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. Escн. 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. Escп. 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 in that activity and make available technical assistance or concultative services to the States.

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

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

Mr. Esch. 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. Esci. 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. Escп. Do you have comparable analogous training programs in other areas?

What the nature of the Public Health Service is, I understand, is you provide a lot of training programs for public service personnel in State programs and all kinds of programs?

Dr. COOPER. I think there is a wide spectrum of ways in which this is done in which the Government does support training efforts. There is capability of the group at CDC to aid development of personnel and laboratories in other places. That type of assistance, I think, would be applicable to this type of program. That is not what I meant when I said the other thing, of outright grants for training. Mr. ESCH. Would you be willing to provide training programs for States that wanted to be involved? For example, if a State such as Michigan, and we have had real leadership there, might want to go into a trainee program in which we would invite camp counselors and individuals with responsibilities in governing and functioning of camps to attend workshops and training programs to provide for that?

Dr. COOPER. We are determining, what the training needs would be by States. We are also making a survey of the voluntary groups to see what kind of training capability they are providing, in order to advise as to where it can be done.

Mr. ESCH. I would emphasize perhaps two things in conclusion. I am sure we could go on and I hope your group can work actively with us even though you might not concur with entirely the views of the committee. There has been a great deal of concern about the study and I think rightfully so.

First of all, that is because of the tardiness in undertaking the study.

Second, it was because of the failure perhaps to clearly define the nature of the study and I think the study, with the study inherently, and both studies that is, the studies by Century and Condura, are under suspicion, and whether that is rightful or not. remains to be seen, and we hope that they have a right to clarify their position.

Then, third, I think, because of the failure to communicate the entire study to the committee, which is to me inexcusable from the standpoint of communications between the administrative branch. and the Congress, but, be that as it may, I think that we do have a problem of difference of opinion between the Department of Health, Education, and Welfare and I suspect that it is more of a difference of opinion between the Office of Management and Budget and the Congress rather than the Department of Health. Education, and Welfare as to what we think might be the nature of future legislation.

I suspect in the forthcoming months legislation will be forthcoming from this committee and from the Congress which will be on the Chief Executive's desk and we hope the Department can work cooperatively with the committee to formulate that legislation even though you might finally not recommend to sign it. I think the Congress will see that this legislation is enacted this year and we hope to use the expertise of the Department cooperatively on that in the months ahead.

Dr. COOPER. I can assure you, Mr. Esch, that the Department is most anxious to cooperate in solving the problem. As I have outlined, our major problem with Federal enforcement legislation is the practicalities of enforcement as a Federal standard and a review, but I will commit ourselves to working with you to help solve the problem.

Mr. Escн. Thank you, Mr. Chairman.

Mr. DANIELS. Dr. Cooper, I want it clearly understood as far as the Chairman is concerned, and I think I express the sentiments of all members of this committee, that with regard to this legislation we do not desire the Federal Government to preempt the field and take over from the states. It merely is the purpose of the legislation to prescribe minimum standards. Hopefully all 50 States will follow the leadership of the Federal Government and enact its own legislation in this area, which I believe must be at least comparable to the minimum standards established by HEW.

Now, if all of the States participate, and hopefully they will, because we have an incentive here the bill provides to give a grant up to 80 percent of their cost. This should be incentive for all of the States to participate. If they do that, then of course HEW does not have to work in this area. But all we want HEW to do is just provide leadership. That is all we want the Federal Government to do.

So I enunciated that to make it clear that I think this is an area that is important to the life and health of 10 million children attending these camps each year and it is very, very important to this country and if we save only one life, I think that is important, too. If we can avoid thousands upon thousands of accidents or illnesses, that is also extremely important.

That is all I have to say and thank you gentlemen for being here today.

Mr. DANIELS. We have a panel consisting of Ms. Charlotte Williams, Dr. Kenneth G. Cook and Dr. Peter J. Verhoven.

I might point out to you people that time is short and the House convenes in about less than 5 minutes and I would like to suggest you submit your statements for the record and, then, summarize your views.

Mr. Escн. In light of some questions we raised earlier and in the situation that we do not have time to go into detail here, I would recommend, without moving, that these three witnesses also be allowed to submit any additional testimony to answer any questions which had come up during the previous panel, if they so care to do, to clarify their position.

I am not certain their testimony, itself, clarifies it and I think we want to be as fair as possible to these three witnesses in light of the fact that many of the questions raised, we may not have time to bring up again to them.

So, maybe we can move along if they wish to submit additional testimony to appear in the record and this goes along with the regular testimony.

Mr. DANIELS. Is there any objection to the motion from the gentleman from Michigan?

Hearing none, it is so ordered, so if you desire to supply the committee with a supplemental statement to that which you have today, it will be perfectly in order. You may proceed.

STATEMENT OF MS. CHARLOTTE WILLIAMS, VICE PRESIDENT, ALPHA II, CONSULTANTS, SOCIAL SYSTEMS MANAGEMENT SACRAMENTO, CALIF.; DR. KENNETH G. COOK, PH. D., CENTURY RESEARCH CORP., ARLINGTON, VA.; AND DR. PETER J. VERHOVEN, NATIONAL RECREATION AND PARK ASSOCIATION, ARLINGTON, VA.

Dr. Cook. Mr. Chairman, my name is Kenneth Cook and I am vice president of the Century Research Corp. and I am licensed as a Psychologist in the State of Virginia.

I was not aware the committee did not have our full report and my statement essentially constituted a summary of that report. I had intended just to submit it for the record. I don't know whether you would like me to read it so that you have some kind of organized summary before you.

Mr. DANIELS. Your report will be printed in the record and, in fact, I make a motion at this time that the statements of all three witnesses be printed in full in the record and I assure you that your statements will be brought to the attention of all of the members of this subcommittee.

Is there any objection to my motion?

Hearing none, it is so ordered.

Dr. Cook, you may proceed to summarize your report, or your statement.

[The statements referred to follows:]

PREPARED STATEMENT OF DR. KENNETH G. COOK, VICE PRESIDENT, CENTURY RESEARCH CORPORATION, ARLINGTON, VA.

Mr. Chairman and members of the committee, my name is Kenneth G. Cook. I am a Vice President of Century Research Corporation of Arlington, Virginia and am licensed as a research psychologist in Virginia.

Century Research Corporation was established in 1952 by Dr. Robert B. Sleight, its current President, to provide research and consulting in the behavioral sciences including human factors engineering, personnel psychology, market research, and consumer psychology. Since its founding 22 years ago, much effort of the organization has concentrated on safety research and we have conducted major projects in air and highway safety and in occupational health and safety.

In the Spring of 1973, Century Research Corporation joined with the National Recreation and Park Association in submitting a proposal to perform studies to assist the Secretary of Health, Education and Welfare in tasks directed by Congress in Title VI of the Education Amendments of 1972. This was a competitive bid with the award based primarily on the technical merits of the proposal.

The principal method used was a sample survey of youth camps from which reports permitting an estimate of the number and nature of medically attended camping injuries and illnesses for one camping season were obtained. In addition, information was gathered on health and safety conditions and other characteristics of the camps included in the survey sample. The National Recreation and Park Association, as a subcontractor to Century Research Corporation, was given the task of providing information concerning the contributions to camp safety by various agencies and organizations and

the adequacy and effectiveness of State and local laws and regulations pertaining to youth camps.

I should like to spend a few moments elaborating on the sampling methods to identify the camps which were requested to participate in this study. Government statisticians consulted a number of sources to prepare a list of 5293 youth camps throughout the 48 contiguous states. These were assigned to camp clusters on the basis of their postal zip code. They tried to arrange clusters so that camps in a cluster were no more than 50 miles apart. The country was then partitioned into four geographical areas-Northeast, Southeast, North Central, and West. Five camp clusters were chosen in random fashion for each of the four areas by assigning random five-digit numbers to each cluster, ordering these numerically, and selecting five numbers randomly from within that ordering.

The chosen clusters are identified by referencing them to a community near the center of the cluster. These are: Olympia, WA; Denver, CO: Abilene, TX; Huntsville, TX; Little Rock, AR; St. Louis, MO; Waukesha, WI: Manitowoc, WI; Grand Rapids, MI: Flint, MI; Macon, GA; Savannah, GA; Hampton, SC; Lakeland, FL; Norristown, PA; Somerville, NJ; Monticello, NY; Poughkeepsie, NY; Hillsboro, NH; Portland, ME.

Century Research Corporation employed Field Representatives who in most cases lived near the chosen cluster areas to service the camps in the cluster. Their first task was to make a preliminary check on the camps in the cluster to see if the camps existed and were actually camps as defined by the study, that they were physically located in the cluster area, and that they would be operating in the summer of 1973. The Field Representatives were asked to add the names of any additional camps found in their area that were not on their lists. They eliminated camps which were on their list but were not operating or not in their area. These adjusted camp lists for each cluster were then arranged alphabetically by camp name, each was assigned a random number, and then the camps were ordered numerically by this number. The first 10 camps in each cluster were considered to be the primary sample and were the first to be contacted. If substitutions were required, they were made in order from the camps listed after the first 10.

Of the 200 camps in the primary sample, 128 were surveyed. Only 27 camps refused to participate for various reasons; six other camps were dropped by us when it was found that they were not providing the promised data. Of the remaining 38 camps in the primary sample, 13 were not youth camps within the definition of the study; three could not be located, five were physically located outside of the defined cluster area. Eight were closed for the season and five more closed soon after the initial contact and hence we had insufficient data from them. Several camps, either in the primary sample or in the substitution lists, were listed as separate camps but proved to be func tionally divisions of camps already considered.

Five survey forms were used for data collection. These were designed by staff in the Department of Health, Education and Welfare, reviewed by consultants, field tested briefly by the American Camping Association and revised

as necessary.

The camps participating in the survey were mostly large with a median capacity of 165 campers although 22% were under 100 in capacity. More than half of the camps were accredited by some camping association and of the accredited camps, 80% were accredited by the American Camping Association. Most camps were required to have some kind of license or permit, but about one-fifth to one-third of the camps, depending on the section of the country, said they were not required to have permits. Frequently permits are issued which do not require inspection, but about half to three-fourths of the camps did require one; in states with laws specifically regulating camps, nearly all camps said they needed to be inspected before being issued a permit.

In camping, the counselor and specialist positions are important. These are the people who work directly with the campers and are in the position to teach and to enforce safety and health rules. They also have latitude to make decisions on activities that could lead to a potentially dangerous situation. Minimum qualifications for counselors varied greatly but may be summarized as follows:

Four out of ten camps specifically indicated that their counselors and specialists must be 18 years of age or older. Many of these stresed that this was a minimum. In some camps with this minimum, the counselors were all older than this.