Tuesday, March 12

PSU Policy AD73 Puts Children In Harm's Way

Revised policy AD73 violates one of the basic tenets of preventing child abuse -- the two person rule.  PSU' created this policy in response to the Sandusky case and it was approved on July 9, 2012. 

Ray Blehar

When the Freeh Report was released back in July 2012, many child protection and sexual abuse prevention advocates lauded it for the improvements in child safety on PSU's campus.  

Here's RAINN's statement:

The results of Louis Freeh's investigation are stunning. It is shocking that the disregard for the children who were victimized was so widespread, and the systemic failure so deep. Beyond whatever changes happen at Penn State as a result of this report, the leaders of every school in America need to take note today. They need to make sure that everyone knows that the safety of kids is always the highest priority, regardless of the potential embarrassment to the school. There are only two appropriate responses to a child being sexually assaulted: first, you need to immediately notify law enforcement, and second, you need to ensure that the child gets the help he or she needs to recover from the attack.

— Scott Berkowitz, president and founder of RAINN (The Rape, Abuse & Incest National Network)

After reading this statement - and having previously reviewed the entire Freeh Report - I wrote Scott Berkowitz several letters and e-mails that pointed out the failures of the Pennsylvania Department of Public Welfare and Centre County CYS  as the primary reason that Sandusky was able to roam free for 14 years.  I asked Mr. Berkowitz to call for a review of PA DPW and CYS.  

That call never came, nor has Mr. Berkowitz ever responded to my e-mails and letters.

Report 1 Falls on Deaf Ears

RAINN, Protect Pa Children, and several other charities all received my first report (demonstrating that PA's DPW and CYS officials failed to conduct a thorough investigation in 1998 and that Louis Freeh's report downplayed the failures) , yet not a single one changed their public statements on the Freeh Report nor did they even bother to write to me to ask questions or get clarifications about my report.

Clearly, these so-called child protection and sexual abuse prevention organizations, just like the media, are "invested" the the current narrative (that PSU officials enabled Sandusky) and do not have the courage to make a stand for the truth -- which is really standing up for children.  They do not have the courage to condemn the Freeh Report for not pointing out the failures of PA child protection system.  And they do not have the courage to stand up and call for real reforms in the PA child protection system.  

They should not be rewarded for their acts of cowardice that are keeping PA's children in harm's way.  RAINN, protectpachildren.org, pa-fsa.org, abolishsexabuse.org, should not receive a single dime from Penn State Alumni.

PSU Policy AD73

The Penn State Board of Trustees, under mounting pressure from alumni, have retreated to the position that they hired Freeh to improve governance and have committed to implementing the report's recommendations.  They have patted themselves on the back for the progress they've made.

However, as Jim Clemente, pointed out, the recommendations of the Freeh report did nothing to help people identify and protect children from "nice guy-pillar of the community" pedophiles.  Clemente, in an interview with Media Mayhem's Alison Hope Weiner, pointed out that Freeh had no prior experience investigating sexual abuse cases.

Clemente's revelation helps to explain why PSU Policy AD73 not only fails to protect children, but actually places them in similar one-on-one situations that Sandusky used to abuse children.  Policy follows (my emphasis added):


It is the policy of the Pennsylvania State University that all Athletics facilities (spaces typically, but not solely, designated for specific intercollegiate athletic program(s) use) will be accessible only by those University athletes and athletic personnel authorized to access such facilities, and during their normal hours of operation. A valid University identification card is required to gain access.

Recreational facilities (spaces typically, but not solely designated for recreational activity not affiliated with intercollegiate athletic activity) are useable only by those individuals with a valid University student or faculty/staff/retiree identification card, programmed (where applicable) to allow proper access to such facilities, plus one related guest.  Access to such facilities will only be authorized during the time each facility is specifically designated as being open/available for use.

While open, these facilities shall have the appropriate staff on duty to oversee operations being conducted at that facility.

Any exceptions to this policy must be given in writing, and approved by the appropriate facilities office responsible for athletic and recreational facility access.
<end policy>

This policy, if I'm reading it correctly, would not have prevented Jerry Sandusky from abusing Matt Sandusky on PSU facilities.  Nor would it keep an abusive parent or uncle who is a University employee or retiree from bringing a child on campus and abusing them.

Part of the $6.5 million paid to Freeh supported the creation of this misguided policy.

The Two Person Rule

It is standard practice in most organizations and programs for youth to have a "two person rule" in  place to protect children and the adults who supervise them.

Here is a sample from Kid's World:

Two Person Rule
The "Two-Person" Rule is designed to protect both children and adults by not giving opportunities for adults to have sustained time alone with a child or student. It also protects staff and volunteers in situations in which a child or student with some significant emotional needs may misinterpret adult interaction or may make false statements about an adult's behavior toward them. By following this rule, many potential problem situations are prevented.

Simply put:
  • The "Two-Person" rule must be in effect at all times during KidsWorld events.
  • NEVER allow yourself or another volunteer to be alone with a child. This applies to children in your own family while serving in KidsWorld.
  • At least one of the volunteers must be an adult.
  • Volunteers must not be related. If they are related, a 3rd volunteer must be present.
Each room will have a 2-way radio in their registration bin. Use it to contact a Zone Leader if you need a second volunteer to keep the Two-Person rule in effect.


Penn State policies are reviewed by the President's Council and the PSU General Counsel as part of the approval process.  It is clear that President Rodney Erickson and the other 17 members of the President's Council, as well as the PSU legal counsel haven't a clue about child abuse prevention.  Nearly 80% of child abuse is perpetrated by a parent.  Another 7% is perpetrated by a relative.  PSU still is under the impression that the danger is going to come from the creepy old man in a raincoat.

Nor do they have a clue about much else when it comes to running Penn State.


  1. Ray, I couldn't agree more. I have worked for 30 years coaching children and it has always been a strict policy that you are NEVER alone with a child, regardless of how well you know that child and her parents. This is SOP for any business that provides services to children, so the fact of it having been left out here is puzzling, to say the least

  2. Jessi's experience with SOPs is mine as well...and I've worked 30+ yrs with college-age young adults and older! Whether working in industry, academia, or gov't agency, I was trained during HR Orientation to always be cautious during one-on-one meetings and to never close the door. Always avoid even the appearance of possible impropriety.

    When the Sandusky story broke, it made no sense to me...how could he have gone unstopped for so long? A Google-search in Nov 2011 suggested to me that Pennsylvania laws/ enforcement/culture regarding child sexual victimization could be a factor. PA stood out nationwide as having a relatively poor record for addressing this problem. Thanks to you guys and the Clemente report, maybe child sexual victimization will finally be understood and tackled!

    I believe that the Sandusky case reveals a PA problem. By focusing on PSU, the media are missing a HUGE opportunity to actually make a difference. The message to them should be "Think of the children. Think of YOUR children. Use your bully pulpit to make a difference, to leave a legacy YOUR kids can be proud of."

  3. When I heard this last year, I immediately recognized that thousands of PA kids would be affected. I used to take carloads of my son's friends to IM and Rec Hall to play.

    Not only is it a poor policy in response to CSA fears, but it just disenfranchises kids, period. That isn't what Penn State should be doing right now or ever.

    A month or so after the change, my cousin, who played on the girl's hoops team at a branch campus, posted on her Facebook wall that she couldn't even go into the gym to shoot around.

    If the University absolutely needs to keep facilities locked up like that, they should provide key cards to every local family where their facilities reside. Or they need to get creative in another way. for the kids.

    I know PSU likes to play the public/private institution card however it suits them on any given issue, but this is another instance where we can say: 'The University gets a lot of State money, so they need to give back to its residents.'

    I know for a fact that facilities have a lot of unused availability. For nine months, I have had this image of children being locked out of play areas and it is just too much.

    1. Plus, this just reinforces the notion that the typical pedophile/child molestor is a shady-looking guy who's hovering around the place (which is exactly the idea that Clemente refutes in his report).

  4. Thanks, Ray. Penn State is trying so hard to be politically correct, that they are not remembering the children. The entire state of Pennsylvania needs to wake up to the reality of child victimization and the ways we overlook potential to eradicate it. Keep up the great work. FTK.