that the full effect of this should not be put into effect where the Federal Government can put their standards into effect in less than 1 year; that is, from the time they make the standards, I am talking about the advisory committee and the Secretary of Health, Education, and Welfare, providing the standards, I think we should then have a year's delay to give the States an opportunity other than those six States, to pass legislation that would give them the opportunity to come within the real of this.

Mr. FORSYTHE. Do you think 1 year would cover the legislation and establishment of a State plan? Some of our legislatures don't meet except every other year and maybe we need 2 years.

Dr. SUSSMAN. If they got off of their duff, yes.

Mr. FORSYTHE. Let's be practical. As I say, some legislatures only meet every second year.

Dr. SUSSMAN. Well, I don't know about this. I would think that 2-well, look, we waited a long time. I don't think 2 years is too long if you are giving them the carrot approach at the beginning that they get 80 percent if they make a plan and make it more incentive for them to come in. I think I would say 2 years would not be too much from my standpoint.

Mr. FORSYTHE. Thank you very much, Mr. Chairman.

I could go on, but I think I will stop.

Chairman DANIELS. I recognize the gentleman from Pennsylvania, Mr. Gaydos.

Any questions?

Mr. GAYDOS. I want to thank my chairman for recognition. I want to congratulate you, Dr. Sussman, for a very practical and forthwith approach to the problem. I think your descriptive terminology is most practical. I feel the same way you do; you tore the bill apart and made a very practical and commonsense analysis.

Let me ask you a few short questions to confirm my impression of what you intended to convey here before the committee.

On page 3 of your statement, you mentioned, and I quote, "A written plan not rigorously enforced will lead to misleading of the consumers involved."

Now, section 7(a) has the enforcement provision in this proposed legislation and it is my understanding that you feel we have sufficiently covered it and you are just affirming the legislative provision or are you questioning the sufficiency of it?

Dr. SUSSMAN. No. I think what I am questioning is my discussion outside of this room. I had the impression that some people were against the Federal Government having a supervisory field inspection staff and what I was saying is that once they approve our plan, I think it is important that they do more than just come around and see that our paperwork is done.

I think they have to get their feet wet and go out without our necessarily knowing where they are going and that involves them having sufficient personnel to make a statistical sampling in each State that gets money.

Mr. GAYDOS. Are you suggesting that we add to the language in the present bill?

Dr. SUSSMAN. No sir, I think the present bill is all right if it is understood that the money is going to be available for them to have a supervisory field staff.

Mr. GAYDOS. Unfortunately, that is also a question.

Dr. SUSSMAN. Well, if you don't, I think you are going to give a misleading and deceptive connotation to the public, because you will have beautiful plans approved and we won't ever know whether they are going to be properly implemented.

Mr. GAYDOS. Well, my response to that, is that this committee does have oversight jurisdiction and should that situation develop, I am sure the chairman would exercise that prerogative and we would go into oversight hearings.

Now, one final question. On page 3, under section 3, subsection 2, we do set forth some standards, the criteria, such as for the safe operation of youth camps. Under this section, personal qualifications for a director and the staff are mentioned. That is at the top of page 3 of the draft, the ratio of staff to campers, and in that area do you agree with me that possibly this section should be strengthened insofar as we should make more specific mention of referral to possible criminal background of personnel? Do you think the language is sufficient to include that, or in other words are you perfectly satisfied that the Secretary would promulgate rules and regulations in this area, which would be sufficiently stringent and all encompassing to take care of that situation?

Dr. SUSSMAN. I would hope so.

Mr. GAYDOS. Do you agree with that observation?

Dr. SUSSMAN. Yes.

Mr. GAYDOS. Doctor, is this a problem as far as you are concerned in your professional standards? Do you hear complaints from people generally involving this area which I referred to this last minute or two?

Dr. SUSSMAN. Not that I can remember.

Mr. GAYDOS. As to moral straightness, for want of a better descriptive term, with people involved with youth in the Nation, do you hear of it, do you think it is an important consideration?

Dr. SUSSMAN. Certainly there are complaints and I think it is a problem and certainly it has to be; I would even use the word "attacked" because I think there is a problem but I am afraid if you put it down in specific wordage, in the Federal law the Supreme Court will change it and then you will have to get it back and I think what you have to do is depend on your advisory council and inspectors to make certain.

You know, we will be looking into that in each different area and I would hope by doing this it will put the white light of knowledge in the fore, and I personally would not want to see us get too rigid in our legislation that we would be tearing ourselves apart, you know, trying to meet the legislation.

Mr. GAYDOS. I agree with you that it is difficult to make particular adjectives stick in interpretation and who is to say who is right? But the reason I asked you that question was because many people are concerned in this area. Recently a group of my constituents in

formed me, they are vitally concerned with it. It seems to be a subject of general discussion among people.

The accusations are many times inaccurate, unsubstantiated, but people talk about these things. I just wanted to get your professional opinion as to whether or not we adequately considered and provided for the matter and I appreciate your frankness.

I would like to make a concluding observation, Mr. Chairman. Pennsylvania, at the time Federal legislation was enacted allowing States to take upon themselves Federal inspection of meats and poultry immediately, without any qualms, allowed Federal people to take over their entire inspection systems in both areas, meat and poultry.

I do share with you the opinion that you have expressed here. The reason for it at that time, as I gleaned from the publicity in the newspaper accounts, I believe, involved the 50 percent participation. If it would have been more, possibly the States' rights theorists would have prevailed in Harrisburg, our State capital. But the 50 percent was an obvious inducement, and resulted in the State giving all of its enforcement inspection power to the Federal Government. So, I do appreciate your remarks involving the 80 percent participating factor which you referred to and in conclusion, I don't think you would argue with 100 percent, would you, if we made it that. I want to thank you for your testimony.

Mr. DANIELS. I now recognize the gentleman from New York, Mr. Peyser.

I want to state, prior to Mr. Peyser's questioning, that Mr. Peyser has been a strong advocate of youth camp safety legislation and has worked very, very diligently to see that some law or laws are enacted in this area by the Federal Government as well as the States. He has worked as hard as myself and other members of this committee in that regard.

Mr. Peyser.

Mr. PEYSER. Thank you, Mr. Chairman.

Doctor, I certainly appreciated your testimony.

Mr. Chairman, I would like to ask unanimous consent that a number of letters I recently received pertaining to deaths of children in camps in the last year or so be entered into the record. They are additional ones which I think would be worthwhile if I may ask for unanimous consent.

Mr. DANIELS. You heard the unanimous consent question. Any objections? Hearing none, it will be so ordered to follow the testimony of the witness who will testify here today.

Mr. PEYSER. Thank you, Mr. Chairman. I do have one thing I would like to comment on at this time, because much of it is in keeping with what you have been saying to us. We have received, as the chairman is well aware, a report from HEW, which was as a result of the legislation passed by the Congress calling for a report on camp safety. The report is a 16-page report. When I received it, when the Chairman, received it, I know we were and are highly dissatisfied with this report for its inadequacies. Generally it seems to say nothing.

Mr. Chairman, 20 minutes before I came into this hearing this morning I received a copy, and maybe you have already seen it, of the Century Research Corp.'s report from which this HEW report is made.

Mr. DANIELS. No. I have not received a copy.

Mr. PEYSER. This report is extremely enlightening. I have just been scanning through it to pick out some highlights because from my interpretation, if there ever is a justification for camp safety legislation, it is in this report. This synopsis in no way reflects what we paid and, incidentally, I had a GÃO request for a study on what we paid for the reports and we paid $187,000 for this report.

I don't care, really, what we pay if the report is good and has something to say and, as I have scanned this report, and it seems to me that it is the strongest statement of "why we should have legislation" of anything I have read. Hopefully, we will get copies of this, obviously, for the committee.

Starting off, taking a few highlights first dealing with counselors. For instance, only 55 percent of the camps inspected in this report require counselors to be 18 years of age. In other words, it means 45 percent can hire counselors under age 18 to be dealing with children.

To go on, let's take drivers, for instance: 56 percent of the camps inspected require a State driver's license for driving vehicles in the

camps.

Now, if we go to the other side of that, it means 44 percent do not require driver's license, State driver's license, and you know the number of deaths we have had reported, and one of the worst was out in California a couple of years ago when a 16-year-old was driving a flatbed truck with children on it and it turned over and several were killed. It goes on to outline that particular area.

In swimming, it outlines in a number of camps the inadequacies of, for instance, the need for chlorine in the pools, and points out that most of the camps involved keep no records at all, of when the pools were chlorinated.

As you know, at a regular pool you see the list each day showing it is chlorinated, and it reports the majority keep no such records as to that type of activity.

On injuries, the only highlight I will pick out at this point, says: In the interpretations of the inspectors, 38 percent of the injuries were preventable in the opinion of those inspecting these camps. That is, 38 percent were considered to have been preventable.

In the area of fire, and this is something that certainly is of interest, fire extinguishers were not available in sleeping areas in 57 percent of the inspected camps.

I think it is important to know that in this report the only camps inspected, and there were 200 camps on-sight inspected, were only those who agreed, of course, to allowing inspectors to be there. Many camps refused. Of the original 200 camps, 72 camps refused to let inspectors come in. So they went out and got additional camps to bring the total up to 200 camps. These are camps, presumably, which felt that they had no basic problems and they were willing to let the inspectors come in. Of that group, 57 percent have no fire extinguishers in sleeping areas.

With regard to food, it showed that 18 percent of the camps had inadequate dishwashing facilities, and 15 percent had no controls for insect or rodent infestation, and once again it points out here that fire extinguishers were not available in the messhalls of 41 percent of the camps inspected.

Going on, 35 percent did not keep any logs and 21 camps of the 200, 21 of the 200, which is a little over 10 percent, had swimming areas that were considered hazardous by the inspectors.

Then, going into the State law section, it outlines in detail from all of the States the laws indicating States that have no regulations as to physical examination for personnel, examination for campers, first aid training for personnel, no requirements whatsoever in any of these.

So, Mr. Chairman, primarily, what I want to bring out this morning is that this report which came from HEW, dated April 29, and this report, which incidentally, was completed in January 1974, which I also have here, issued nearly 312 months later and I find no relationship between what I have in this hand and what this record in this hand actually shows.

Mr. DANIELS. Mr. Peyser, I might state to you that the administration witnesses are scheduled to appear before this committee on June 13, and at the same time the people who made that report have also been invited to participate in the hearings.

Mr. PEYSER. Good. I think that is excellent, because it will be most interesting to hear how this report in my one hand reflects what I have in this report in my other hand.

I will be glad to get you a copy of this. I just received it this morning; I had it sent up from Atlanta. It seems to me that every justification for this legislation is presented in the statement in this hand even though HEW reaches a conclusion in the one in this hand. that there is no need for legislation.

Mr. DANIELS. Well, the staff has requested a copy of that report. Mr. PEYSER. Fine.

Doctor, I did not mean to, in effect, utilize your time on this, but I felt it was important and in keeping with much of what you said on this question. One thing I would like to know, from you, is whether in your own work with camps, do you find or have you found any camps that are reluctant to have people come in?

I understand in the State of New Jersey, it is voluntary that inspections be made; is that correct?

Dr. SUSSMAN. It is voluntary, Mr. Peyser, up until this year.
Mr. PEYSER. Up until this year?

Dr. SUSSMAN. And one of our inspectors had the seat of his pants. torn off, so it was sort of reluctant inspection at that point.

But I would say that most of the camps, once we have the authority, have given us no difficulty. But it is a question of not having the authority previously and I think, and I don't recall who it was that was speaking about it, I guess Mr. Forsythe, I think if you don't have authority to go in you don't really, you know, have a way of doing it.