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We see no evidence to indicate that any changes are likely to occur that will assign to camping safety a higher priority.

We can only conclude that accident data are still inadequate for planning effective accident prevention programs, and no system appears to be developing at the national or State levels. A good accidental injury data system would provide a basis for effective standards which could contribute to improved safety performance. Safety standards have not been adopted to any great extent by the separate States in spite of some public attention. Inspection and enforcement of camping health and safety regulations varies greatly among States and communities, and there appears to be little prospect of general improvement.

We conclude, therefore, H.R. 1486, properly implemented, would establish this long-sought accident data system; it has the machinery to promulgate safety standards based on this accident data and places the enforcement of such standards on a par with other governmental responsibilities.

Thus, The National Safety Council supports the purpose and many of the provisions of this pending safety legislation for youth camps. In fact, I can say we support it in its entirety.

Furthermore, the Council believes this measure can be enhanced by considering the following recommendations:

Advisory Council-That the composition of the proposed advisory council on youth camp safety referred to in section 15 be more precisely defined so as to insure a consensus of interested parties. Moreover, the size of this advisory council, which is to consist of the Secretary of HEW and nine persons, hardly seems adequate for the complex demands that will be placed upon such a group. An advisory council consisting of representatives from appropriate Federal agencies, State government officials with camp supervisory responsibilities, youth serving organizations, camp operator organizations, safety, health, and education organizations and other interested parties, would be better constituted to discharge the responsbility incumbent on such a council. The National Safety Council recommneds that the size of the advisory council be raised to a level that would better represent the various youth camp interests.

Standards Development-We recognize that no object found in nature or produced by man is totally without some risk of harmful interaction for young campers. A basic National Safety Council precept is that the elimination of all risk of injury will never be fully achieved, even with the simplest of tasks. Nevertheless, we must continue to strive to reduce the risk level until it approaches zero. Since we can never achieve absolute freedom from risk under all conditions, we must therefore address ourselves to the degree of safety that can be achieved, recognizing the obvious constraints inherent in camping.

The Council espouses the principle that every practical effort should be made to determine and then remove or control the probability and the consequences of those undesired events arising out of hazards, malfunctions and failures, thus assuring optimum safety with the constraints of known technology and available resources. The Council recommends that, even in the absence of a current accidental injury reporting system, many of the existing safety

standards, voluntary in application but strongly supported by camping associations, would serve as a valid reference on which to prepare official standards.

The Council recommends that the standards promulgated under this safety legislation should be, insofar as possible, consensus standards. The consensus principle basically involves two essentials: Securing representation from those groups that would be affected by the standard; and predominant acceptance by such groups.

The Council recommends that all standards eventually promulgated by the Secretary of HEW should preempt State standards applicable to he same aspect of safety except where the State standards are more rigorous or where local conditions warrant a variation from a Federal standard.

To leave this decision of when to enact safety standards and how rigorous they should be completely in the hands of the individual States will result in a patch quilt of separate requirements. Those States that invoke high quality standards may only cause the marginal camp operators to move to other States with more permissive safety standards. The parents, who ultimately must make the decision regarding the camping experience, would still be confronted with a bewildering array of claims as to the safety merits of competing camps.

Consultative Services-The Council recommends that there be a provision for a camp operator to request from the Secretary, or from a State with an approved plan, consultative services for the purpose of: interpreting applicable standards; determining compliance with the applicable standard on specific physical conditions or environment; and determining alternative methods of compliance.

Requests for consultative service or assistance should not result in any sanctions when the inspection was made at the request of the camp operator. If, however, in the course of providing such consultative service, an existing condition is discovered which constitutes an imminent danger, then it should be abated immediately and some mechanism should be provided to enforce abatement of such danger.

Such consultative services, I think, would go a long way in eliminating apprehnsion and enhancing the voluntary compliance which is an absolute necessity to the achievement of the purpose of the youth camp safety legislation.

Penalties-We strongly concur with the "general duty" clause (section 4 of H.R. 1486) and regard this as an essential element in youth camp safety legislation.

The Council would also favor a provision for "first instance" sanctions, when warranted, subject to the right of consultative service. Such a provision will encourage compliance with a newly promulgated standard at a date sooner than might be the case if there were no "first instance" sanction. The Council is of the opinion that "first instance" sanctions for nonserious violations should be discretionary, not mandatory.

Education and Training-There will be a need for youth camp operators to become familiar with the new safety standards and accident reporting systems.

The Council recommends that some provision for the education and training of camp operators be included in any legislation. This will assist in securing voluntary compliance.

Travel Camps-The requirement for travel camps to register with the Secretary of HEW appears sound and is undoubtedly a necessary procedure for those camps whose itinerary includes two or more States. Moreover, the Council believes that travel camps should comply with all applicable State safety and health standards in each State in which they operate when the State has an approved plan.

There are undoubtedly travel camps which originate and terminate their travel without leaving their home State. Such cases can be administered by the State in which they are operating, providing the State has a plan previously approved by the Secretary. The distinction between travel camps engaged in intrastate travel and resident camps would appear to be of little consequence. This suggested arrangement would enable a State of exercise more complete jurisdiction over the entire youth camping population.

Such primary State jurisdiction would also apply to the inspections. investigation and records that are required under section 9. Federal Recreation Camps-The provisions of section 14 regarding the authority of the Secretary of HEW to develop safety standards governing the operation of camps located on Federal property is sound.

The Council believes that an additional stipulation may contribute to a uniform set of State standards. This would direct the Secretary to establish standards for the Federal properties that are as close as possible consistent with those of the State in which the property is situated-so long as the State has an approved plan.

This arrangement would minimize the possibility of youth camps under the jurisdiction of the State and camps under the control of a Federal land management agency sharing a contiguous boundarv but operating under a different set of safety standards.

Research-The Council also suggests that a provision be included for research, special studies and demonstration projects.. This recognizes that all of the answers to youth camp safety are not known, and that legitimate_difference of opinion will exist in achieving optimum safety performance. There are several national nonprofit organizations with the interest and capability to assist in achieving the objectives of this act.

Finance We also urge the Congress to consider any action it may take that establishes a national policy ou youth camp safety as being worthy of adequate financial support.

Unless Congress stays with its initial intent and continues to appropriate sufficient funds to assume effective fulfillment of that intent, disappointing results are virtually a certainty.

This is especially true of cooperative efforts between Federal and State Governments.

In planning for adequate financial support the experience of the Occupational Safety and Health Act indicate that there will be a variable number of states that will directly participate in the implementation of this act; so both Federal and State enforcement need to be considered.

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In closing, I want to thank this subcommittee for providing us with an opportunity to comment on this pending safety legislation. Safety is our only business. The Council will welcome, within the constraints of our resources, the opportunity to participate in those programs that will contribute to the reduction of accidents in youth camps throughout this Nation.

[The appendix referred to follows:]


1. Youth camp director's safety guide

This is a 60-page reference which provides specific guidance on such matters as staff selection, training, inspections, and supervision of program activities. It has been available since 1972.

2. Safety education data sheets for:

(A) Camping

(B) Fishing

(C) Counselors and helpers in summer camps

These are brief references intended for teachers, resource managers, and program leaders. Single copies are provided free of charge. They deal with specific safety advice for activities commonly associated with camping. 3. Family safety magazine articles

(A) This quarterly magazine is consumer oriented and has a circulation of 1,600,000. In the spring 1969 edition an article titled, "What Do You Know About Your Kids Camp?," contained guidance for parents in the selection of a summer camp.

(B) Other editions of this magazine have contained similar instructions on hiking, water, snakes, lost children and organized sports for children. 4. Environmental health and safety in children's resident summer camps A seminar curriculum guide, 181 pages, 1966, by Indiana University. The National Safety Council participated as an advisor to the Public Health Service in the development of this guide.

Mr. DANIELS. I want to thank you for a fine statement and the contribution you have made here today. I wish to state I am sorry I was not here at the beginning of your testimony but I have read it and am familiar with it. I take it you do not endorse this legislation H.R. 1486.

Mr. TOFANY. Yes.

Mr. DANIELS. I don't have any additional questions and on behalf of the committee express our sincere thanks.

Mr. TOFANY. Thank you.

Mr. DANIELS. Our final witness for the day is Dr. John Kirk, New Jersey School of Conservation.

Mr. DANIELS. I welcome you on behalf of the youth camp safety legislation and we are glad to have you here today. You have a statement?

Dr. KIRK. Yes.

Mr. DANIELS. Would you like to read it?

Dr. KIRK. I would.

Mr. DANIELS. You may proceed.


Dr. KIRK. Mr. Chairman and members of the Select Subcommittee of Labor: My name is John J. Kirk, and I am presently employed as director and professor of environmental studies at the Montclair State College, New Jersey School of Conservation, lo

cated in Stokes State Forest, Sussex County, N..J. This facility is the largest resident center for environmental studies in the Western Hemisphere, and one of the programs conducted is a natural science summer camp for children between the ages of 8 and 14.

My interest and concern for the safety and welfare of children in camps extends beyond my present professional responsibilities. however; and I would like to take a few moments to share some of my experiences with you in order that you may better understand and appreciate my desire and interest in participating in these hearings. I have been a professional in the field of organized camping for the past 24 years. In 1963, as a member of the National Standards Committee of the American Camping Association, I was one of the authors of the "Consolidated Standards," which was the instrument used to accredit camps in the American Camping Association prior to the present standards. In 1965 I was appointed to the national board of directors of the American Camping Association as national standards chairman and served in that capacity for 5 years supervising the accreditation program for the 3.000plus member camps in the 50 States. In that capacity I initiated the research project which resulted in the present standards document of the American Camping Association, which has been in use for the last 2 years.

I have also served in the capacity of national vice president and national president of the American Camping Association—a commitment of 9 years' service on the national board of directors.

From 1959 to 1963 I served as the administrator and supervisor of the camp licensing and inspection program for the State of Michigan. In 1960 I had the opportunity and privilege of revising the State regulations affecting the 1,000 youth camping programs in the State of Michigan, a program which, if you will pardon a strong personal bias, is one of the best in the United States.

In 1962 and 1963 in fulfillment of the requirements for the degree of Doctor of Philosophy at the University of Michigan in Ann Arbor, I conducted a national research project which consisted of a critical analysis of the laws in the 50 States affecting the operation of children's summer camps and the development of a model State law and a model set of State regulations. Copies of the concluding chapter of that study are available for the members of the committee if you desire them, Mr. Chairman. Another point that became quite clear as a result of that study was the need to standardize the regulatory programs throughout the 50 States. This, of course, could best be achieved through the enactment of Federal legislation.

This leads me to my observations and reactions to H.R. 1486, which I consider to be an extremely fine bill; and with a few slight changes or modifications, would be excellent. In any event, I do want to go on record, Mr. Chairman, as strongly favoring the concept of Federal legislation, and I believe there is a great need for such legislation in order to protect the 72 million children who attend camps in the United States each summer. In looking at the specifics within the bill, my concerns are as follows:

(1) Grants to States, section 7. I believe the 80 percent subsidy of State programs would prove to be an excellent incentive, and

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