The following archived on 03/09/2009

The much anticipated updated California organized camp regulations have been adopted by the California Secretary of State.

You are highly encouraged to review the following information:

The following archived 01/2009

Proposed Organized Camp Regulations

Since receipt of the DHS "Notice of Proposed Rulemaking" regarding Organized Camps, representatives of the California Collaboration for Youth ("CCFY") have collected extensive comments from Camp Directors throughout the state, met with the California Department of Health Services ("DHS") to discuss the comments received to date, and worked together to gain a better understanding of the process going forward.

Summary

• These regulations, 10 years in the making and not previously revised for nearly 50 years are finally moving forward.
• Your attention to this is time critical. Please read this memo completely and respond as requested by friday, 4/6/07.
• What we need most from you is simply to put the sample letter (MS Word) on your letterhead and mail it to dhs so your support is added to our collective voice. If you do nothing else, please take 2 minutes and do this now!
• If you don't need to know more, then that's all you need to do. If you want to know more, read on. . .

Background
To provide a context for considering our comments, please understand that the current process of updating the Organized Camp Regulations began in the early 1990's. At that time, a collaborative effort between all of the stakeholders in the organized camp community in California and DHS resulted in a version of the proposed regulations.  This version began the regulatory review process with DHS in 1997 where it has languished until now.  

We cannot emphasize enough the importance of having these regulations updated. All one has to do is pick up a newspaper (or check Yahoo) to watch the daily drama surrounding Walter Reid Medical Center in Washington DC and care for our veterans to get a glimpse of what would happen to us in the event a major tragedy occurred in a California organized camp and the media and parents subsequently learned that our industry's regulations had not been updated since the 1950s!

CCFY has convened two conference calls and one in-person meeting with representatives of numerous state and nationally affiliated camp organizations to gather input on the regulations. We have prepared a response to the Department's proposed regulations, reflecting the concerns raised and the clarifications we have received from DHS staff as well as suggested revisions. With these regulations so long in the making, we feel it is important that the Department receive numerous letters of testimony in support of the regulations moving forward, with reference to the noted changes and clarifications advocated by CCFY.

So while we may not love all aspects of the proposed regulations, the fact that they have been in suspense pending public comment since 1997 and the reality of legislation created in reaction to a bad event lead us to urge DHS to move forward as quickly as possible to finalize and adopt these regulations. The current version was disseminated to all of us on January 5, 2007, which is the first time any of had an opportunity to see what "edits" had been made during the review process. The last thing we can afford is for these regulations to end up on the same shelf gathering dust for another 10 years. In the future if technical changes are needed, CCFY can pursue legislation to address these issues on our behalf.

Comments Received
Attached please find a draft version of the comments CCFY has received from camps and professional associations (ACA, CCCA, WAIC) throughout the state. All comments we plan to submit are included in this letter. If a comment or concern of yours is addressed in this letter, you do not need to repeat it in your own letter. We have been advised that a "rulemaking" hearing is different from a "legislative" hearing, in that a volume of "comments" HURTS the cause (does not help), because more comments increases the time it takes for DHS to respond as required by law. Ideally to the greatest extent possible, therefore, it would be in our best interests to submit one (1) letter that incorporates all comments we feel DHS needs to consider.  

Please review the Comments (MS Word) from CCFY for your consideration.  Please review these comments carefully. If you have additional concerns not reflected in the attached "Comments" memo, we would encourage you to speak to one of the many camping representatives listed at the bottom of this memo who were engaged in the conference calls and meetings and who may be able to speak to your concerns by sharing information from our discussions.

Your comments should be directed to CCFY through one of the people below. Please let us hear from you if you have any concerns, additions, or changes prior to March 30, 2007. If we do not receive any input by that time, we will submit the Comments letter (MS Word) to DHS as representative of our industry's position on the proposed regulations.

Letters of Support
Where volume DOES help is in submitting letters of support. Accordingly, we have a Sample Letter of Support (MS Word). If you are so inclined, please send such a letter on your camp or organization's letterhead (or both) as soon as possible. The more letters of support DHS receives, the better!

Letters of support can be mailed to:

California Department of Health Services:
Office of Regulations
P.O. Box 997413
Sacramento, CA 95899-7413

They can also be faxed to (916) 440-7714 or e-mailed to regulations@dhs.ca.gov, but in each case you must reference the package "R-15-97." It is our hope (and belief), however, that our industry can speak with one collective voice.  

Process
In response to a written request, DHS has scheduled a public hearing Monday, April 9 at 10 AM in Sacramento. This effectively extends the comment period until April 9, so all letters must be received by 5 PM on April 9. The purpose of the hearing is to accept oral and written comment on the regulations. Pursuant to the administrative procedures act there will be no discussion or debate during the hearing. Furthermore, there is NO difference between comments submitted in writing and those submitted orally. As such, the same guidelines discussed above with respect to written comments apply to oral comments given on April 9.  

It is anticipated that, due to the lengthy time involved in a regulatory process, these regulations will not be implemented until Summer, 2008.  CCFY has been asked to participate in the development of a handbook highlighting the revisions to the Organized Camp Act, a project we are pleased to undertake.

RSVP for In-person Hearing
If you have submitted a letter or comments already, you will NOT need to say anything at the hearing. However, we would like a good number of people who support the regulations to attend so we can ask you to stand and show that you are in support.  

Please let us know if you are planning to attend the hearing so DHS can anticipate ample time and space for participants. Thank you in advance for your assistance in this important process.  If you have any questions, also please feel free to contact the CCFY legislative office at (916) 447-7341.

Michele Branconier - ACA So CA (760) 345-2926
Roger Williams - CCCA (831) 430-1230
Tom Horner - WAIC (626) 296-4040
Tim Holland - ACA No CA (530) 273-6744
Frank Reigelman-Boy Scouts of America (972) 580-2421
Stanton Whitling - CCCA (559) 335-2000 x418
John Green - YMCA of the USA (800) 872-9622
Andrew Townsend - ACA No CA (831) 479 6714
Kim Rosiar - CCCA (800) 833-1444