the effect of raising the standard of care to include the provision of these types of devices. Also, the cost of some of the communication systems and portable detectors is minimal. At minimal expense, sport and recreation managers should not be unduly burdened by the cost of these devices. Lightning Safety Recommendations In addition to emerging technology, another recent development is the publication of position statements of recommendations and guidelines for lightning safety in the context of sport and recreation by professional associations. These recommendations potentially have the effect of increasing the standard of care for sport and recreation managers if future Court decisions require adherence to published lightning safety recommendations or guidelines. Sport and recreation managers should therefore be aware of professional associations that have lightning safety recommendations or guidelines that are relevant to their programs. If they wish to follow the recommendations, they would ultimately need to develop a risk management plan that addresses lightning safety and identifies policies and procedures designed to reduce the risk of injury and death to participants from lightning. Professional associations relevant to the field of sport and recreation management that have published and adopted lightning safety recommendations include the National Athletic Trainer's Association (NATA, Walsh et al., 2000), the National Federation of State High School Associations (NFSHSA, Schultz, Zinder, & Valovich, 2001), the National Collegiate Athletic Association (NCAA, 2001 ), and the United States Golf Association (USGA). The National Athletic Trainers' Association (NATA) has publishcd a position statement on lightning safety for athletics and recreation (Walsh et al., 2000) which other associations have adopted in some form. The recommendations are also similar to those set forth by the American Meteorological Society (AMS, Holle & Lopez, 1999). The National Athletic Trainer's Association has been instrumental in formulating lightning safety recommendations that are focused on both sports and recreation. The NATA recommends the formulation and implementation of a "comprehensive, proactive lightning safety policy or emergency action plan specific to lightning safety" (Walsh et al., 2000, p. 472). The NATA identified six essential components of a lightning safety policy or emergency action plan. First, organizations should designate a person in their organization with the authority to remove participants from sport and recreational activities in the event of lightning. This person would undergo formal training in lightning safety identification and emergency procedures. Second, a weather watcher should be appointed who looks for indications of threatening weather and notifies the person with authority to cancel or suspend play if severe weather becomes dangerous. Third, a method for monitoring lightning associated with approaching storms should be identified. It is recommended that monitoring consist of both watching the sky, and implementing another form of monitoring through electronic means. Fourth, it is recommended that safe siructures for seeking shelter from lightning be built, properly identified, and placed in areas where they can be quickly accessed if needed. Dugouts and other buildings that are not grounded should be discouraged for use in lightning storms.

6 SI- - SpOn Rlrearrh Inrclllgcnee rpomvr This material has been copied under license from the Publisher. The World's Leading Sport Resource Centre &- Any resale for profit or further copying is strictly prohibited. Perspectives on lightning safety risk management in sport and recreational activities Fifth, it is recommended that specific criteria for suspending and resuming sport and recreational activities be implemented. It is recommended that a flash-to-bang count be used to determine when play should be suspended. The flash-to-bang count represents the time between when a flash of lightning is seen and the associated thunder is heard. If there is a 30-second or less interval between the flash of lightning and the sound of thunder, the immediate evacuation of participants from the outdoors to a safe shelter is recommended (Cooper, Holle, & Lopez, 1999). For resuming play, it is recommended to wait at least 30 minutes after the last lightning strike is seen or thunder is heard (Schultz, Zinder, & Valovich, 2001). Lastly, it is recommended that lightning safety strategies be implemented such as requiring staff members to maintain current cardiopulmonary resuscitation (CPR) and first aid certification. Knowledge of CPR and first aid is critical for first responders who might attempt to resuscitate and provide care to a lightning strike victim (Walsh et al., 2000). The NCAA has also put forth a position statement on lightning safety. In conjunction with the National Severe Storms Laboratory, the NCAA has developed lightning safety guidelines for collegiate athletic programs (NCAA, 2001 ). Several procedures are advocated by the NCAA (2001) for colleges and universities to promote lightning safety. First, the NCAA suggests that a chain of command be designated to determine who will monitor for threatening weather and who will make the decision to remove athletes from a site or event. This should include the development of an emergency plan that indicates instructions for participants as well as spectators. Second, a weather report should be reviewed each day to determine the potential risk of threatening weather. Third, during events, the National Weather Service should be monitored for severe weather or lightning "watches" or "warnings." Fourth, coaches and athletes should know the closest "safe structure or location" to the field or playing area and how long it takes to get there. Fifth, athletic officials and coaches should be aware of how close light- ning is to the field or playing area. This may be determined by several measures from the flash-to-bang count, to more advanced technologies such as lightning predictors or detectors. Lightning Safety Research Given the previously discussed legal concerns, it is important to develop an understanding of the scope and nature of lightning safety policies and procedures in sport and recreation programs. The types of programs in sport and recreation vary greatly. Therefore, research is warranted that would examine lightning policies and procedures in areas as diverse as aquatics, outdoor recreation in state or federal parks, collegiate or high school athletics, golf, municipal park and recreation agencies, and organized outdoor recreational sports. At present, very few studies (Hronek, 1999; Spengler, Connaughton, Zhang, & Gibson, 2002; Walsh, Hanley, Graner, Beam, & Bazluki, 1997;) have been conducted which investigate lightning safety policies and procedures in outdoor sport and recreational activities. More research in this area is needed. In the context of collegiate sports, one study investigated lightning policies in NCAA Division I collegiate athletic programs (Walsh et al., 1997). Athletic trainers were surveyed by phone to determine if their program had a lightning policy, whether they had a safety plan, who was responsible for the lightning safety plan, and the presence of various lightning safety procedures. The study indicated that 92% of the departments surveyed did not have a formal, written lightning safety policy (Walsh et al., 1997). Another study investigated weather-related safety procedures in outdoor recreational activities on state and federal public land (Hronek, 1999). The study sought to determine whether agencies had procedures in place to warn visitors of severe weather conditions and their management's knowledge of statutes requiring them to provide weather warnings. The study found that the majority (67%) of agencies surveyed did not have written operational procedures to

7 - EI The World's Leading This material has been copied under license from the Publisher. Sgo" Rrsrrrrh Sport Resource Centre WWWWWW.a Any resale for profit or further copying is strictly prohibited. In.cllllcncc rd0mrr John 0. Spengler, Daniel F! Connaughton, Jeff Earnshow warn visitors of severe weather conditions (Hronek, 1999). Most recently, a study was conducted to examine Florida municipal recreation and park agency director's perceptions of the probability of lightning strikes and safety risks, and selected lightning-related safety policies in the context of outdoor recreational sport activities (Spengler et al., 2002). Descriptive statistics were utilized to determine the level ~ ladherence f to lightning sofety recommendations set forth by the NATA, AMS, and NFSHSA. The results indicated that although perceptions of lightning safety risk were high among directors of Florida municipal recreation and park agencies, the majority (57%) had neither a written lighting safety policy nor a written lightning safety plan. The research demonstrated the need for lightning safety education and training for municipal recreation and park employees, and the development of lightning safety policies and procedures. Conclusion The goal of risk management is to reduce the exposure to loss for an organization. In the field of sport and recreation, negligence lawsuits constitute the bulk of these potential losses. With emerging technology that can improve lightning prediction and detection, the publication and adoption of lightning safety guidelines and recommendations by professional associations, and the conduct of further research identifying adherence to these guidelines, the standard of care for lightning safety is likely to rise. For administrators who manage outdoor sport and recreation programs, there is a growing need for education and training regarding lightning safety. This would involve knowing the dangers associated with lightning, the legal implications of a negligence or wrongful death lawsuit resulting from a lightning strike, the recommendations associated with developing policies and procedures to improve lightning safety, and staying abreast of emerging technology in lightning safety detection and prediction. To emphasize the importance of understanding the danger to spectators or partici- pants in sport and recreation settings, it is incumbent upon professional associations to provide lightning safety education courses and materials to their members. Understanding the risks is the first step in developing a plan to minimize them. The guidelines and recommendations established by the NATA, NCAA, USGA, and the NFSHSA provide excellent reference and guidance on lightning snfety pelicies and procedures. The recommendations are available through these organizations or from Internet sources. Additionally, sport and recreation managers should monitor future developments in lightning detection equipment as well as related research on lightning safety. By doing so, facilities and programs can be designed and managed to minimize the risk from lightning strikes. If the risks associated with lightning are understood, and measures are implemented to reduce the risk of lightning-related injury, the outcome for sport and recreation managers will not only be protection from financial liability, but most importantly protection of the public from danger. Acknowledgements The authors would like to thank their wives for their patience and support of their work and writing endeavors. REFERENCES Alexander, R. (1 999). Lightning strikes and negligence in sport. Journal of Legal Aspects of Sport, 9(2), Black, H.C. (1 979). Black's Law Dictionary (5th ed.). St. Paul, MN: West. Bennett, B.L. (1997). A model lightning safety policy for athletics. Journal of Athletic Training, 32(3), Bier v. City of New Philadelphia, 464 N. E.2d 147 (Ohio 1984). Cherington, M. (2001 ). Lightning injuries in sports: Situations to avoid. Sports Medicine, 3 1 (4), Cooper, M. A,, Holle, R. L., & Lopez, R. E. (1 999). Recommendations for lightning safety. Journal of American Medical Association, 282( 12),

8 =I- Soon Rcscarrh Inrclll~cncc rpomvr This material has been copied under license from the Publisher. The World's Leading Sport Resource Centre &- Any resale for profit or further copying is strictly prohibited. Perspectives on lightning safc?ty risk management in sport and recreational activities Cwinn, A.A., & Cantrill, S.V. (1 985). Lightning injuries. Emergency Medicine in Review, 2, Fahmy, F.S., Brinsden, M.D., Smith, J., & Frame, J.D. (1 999). Lightning: The multisystem group injuries. Journal of Trauma: Injury, Infection and Critical Care, 46(5), Franklin, D. (2002). National Weather Service: Lightning Safety - Why do some clouds produce light-. ning and not others? Retrieved September 16, 2002 from the World Wide Web: noaa.gov/science. htm Homes v. State, 808 S.W.2d 41 (Tenn. 1991). Holle, R.L., & Lopez, R.E. (1999, October). Updated recommendations for lightning safety Bulletin of the American Meteorological Society, 80(10), Hronek, B. (1999). Weather related liability in outdoor recreation. Proceedings of the 1999 Northeastern Recreation Research Symposium. USDA General Technical Report NE-269, Keen, C. (2001). Zap-free sports. University of Florida uses lighting detectors at football games. Retrieved September 16,2002 from the World Wide Web: hhp:// news/lightningame. htm. Kithil, R. (2000). An overview of lightning detectionlwarning systems. Retrieved September 16, 2002 from the World Wide Web: com/nlsi~lhm/ewc9.html Kithil. R. (1998). Lightning safety for campers and hikers. The Outdoor Network, ix, (2). Retrieved September 16, 2002 from the World Wide Web: Long, C. (1 999). Researchers plug into the mysteries behind lightning. Retrieved September 16,2002 from the World Wide Web: org/disasters/990629lightning/ Maussner v. Atlantic City Country Club, Inc., 691 A.2d 826 (N.J. 1997). National Collegiate Athletic Association. (2001 ). NCAA guideline 1 d: Lightning safety NCAA Spom Medicine Handbook, National Weather Service. (2002). Lightning events: historical fact sheet. Retrieved September 16, 2002 from the World Wide Web: noaa.gov/om/wcm/lightning/resources/ltg-events.pdf Price, S., Barry, F?, & Phillips, T (2001). Where lightning strikes: Science at NASA. Retrieved September 16, 2002 from the World Wide Web: nasa.gov/headlines/y200 1 /ast05decl.htm Prosser, W.L. (1980). Law of Ton's (4'h ed.). St. Paul, MN: West. Schultz, S. J., Zinder, S. M., & Valovich, T. C. (2001). Sports medicine handbook. Indianapolis: National Federation of State High School Associations. Shadiack, M. (1 998). Torts-act of God-does a golf course owner and/or operator owe a duty of care to their patrons to protect them from lightning strikes? Seton Hall Journal of Sport Law, 8(1), Spengler, J.O., Connaughton, D.P., Zhang, J., & Gibson, H. (2002). An analysis of lightning safety policies and procedures in Florida municipal park and recreation agencies. Journal of Park and Recreation Administration, 20(3), Tonner, C., Sawyer, T, & Hypes, M. (1999). Legal issues in golf: A 25-year litigation history, Journal of Legal Aspects of Sport, 9(2), Walsh, K.M., Hanley, M. J., Graner, S. J., Beam, D., & Bazluki, J. (1997). Survey of lightning policies in selected division I colleges. Journal of Athletic Training, 32(3), Walsh, K.M., Bennett, B., Cooper, M.A., Holle, R.L., Kithil, R., & Lopez, R.E. (2000). National Athletic Trainers' Association position statement: Lightning safety for athletics and recreation. Journal of Athletic Training, 35(4), (2002). Lightning detection systems. Retrieved September 16, 2002 from the World Wide Web: asp JOHN 0. SPENGLER, J.D., Ph.D. Assistant Professor Department of Recreation, Parks, and Tourism University of Florida PO. Box Gainesville, FL spengler@hhp.ufl.edu Tel: (352) , ext Fax: (352) DANIEL P CONNAUGHTON, Ed.D. Assistant Professor Department of Exercise and Sport Sciences University of Florida JEFF EARNSHAW, M.S. Department of Recreation, Parks, and Tourism University of Florida