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used to transport campers? Would you consider it stringent that special requirements for those who drive those vehicles carrying young campers exist? Would you consider stringent sanitary requirements in kitchens and safety in fire situations for children in areas in which they would be in?

Would you desire to see that standards for counselors and a certain level of training, for instance on the waterfront, have to be children?

We have instances where just 1 week ago at our hearings in Bear Mountain where it was stated that there were 75 children swimming and one lifeguard. So if we felt that the maximum a lifeguard could observe in, let's say lake swimming, were 25 children, that in that instance where there were 75, there ought to be two or three lifeguards on duty instead of one. So all of these requirements are the types of things we are calling for in the establishment of minimum standards at the Federal level.

Your position could be used by those who oppose this legislation as a statement by the Girl Scouts that this could be detrimental and could threaten this vital program for half a million Girl Scouts each year. The inference I get from that is that you would be putting yourselves basically in a position for the standards which are not even listed in the bill.

Mrs. OAKERSON. There is no intent of going on record against minimum safety standards. Practically everything you mentioned is explicitly in our safety standards booklet. The ratio of qualified adults to swimmers is a basic requirement. The same is true of camping situations-so many adults for so many girls all other at the different age levels.

If I may try to clarify what we do mean. I noticed a provision of the bill which spoke of building and site plans. In a resident camp. that is wholly appropriate and applicable. On the other hand, for a camp on a city street or a vacant lot or on farm land or in a backyard, different types of plans are applicable; however, those are not distinguished in H.R. 1486. It needs to be clarified. Does that mean after the day camp or troop camp has been set up, does it mean

Mr. PEYSER. Just a moment. Then perhaps where you say "stringent regulations regarding sites, facilities appropriate for residential camping"-what do you mean by residential camping? That is on page four of your testimony. It is a residence where they live, where you are away at camp.

Mrs. OAKERSON. Resident camping is defined in the bill
Mr. PEYSER. I am assuming it is away at camp.

Mrs. OAKERSON. Yes, resident camp.

Mr. PEYSER. If you are assuming that, why are you opposed tonow you say stringent. I don't know what stringent means. But if you took stringent and said minimum, which is what the legislation is calling for, the establishment of minimum safety requirements be established by the Secretary of HEW, would you then object to minimum safety standards that are stated in this case?

Mrs. OAKERSON. Certainly not. We do not feel that standards which would apply to resident camping could be applied to all day camp situations or troop camping situations.

Mr. PEYSER. Of course in a day camp, you don't have sleeping facilities that are involved very much in this. You do not have the problem of fire extinguishers and sleeping facilities that are involved. in residence camps. But, you see, your statements here and what I am trying to get at is that I think it would be a very poor position for the Girl Scouts to, in effect, come out and say that the regulations regarding the sites and facilities appropriate for resident camping threaten its program, because I would think you probably qualify in every way for every such regulation.

But there are many, many camps that do not qualify. And your position is the basis of argument for those who don't qualify and who say, as we have had a camp owner say just a week ago, it is going to cost us too much money to have windows that go out instead of in and have windows they can get out of. I am not concerned about it costing them too much money in these kinds of situations. But from your testimony, you are unsupportive of your position.

Mrs. OAKERSON. No, that is not the intent of our testimony. I feel that our long record as far as building, health, and safety standards for our own organization and enforcing those health and safety standards should make that clear at the outset. We are speaking from our own background and experience in the field. When we use the word "stringent," that does not refer-perhaps that was poorly used to rules and regulations that refer to the applicability of rules and regulations.

Mr. PEYSER. To the what?

Mrs. OAKERSON. Applicability of rules and regulations.

Mr. PEYSER. I don't understand what that means.

Mrs. OAKERSON. In the bill, the various kinds of camps that we have discussed are not specifically spelled out. You will notice when I was talking about troop camping, I said "if" troop camping is to be covered by the bill.

Mr. PEYSER. All camping is to be covered by the bill. I would really urge you to think this over, and perhaps even at another time. to realize the implication of what this statement that you have given us is on this total area of camping. I think we have many people who oppose this legislation, for a variety of reasons, having nothing to do with what you are talking about. If they could, in effect, sav, listen, the Girl Scouts sav this, this is testimony that is open. It is all recorded and available to everybody. If they could say Girl Scouts say this legislation could ruin our camping facilities for half a million girls and therefore we are very leery of this, I think it would be a very bad position to cast the Girl Scouts in.

I won't pursue that particular line any further, but I would urge that perhaps you would like to restate that position to clarify it and hopefully say that there is no reason in the world the Girl Scouts would object to minimum safety requirements, whether it deals with resident camps or day camps or anything else, because I can't conceive of that as being a position of the Girl Scouts Council. So perhaps you could think of that.

I do want to ask another question. I am sorry for taking a little time on this. This deals with this question of statistics. This comes into your area. I notice that you indicated-and this deals with how many campers are involved in the statistics you give us on

page six. The total numbers of campers involved is the 160,000 troops with 3 million girls enrolled. The statistics are based, I gather, on 175,000 girls. Is that right, that you have given here on the accidents? What is the basis for the numbers?

For instance, you come up with .005 injury ratio. What is that on the total of how many campers?

Ms. PINNEY. There are at the present time approximately 3 million Girl Scouts in the country. In 1973, 175,000 of those girlsa few of those who would have been nonmembers but most would have been Girl Scouts-attended resident camps where they went and lived totally away from their parents for periods usually of at least 6 days up to 14 days and sometimes even more. In addition to that, we ran 3,500 day camps, at which approximately 500,000 girls, and probably a few boys, attended. Those are mostly run on borrowed sites.

When I say "mostly," our data early in May indicated 71 percent of those day camp sites were borrowed. Those are largely operated by 50,000 adult volunteers. The 3 million troop camper days are camper days calculated just as the Department of HEW calculated camper days when they calculated the accident rate. If we turn all of the 175,000 girls who attended resident camps into camper days rather than different girls, and the 500,000 girls who attended day camps into camper days you come up with the number of camper days which, if divided by the 36 injuries, results in an injury rate of 0.005 per camper days.

Mr. PEYSER. What I am trying to find out is how you arrived at the figure of 36 injuries. Was this based on a questionnaire to Girl Scouts camps which involved 175,000 campers or 500,000 campers?

Ms. PINNEY. It involves 3 million girls camping approximately 7 million days.

Mr. PEYSER. Okay. I am not concerned about the days. Here is my observation. My observation is that to assume that 3 million girls over the course of a summer camping season, that 36 children were hospitalized, which is I think the definition that you are using.

MS. PINNEY. Not completely, but it is quite close.

Mr. PEYSER. I think it said here, "We sent out a questionnaire. early this year asking that local councils report to us accidents which occurred in 1973 and defined serious as an accident in which the victim was admitted to the hospital or in which life function" —and so forth.

So admitted to a hospital as the result of an accident is one of your definitions. If you are suggesting to us that out of 3 million children in camp, only 36 were admitted to a hospital, I would like to take a great exception to that figure, because I think we can with our own newspaper clipping service do better than that or worse, if you will, dealing with Scouts camps. So I could say that I would love to think the figure was correct, but I don't think for 1 minute that 36 out of 3 million were admitted to the hospital.

Ms. PINNEY. We had three sources from which we drew the accident reports and injury reports. We have a normal standing order that all serious accidents, illnesses, fatalities, and so forth are to be

reported to our national organization. We had access to those figures. The term "serious" is not really defined in that directive, consequently the reporting under that directive varies considerably. We also have an accident insurance program for our members. We have those reports. We also have the questionnaire we sent out to determine if there was anything else that hadn't been reported to our organization.

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Mr. PEYSER. You are stating by your figures that 36 were the only ones that were hospitalized over the period of 1973 camping? Ms. PINNEY. We think that is fairly accurate.

Mr. PEYSER. Thank you. I would yield back, and I would hope that the Girl Scouts would reconsider and resubmit a statement concerning this bill, because I can't picture the Girl Scouts coming up with this kind of response at this time.

Mr. DANIELS. I recognize the gentleman from Connecticut, Mr. Sarasin. Do you have any questions?

Mr. SARASIN. Thank you, Mr. Chairman.

How many Girl Scouts councils are there?

MS. PINNEY. 356.

Mr. SARASIN. And the 297 responses were from the 356 councils? Ms. PINNEY. That is correct.

Mr. SARASIN. Was there any further attempt made to get information from the nonreporting councils?

Ms. PINNEY. As I stated earlier, this was a third attempt to get the statistics, because we have a normal reporting system, and the accident insurance covers every member of the organization. So we have no reason to think that the reporting was not complete.

Mr. SARASIN. The reluctance of the Girl Scouts to allow the Secretary by regulation to distinguish the different types of camping disturbs me, and I am not sure we are communicating properly. I am concerned, though, that the Girl Scouts may be saying that the proper standards for buses, for example, shouldn't be applied across the board. Would that be your position?

Mrs. OAKERSON. No, buses did not really enter into the consideration here. I am very sorry that we have come across in this way, because we felt that we could and we should come and say frankly what our concerns would be. We feel no threat as far as our own camping is concerned. We see needs to improve health and safety standards, but we do feel that distinction should be made. What we are saying is that the great variety of camping experiences that are offered should be distinguished.

Mr. DANIELS. I am sorry, we must suspend this hearing this morning because of the fact that there is a meeting of the full committee scheduled for this time. If you will wait a few minutes, we would like to have you testify further.

[Short recess]

Mr. DANIELS. The Select Subcommittee on Labor will come to order. We will continue with the hearing scheduled for this morning.

Mrs. Oakerson, you are appearing in the official capacity and speaking for the Girl Scouts of the United States of America? Mrs. OAKERSON. Yes, I am. May I try to clarify?

Mr. DANIELS. Yes.

Mrs. OAKERSON. Mr. Chairman, please let there be no misunderstanding-we heartily endorse the intent of the legislation under consideration in H.R. 1486. We applaud your efforts. Our concern is that unless distinctions are made in the legislation among the variety of camping programs which we have outlined, there can be misapplication of the law which could undermine the intent of H.R. 1486. We want to cooperate with you to the fullest extent and offer again the expertise of our camping program staff to provide additional language for your consideration, in the way of definition and specific subsections. We do not propose to relax or make less stringent the language that already exists in H.R. 1486. Rather, we propose to offer for your consideration language to enhance the intent and applicability of the law.

Mr. DANIELS. I want to thank you. I appreciate your making that statement, because you had me entirely confused. Now, on page 4 of your statement, you ask for an exclusion for day camping. On the other hand, you say if this is not possible, you desire that the committee give special consideration to the unique qualities of day camping.

As I pointed out to you earlier today. I would like you to examine section 5 of H.R. 1486, the legislation under consideration, and point out to you that we do not establish standards for any particular type of camp here. I refer to that particular paragraph that refers to the term "youth camp" and what it would accomplish. But it will mean and cover day camps or resident camps.

Subparagraph (b) of that section is applicable to travel camps. Now, you state that the standards of the Girl Scouts of America would complement this legislation. Now, we don't establish standards here. We do request the Secretary to, after consultation with the various groups interested in camping, promulgate the necessary standards, rules, and regulations which would be applicable.

Now, the purpose of these hearings is to get the various viewpoints. We welcome your thoughts and perhaps we can establish a category of day camping to cover the Girl Scouts of America. We don't want to inhibit camping. I think it is a very, very worthwhile activity in which all the youth should have an opportunity to participate. I applaud the Girl Scouts of America for the work they have done in this field. But I am sure you are just as much interested in the safety and health of the children as I am and the members of this committee who are supporting this legislation. We want to protect these children who suffered in 1973, the 16 from falls, 7 from horseback riding, 3 from snake bites, 2 from winter sports and 8 from other causes.

Now, perhaps if there was legislation in this field either on the Federal or State level, some of those injuries might have been avoided. You made a recommendation in your opening statement that the board which consults with the Secretary should be enlarged rather than be limited to nine members. May I ask you at this point how large a board do you perceive to be one that would be satisfactory to the Girl Scouts?

Mrs. OAKERSON. I do not have any specific figure in mind. However, I am concerned that a small board will not be adequately

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