has been some hazard that has not been reported, and we will have more figures for you in the next year or two.

Chairman DANIELS. How many are licensed in the State of New Jersey?

Dr. SUSSMAN. With our resident and day camps, we anticipate we will be licensing close to 500 camps.

Now, it is a small State and we were rather amazed at what we found ourselves when we got into it.

Mr. DANIELS. Does New Jersey require that each camp acquire a license from the State?

Dr. SUSSMAN. Yes.

Mr. DANIELS. Does the State charge a fee?

Dr. SUSSMAN. The fee is minimal and we had a meeting with the advisory council and suggested a fee of $25 for resident camps and $10 for day camps.

Mr. DANIELS. With regard to health and safety, there is a great deal more involved in the operation of camps than just food.

Dr. SUSSMAN. Yes, and we are interested in and we are working with the fire marshals in New Jersey and the fire officials in each municipality in New Jersey, to make certain that those requirements . are maintained and we are setting up requirements on that.

The safety, water safety and lifesaving techniques that are applied, are of major interest. We have seen some situations where a simple thing like stringing an electric wire from a shed down to the waterfront with open cables, has resulted in a possibility at least of injuring the fish, if not the children, and we are interested in going into that type of safety also, and our regulations are covering that. We are interested in the automobile safety in connection with the bus and the use of the bus either coming on the property or going off.

All of this is going to be covered or it is covered, rather, in our regulations. We will forward a copy of our regulations which will be enacted within a month.

Mr. DANIELS. What Department in the State of New Jersey has jurisdiction?

Dr. SUSSMAN. The State Department of Health.

Mr. DANIELS. In formulating your rules and regulations, did you invite the camp operators to participate?

Dr. SUSSMAN. Absolutely. We would not have been able to do it if we had not had their help because we didn't know enough about it truthfully, to do it without the help of people like The American Camping Association, Boy Scouts, YMCA and YWCA.

Mr. DANIELS. How much did the Committee on Appropriations in the State of New Jersey authorize for operation in the first year? Dr. SUSSMAN. The State of New Jersey appropriated $100,000 this year. I should tell you that $100,000 is really not the amount of money spent because we have 500-some-odd municipalities in New Jersey and all of them have health officers and sanitarians.

We are integrating the work with our local health departments in such a way that the amount of work that will be done in camp

safety cannot be looked at by the amount of a State appropriation, because it will be magnified enumerable times by having local health officials working with us on it. They all are going to be trained by our group.

We don't expect to get this all done this year, but we are going to be working with the Red Cross. The Red Cross has agreed locally and will be working with us on training our people.

We don't intend our inspectors to be all life-safety experts but they are going to be trained to know whether the people that are there meet those life-safety standards, whether it be swimming or first aid or what have you.

Mr. DANIELS. Does the New Jersey Legislature provide for reporting of all accidents which might result in fatalities?

Dr. SUSSMAN. Yes, our regulations are going to provide for a requirement, well, they do require that, that is why I told you before our regulations will require that accidents and illness be reported.

Mr. DANIELS. Dr. Sussman, what is your position with regard to the Federal Government establishing minimum health and safety standards for youth camps where the States have not enacted any legislation in this area?

Dr. SUSSMAN. Well, that was the point I was trying to make before, Mr. Chairman, that I think it is important that if the States do not do it, since we protect dogs and we protect the meats, I think it is important that the Federal Government come in and do it. If you do set up minimum standards under the Secretary of HEW and a specific State does not comply, since many of the children go from one State to another and it is based on interstate advertising and interstate commerce, then I think that the Federal Government has a responsibility to go into that State which fails to provide and provide the same type of inspection as they are requiring in other States that do have a plan.

Mr. DANIELS. Thank you very much.

I call upon now my capable colleague from New Jersey, Mr. Forsythe.

Any questions?

Mr. FORSYTHE. Thank you, Mr. Chairman, and thank you, Dr. Sussman, for a very, very good, hard-hitting statement.

I have just a few points that I would like to review with you for, perhaps, some clarification.

On the matter of administrative hearings which you referred to, and establishment of State plans, I believe in the bill that section 6d), "whenever the Secretary finds after affording due notice and opportunity for a hearing", does preceed the appeal of the States that want to go to court if a plan is not approved by the Secretary. Do you still believe there should be something more than the opportunity for notice and hearing before the Secretary and review of a plan?

Dr. SUSSMAN. Well, maybe that would cover it, but I was hoping that before you got to the court of appeals that there would be a set up, and it does not seem to me that it is in here yet. Maybe I am wrong. It does not seem to be the same type of administrative hearing that is set up in some other Federal legislation.

This may be my, you know, misunderstanding in reading it, but if it is understood-well, what I mean is, I don't want the same inspector or same regional officer, say if I am in New Jersey, normally they give us the regional officer from New York and never give us a regional officer from New Jersey; you might look into it sometime. They also have the New York office of a region. They never have a New Jersey office of a region.

Mr. FORSYTHE. Or Pennsylvania.

Dr. SUSSMAN. Yes. It is also New York there. I don't think the man, in any event, who determines the money, whether our plan is approved and whether we are meeting the requirements, is the same hearing officer. I wanted to make certain that the hearing system was set up independently of the administrative process, the same people that do that.

I would like them to be in an adversary position if the people that are in this regional office are not the same ones that are making the hearing for the Secretary.

Now, maybe that is implicit in here, but I don't know.

Mr. FORSYTHE. I am not an attorney, nor do I have full knowledge of the Administrative Procedures Act, which I am sure does apply in this set up that we have, but your point, I think, is well taken. I am sure we can review this to see that that kind of thing is covered for you.

Going to travel camps, I believe that the bill does provide that travel camps are absolutely a Federal responsibility. You, I believe, make a point that the State of origin of that camp should really be the controlling initial place for that camp to be licensed and so

forth.

Dr. SUSSMAN. Yes. I am trying, I make two points in my presentation. One is that the travel camps should be under the responsibility of the State of origin, that is, they are the ones that should see whether they have a water safety man with them and they should see whether their vehicles are properly taken care of, the same as they would if it were a resident camp.

I also made the point on Federal recreation grounds within a specific State, and this, I told you before, may create a problem; but staying with the travel camps, I think we would have much better cooperation between the Federal staff and the States if the Federal Government, and I don't want to say this this way, but maybe if I did it would make it understandable, would keep their sticky fingers off of the requirement being different on the travel camps than they do for resident camps.

Mr. FORSYTHE. Yes, but don't you have a problem for instance, that a travel camp may be in the State of origin and its office, really it is just an office, and that they would travel by commercial transportation, for instance, through the West, to originate a pack trip or whatever, so you would not have facilities at the point of origin that the State really would be able to see and even foreign travel, of course, is included in travel camps.

Dr. SUSSMAN. Congressman Forsythe, let us get back to the realistic appraisal.

I don't really think you will ever have an army of inspectors big enough on the Federal staff to do what I conceive might have to be done if you really expected to inspect a travel camp to same way you are going to inspect a resident camp, because-let us take this

case.

A camp starts from New Jersey and they go into the Pennsylvania mountains and they go to four different places and they go down some rapids and they are coming off the rapids and portaging their canoes and picking up other buses, you are not going to have an inspector going with them.

Mr. FORSYTHE. But you are not implying that the New Jersey inspectors should follow this camp to Pennsylvania, Arizona, or anywhere else?

Dr. SUSSMAN. I don't think any inspector is going to be able to do that. That is what I said before, that what you have to do when you start a travel camp is find out whether the campers are under control of people that are properly trained, whether the vehicles are properly organized, whether they meet those safety standards.

From there on, we will not be able to protect them if they are on a travel camp going down the rapids; some of them are going to drown, some of them will get wet and there will be some broken feet and there will be safety hazards incident to that type of camp.

Mr. FORSYTHE. But won't the Federal system be more able to follow that travel camp and either there will be a State plan in that State in which they are actually operating that has been approved, or assuming there is not, the Federal Government is responsible in that State to be supervisory and inspecting where they are functioning.

Dr. SUSSMAN. I would hate, I mean, I know you are against it.
Mr. FORSYTHE. No, I am trying to find a place.

Dr. SUSSMAN. No, I know that you are against what I am about to say. I would hate to set up a Federal bureaucracy with the redtape incident, in fact, almost like you have in an aviation travel plan, to require the camp to tell you exactly where they are going and not vary their schedules so that an inspector might catch them at one point or another. I mean, this is an impossibility.

Mr. FORSYTHE. That is not what I am implying.

Dr. SUSSMAN. I know you are against that, I say.

Mr. FORSYTHE. I am just trying to find a way, when a travel camp moved through different States, that if, for instance, if New Jersey is going to be the supervising agency and it loses control, as soon as they cross the State lines, that is, somebody has to see that when they do get equipment in some other States that it is approved, or that it has been approved and so forth.

How do we pull that together if we don't use the coordinating function of the Federal system, not the inspection per se, except where a State does not have an inspection system?

Dr. SUSSMAN. I will put it this way in answer to your original question. I think that the State of origin has the responsibility to see that that travel camp, when it starts out, is properly equipped, has the proper personnel, and has the proper thinking about where they are going.

Mr. DANIELS. Will you yield?

Mr. FORSYTHE. Yes.

Chairman DANIELS. All right, Doctor, I follow your argument, but let us assume for the sake of discussing this point that a travel camp originates in the State of Texas and travels from Texas to Louisiana to Florida, North Carolina, and Virginia, and none of these States have effective youth camp safety laws, none of them. Who should supervise and control a travel camp that has its point of origin in Texas and travels through the States I just mentioned? Dr. SUSSMAN. It is obvious through the legislation you have there that you are going to have effective control because the Federal Government is going to be there doing it.

If the States do not have it, there is no question about that. I am saying the original control should stay with the States and the origination of the camp should be the State.

Mr. Forsythe, in line with what you are stating, and I don't know how this is built in, if they leave New Jersey where we don't have mountain problems and go to Pennsylvania where they do have mountain problems, and the State of Pennsylvania has seen fit to set up standards for people hiking in mountains, then I think the traveling camp is responsible to the State of Pennsylvania when they are in the State, the State of Pennsylvania.

All I am trying to avoid is having Federal officials running around trying to catch up with the travel camps.

Mr. FORSYTHE. I think now we are in agreement because this is really the point I was trying to get at, where they do move into a State with a State plan, that the responsibility moves with them rather than the originating State losing them, because you are not going to get the equipment from the originating State and let us move further than Pennsylvania, as I say, to the Far West. Hopefully that State will have a plan, if they don't, as the chairman says, it is the Federal responsibility.

Now, two more points quickly. On the question of States' camp safety plan, and I think we are trying in the legislation in the bill here to determine how long should States have to get a plan approved before the Federal Government moves in?

I think we ought to have some standard here and I don't think the Federal Government ought to move into all of these other 44 States immediately, but we should have something on that. I am actually talking about section 8(a), where the Secretary should be responsible for the youth camp safety standards in States which do not have in effect a State-approved plan under section 6.

Dr. SUSSMAN. I think you are really talking about section 17 under "Authorization" there because I think eventually you will have to change this particular bill. I don't know-the copy I have says it was introduced in January, 1973, and it talks about under section 17, "For Fiscal Year June 30, 1973", so you will have to make a change on that.

But getting back to your point, it seems to me we should not make the Federal Government, or whether the States have a plan like the six States that the chairman mentioned, I think that the funds could start going to them as soon as you have approved the plan. I think