Request to Exempt Camp Counselors from Minimum Wage
The Massachusetts Camping Association speaks for more than 1,200 camping programs throughout the Commonwealth.
Massachusetts camps 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.
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Seasonal camp staff positions are 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 minimum wage to camp staff and recognize the unique nature of
the camp staff experience. Most states have adopted the Federal standards for this exemption.

States that border MA exempt camp staff from minimum wage 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’s wage 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.

Massachusetts camps provide unique experiences for training and first jobs to thousands of Massachusetts
teens 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.