About Me

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I am a consultant and general counsel to International Ride Training LLC as well as a practicing attorney in Avon, Connecticut. A particular focus of mine is the legal needs of the amusement and tourism industry. My focus on the amusement industry derives from my pre-law career as an operations manager with Cedar Fair Entertainment Company and Universal Orlando. Having started my career as a ride operator at Cedar Point in 1992, I progressed through the seasonal ranks and ultimately became the Manager of Ride Operations and Park Services at Worlds of Fun in Kansas City. I also worked in Universal's operations department during the construction and development of Islands of Adventure. Today, I am an active member of the New England Association of Amusement Parks & Attractions and the International Association of Amusement Parks & Attractions. I have been invited to speak at amusement industry meetings and seminars and have worked on a variety of matters relating to this industry.

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This Blog/Web Site is made available for educational purposes only as well as to give you general information and a general understanding of the law, not to provide specific legal advice (or any legal advice). By using this blog site you understand that there is no attorney client relationship between you and the Blog/Web Site publisher and / or author nor can such a relationship be created by use of his Blog / Web Site. By using thisBlog / Web Site you understand that any statement on the blog site are solely those of the author and do not reflect the views of Wiggin and Dana LLP or International Ride Training LLC. By using this blog site you understand that the Blog/Web Site is not affiliated with or approved by Wiggin and Dana LLP or International Ride Training LLC. The Blog/Web Site should not be used as a substitute for competent legal advice from a licensed professional attorney in your state or jurisdiction. This blog is not published for advertising or solicitation purposes. Regardless, the hiring of a lawyer is an important decision that should not be based solely upon advertisements.

Saturday, May 16, 2020

13 Reasons Why You Should Feel Safe Going Back To Amusement Parks This Summer

We’re in a strange time and, while I’ve been away from writing for quite some time, I think circumstances warrant a brief revival of the blog.  Is this my last article?  Probably not.  But maybe.  We’ll see how things go over the next few months.  The reason I’m back is because I've been recently asked by a friend to explain why it will be safe for her to go back to her local amusement park - something that I know raises a lot of eyebrows in the current environment. I thought this might be a question that others are interested in so ... here goes. 

For background (for those that don't know what I do these days), I am still a lawyer as I’ve been for the last 15 years, but I’m also a consultant to the theme park industry specializing in operations. As many of you know, I've been involved in ride operations in one form or another for 27 years.  Through our company, International Ride Training LLC, my partners, the amazing duo of Cindee Huddy and Patty Beazley, and I advise amusement parks around the globe on the best way to manage people and, in particular, run rides. We don't do anything with maintenance, foods, games, or retail. We know rides and, more generally, operations - and hopefully without sounding too arrogant - we are pretty good at what we do. 

Since this whole thing began, we have done pretty much nothing except help the amusement industry get ready to reopen in a manner that is safe from both a traditional ride safety perspective and from a public health perspective. So I know – very, very well - what is being done behind the scenes to make sure that it is safe for you to come to the park this summer.  Our industry is, however, an unfamiliar one to most people who see only the end result in the park but have no idea what it takes to actually operate on a daily basis.  Because of this, many in government and in the general public instinctively believe that an amusement park, water park, or family entertainment center cannot open in a COVID-19 world.  In short, those people are wrong and are operating from a lack of understanding about what parks can and will do to limit exposure.  So I thought I would share those things with you so you have some better idea of what to expect when/if you return to the park this summer.  I should also add that I work with parks all over the world, so I'm not speaking for any one particular park specifically. While every park may do things slightly differently to get ready to welcome you this year, in general, you can expect to see some or all of these precautions the next time you visit a park this summer.

1.     A Park Is Not A “Mass Gathering”

Before showing you some of the sausage-making on the changes you will see this summer, one thing that I need to emphasize is that an amusement park, waterpark, or family entertainment center is not a "mass gathering" like a sporting event, concert, or theatrical event - even though state governments keeping saying they are. While it is easy for parks to get lumped into that category because, like those other events, parks admit tens of thousands of people per day during normal operation, doing so overlooks guest density. Density is a critical issue to keep in mind when talking about mass gatherings. Most parks have dozens, if not hundreds, of acres to spread people across. So while both a large park and a baseball stadium might host 50,000 guests in a day, the density of those guests is vastly different. Park guests are typically spread out all over the park, whereas spectators at a baseball game are sitting elbow to elbow and all occupying the limited public spaces in the stadium. Think of it this way: At a game, you might have to wait 45 minutes to get into the bathroom because 15000 people in your section of the stadium are all trying to use it too. In a park, you might wait 5 minutes (and usually you don't wait at all) because there is a lot fewer people in the are trying to use that bathroom. Because of density, it is not correct to think of parks as a "mass gathering". Sheer number of people doesn't really matter - what matters is how dense they are, or put another way, how much space those people have to themselves.

2.     Limited Attendance

Now that I've addressed density, let's talk about attendance levels at parks this year. Current CDC distancing recommendations are 6 feet or 36 square feet per person (slightly less if you draw a circle around a person, but we can use 36 square feet since that is easier). At most parks during normal operation, it is not at all unusual for guests on the midway to be separated by well more than six feet. Rarely does a park get so packed that public spaces are literally shoulder to shoulder. Even so, to be absolutely sure that crowds will not get so big that people start to get concerned about distancing, parks are limiting their attendance to allow in SIGNIFICANTLY less people per day this summer.  Remember -  DENSITY is far more important than number of people - how many people is a park allowing in and how much room does that number allow for each guest.  And limiting attendance is how parks minimize guest density to comply with public health distancing requirements.  Importantly, parks are not generally starting from a number representing 100% capacity and working backward to determine how many people they can fit and still comply with distancing recommendations.  Instead, most parks are starting from the assumption that each guest will get FAR MORE than the minimum 36 square feet required and they are calculating their attendance caps by dividing this per-guest allotment into their total public space square footage.  In fact, the vast majority of parks (and I don’t personally know a park that isn’t doing this) is calculating their attendance cap to allot double, triple, or even more square footage than just 36 per guest just to be safe. I personally know of parks that have set their attendance cap for this summer based 100-200 square feet per guest and I know of one that has gone as high as 250. Point is ... that is a lot of room per person.  In some cases, parks are allotting enough space for each guest to carry around a decent sized bedroom with them everywhere they go.  That is significantly more than you will get at a grocery store, hardware store, or restaurant. 

So you will have a lot of room to yourself in the park, but it gets better because....

3.     Guest Density will actually be EVEN LESS than what the park calculates for attendance purposes

Those attendance caps are typically based only on available square footage in publicly accessible areas like midways and food patios. Ride queues, retail shops, and indoor restaurants are not usually included in the calculation. This is important for two reasons:

First, it means that the park has enough square footage to have every single ride, restaurant, and retail shop closed all at once and still give every guest more than the recommended 36 square feet to themselves on the midway.

Second, and relatedly, this means that the minute people start standing in lines at rides, going to indoor restaurants, or shopping for merchandise, the spacing gets LESS DENSE. For example, a park with 100,000 square feet of public space might set its attendance cap at 1,000 to allow everyone a minimum of 100 square feet (this would be a very small park, but let's use these numbers because they are easy). But ride queues, shops, and restaurants add another 20,000 square feet to the park which was not factored in when setting the attendance cap. So, instead of 1,000 guests having 100 square feet to themselves, they could have as much as 120 square feet once guests start doing fun things. 

So, once people start riding rides, you will have even more room to yourself in the park, but it gets better because .... 

4.     Families / Co-Habitants Are Not Counted In The Attendance Cap Either 

The spacing calculations done to figure out per-guest square footage and attendance caps assume that each and every guest has to stay distanced from each and every other guest. But, per the CDC, guests living under the same roof do not need to stay distanced in public because they are already living in close proximity at home. That's important because a significant percentage of park guests are families or people that live together. And while each of those people will count toward the attendance cap, they will not need to stay distanced from one another once they are inside. This creates EVEN MORE room to space other people apart. 

So, once families arrive and people start riding rides, you will have even more room to yourself, but it gets better because....

5.     At Least Initially, Parks Will Be Admitting A Lot Fewer Guests Than Permitted By The Attendance Cap

Many parks are likely going to take a cue from Disneyland Shanghai which reopened this week. While it was permitted to allow up to about 26,000 guests through the gates on day one (about 30% of its max capacity of 80,000 reportedly), it actually allowed a lot fewer just to make sure things went OK. I expect that parks in the US will do the same when they open - at least initially - to assess how the new precautionary procedures are working.

So this will give early guests even more room to themselves, but it gets better because ...

6.     Parks Are Actively Controlling Attendance At The Gate

Many, not all, but many parks this summer will require guests (even season pass holders) to make reservations so that the park knows exactly how many people are coming on a particular day. When the park hits the attendance cap, no more tickets get sold. And if you show up without a reservation, you won't be admitted. Period. This system prevents an unexpectedly large crowd on any random day that might overwhelm the system and reduce guest distancing below acceptable levels. For parks that won't require reservations, expect to see more attention paid to "in-park" attendance levels to ensure that the park stays under the attendance cap and expect to hear about parks turning guests away because of distancing concerns (assuming they get busy enough to do that).

So guests will have PLENTY of room in the park because, in addition to everything else, only people with reservations can come, but it gets better because ....

7.     Expect Guest Screening At The Gate:

Just because a guest has a reservation, though, does not mean they automatically will be admitted to the park.  Guests at most facilities will have to go through some level of screening to minimize the risk that infectious people are allowed in.  At a minimum, expect most parks (depending on local health recommendations and requirements) to have a strict facemask policy for all guests.  Remember – parks are private property.  If you don’t want to wear a mask to protect other guests from your potential infection, that’s fine – but they don’t have to allow you past the front gate.  Guests may also see temperature screening at the gate (although, honestly, I’m not a fan of temperature screening as it simply doesn’t detect enough to be an overly reliable tool for screening – but it makes people feel better, I suppose) and/or be asked about whether they are experiencing symptoms.

And, incidentally, for anyone that thinks the ADA means you don’t have to wear a mask – think again.  That topic could take up an entire blog post on its own, but suffice it to say that the mask is there to prevent a direct threat to the health and safety of other guests and employees.  A park can probably rely on that fact alone (in the absence of any equally effective alternative) to insist that everyone – even people with disabilities - wear one or don’t come in.

So, you will have tons of space to yourself, attendance will be by reservation only, and parks will screen guests for health issues before they are allowed in … but it gets better because …

8.     Ride Lines are being reconfigured and guest spacing controlled:

OK, so guests will have tons of room on the midway, that should be clear by now, but what about the line for rides. Lines are the bane of most park's (and park goer's) existence. You will see significant changes to lines that are being instituted solely to ensure that the rider’s health is protected.

The first change to the ride line you might notice is that there isn’t one (or there’s a very short one).  The need to keep guests distanced has resulted in a lot of parks implementing new “virtual queue” technology even if they never had this technology before.  A virtual queue uses an app on your phone to assign a place in a virtual line for a particular attraction.  The app notifies you when it is your turn to ride or may set an appointment time for you to go to the attraction.  When you arrive, instead of an hour long wait for the ride, you might have a 10-15 minute wait in an abbreviated queue.  

The second change you might notice is that queues will probably have spacing markers on the ground to help guests figure out where to stand so they remain six feet apart (again, families and co-habitants need not distance).   These may be fancy, custom made decals (like at Disney Shanghai) or they may simply be duct tape or hazard tape on the concrete.  Either way, the purpose is the same.  You might also see an employee walking the line reminding guests to stay distanced.

The third change to the ride line you might see is that there’s a lot less of it being used.  If the ride has “back and forth” style queues, those generally won’t work with distancing requirements because as guests wind their way through the line, they come within six feet of guests travelling in the next row over heading the other direction.  So, many parks with these style of queues will be reconfiguring them so that only the perimeter is used. If a switchback is used, expect to see a couple of empty queue rows between occupied rows to allow for six foot distancing.

So that is great!  You will have lots of space to yourself on the midway and you will have lots of space to yourself in line, but it gets even better because …

9.     Ride Operators will be distanced throughout as much of the ride operation as possible.

In any ordinary ride operation, there are times where people have to get close together.  Think about the ride operator checking the height of your child by getting really close, or the platform attendant that has to get close to check your seatbelt or lap bar.  Well, some of that might be changing and, if it doesn’t, you will probably see more personal protective equipment to protect both guests and employees.

My company, International Ride Training, has issued guidance to the entire industry – anyone that wants it, not just our clients – on how to operate a ride in a distanced fashion.  I can almost guarantee that not every park will adopt all of IRT’s recommendations, but you are probably going to see some of the following in the park you visit this summer:

·      Ride operators will measure children from a distance using fixed height measurement devices like height signs rather than relying exclusively on height sticks.  Parents may be asked to assist with getting their child properly positioned for an accurate measurement so that the employee can stay distanced.

·      Your park may have a designated height measuring station near the entrance to allow children to be measured once at the beginning of the day.  This reduces the number of opportunities for exposure between ride operators at each ride and the child since the child won’t have to be measured over and over.

·      Ride operators may assign seats on rides.  While riders frequently like to wait for their favorite seat, to keep guests spaced apart on ride units, employees will assign seats.  This also enhances distancing since riders will not be waiting together for the front or back seat on a coaster.

·      Rides will operate at reduced capacity.  While families / co-habitants can ride together, other guests will need to stay distanced.  This may mean that strangers won’t get grouped together, operators may leave ride units empty to maintain distancing between other loaded ride units, or seats may be left empty to create spacing.  On a coaster, for example, you may see guests seated in a staggered fashion so that no rider has another guest next them, immediately in front of them, or immediately behind them.

·      Riders on many rides will wear facemasks during the ride.  While it is likely that riders on some rides will not be able to wear facemasks, many riders will.  This will also reduce guest exposure to potential infection.

·      Ride operators may ask guests to assist in checking their own restraint security.  A process of operator-observed guest verification has already been in place on some attractions at Disney and Universal for some time.  Expect to see this procedure expanded to other parks so that ride operators can stay distanced.  This might slow down dispatch times for some rides, but it is necessary to keep operators and guests distanced and safe.

·      When ride operators cannot ask guests to check their own restraints, guests will probably see employees wearing additional protective equipment.  Most parks will probably require employees (and many will require guests) to wear facemasks.  Where a ride operator has to get close to a guest, you might also see the employee wearing a plastic face shield over the facemask as an additional layer of security.

·      Guests will likely be offered hand sanitizer, or at least directed to a hand sanitizer location, as they get in line, as they board the ride, and/or as they exit the ride.  For many parks, guests will be given hand sanitizer at least twice at every ride.  This helps reduce surface contamination for ride unit and restraint surfaces.

So that is great!  Guests will have plenty of space to themselves in lines AND on the rides, but it gets better because … 

10.  You Will See A LOT more cleaning and sanitizing going on …

Distancing is only half the equation, the other half is cleaning and sanitizing.  Parks are tackling this in two ways.  A) Clean the person, and B) Clean the surface.

As for “Clean the Person,” park guests can expect to get hit over the head with new signage and spiels reminding guests of the importance of washing hands and sanitizing.  Guests will almost certainly see new hand washing stations installed throughout the park and even more sanitizer dispensers.  Employees will be stationed throughout the park to assist guests with distancing, but also to remind guests to wash hands and use sanitizer.

Cleaning the Person is the most important step to be taken to reduce the potential for infection, but parks will of course not stop there.  The second part of an amusement park’s sanitization program is to step up cleaning of surfaces in the park.  In most parks, the great news is the nature helps out significantly.  The latest CDC recommendations on surface disinfecting state that for surfaces located outdoors, no change to a park’s general cleaning regimen is necessary.  This is because wind, space, and direct sunlight work together to reduce viral concentration outside – even on surfaces.  Nonetheless, you will still see a lot of employees cleaning and cleaning frequently.  Parks are paying close attention to the chemicals they are using to ensure that they are EPA approved for COVID-19, and they are paying a lot of attention to how to properly use those chemicals to ensure they are effective.  From restrooms, to food counters, to ride queues, to cash registers, expect to see a significant amount of cleaning to keep guests safe this summer.

So not only will guests be distanced but they will be clean – and so will the park surfaces – but it gets even better because ….

11.  Cashless Payment and Mobile Apps Are Going To Be A Lot More Frequently Used

OK… I know I said I don’t work with food and beverage or retail.  That’s true.  But I have been involved in many conversations over the last three months to know at least some of what is in store (no pun intended) for these locations in the park.  To further reduce the potential for viral spread, many parks are either expanding the use of cashless systems they already have or are will be implementing brand new systems to reduce contact between guest and employee.  Many parks that never used mobile ordering for food and beverage locations will now have them and, in many locations, this will be the only way of ordering food or drinks.  

So you will be distanced in the park, on the rides, clean everywhere, and won’t have to touch money … but it gets better because…

12.  Expect To See All The Things You See In Your Local Restaurants, Only At The Park

Food and beverage service won’t only be different because of the way you order or pay, it might even be different in how it is served, what is sold, and where you eat it.  Across the United States, restaurants are reopening at reduced capacity with tables spaced apart.  You will see this at parks too.  Restaurants in your hometown are likely moving to disposable menus or posted menus to reduce surface contamination.  You will see this at parks too.  And your local restaurants may reduce menu items or eliminate buffets and salad bars to further reduce potential exposure either between guests or employees.  You will see that at your local park too.

13.  Waterparks Have All This … And Something Extra

For those of you who frequent waterparks, you will see much or all of everything I’ve just gone through when you return.  But waterpark guests get a bonus.  The latest CDC recommendations for aquatic facilities make clear that there is no evidence that the virus can survive in treated water or on surfaces that are consistently covered in treated water.  That means that guests on water slides, wave pools, swimming pools, lazy rivers, and other aquatic attractions are at an even lower risk of exposure than guests in other kinds of facilities (and, as shown above, that risk is pretty low already).   Of course, waterparks will still be sanitizing tubes, mats, rafts, life jackets, and other frequently touched equipment and surfaces, but the presence of treated water will help significantly in reducing risk of infection from swimming or immersion in water.

So there you go… To say that the amusement industry has given this a tremendous amount of thought should by now be, I hope, obvious.  The entire industry has collectively spent thousands of man-hours over the last three months thinking about this issue, planning for it, and adjusting those plans as the data or the public health recommendations change.  And we will continue to do so.  

Is it safe to go back to a park?  I can’t answer that for you.  I think it is, but you can look at all of this and decide for yourself.  And if you still aren’t sure, by all means, contact your favorite park and ask them to tell you everything they are doing.  I’m sure you will hear a lot of what I’ve just told you, but at least you will know that its in place at your park.  

I hope to see you riding the rails this summer.  And I mean that more sincerely than ever before.


  1. Great write-up and run down of what we can expect in the amusement industry this summer when they are finally able to open. I am curious how all of this will affect the bottom line though. Some parks have already made the decision to simply remained closed this year. There are too many hurdles for them to overcome and the cost of opening is greater than the cast to stay closed. Is it even worth opening if a park can only operated at 50% capacity along with ride restrictions and a greater over all operation cost? I think only time will tell, and it will be interesting to watch.

  2. Hahahahaha, ah hahahahaha.

    Theme park not a mass gathering - have you folks been to a profitable park during summer peak?

    Being that’s how you start this and base all the logic off of it...I just can’t take it seriously at all.

    Asian parks are opening bc companies there are required to pay their employees during this time; it only benefits the bottom line to have folks going through the turnstiles.

    Park goers in the USA are extremely entitled as they feel their fee to get in allows for any behavior, anyone who has been a front of the line employee knows this. I cannot imagine the challenge of providing quality customer service during this time.

    I’d love to get back to work but publications like this that create a false sense of security are adding to the problem not aiding the solution.

  3. Nice post! Just in item #1, there are elements of mass gatherings within theme parks (theaters, parades, etc), so those need to be managed appropriately. Cheers!

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