attended and therefore the results would mean very little. I also feel that various people with camping expertise should be represented there.

Mr. DANIELS. May I suggest this: What I envision is that the Secretary would appoint to this board representatives of national organizations that have some knowledge and some expertise in this field, such as the Girl Scouts of America, Boy Scouts, American Camping Association, and other groups that have a wide interest in this area.

Mrs. OAKERSON. By no means.

Mr. DANIELS. It would be difficult to manage.

Mrs. OAKERSON. Nine seemed a rather small number to me. I thought possibly of 15 or 16.

Mr. DANIEL. You may implement your statement and submit an additional statement and make your recommendation as to how large you would prefer to see the board, and also I would like to have your recommendation as to the nature of the organizations which should be represented on this board.

Mrs. OAKERSON. All right, we would be happy to give you that information.

We have retrieved the data on the number of children who were in the pool at the time of the drowning we mentioned earlier.

Ms. PINNEY. We took advantage of the brief recess to make a telephone call to the office of the council under whose jurisdiction the accident occurred. All the information I had earlier was simply that Girl Scouts camping standards were met. There were 13 children in the pool at the time of the drowning, supervised by two water safety instructors and two adults.

Mr. DANIELS. For that number of children. I think you did have safeguards and precautions. Of course, you could very well understand that if we had 300 or 400, that number would have been totally inadequate.

Ms. PINNEY. Yes, it would, sir.

Mr. DANIELS. Now, as I pointed out, there are no standards specifically set forth in this legislation. All we do here is establish the outline by which this legislation will operate. You would have the opportunity, and we should get it under due process, to comment and get your viewpoints as to what standards should be enacted. I don't know what your standards consist of. If you have any particular standards, I would appreciate it if you would submit your standards to us and we will file it with the record of this proceeding.

Mrs. OAKERSON. We have.

Mr. DANIELS. I have no further questions.

Mr. Sarasin, do you have any questions?

Mr. SARASIN. With regard to your last statement, Mr. Chairman, do I understand that the Girl Scouts standards have been presented to us for the record? May I ask, then, if you provide the standards for various types of camping, troop camping and day camping? Ms. PINNEY. Yes, we do. The standards are quite specific for day camp, troop camp, and resident camp.

Mr. SARASIN. Then it is certainly possible to create standards for the various types?

Ms. PINNEY. Yes, it is. We would like to point out there is a subsection in the bill on travel camping. We would like to see subsections on other types of camping.

Mr. SARASIN. The bill would of course provide for minimum standards, then Federal enforcement in the event States do not create standards and enforcement. Do you feel that is a good idea? Ms. PINNEY. We would take somewhat the same position that the American Camping Association, Boy Scouts, and other colleagues have, that State enforcement is probably most desirable with the people in the States somewhat closer to the operation of the camps. Most camps are under various kinds of health departments and other kinds of regulations in States already. So we would really like to see State enforcement.

Mr. SARASIN. But in the event the States do not act, what then? Ms. PINNEY. We would hope that the States would act. In the event they don't, we do need to safeguard the safety of the youth, and whatever is necessary to insure that would have to be done. I hope that the legislation would encourage the States to do it themselves.

Mr. SARASIN. It certainly does that, but provides a back-up if they feel that the Federal Government would become involved. Personally, I agree with you that the States should primarily be the ones responsible for that.

May I ask if you have statistics on prior injuries or statistics for injuries of years prior to 1973?

Ms. PINNEY. As I stated earlier, we have had a system of collecting information about accidents for many, many years. I am not quite sure when it was instituted. However, the accidents were not well defined. I would think that our accident statistics for 1972 and prior would not be as reliable as our 1973 statistics. We do have some, but I don't think they are complete.

Mr. SARASIN. I think one of the things we are going to have to do, at least by regulation, is to define various types of injuries so we can get complete reporting throughout the Nation. I wonder if your present definitions might be helpful to us. If possible, I would ask you to submit those also for the record. [The information referred to follows:]

GIRL SCOUTS OF THE U.S.A., Washington, D.C., July 23, 1974.

Hon. DOMINICK V. DANIELS, Chairman,
Select Subcommittee on Labor,

U.S. House of Representatives,
Washington, D.C.

DEAR MR. CHAIRMAN: As you will recall, Girl Scouts of the U.S.A. testified before the Select Subcommittee on Labor on June 12, 1974, in support of H.R. 1486, the Youth Camp Safety Act. We applaud your efforts on this legislation and offer for your consideration the enclosed language, designed to enhance the intent and applicability of this Act.

First, we propose a redefinition of "youth camp" and the types of camping encompassed therein-resident, day and troop. Second, we propose a directive to the Secretary of HEW to make suitable distinctions among these types of camping programs in the promulgation of youth camp safety standards.

Girl Scout camping as an integral part of the Girl Scout program has the following objectives:

To promote the physical and mental well-being of every girl and leader. To develop resourcefulness, initiative, self-reliance, and recognition of the worth and dignity of each individual.

To develop a sense of responsibility, qualities of leadership, and an awareness of the capacities of all people.

To provide an inner satisfaction, a sense of awe and wonder, and a deep enjoyment for both girl and leader.

To provide a sense of accomplishment.

To stimulate each girl's awareness of the scope of the natural world.

To develop the individual's sense of responsibility to conserve the natural world.

It is our feeling that, although every group which goes camping may not have such specific and comprehensive objectives, that some sense of these objectives is a meaningful addition to the language that appears in the existing bill. We have, therefore, replaced "a camp, as the term is generally understood" (Sec. 3(1)).

Sec. 3. For purposes of this Act

DEFINITIONS

(1) The term "youth_camp" means a resident, day, troop or travel camp conducted on any parcel or parcels or land which utilizes the resources of natural surroundings for the purpose of providing a creative, recreational and educational camping experience.

(A) The term "resident camp" means a youth camp accommodating 5 or more children under 18 years of age, living apart from their relatives, parents or legal guardians for a period of 5 days or more.

(B) The term "troop camp" means a youth camp which provides not less than 24 hours a day camping for organized groups of 5 or more children under 18 years of age within a parent council of a national voluntary youth serving organization.

(C) The term "day camp" means a youth camp operating for a portion of the day, but less than 24 hours a day, and conducted on a permanent campsite for at least 5 days during a two week period, for 5 or more children under 18 years of age.

(a) A permanent campsite means an outdoor campground containing within the premises thereof temporary or permanent structures and installed facilities which are continuously or periodically used for camping purposes for a portion of a day by a youth camp operator. (D) The term "travel camp" means-(no change from language in H.R. 1486/S 3639)

PROMULGATION OF YOUTH CAMP SAFETY STANDARDS

Sec. 5. The Secretary shall develop, and shall by rule promulgate, modify, or revoke youth camp safety standards. In developing such standards, the Secretary shall consult with State officials and with representatives of appropriate public and private organizations, and shall consider existing State regulations and standards and standards developed by private organizations which are applicable to youth camp safety and shall make such suitable distinctions in the standards as are necessary and appropriate to give recognition to the difference in conditions and operations between resident, troop, day and travel camping. The Secretary shall make the initial promulgation of standards required by this section within 1 year after the effective date of this Act. KATHLEEN B. Ross, Washington Representative.

Ms. PINNEY. We have. Mr. SARASIN. I have no further questions, Mr. Chairman. Mr. DANIELS. In concluding, may I also direct your attention to section 7 of the bill. No grant may exceed 80 percent of the cost for carrying out State plans. Now, I agree with your view that we would prefer States to adopt legislation, to carry out the laws of their own States. However, since 26 States have no legislation in this area at all, I feel that the Federal Government should establish the leadership and encourage the States to adopt this legislation.

You will also find in the proposed legislation that the Federal Government wants to establish minimum standards. Nonetheless,

the States would be obliged to institute plans which are at least equal to the Federal standards that may be promulgated. I believe that the States ought to control their own programs, but they should be effective programs. Hopefully, more of the States will adopt such legislation up to the present time by virtue of action that we have endeavored, this committee has endeavored, to take in the past. I want to point out to you that after the statute which was voted by Congress in 1971 legislation, that I personally sent a copy of the bill of the legislation pending to each of the Governors of the fifty States. As a result of that action, six States have taken affirmative action along this line. Hopefully we can get the other 44 along. With that, I think we have no problem.

I want to thank you ladies for coming here today. We will recess until 1:00 o'clock.

Thank you.

[Whereupon, at 12:05 p.m., the subcommittee was in recess, to reconvene at 1:00 p.m., the same day.]

AFTER RECESS

[The subcommittee reconvened at 1:05 p.m., Hon. Dominick V. Daniels (chairman of the subcommittee) presiding.]

Mr. PEYSER. The committee will come to order. Mr. Daniels will be with us in a few moments. He has had an opportunity to review your statement. We would like to hear from you and as the chairman has said, if you would like to have your entire statement in the record, we will do so and you may summarize it or whatever you want to do.

Mr. TOFANY. It is a reasonably short statement and so I will proceed. Your courtesy is very much appreciated.

STATEMENT OF VINCENT L. TOFANY, PRESIDENT, NATIONAL SAFETY COUNCIL, ACCOMPANIED BY HARRY N. ROSENFIELD, GENERAL COUNSEL, NATIONAL SAFETY COUNCIL; AND JOHN FLEMMING, MANAGER, PUBLIC SAFETY DEPARTMENT, NATIONAL SAFETY COUNCIL

Mr. TOFANY. Mr. Chairman and members of the subcommittee, the National Safety Council welcomes this opportunity to testify regarding the pending H.R. 1486, Youth Camp Safety Act. We are grateful to you, Mr. Chairman, for pressing this issue. Your perseverance and that of the Congress is such that the 1975 camping year may prove safer than it would have been otherwise.

As a matter of identification, the National Safety Council is a nongovernmental, privately supported, public service organization chartered by the Congress of the United States to further, encourage, and promote methods and procedures leading to increased safety, protection, and health whenever exposure to accidents can and does result in death or injury to people.

I am accompanied today by Mr. Rosenfield, to my left, and Mr. John Flemming, the manager of our Public Relations Department in whose sphere of activity falls all camping activities.

The council has been concerned for the safety of young people while they enjoy the benefits of attending a youth camp. Our educational effort in this regard have spanned many years and are summarized in an appendix to this statement. I should like to submit copies for the committee's files.

This represents the third time in recent years in which the National Safety Council has reported to this select subcommittee on the subject of the safety of youngsters while attending organized camps. The council's views were expressed on July 21, 1971, in a presentation by Howard Pvle, then president of the council.

At that time, among other things, we expressed serious concern over the lack of comprehensive data on accidents and injuries that arise out of the operation of youth camps. Even earlier, on May 21. 1969, the council recommended the passage of H.R. 763, which called for a survey of the health and safety situation in youth camps. The council's position has not changed and we now reaffirm those positions. Since that time there has been considerable national attention directed to almost every area of accident prevention. Unfortunately little governmental progress can be reported for organized youth camps.

It seems somewhat incongruous and I think this morning Chairman Daniels very wisely pointed it out, that the employees of a private camp are currently protected by Federal legislation, but the youngsters attending the camp are not.

We believe these youngsters should have the benefits of comprehensive health and safety standards consistent with sound camping experiences and that such standards have the force and effect of law. The youth camp safety survey which the council recommended and which the Department of Health, Education, and Welfare conducted pursuant to Public Law 92-318 has been carefully studied, and the following observations are offered: the limited accidental injury data obtained from the study are probably not typical of what is occurring in youth camps in general and appear to be based on a biased sample. Particularly disturbing is the fact that of the approximately 200 camps originally selected for this study, only 128 were actually surveyed. Quoting from the U.S. Department of Health, Education, and Welfare report to Congress [page 6, paragraph C], "The resulting sample was, in fact, a selection of volunteer participants." "One cannot assume that health problems existed in camps that volunteered for this study at the same rate with which they existed in camps choosing not to participate." This situation appears analogous to that in occupational safety and health wherein the record shows that members of the National Safety Council, that is, volunteer participants, had an injury frequency rate that was 70 percent lower than nonmembers and a severity rate that was 40 percent lower than nonmembers for manufacturers.

Consequently, we suspect that the statistical findings in this HEW study reflect the safety performance of the better managed camps and cannot be regarded as reflecting the situation in camps in general.

The HEW study reveals very little effort on the part of most States to take action to protect the lives of youngsters while attending camp.