Request to Exempt Camp Counselors from Minimum Wage

The Massachusetts Camping Association speaks for more than 1,200 camping programs throughout the Commonwealth. Massachusettscamps employ over 23,000 seasonal employees over the summer, with most of these camp employees employed between six to ten weeks.

Camps have an uphill challenge to comply with the Commonwealth’s minimum wage regulations that require tracking of hours worked and pay associated with that requirement. Camps historically negotiate a salary for the short summer season but cannot do this under current law. For this and other reasons, camps are requesting an exemption that would allow camp counselors be considered exempt workers under Massachusetts law.

Section 13(a)(3) of the US Fair Labor Standards Act provides a FULL exemption from the minimum wage and overtime provisions of the FLSA for all summer camp staff that are employed on a seasonal basis. The vast majority of states, including all Northeast states, mirror this important exemption. Massachusetts does not.

  • Seasonal camp staff positionsare not living wage jobs. Candidates are choosing these jobs to gain training in teaching, leadership and outdoor or experiential education. Camps are uniquely positioned to provide workforce development training to teens that would not gain these skills at school.
  • Federal wage laws provide exemptions from minimumwage to camp staff and recognize the unique nature of the campstaff experience. Most states have adopted the Federal standards for this exemption.
  • Statesthat border MA exempt camp staff fromminimumwage requirements. Camps have always established clear letters of agreement with counselors defining remuneration based on the entire summer’s experience.
  • Current regulations attempt to address the problem but the minimum wage laws are in conflict with the goals for the current Labor and Workforce guidelines for student camp employee wages.
  • Thousands of underserved and needy Massachusetts youth attend camp annually through the efforts of camps whose mission is to provide these deserving youth the opportunity to grow and learn within a safe summer camp environment. The Commonwealth’swage laws, in conjunction with DPH camp licensing requirements for appropriate staff-camper ratios and staff age requirements will disproportionately impact Massachusetts’ Day and Resident Camps. Camps around Massachusetts will be extremely challenged to financially sustain their camps and some may be forced to close or move their business out of state.
  • Massachusettscamps provide unique experiences for training and first jobs to thousands of Massachusettsteens each summer. Camps here also maintain open spaces and are stewards of some of the finest undeveloped properties in Massachusetts. Increased pressure in areas like the wage laws could force them out of business and their loss would also threaten the $11.2 million in out-of-state tourism spending that summer camps bring to the Commonwealth.