December 8, 2016 Office of the General Counsel Department of Public Health 250 Washington Street Boston, MA 02108 Via Email: Re: 105 CMR 430.000: Minimum Standards for Recreational Camps for Children (State Sanitary Code, Chapter IV) Dear Commissioner Bharel and members of the Public Health Council, Thank you for the opportunity to submit testimony on the proposed amendments to 105 CMR430.000 Minimum Standards for Recreational Camps for Children (State Sanitary Code, Chapter IV). Mass Audubon Camp Directors were in attendance at the hearing in Boston. We were glad to have the opportunity to speak with Mr. Hughes and Mr. Williams and to receive clarification on the intent of a few of the proposed changes to the code. At this time, Mass Audubon would like to provide written testimony on behalf of our Camps for Children. Mass Audubon currently operates 17 licensed day camps in the Commonwealth which serve over 10,000 campers annually. Our camps are accredited by the American Camping Association. We, as an organization, are committed to child safety in all of our programs and fully support the Department of Public Health’s goal to provide quality care of children. We applaud the work that the Department of Public Health has done to update and clarify the camp regulations; however we have concerns regarding details of a small sample of the proposed amendments. We respectfully submit the following suggestions for consideration. 430.1000: Camp Counselor and Junior Counselor Requirements The proposed change at the end of 430.100(A)(1) from “or” to “and” will ensure that the counselor will be trained and ready to supervise campers. However the proposed change in requirement from required expertise as a “participant in structured group camping” to “junior counselor” will significantly limit the applicant pool for hiring camp counselors. This proposed
December 8, 2016 Office of the General Counsel Department of Public Health 250 Washington Street Boston, MA 02108 Via Email: Re: 105 CMR 430.000: Minimum Standards for Recreational Camps for Children (State Sanitary Code, Chapter IV) Dear Commissioner Bharel and members of the Public Health Council, Thank you for the opportunity to submit testimony on the proposed amendments to 105 CMR430.000 Minimum Standards for Recreational Camps for Children (State Sanitary Code, Chapter IV). Mass Audubon Camp Directors were in attendance at the hearing in Boston. We were glad to have the opportunity to speak with Mr. Hughes and Mr. Williams and to receive clarification on the intent of a few of the proposed changes to the code. At this time, Mass Audubon would like to provide written testimony on behalf of our Camps for Children. Mass Audubon currently operates 17 licensed day camps in the Commonwealth which serve over 10,000 campers annually. Our camps are accredited by the American Camping Association. We, as an organization, are committed to child safety in all of our programs and fully support the Department of Public Health’s goal to provide quality care of children. We applaud the work that the Department of Public Health has done to update and clarify the camp regulations; however we have concerns regarding details of a small sample of the proposed amendments. We respectfully submit the following suggestions for consideration. 430.1000: Camp Counselor and Junior Counselor Requirements The proposed change at the end of 430.100(A)(1) from “or” to “and” will ensure that the counselor will be trained and ready to supervise campers. However the proposed change in requirement from required expertise as a “participant in structured group camping” to “junior counselor” will significantly limit the applicant pool for hiring camp counselors. This proposed