The present staff consists of 14 camp consultants possessing at least master's degrees in education or a related field, a professional background which includes a minimum of two camp seasons of administration in a children's camp and permanent full-time employment as an administrator or supervisor in a children's organization. In other words, they work for us in the summer. They are hired on what we call a permanent intermittent basis. For instance, in the Upper Peninsula, if somebody writes to me and asks, they want to start a camp and we feel it is quite expensive to send somebody from Lansing up there, I have a man who lives in the Upper Peninsular who is in a school system and he can go ahead and we will pay him, because they are hired all year around on this permanent intermittent basis and make arrangements with the camp operator to look over his program, the site, and make a decision on whether he feels we should consider him for licensing.

Because camps operate primarily in the summertime, all but one of the consultants are professional educators in a university or public school system. I think we have three doctors of education or philosophy on our staff.

This arrangement has proven so mutually satisfactory that the 14 consultants employed in 1973 are returning this year. The average tenure for a consultant is approximately 4 years.

This is an important aspect of the Michigan licensing procedure. Our personnel is qualified to be competent consultants who can offer a service to the camps beyond determining qualification for license. In other words, we try to avoid going in there with a policeman's hat. They know that is what we are there for, but in the last few years I noticed a real feeling of friendliness with the camp operators and in their comments about the consultants.

Until 1962, inspection and evaluation of camps were performed by child welfare workers in each county. This system provided a minimum of service to camps since most of the county workers seldom had any experience in camping, yet were assigned to inspect and evaluate camps. There was little consultive role as far as total program was concerned.

In 1962, the licensing of camps was assumed in part by graduate students in the department scholarship program working on their master's degrees in social work. In general the students did a fair job. In fact, some of them did a very good job, although it was seen as a temporary position and there was little desire to identify with camping or with the consultative aspects of the responsibility.

Another problem we found was very seldom did we get these people back for the following year and we feel it takes nearly a third of a camping season, I don't care how much experience a person has in running a camp, before they can go into a camp and give what we consider a good evaluation and good consultation.

In 1965, we were licensing 900 camps. At this time a move was made in the direction of employing school administrators who had camping administrative experience and who, because of the nature of their full-time employment, were available for summer work. The caliber of consultant we have been able to obtain by this move has added continuity to our program and enhanced our image in the

eyes of camp directors and the public. The new consultants are ableto perform a true service in consultation as well as that of an inspector of children's camps. They lend continuity by returning annually and ably represent our department professionally by their maturity, background, and work habits.

We believe that licensing need not be seen as a threat or as a harassment; it ought not lead to fear of closure. Last year nearly 900 camps were licensed: 93 percent received onsite evaluations; 816 of the camps received full licenses; 45 were placed on a provisional basis. Only seven were denied licenses pending meeting the minimum standards.

Mr. DANIELS. Does that conclude your testimony, Mr. Feehery?

Mr. FEEHERY. No. I am very much in favor of your bill and I really think it is needed, if nothing else, from some of the things I have heard yesterday.

Mr. DANIELS. You were in attendance here yesterday?

Mr. FEEHERY. Yes.

Mr. DANIELS. Tell the committee what you heard and what you think that has impressed you most?

Mr. FEEHERY. Well, some of the things that I heard were the age of some of the staff members involved where some of these accidents occurred and also the lack of supervision in certain areas, the death rate that appeared or seemed apparent in certain States and from what I can gather the complete lack of a camp having to do certain things. In other words, to have minimum standards, let us say.

I am in favor of the bill because I feel that if there are a number of States, as you stated yesterday, that do not have a licensing law, I know from experience that a number of camps are going to try to avoid having certain things. In fact, even in camps that we license, and they know it is a law, we find many situations where, well, not many, but we find situations where the staff are underage, improperly trained. We find unqualified people on the waterfront. We go through this in a State where licensing is already a law and I can just imagine if all of a sudden we didn't have licensing in the

camps.

Mr. DANIELS. In 1965 you finally amended your camp law in the State of Michigan to attain a more effective law, is that correct?

Mr. FEEHERY. I began work with the State of Michigan in 1964 and it was done prior to that. I think it was around 1960, 1961 or 1962 that they were amended.

Mr. DANIELS. Well, the State of Michigan is reported to be a pioneer in this field and had adopted the first camp safety law in this country. At least that is what we were told in these hearings. Now, prior to enactment of this law, can you tell me what the records will show with regard to facilities and the number of camp accidents and illness which occurred annually? Do you possess any statistics on that score?

Mr. FEEHERY. Unfortunately, I don't have any statistics prior to the time I began working with the State of Michigan. However, I have heard, Dr. John Kirk has told me, that the reason for these laws being changed was because of the number of accidents and I understand the year prior to the time there was more teeth put in

the law, let us say, because there were rules prior to that, that there were six deaths in Michigan camps and we have not even come close to that since.

Mr. DANIELS. In 1 year.

Mr. FEEHERY. From what I understand, it was in 1 year.

Mr. DANIELS. And that occurred in what year?

Mr. FEEHERY. Well, it was prior to 1964. I would think it probably happened around 1961, because I think around 1961 or 1962 this was the case.

Mr. DANIELS. Well, what has been your record after enactment of this law? Were any fatalities sustained after 1961?

Mr. FEEHERY. I don't know if any fatalities were sustained after 1961. However, there had been fatalities in Michigan camps since I have been there.

Mr. DANIELS. Well, I am talking about the period of time you have been there. Let's take from 1965 up to the present date.

Mr. FEEHERY. OK, from 1964 to 1973, we have had six deaths by drowning, and two of those were on camp waterfronts and three were on trips and one was in a pool.

All right, we had one death by a child falling off of a horse. We had a death by a child falling off of a cliff. We had one death in a truck accident and we had one death where a child was buried in sand.

Mr. DANIELS. Well, now, if these camps are properly supervised and you have engaged competent help, can these fatalities have been avoided which you just described?

Mr. FEEHERY. I think that is one of the reasons I said earlier I was really appalled by some of the things that do go on in the camps in States other than ours, and probably in some cases in ours, appalled that with the laws we have and the enforcement we have we still lose children in the camps. However, we feel that by these laws there would be many more accidents which can be prevented.

I think it goes the same way with ACA. Even though they have standards and maybe a person will go into a camp and there will be all of the standards that should be met, there will still be accidents in the camps.

But I think what we are talking about is this: OK, we may have one in 1 year with the law and maybe six without it.

Mr. DANIELS. What you are saying is if you did not have this law on the books the number of accidents might be much higher?

Mr. FEEHERY. Right, sir. What I am saying is that without this law I am just sure the number of accidents would be much higher, because we hear of things that go on in the camps when we are not there and we cannot be there all the time. So I know if they do not think we are going to come in, or not going to give them some kind of evaluation or consultation or that possibly the parent would not have any place to complain to if certain things were going on in a camp, I am sure there would be many more accidents.

Mr. DANIELS. Mr. Feehery, what is the record with regard to accidents and illness since 1964? Now, I don't want a guess. You are acquainted with this law. You came here as a witness to testify about your Michigan State law. I would like to have specifics. If you do

not have that information available, you may submit it for the record.

Mr. FEEHERY. Our records and reports are kept for 3 years. After 3 years, they are destroyed. So I can only go back accurately for 3

years.

Mr. DANIELS. I will accept the last 3 years.

Mr. FEEHERY. However, the deaths that I have given you, I know that they happened.

Mr. DANIELS. I would like you to give a statement for the record officially as to fatalities, accidents, and illness.

Now your Michigan law requires a licensing fee. Is there a fee charged in connection with obtaining a license?

Mr. FEEHERY. There is no charge for a camp to operate in Michigan.

Mr. DANIELS. Is the camp inspected prior to its opening?

Mr. FEEHERY. The camp is checked by the fire marshal and by the county health department and one of our consultants or I will take a look at the site and evaluate the proposed program for the particular camp, plus the qualifications of the director.

Mr. DANIELS. Well, the camp is inspected prior to obtaining approval for a license?

Mr. FEEHERY. Yes, a camp is checked before licensing.

Mr. DANIELS. Now, with regard to personnel employed in a camp, is there anything in the Michigan law which requires checking into the character and reputation of such people?

Mr. FEEHERY. One of our rules states that the camp, that there shall be in the camp file information concerning the employee that would attest to his qualifications and that also, certainly, as far as we are concerned, would refer to his character and his qualification, in other words, to work in a children's camp. This is available to our consultants when they go into a camp.

Mr. DANIELS. Let me ask you specifically this question. Does the Michigan law require that a lifeguard be in attendance while the children are swimming?

Mr. FEEHERY. In resident or day camps we require that a water safety instructor is on the waterfront.

Mr. DANIELS. Is he required by your law to have experience?

Mr. FEEHERY. He is required by our law to have current certification. We will accept equal qualification from the YMCA and Boy Scouts, which they have comparable to a WSI.

Mr. DANIELS. He is required to have certification as to what?

Mr. FEEHERY. That he has completed the water safety instructor course. We don't actually test him before he runs the program. We do evaluate it when we go in there, but we accept the certification that he is qualified and he has to be 18 or older to direct a camp waterfront. In a troop or travel camp we require a senior lifesaver.

You might want to know the reasons. You see, your lifesaver is very well qualified for saving someone's life. However he may not have background in directing a large waterfront or to instruct swimming and of those deaths and drownings that I mentioned to you. I found that everyone of those children were nonswimmers. So we feel that if there is instruction on the waterfront, that possibly

some of these deaths may have been prevented. In other words, the sooner a child can learn to swim at a camp, the better his chance that he will survive.

Mr. DANIELS. Well, therefore, shouldn't your lifeguard or lifesaver have some experience in this type of work?

Mr. FEEHERY. I think that would be desirable. However, it is very difficult to get water safety instructors the same as it is to get nurses, and when a person takes the course we hope, at least I go to the course and I speak at the course and observe part of it, which is given by the American Red Cross, and if he passes that course we feel he should be able to run a camp waterfront. If, when we go in to evaluate the camp, we feel he is not competent, then the swimming program closes until a competent person is there.

Mr. DANIELS. You are satisfied as long as he has the certification of the American Red Cross?

Mr. FEEHERY. Yes. I think it is the same way with a doctor or anything else, once they have the certification, the requirement is satisfied, but when we observe the operation, if we do not feel that it meets our standards, even though the person is satisfied, we will discontinue that operation.

Mr. DANIELS. I now recognize the gentleman from Connecticut, Congressman Sarasin, for questions.

Mr. SARASIN. Thank you, Mr. Chairman. Mr. Feehery, I thank you for taking the time to be with us this morning.

I have several questions, some of which were prompted by your statements and answers to the chairman's questions.

With regard to the certification by the Red Cross, does it include the training on conducting a waterfront course or is it just lifesaving certification?

Mr. FEEHERY. The American Red Cross requires that a person has their senior lifesaver authority, they have to qualify as a senior lifesaver to be a water safety instructor. At the National Aquatics School, where we get many of our people that are on camp waterfronts in Michigan, and at the colleges, they actually, well, part of the course includes running camp waterfronts. In fact, that group is separated from people working at pools and things like that. So it does require lifesaving and not just instructor swimming.

Mr. SARASIN. But does it also require instruction on how to conduct a course with a specific number of children, including a curriculum guide?

Mr. FEEHERY. Yes, to be a water safety instructor they have to instruct at least I think six children every 2 years to keep it current and they have to pass a course of instruction in order to be qualified and they are pretty, at least in most places, they are pretty tough on this. My daughter happens to teach at the National Aquatics School in Michigan and not every person that takes that course gets through. In fact, when they allow 17-year-olds to come in there, 33 out of 66 flunk. That was to take the course.

We won't allow that 17-year-old on the camp waterfront. He still has to be 18.

Mr. SARASIN. With regard to 10 fatalities which you mentioned, does the State of Michigan conduct an investigation or does your de