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Dr. COOPER. Can I put it in a little different perspective, Mr. Sarasin ?

Mr. SARASIN. Yes.

Dr. COOPER. We did not send out a call and say which camps would volunteer, so it is not voluntary in that sense. When the camps were compiled, the randomization process picked out these camps, and they were asked if they would cooperate and they said, “Yes.” That is not voluntary in the sense they said, “We volunteered to do it."

As we pointed out, of the 200 originally approached, 128 said "yes" and followed through and 27 said “no” categorically and the rest of the difference between the original 128 and 200 did not meet the criteria for a variety of purposes. Substitutes had to be secured from another random selection in which they were again approached and asked if they would cooperate.

Mr. SARASIN. Of the 27 that refused, was any attempt made to view the camp, take a look at it from a distance, or whatever, to have somebody there to determine how that particular camp might fit in the sample?

Dr. LANE. Yes. And some of them from available information such as pamphlets and brochures, some information was obtained about their acceptance and affiliations and so forth.

Mr. SARASIN. I assume that the information that came from the 27 camps did not appear anywhere in the reports or summary.

Dr. LANE. I think perhaps the representative of Century might be able to answer this question. I cannot recall, and I don't have the report before me, but I think the most important thing about the 27 is they were not all nonaccredited, for instance. I believe there were some Boy Scout camps and ACA camps in there and most refused to participate simply because of the volume of work it would take them, they felt, to fill out all of the various accident and injury forms.

Dr. COOPER. We would not wish anyone to conclude because the 27 categorically refused, they were necessarily poor camps.

Mr. SARASIN. Thank you. Thank you, Mr. Chairman.

Mr. DANIELS. I now call upon the minority leader of the subcommittee, the gentleman from Michigan, Mr. Esch. Any questions?

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

We seem to be a little on a treadmill this morning because the committee is concerned, I sense, about two areas and one is the procedure of the study itself and, second, the conclusions drawn from it.

I would like perhaps to go over some of the treadmill with you, if we might, in order to get the situation clarified. Then perhaps we can move on to more significant aspects, that is, the Department's posture in terms of any type of legislation.

I think it is important for us to review the first aspect. I want to make sure I understand the chronology here, Dr. Cooper. It is my understanding it took the Department of Health, Education, and Welfare from the summer of 1972, or June 23, 1972 specifically, until the following summer to develop the basis which a survey would be put into the field.

Dr. COOPER. No, sir. I think it took to the following summer to get going, but not to develop the basics on which the study would be done.

Mr. Esch. Well, your testimony that you just gave indicated the reason for the delay was the fact you had to develop the proper instrumentation and the questions and so forth.

Dr. COOPER. As I pointed out in the original questions of the chairman, actually in March the RFP's were mailed out, which indicates that even prior to that time, the actual design of the study and questionnaires were completed.

Mr. Esch. But it took from June until March 1, 1973?
Dr. COOPER. That is right.
Mr. Esch. Nine months?
Dr. COOPER. Yes, to get all of that preliminary work.

Mr. Esch. How many individuals in the Department of Health, Education, and Welfare were working on the development of this during that 9-month time period?

Dr. COOPER. In my inquiries about that, in preparation for this hearing, we indicated that there were about four people, two of which were probably full time and two of which were probably part time, who were working on this right after the enactment of legislation the previous June.

Mr. Esch. That seems somewhat incredible to me because we have been working in the Office of Technological Assessment and we have a capability of getting out a contract within a much shorter period of time. However, I won't question that-it is a matter of record.

Now you suggested that because of the inadequate questions and the nature of the study that you handed over to Century, it was not Century's problem in terms of the data, but actually it was the basis on which the Department of Health, Education, and Welfare took these 9 months to develop the inadequate survey techniques, that on that basis after 9 months you were unable to come up with

any

detailed study that was valuable?

Dr. COOPER. No.

Mr. Esch. That is really what you just said. Do you want to clarify?

Dr. COOPER. I didn't say the techniques were invalid. The techniques were valid. The data base on which they were drawn was deficient. In my review of the situation, I would not conclude that Century was deficient in any of this. We presented them with the RFP with specifications to utilize a certain type of sampling technique for certain types of things.

We drew our information and conclusions from valid statistical analyses and techniques from an inadequate data base. The inadequate data base is the problem we have all spoken to and you have spoken to many times. That is wherein the deficiencies in the study design are derived.

It is not from an incompetent statistician or incompetent contracto. The questions were not applicable in a certain sense to answer the questions in numbers because we made our assumptions from the wrong data base.

Mr. Escu. So I knew that you would want to clarify that for the record even though we might have a disagreement upon that.

Dr. COOPER. I understand, yes.

Mr. Esch. Then my understanding is what Century really did was go out into the field and provide the actual survey function?

Dr. COOPER. Yes. Mr. Esch. What was the amount of the subcontract? Dr. COOPER. Under $40,000. I do not have the exact figure. We will provide it.

Mr. Esch. Century was responsible for the development of the methodology of this study, after being given the data base?

Dr. COOPER. No.
Mr. Esch. What was the function of Century?

Dr. LANE. Century was supposed to pull together all of the report, or all of the study except for that phase that dealt with analysis of law. Part of this study, going back to the original language that Congress wrote into the enabling legislation, was to determine the contribution to youth camp safety being made by national, State and local public and private agencies, to ascertain the adequacy of State laws governing various aspects and to evaluate the effectiveness of current enforcement procedures.

It was these things that the National Recreation and Park Association was asked to look into. In other words, what are voluntary agencies doing in the field-State and local agencies and what State and local law enforcement is going on in the field.

Mr. Esch. I thought the Cordura Corp. did that.
Dr. LANE. No, sir.
Mr. Escut. They would compile the State laws

Dr. LANE. No, sir, they were compiling and analyzing. What they did was submit laws to a panel of 39 experts in the field largely from voluntary organizations, asking them to rate whether these laws and existing regulations were adequate.

Mr. Esch. I am trying to have you define what Century did, because they took 128 or they ended up with 128 out of 200. How did they move from 128 to a sample of 212?

Dr. LANE. This is a fairly strainghtforward process. Their initial sample technique was to identify 20 clusters of 10 camps based on the groupings largely provided by the American Camping Association. Then their representatives went out to the local areas and, in fact, tried to provide, within that local area, a more complete list, a list not just of all camps on the original American Camping Association list, but of all camps in that area. Then they randomized those and drew 10.

They went to those 10 and if one or more refused or, in fact, did not fit the definition of a summer youth camp, as we gave it to Century, another camp was drawn at random from that list to replace it. So they would come out in theory with 200 and then, as explained, following Mr. Daniels' question, if that campsite was used by more than one camp, that other camp was also enrolled and, therefore, they wound up with 212.

Mr. Esch. On the basis of the poor and inadequate statistical information I have it coming out as $884.11 per camp actually visited. That is on the basis that you gave. Do you think that normally follows a pattern of other contracts which the Department lets out

in terms of specific investigations? Does it normally cost $884.11 to investigate ?

Say, for example, if someone in your Department went out, would that be the cost factor you would consider?

Dr. COOPER. I think the difference here, and I don't consider it an unusual cost, and I have not made the same calculations and I don't know if the $884 is the correct number, you know, the 187 minus $40,000 divided by 212, but, as Dr. Lane pointed out, this was a repeated process of visiting.

Mr. Esch. I understand that. How long was each visit?

Dr. LANE. Many visits, in fact, took a full day in the field because the illness forms had to be filled out.

Mr. Esch. Would you give us, for the basis of the record, or Century, the number of man-hours per visit?

Dr. LANE. They very often-well, the man had to go from his base to the camp.

[The information referred to follows:]

NUMBER OF HOURS SPENT BY CENTURY FIELD PERSONNEL

IN

GATHERING INFORMATION AT THE 212 SUMMER YOUTH CAMPS INCLUDED IN THE DHEW SUMMER CAMP STUDY

Field Staff (24 individuals) Time spent visiting 212 camps—multiple visits per camp at approximately weekly intervals throughout the season, 4,837 hours.

Additional Time spent training Field Staff and supervising their activities, 1,470 hours.

Total Time spent visiting camps, 6,307 hours.
Average Time spent in visits to a single camp, 29.8 hours.

Mr. Esch. These were randomly selected, but the randomly selected have been in the eastern two-thirds of the United States.

Dr. COOPER. I think you will find the great preponderance there, but if you compile a list

Mr. Esch. But they were not randomly selected throughout the United States?

Dr. LANE. Well, sir, the random sampling frame should have made any camp equally likely to be included and the breaks of the game found only one cluster up in the Pacific Northwest and two or three others west of the Mississippi. This was achieved by valid random sample techniques with both Government and private statisticians looking over the shoulders of the people who do the sampling.

Mr. Esch. Let's go to one other thing. The conclusion reached by the Department as to the study was that, because of the problems inherent within the study, that there could be no conclusions drawn from the study, just generalizations made by the study, no hypothesis which could be valid and acceptable as to which can be valid on any basis by the Department of Health, Education, and Welfare?

Dr. COOPER. That is not the conclusion that the Department makes. The conclusion the Department does make is that the data they found is not applicable to all camps necessarilv. It, in no sense, means that the Department does not feel that even the data available does outline a problem and a serious one.

Mr. Esch. Would you tell us, Dr. Cooper, what specific conclusions and generalizations or what hypothesis you specifically accept as a result of the study!

Dr. COOPER. We concluded, as indicated in my testimony at several points—six points I believe I reiterated—the fact there was inadequate reporting, inadequate enforcement, that there were preventable accidents, that there were only a small number of States that are providing adequate laws, as has been pointed out before, and we also point out that the rates of severe injury and illnesses that were found in that particular sample concluded that they are not necessarily applicable to all of the camps, and that it is not incompatible with previous data.

Mr. Esch. Let's get in where you obviously say you are in a transition situation as to what the Department might support. Will the Department support either by legislation or further action a centralized national reporting system of all accidents and deaths and have that mandatory rather than just voluntary?

Dr. COOPER. I think that administrative choice of how to report them on that basis would be something that we would be willing to consider as to how that best and practically can be achieved. We are interested in achieving that objective.

Mr. Esch. Would the Department support that idea, since you suggested there is general inadequate enforcement of the existing laws and regulations as well as some deficiencies in the laws themselves, will the Department support an attempt by Congress to encourage both further State legislation in this area as well as adequate enforcement of existing laws and future laws?

Dr. COOPER. Certainly by the States, sir.
Mr. Esch. By the States?
Dr. COOPER. Yes.

Mr. Esch. Do you think, or rather, does the Department of Health, Education, and Welfare and Public Health Service have any responsibility to suggest model standards that ought to be followed?

Dr. COOPER. Yes. We are working on model standards and legislation now, and we would be pleased to make continued efforts that activity and make available technical assistance or concultative services to the States.

Mr. Esch. To what degree? Whom are you working with in that area? What groups? Or are vou doing it in-house?

Dr. COOPER. We are doing it in-house.

Mr. Escu. To what degree would the Department be willing to provide training, or engage in training programs or grants or developments of training programs for camp personnel

Dr. COOPER. Do you mean the support of training programs financially for personnel ?

Mr. Escu. Yes.

Dr. COOPER. The Department does not recommend the Federal support of training programs for these personnel.

Mr. Esch. Why?
Dr. COOPER. We think it is a State responsibility.

Mr. Escu. Do you have comparable analogous training programs in other areas?

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