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Children's camp licensing dates back to 1939; however, it was not until 1944 by the enactment of Act No. 47, (P.A. 1944) when the Department of Social Services was charged with the responsibility for regulating non-governmental camps that the law was enforced. At that time the administrative rules for camps was vague and, although included general child care concerns, were geared primarily to the area of sanitation.

From 1944 until 1960 there were few changes in the rules. In 1960, because of an increase in serious accidents, some fatal, the rules were rewritten to place greater emphasis on safety in the areas of hazardous program activities as well as general child care and sanitation. This resulted in a noticeable de crease in accidents and fatalities, especially on the waterfront. Some additional rules were updated between 1960 and 1971. They were not, however, specific and did not include enforceable areas in fire safety and sanitation by the licensing agency. In 1973 the rules for children's camps were completely rewritten and divided into three sections; general provisions, fire safety provisions, and sanitation provisions. The general provision section covers adminis. tration; supervision; staffing; site, facilities and equipment; care of children; health supervision; nutrition and food service; waterfront supervision; records and reports; and transportation.

The department of Social Services administers the licensing program with assistance form the Dept. of State Police, Fire Marshal Division; and State and County Health Depts. Evaluations are performed while the camp is in op eration by licensing consultants from the Department of Social Services and inspections of site and facilities are conducted annually by the fire marshal and the county health department. A report of evaluation and inspection is then sent to the Dept. of Social Services where a final decision is made on the licensure by the supervisor of camping services. The camp operator is informed of this decision and receives a copy of all reports.

With over 200,000 children attending some 900 camps in Michigan, the competency of the licensing staff performing the actual on-site evaluation is very important. By having experienced consultants, the quality of child care in camps is being constantly upgraded and continuity is maintained in the overall licensing program. The present staff consists of 14 camp consultants possessing at least master's degrees in education or related field, a professional background which included a minimum of two camp seasons of administration in a children's camp and permanent employment as an administrator or supervisor in the children's organization. Because camps operate primarily in the summertime, all but one of the consultants are professional educators in a university or public school system. 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 four years.

This is an important aspect of the Michigan licensing procedure. Our person. nel are qualified to be competent consultants who can offer a service to the camps beyond determining qualification for license.

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, 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.

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 calibre of consultant we have been able to ob tain 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 able to 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 an harassment; it ought not lead to fear of closure. Last year nearly 900 camps were licensed.

Ninety-three percent received on-site evaluations; eight hundred and sixteen of the camps received full licenses; forty five were placed on a provisional basis. Only seven were denied licenses pending meeting the minimum standards.

Mr. DANIELS. Our next witness is Mr. L. S. Christofero, Manager, Camping and Engineering Service, Boy Scouts of America, North Brunswick, N.J.

Before you proceed, sir, I would like to extend a welcome to a group of students from the Langley Cooperative School, of McLean, Va. Î understand they are eighth-grade children and I will be glad to come down and greet you after this hearing is over in about 1 hour. I understand that your director is a friend of our colleague, Mr. Peter Peyser of New York, who is not with us this morning.

I hope you pay attention and listen carefully to what the witnesses have to say and what we members of the committee say on the dais here also, and I trust you get some benefits from this hearing.

Mr. Christofero, you may proceed.

STATEMENT OF L. S. CHRISTOFERO, MANAGER, CAMPING AND ENGINEERING SERVICE, BOY SCOUTS OF AMERICA, NORTH BRUNSWICK, N.J.

Mr. CHRISTOFERO. We appreciate the opportunity to be here and participate in this testimony. The Boy Scouts of America has carefully reviewed H.R. 1486 to be cited as the "Youth Camp Safety Act."

Since it has always been concerned about the welfare of all youth, the Boy Scouts of America heartily endorses the intent of this bill as it did all predecessor bills on youth camp safety.

THE SCOPE OF SCOUT CAMPING

The Boy Scouts of America is chartered by Congress and reports to that body each year so we feel a deep obligation to provide safe, healthy camping opportunities for young people.

In local Scout councils throughout America we camp approximately 780,000 young people in our 600 long-term summer camps annually.

TROOP AND PATROL CAMPING

In addition to their long-term summer camp experience, hundreds of thousands of young people enjoy short-term or weekend hikes and camps throughout the year with their own troop or patrol.

Since this requires eternal vigilence in matters of health and safety, the national standard camp rating has been developed over 25 years for all Boy Scouts of America long-term camps. The rating contains 117 separate items ranging from safety standards to program standards.

This rating includes a precamp inspection required 30 to 60 days prior to camp opening and a full inspection soon after each camp

opens.

These inspections are conducted annually in all of our camps by carefully trained volunteer and professional adults representing the National Council Boy Scouts of America.

The inspectors have the authority to initiate closure of a camp or any of its sections should it fail to comply with mandatory standards. Copies of these standards have been submitted for members of the subcommittee.

I would like at this point to just go over briefly how we operate in respect to these standards.

First of all, the 30-to-60-day precamp inspection, which has mandatory standards in it which must be complied with before the camp opens, requires that the members of the local council of health and safety committee, the Scout executive, the camping committee people and other executive board personnel and local insurance and fire prevention people, conduct an inspection and a report of that inspection is made to the regional Scout office. Then the regular standard inspection is conducted by our trained personnel and this requires, first of all, a presentation of documents, the development plan for the camp and there must be a conservation plan for the camp prepared by a Government agency or a qualified technician, job specification, staff manual or copies of letter of employment in which the jobs are specified, the camp operating budget, the inventories and conditions, a letter of agreement with a local hospital must be produced, current, a letter of agreement with the fire department or other related agency and a record of water tests.

Now this certification then must be submitted, must be current, or the camp cannot open. The responsibility for this list is first of all with the local council and eventually of course the National Council of the Boy Scouts of America.

We have 26 items in standards that are marked as mandatory. Failure to comply with any one of these 26 items will result in closure of the camp or that particular section of the camp that does not meet the standards. We have ratings, or course, the national standard, an A rating and a B rating, the national inspection camp certification and also, C, a national inspection, but all of these require first of all the 26 health and safety standards must be met.

To take just a moment as to what they mean, there has to be a current written agreement or exchange of letters with the hospital. There has to be written plans for handling major emergencies such as floods, severe storms and so on. There have to be proper standards of instruction, supervision and safety training carried out in the aquatic program including the use of boats, canoes and all aquatic facilities and they must comply with State and U.S. Coast Guard regulations.

The waterfront director must be current, have taken a Red Cross or Boy Scout week-long course in waterfront direction and water safety and he must be at least 25 years of age.

All motor vehicles must be in good mechanical condition. For several years we have had a regulation that no children, that no campers are transported in trucks except in the cab and that all of these vehicles must be in good condition.

We require that a local fire company or the warden has checked the facilities in case of possible call and has submitted written recommendations or has on file a confirming letter. We also teach our young people in our troops a fire guard and should a fire start in any part of the camp then the troop can handle it.

Included on this, on page 9 of the standard you have, is the action to close a camp should it fail to comply. A council, that is the local council, that ignores or fails to take corrective action on one or more mandatory standards will be requested to close the program area so affected until the corrective action is complete.

Standards essential to the health, safety, and welfare of all campers are marked with an asterisk. If these standards are not met, the council may be advised to close the camp until corrective action is taken.

Then it goes on to explain the procedure for closing that camp or some part of it should it fail to comply.

I have submitted this document. In addition to that, we have a checksheet and for the record this is a worksheet which goes along with our standard pamphlet. This is the one here that the inspector

uses.

Mr. DANIELS. Mr. Christofero, you have submitted that to us for the record?

Mr. CHRISTOFERO. I did not this one, but I will. I have copies of it.

Mr. DANIELS. We would appreciate it if you leave some copies here.

Mr. CHRISTOFERO. Also, we have, in order to keep a record of it, the final report made in respect to this, which is kept, a copy in the local council office, one in the regional council office and our national office. We have a record of all of our 600 camps.

We train our people through the manuals we have in camp safety and aquatics and I would be happy to leave copies for the committee. Our national camping schools, about 40 schools are conducted in which we train our people.

We have traveling groups and it has been mentioned a number of times in the testimony here the past 2 days in which we have approximately 500,000 young people and leaders who are involved annually in travel groups and we administer a tour permit system which requires all groups to file records of adequate leadership, proper vehicles, insurance and itinerary.

Mr. DANIELS. While you are on that subject, there has been some discussion here in the last couple of days about licensing of travel groups. Should they be under the jurisdiction of the Federal Government or the State where the tour originally originated. Do you have any opinion on that?

Mr. CHRISTOFERO. We feel that the State of origin should be where the licensing is done. However, I think there ought to be some sort of regulation because we go across States, we don't much with our scout troops, but sometimes we do, so we feel, although the State of origin should have the responsibility of licensing, or whatever we want to call that, there has to be some sort of a Federal regulation that goes across the State lines, as these people travel.

We recognize also that with the great number of troops, at least as far as we are concerned who do this, that it can be extremely cumbersome for one agency to keep track of these all over the country. That is why I make the statement, sir, that the State should do the original licensing.

In cooperation with other organizations, the Boy Scouts of America work with many national and local organizations including the American Camping Association. We are at present working with the American Camping Association to develop a set of national standards, camp inspection, that can be recognized by all camps within the American Camping Association and Boy Scouts of America scope of jurisdiction and we recommend these standards to be referred to in the development of any Federal standards.

Now, we have some minor concerns about the bill, that legislation include all facets of organized camping in addition to recreation and educational groups, programs or clinics within camping characteristics, and we say this simply because if they say it is not camping and it is, it still should come under the regulation, we feel.

That the Federal Government with its ultimate responsibility for the law and its minimum standards, encourages uniformity among States.

That implementation be the responsibility of the States. Whatever the report on youth camp safety said here, or however we feel about it, the one thing that is evident here is there are not enough States that have camping regulations. So our feeling is, as we look at the possibility of Federal legislation and the assistance it can give, that this will encourage, and I perhaps should use the word "urge" more States to do something about camping regulations. This is why we heartily endorse this bill.

That travel camps should be governed by State law of the State of origin and I would change that to say "should be originally licensed."

That youth camp safety implementation be funded by public funds, Federal, State, or both, rather than by fees from camps that would eventually come from the boys or girls themselves.

That further development of the law and its implementation use the resources and expertise of recognized camp leaders and opera

tors.

The Boy Scouts of America believes that national agencies with established standards equivalent to those ultimately developed by HEW be permitted to conduct their own inspections in lieu of Federal or State inspection and the agency to file a copy of the inspection with the State.

We, even though Michigan has a law, still inspect our camps through our own Boy Scout system.

That special attention be given to coverage of all types of programs, making clear definition in order to preclude any contest of possible ambiguities.

I guess what I say here is we would like to see it clearcut so there are no loopholes in it and, in following up, refer page 9, section 8A, "Secretary responsible for the enforcement of youth camp safety standards:", and there we would hope that specific emphasis be given to methods, trained personnel, and specifics as to how this will be done.

Refer page 13, section 12, Variations: Concern here is for qualification, knowledge, and training of "field inspector."

Refer page 14, section 15, Advisory Council on Youth Camp Safety: Again that this body should include as members, representa

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