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Health aspects of the factories Bill
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PUBLIC HEALTH.
Health
Aspects
of
the
F~RL'ARV,
Factories
Bill.
By JOHN J. BUCHAN, M.I)., Ch.B., I ) . P . H . , Medical Officer of Health, Bradford, and IAeut.-Col. F. E. FR~MANTLE, O . B . E . , M.P., M.B., M.Ch., F . R . C . P . , F . R . C . S . , D . P . H . ; Consulting County Medical Officer of Health, Hertfordshire. Although there is some uncertainty as to the ultimate fate of the Bill, it is appropriate that its objects and effects should be discussed, and no more suitable contributors than Dr. ]. J. Buchan and Colonel FremantIe, whose papers are given below, could h'ave been found to open the discussion on the subject which took place at the ordinary meeting of the Society, i~ London, on November 18th, 1927. D R . J. J. B U C H A N . this discussion 1 wish, first of all, I toN opening pay tribute to tile very great influence for good which Factory Legislation has exercised upon the social condition of the people of England. Always the subject of keen opposition and controversy, successive Factory Acts rapidly became accepted by all as necessary steps in social progress, and to them chiefly are due the abolition of child labour in this country and the relief of women and young persons from onerous conditions of employment. Factory legislation in England began 125 years ago, and therefore preceded by many years legislation in Public Health and in Education. To some extent this accounts for the difference in administration, as well as for the somewhat ill-deterrnined relationship of the older service with these more recent and more rapidly growing social services. The Factory Acts are administered directly from Whitehall by a branch of the Civil Service under an important Government Department which, however, has hardly any other functions of a similar nature. Health and education services are administered by local authorities supervised from Whitehall by other Government departments, and this fundamentaldifference in the administration renders co-ordinated work exceedingly difficult. Factory Legislation is now almost wholly concerned with questions of health, safety and the welfare of persons in industry, but communal efforts of this kind cannot stand alone and be administered alone if they are to give the best results. The present Factories Bill is chiefly a consolidation measure and marks few fresh developments in legislation of this kind. It is difficult to understand why there has been so much consolidation of Factory Law since 1878,
with so little new added, because as it stands to-day, the law is not particularly involved or difficult to understand, tn the circumstances comment on the present Consolidation Bill must of necessity be confined to smaller detail. The first point which one notices is the new definition of " factory." In previous legislation considerable difficulty was experienced in defining factories and workshops, and in the present Bill this is got over by abolishing the distinction and using" the one term " factory." Despite this attempt at simplification, the definition of " factory " in tile Bill is not simple, while the abolition of the distinction between factories and workshops will make administration of the law still more difficult, as between sanitary authorities and the Factory Department. The effect of the change will be to lav the responsibility in sanitary matters in what are now workshops in the first instance upon the Factory Department, and this is a change which is hardly likely to make for efficiency and economy. In the last Report of the Factory Department, out of 145,411 factories, the Factory Inspectors dealt with 19,582 matters of sanitation, whereas out of 128,793 registered workshops, district councils dealt with almost 40,000 matters of sanitation. If the Secretary of State, therefore, proposes to maintain the same standard of work as has been held in the past, and do the work through the Factory Department, a large and unnecessary increase of the staff of factory inspectors will ensue. The Secretary of State mav delegate certain duties now being taken from them to the district councils, and if he does so, I have no doubt that the officers of local authorities wiil be willing to help him, but the Secretary of State must remember that he is not Parliament, and district councils as a whole have no great love for the delegated duties of Cabinet Ministers.
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PUBLIC
It is interesting to note that previous factory legislation so long a g o as in the Act of 1878, rejected the procedure which the present Bill attempts to resuscitate, the Factory and W o r k shops Act of 1878 repealing certain words in Section 91 (6) of the Public Health Act, 1875, so as to make the sub-section applicable to factories and workshops under the Factory Act and to be administered by the local authority, The experience of fifty years in this procedure does not, t think, warrant the reversion to the older and inadequate methods. The present Bill, in pursuance of the course it sets out on, proposes to delete the words " factory, workshop or " from the sub-section just mentioned, but this amendment is futile, as much more profound alteration is necessary to prevent the Public Health Act, 1875, being applicable to factories. Very difficult positions will be apt to arise if the arrangements forecast in the Bill become law, and only by the greatest care and consideration on the part of both the Factory Department and Local Authorities can these unnecessary difficulties be overcome. The Secretary of State will have great difficulty in determining whether a district council is able or wiiling to undertake the duties of enforcing sanitary provisions, and when he does so determine, he will not be able to delegate under the Bill certain provisions which should necessarily be delegated to them; thus, for e x a m p l e , the lighting of workshops and the prevention of spitting in workshops and bakeries--important matters which must remain in his own hands. It is unnecessary to stress this matter further, but it is possibly wise to point out that the reports of the Factory Department have not shown any great degree of success of that department in dealing with sanitary matters. This is easily understood when it is appreciated that this department has not had the training, experience or opportunity for doing sanitary work of the nature they may now be required to undertake. In the first part of the Bill, Clauses 10 and 11, giving power to act in default of a district council, look well on paper, but it is impossible to put them into operation, and it is difficult to see why they are repeated from the 1901 'Act. Clause 12 gives power to the Secretary of State, in consultation with the Minister of Health, to order special medical supervision of the workers in particular circumstances This should b e an important
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new power, but the clause is weakly drafted, and will be difficult to operate, as such medical supervision may be refused by the workman, and the reasonable provision which an employer may make for this purpose might be regarded by the Secretary of State as very far from reasonable. The second part of the Bill deals with questions of safety, and does not at the moment call for special comment ; this is also true with respect to the third part, dealing with welfare, incorporating the powers with respect to special welfare orders under the Police Factories, &c., Act, 1916, which is in part repealed. In the fourth part of the Bill, Clause 43 prohibiting spitting in Factories has already been referred to. Clause 47, prohibiting heavy lifting by women and y o u n g persons so as to cause injury, )s a power which is very difficult to put into operation, as weight lifting depends very largely on individual physique and condition, and Factory Inspectors who would have to administer the Clause would on this account be slow to put it into effect, as they would not be sure of their ground. Clause 52 deals with underground rooms, and so far as they affect workshops, provision should be made for delegating the powers it gives to the district council, otherwise one may have a local authority saying that an underground room is, under the Health and H o u s i n g Acts, uninhabitable, and the factory inspector certifying it as fit for work to be carried on or v i c e v e ~ ' s a . Clause 53 deals with basement bakehouses, the term " bakehouse " in this Clause being quite different from that in the general interpretation clause, under which the storage rooms are not regarded as part of the bakehouse, and the definition thus becomes distinctlydefective. The position of bakehouses in this Bili is peculiar. It is not clear whether all are factories or not, but in the fourth schedule of the Bill, the provisions of the Factory and W~orkshop Act, 1901, are re-enacted to be administered by district councils. Here, however, the question arises as to whether Clause 2 (a), requiring regular cleansing, operates, and if so, whether the factory department or the local authority are to administer it. This is a point which requires to be made clear if this Bill is being proceeded with. Part V. deals with accidents and industrial disease, and contains no new features of
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FEBRUARY,
PUBLIC HEALTH.
interest, but Part VI, dealing with the employment of women, y o u n g persons and children, contains, in Clause 86, a provision which requires young 'persons under the age of 16 years to be examined bv " the appointed doctor " and certified as fit for employment within a short time of their entering a factory. This Clause applies to factories under the new definition, but provides that the Secretary of State may exempt from its operation factories where mechanical power is not used. In the present law, the examination and certification for workshops is optional upon the occupier, so that the change forecast is an improvement. The term " appointed doctor " takes the place of " certifying surgeon in the present law, but it does not mean the same thing, as " an appointed doctor " is appointed to act for the purpose of a definite provision of the Act, so that for different provisions, different " appointed doctors " may be appointed. This Clause goes on to give considerably more power to the appointed doctor than was previously given to the certifying surgeon. He may give his certificate in respect of a particular factory or group of factories, and in respect of particular work or processes, and he may require physical defects to be remedied and re-examination to be done at specified intervals, and when he does impose conditions in his certificate, these must be observed. Further, the Secretary of State, in consultation with the Minister of Health, may by order transfer to the County Council the duty of arranging for the medical examination and certification of young persons under this Clause. VVhen this is done, the appointed doctor for this purpose is to be appointed under Clause 112-by the local authority; what " l o c a l a u t h o r i t y " means here, I will not attempt to define. It is the duty of the local education authority under Clause 86 to arrange for the production of the child's school medical record for the confidential information of the appointed doctor, and rules may be made by the Secretary of State and the Minister of Health to this effect. Further, the Secretary of State may make rules governing the kind of examinations, the forms of certificate, the facilities for examination, and any other matters. The whole of this Clause is good so far as it goes, but it all depends upon what the Secretary of State does. In it a long step is taken towards meeting the present day objections to the medical examination and certification of young persons. By it the "
Secretary of State would be able, in consultation with the Minister of Health, to set up such a system as would sufficiently protect those children noted as physically defective in their school life from entering upon factory employment unsuitable for them. Of course, this can only refer to factor~' employment, and the circumstances of these children illustrate welt the inadequacy of dealing with employment hygiene in a sectional manner. Clause 87 is a repetition of Section 67 of the Act of 1901, a section which, because of a minor defect, has not given tile benefit expected from it. This defect is repeated here, and it is one difficult to obviate. The clause provides that when a y o u n g person is employed in a fashion prejudicial to his health, a factory inspector may by notice require medical certification and examination. It is easy to understand that a factory inspector will be very slo.w in putting such a power into operation, especially when a certificate of fitness has already been given. This Bill, if it becomes law, will only be administered for the benefit of the people by the closest and most friendly co-operation between the Factory Department and Local Authorities. This co-operation has existed in the past, and despite the severe trial which this Bill wilt put upon it, the officers of local authorities generally will endeavour to see that it is continued in the future. LIEUT.-COL.
F. E.
FREMANTLE.
1 will endeavour to make my points separately, and leave it to others to clear up the contrast between them and those of" Dr. Buchan, if there is any contrast. Dr. Buchan suggested that the Bill was little more than a consolidating Bill. It is true that in many respects the changes are only of degree, and may seem to us minor in character, but it is the fact that they are definite provisions for improvement, which makes it so difficult for employers in industry to accept them at a time when industry is very hard put to it to make both ends meet. Industry is afraid of harsh administration purely in regard to the letter of the law, and without regard to the practical difficulties that face them. Therefore, a great deal depends upon how far we expect the administration t o b e reasonable, and in accordance with ordinary British administration. I should like to mention several points which, if not directly in the line of health, do closely affect the health of the worker.
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WelJare.~To deal with smaller questions first, the Welfare provisions (Clauses ;H/41) are negligible. Two important matters are altogether omitted, the supply of washing accommodation and of means of keeping and drying clothing. Neither of these need be elaborate, and in the small workshop, all you want is a tin basin and a row of hooks over one of the hot water pipes. No. doubt the larger works would provide a proper drying room, but the girls must have some means of drying their wet clothes---otherwise they put them on wet in the evening. FVeights (Clause 47).--This probably is right, but the people who really want protection are boys (who are not covered by the Clause), much lnore than women and girls. W o m e n are reluctant to move heavy weights, for they know the "danger, but boys take a pride in carrying weights of 100 lbs. or over. Hm~rs (Part V I ) . - - T h e only restrictions imposed by the Bill are on women and y o u n g persons, that is, between 14 and 18. The hours of men are not restricted, and never have been restricted in Factory Acts. The hours of women and y o u n g persons are not to exceed ten a day, or forty-eight a week, and the period of employment, that is, the time passed in the factory, including both work and meal times, is not to exceed twelve hours a day. 1 will deal with the normal hours firsl, before going on to the more flagrant case of overtime. Nine or Ten Hours D a y . - - A good deal of controversy will arise on the question whether the hours worked should be ten, as in the Government's Bill, or nine, as in the Labour P a r t y ' s Bill of 1924. Be it noted that in neither case can the total weekly hours exceed forty-eight, and there is something to be said for both. The case for ten hours is that it enables a five-day week to be worked, leaving both Saturday and S u n d a y free. This cannot, of course, be done on a nine-hours' day. Some trades prefer the five-day week, and work ten hours a day on Monday, Tuesday, Wednesday and Thursday, and eight hours on Friday, thereby not only getting Saturday and S u n d a y free, but coming home two hours earlier on Friday night. The free Saturday is much appreciated by the working w(~man for washing, etc. The case against ten ho~ars is that the period of employment is too long. Let it be remembered that we are talking of women and
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young persons only, and that under Clause 6(i, I, c. they cannot be worked for more than ,4~ hours without a meal interval. Therefore, the ten-hour worldng day really means a period of employment of at least 11{ hours, for to the ten hours' work must be added two meal intervals, say one hour for dinner, and half-an-hour for tea. This is not the case with a nine-hours' day, for the employees would only have their dinner at the works and their tea at home. Such is the case, and, while admitting that there are arguments for ten hours, I believe that nine hours is better, at any rate, for y o u n g persons. For women, there may be a case for the ten-hour day. For them, to have Saturday free may be a boon. But for y o u n g persons, boys and girls from fourteen to eighteen, it is better to spend a shorter time in the factory, even at the expense of working a few hours on Saturday. The arguments in favour of the five-day week for women do not apply to them. There are no special educational facilities on Saturday, and the girls would undoubtedly be made to work at home. I suggest, therefore, that the nine hours' day (and ten hours' period of employn:ent) be restored, at any rate, for young persons. If any concession has to be made, possiMy young persons between sixteen and eighteen m i g h t be allowed to work the ten hours' day or eleven and a half hours' period of employment, though I am doubtful even about this. But I have no doubt at all that it is better to keep boys and girls of fourteen and fifteen at work for a few hours on Saturday rather than subject them to a period of employment of eleven and a half hours. Remember ~hat you must add to the eleven and a half hour day the time of getting to and from the factory, so that the total time that they are occupied becomes so.mething tmpleasant to contemplate.
Overtime (Clause 67).--These provisions are so remarkable, and fly in the face of our industrial history to such an extent that they must be treated at length. The Bill introduces two new principles, first, permission to work y o u n g persons overtime, and, secondly, the extension of general overtime to all trades, and not only to the seasonal ones. Broad " 1y speaking, overtime for y o u n g persons is at present illegal. Moreover, no overtime is at present allowed in textile factories, either for y o u n g persons or women,
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PUBLIC HEALTH.
beyond the legal week of fifty-five and a half hours, and no woman or y o u n g person can be employed for more than ten hours a day. In certain non-textile trades thirty davs' overtime is allowed in the year, and fifty for certa4n perishable trades. Under the Bill, overtime may be worked in any factory, whether a seasonal trade or rlot, and without special circumstances or special order, for 100 hours in the year, or six hours in any week. Therefore, for the first time, y o u n g persons can be worked overtime, a thing not possible before, except on rare occasions. Also the overtime for women in textile trades is extended. Further, the Home Secretary may, in the case of seasonal trades, or to meet a sudden and unforeseen pressure, allow a further fifty hours a year, or three hours in any week, for women and for y o u n g persons from sixteen to eighteen (not from fourteen to sixteen). The total hours worked, however, must not exceed eleven a day. Just see what this means. Eleven hours' work carries with it two meal intervals, say half an hour for dinner and half an hour for tea, which brings the total period of employment up to twelve hours a day. Moreover, the forty-eight hours' week can be raised to fifty-four hours for all trades (forty-eight hours plus six hours overtime), and to fiftyseven for some (fifty-four hours plus three hours extra overtime), provided the total working hours do not exceed eleven a day, and this may be the case for seventeen weeks in the year. In the Act of 1901, the maximum week was sixty hours (in fact, the sixty hour week dates, from 1.847), and the reduction from sixty twenty-five years ago to-fifty-seven to-dav is a poor thing for a party which calls itself progressive to enact. Indeed, the fiftyseven hour week is not far off the sixty hour week of eighty years ago. Of course, fifty-seven hours cannot be worked all the year through, as sixty hours could in 1847, but fiftv-seven hours is too long. In a recent report of the Chief Inspector of Factories it is stated that the forty-eight hours' week is practically universal, and therefore, the Government Bill lags behind the general practice of the country, and not only behind the better employer. At the same time, we must regretfully recognise that some permission for overtime for adult women may have to be conceded generally, and not only in the scheduled trades. This should not extend to young
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persons; at any rate, those under sixteen. But we ought to fight hard against a general allowance of overtime with a special addition on the top of it, and, in a n y event, the total number of overtime hours should n6t exceed 100 a year, general and special combined. In fact, I feel doubtful whether it should go as far as this. To this concession should be attached a proviso that the hours worked should not exceed ten in any day, with an extension to eleven in scheduled factories, or factories working a five-day week. Fo.r young persons, no overtime above the forty-eight hour week should be allowed, certainly none for those below sixteen, and, if allowed for those between sixteen and eighteen, only by special exception. It sho.uld be added that the Bill gives special conditions for fish c u r i n g a n d jam making, in which cases the H o m e Secretary can fix any working day he pleases. This is probably right, for those are trades carried on at great pressure during a few weeks of the year, but the existence of the exception reinforces the argument for a reduction of general overtime. Special emergencies are met, and rightly so, and if, in addition, the long overtime in the Bill is allowed to stand, it really means an increased working week.
Certification of Fitness ]or Employment, Cl. 86 (4).--This may be entrusted to the County Council. The existing Certifying Factory Surgeons, men in private practice, appointed by the Secretary of S t a t e - - m a n y of whom have had long experience and intimate knowledge of factory processes---should be retained unless there is good reason to the contrary. There is no reason why they should not serve under a County Council instead of, as hitherto, under the remote supervision and guidance of the ~Vhitehall inspectorate. Attention is drawn to Clauses 86 and 112 by which : ...... (a) Certifying Factory Surgeons are to be called " appointed doctors " - - a bad innovation for which " medical officers " might well be substituted ; (b) their certifying duties may (here it is provided) " after consultation with the Minister of Health " be transferred to the County Council--who would naturally appoint their Medical Officer of Health or School Medical Officer (generally the same person) or his Assistants. Attention is also called to Clause 91, by
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PUBLIC HEALTH.
which certain Institutions may :--(a) submit to the Secretary of State for approval t h e i r own scheme for regulation of hours of emplo.yment, etc., as an alternative to the provisions of the Act ; and (b) appoint their own medical officer to be the " appointed doctor " for the institution. Administration.--Under the 190iAct a large measure of local devolution was secured, bringing the administration of public health in industry into relation with the general administration of public health, e.g., the sanitary provisions with regard to workshops and workplaces were thereby to be administered by the Local Sanitary Authorites. By the present Bill, except for small factories attached to a dwelling-house or shop (C1. 9), these provisions are to be enforced by Home Office Inspectors. The Secretary of State may arrange with a District Council for the enforcement of these provisions; but the scheme in general remains one of re-centralisation uncler Whitehall instead of progressive de-centralisation under Local Authorities. It should be considered whether the Society of Medical Officers of Health cannot press for a medical department under a chief medical officer at the H o m e Office, the chief medical officer being directly responsible to the Secretary of State. At present, the medical inspectors are under a Chief Inspector of Factories, a l a y m a n ; and much of the policy and administration, vitally affecting the health of the workers, including even the decision as to need of re-examination for fitness of individual workers, is decided without medical advice. This is not the case in either the Ministry of Heahh or Board of Education; and until the responsibility for medical advice is laid on medical shoulders in the Home Office there can be no confidence in the improvement in industrial health under the Home Office. Factory legislation being a vital par¢ of health administration, covering the life of a majority of the population during the greater part of every working day, it should be closely associated with health administration under the Ministry of Health and Board of Education. The effort to establish the Ministry of Health in control of all measures now, or in future, knit up with the work of every Department of State failed in the Ministry of Health A~t, 1919. But the practical result of experience in so far as health in Schools is concerned has been the establish-
¸1t8
ment of an official liaison between the medical department of tile Board of Education and that of the Ministry of Health, the Minister ot Health giving the responsibility for advising as to the health policy of the Board of Education. Similar liaison should be established in the matter of Industrial H y g i e n e between the Home Office and the Ministry of Health. The present Bill should be used as an opportunity for urging the linking up of every measure affecting the health of the people in close and effective relationship with the Ministry of Health, and no decision on matters of policy affecting" health should be made by the Home Secretary except " after consultation with the Minister of H e a l t h . " If the proposal of the present Bill (CI. 9) is retained, to resume direct responsibility by the Home Office for the health supervision of Workshops and Workplaces, except where he is satisfied that it '' will be satisfactorily performed bv a District Council," the concurrence of the Minister of Health is essential.
I) I S C U S S I ON. Dr. A. H. Bygott (County Medical Officer of Health, VvTest Suffolk) urged the necessity for the taking over of all health functions of the Home Office by the Ministry of Health. A Ministry of Health had been formed for that very purpose, and the work of the Home Office in that respect could, and ought, to be transferred at once. It was interesting to note that two of the Bills had been produced by different political parties, but that the differences in them were not great. T h e y differed on the question of cubic space, one specifying 400 cubic feet in newly constructed factories, and the other a lower figure. No one, he felt, ought to be allowed to work in a space of tess than 400 cubic feet. There was provision in the Bill under discussion that a factory for certain purposes must be heated to a temperature of 60°F.; in D r . B y g o t t ' s opinion 85 ° would be ample. Overtime by young people should be prohibited except in the case of breakdowns, or other extreme emergency. School medical inspection should be coordinated with the work of examination and certification by factory doctors, who ought to be officers of a local authority and possess some specialist qualification. T h e reason that the Home Office had the supervision of factories was that it had started many years ago when there was no other authority to deal
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with them. The work could now be done by counties and large county boroughs very much better than it was being carried out at present. The Bill ought to pass because it was a measure of reform. Dr. Cyril Banks (Medical Officer of ttealth, Halifax) said that it would be greatly deplored if medical officers of health were to be deprived of the limited powers they possessed at the present time in regard to factories. As local people they had greater powers of influencing owners to carry out improvements, and the owners realised that in the striving after efficiency the officers of the local authority could be reasonable in their demands. Dr. Stella Churchill, L.C.C., asked whether the time had not arrived for the inclusion of provisions for y o u n g people engaged in offices. In regard to hours of employment in factories, to expect any y o u n g person to work forty-eight hours a week, with a possibility of overtime, was preposterous, especially in view of the amount of unemployment that existed. Dr. Churchill also referred to the need for preventing the use as workshops of dwellinghouses, many of which were unsuitable for the purpose. The appointment by an employer of his own medical officer was a dangerous procedure for the reason that the medical practitioner so engaged would not feel so free to say what he thought if his employment depended upon the will of a'private employer. The Chairman (Dr. E. H. Snell, Medical Officer of Health, Coventry) said that the small amount of time given to factories by factory surgeons made the service a mere make-believe, and it was unlikely that the factory surgeon would claim that it was anything else. On the question of the appointment of factory medical officers, surely such officers were required inside the factories and workshops to study the conditions of the work in relation to the employees. Dr. J. J. Buchan, in reply to various points raised, claimed that Col. Fremantle's suggestion for the setting up of a medical department under a chief medical officer at the H o m e Office, responsible to the Secretary of State, could justifiably be taken tip b y the Council of the Society. On the whole, Dr. Buchan expressed agreement with the views of Col. Fremantle. The objection to Clause 47 with respect to the lifting of weights by women and young persons, was that the matter was one for medical opinion, and not for a factory inspector. In regard to factory inspectors in
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general, Dr. Buchan said that they were an extremely able and efficient body Of men, and were far better than the general opinion the public had of them. Employers should be encouraged to engage their own doctors, but in the official arrangements the appointed doctor should be someone appointed by an independent authority and be able to go into the factory to see that matters were right. Dr. Bygott had got to the root of the matter when he had said that all questions of health in factories ought to be dealt with by the Ministry of Health. Finally, Dr. Buchan said it was necessary to think of the child in school, and what it was going to do afterwards, whether in factory, office or other occupation, and the whole subject had to be considered not only from the public health, but from the educational point of view.
DR. G. W . FLEMING, of Swindon, has received the appointment of Medical Officer of Health and School Medical Officer for the borough of Todmorden. The salary is ~800 per annum. THE subject given by the Royal Sanitary Institute for essaysincompetition f o r t h e H e n r y Saxon Snell Prize in 1927 was " Sanitary Accommodation, Appliances, and Fittings for Hotels and Flats, with suggest-ions as to proper placing, arrangement, ventilation, and lighting, particularly where there are no external walls in which windows can be placed." Eight essays were received, including one from India. Acting on the advice of the adjudicators, the council have awarded the prize of 50 guineas and the silver medal of the Institute to Mr. H e n r y H. Clay, A . R . S a n . I . (St. Marylebone), writing under the motto " Equipoise." ThE M . B . E . conferred on Mrs. Florence Elizabeth Pearse, inspector of midwives and superintendent of health visitors at Oxford, is a well-deserved recognition of a valuable branch of the public health service. Another honour in the New Year list that has been thoroughly well earned is the O . B . E . awarded to Miss Jeannette Halford. As Founder and H o n o r a r y Secretary of the National League for Health, Maternity and Child Welfare, Miss Halford has given years of unselfish labour for the advancement of welfare schemes.
PUBLIC HEALTH.
Health
Aspects
of
the
F~RL'ARV,
Factories
Bill.
By JOHN J. BUCHAN, M.I)., Ch.B., I ) . P . H . , Medical Officer of Health, Bradford, and IAeut.-Col. F. E. FR~MANTLE, O . B . E . , M.P., M.B., M.Ch., F . R . C . P . , F . R . C . S . , D . P . H . ; Consulting County Medical Officer of Health, Hertfordshire. Although there is some uncertainty as to the ultimate fate of the Bill, it is appropriate that its objects and effects should be discussed, and no more suitable contributors than Dr. ]. J. Buchan and Colonel FremantIe, whose papers are given below, could h'ave been found to open the discussion on the subject which took place at the ordinary meeting of the Society, i~ London, on November 18th, 1927. D R . J. J. B U C H A N . this discussion 1 wish, first of all, I toN opening pay tribute to tile very great influence for good which Factory Legislation has exercised upon the social condition of the people of England. Always the subject of keen opposition and controversy, successive Factory Acts rapidly became accepted by all as necessary steps in social progress, and to them chiefly are due the abolition of child labour in this country and the relief of women and young persons from onerous conditions of employment. Factory legislation in England began 125 years ago, and therefore preceded by many years legislation in Public Health and in Education. To some extent this accounts for the difference in administration, as well as for the somewhat ill-deterrnined relationship of the older service with these more recent and more rapidly growing social services. The Factory Acts are administered directly from Whitehall by a branch of the Civil Service under an important Government Department which, however, has hardly any other functions of a similar nature. Health and education services are administered by local authorities supervised from Whitehall by other Government departments, and this fundamentaldifference in the administration renders co-ordinated work exceedingly difficult. Factory Legislation is now almost wholly concerned with questions of health, safety and the welfare of persons in industry, but communal efforts of this kind cannot stand alone and be administered alone if they are to give the best results. The present Factories Bill is chiefly a consolidation measure and marks few fresh developments in legislation of this kind. It is difficult to understand why there has been so much consolidation of Factory Law since 1878,
with so little new added, because as it stands to-day, the law is not particularly involved or difficult to understand, tn the circumstances comment on the present Consolidation Bill must of necessity be confined to smaller detail. The first point which one notices is the new definition of " factory." In previous legislation considerable difficulty was experienced in defining factories and workshops, and in the present Bill this is got over by abolishing the distinction and using" the one term " factory." Despite this attempt at simplification, the definition of " factory " in tile Bill is not simple, while the abolition of the distinction between factories and workshops will make administration of the law still more difficult, as between sanitary authorities and the Factory Department. The effect of the change will be to lav the responsibility in sanitary matters in what are now workshops in the first instance upon the Factory Department, and this is a change which is hardly likely to make for efficiency and economy. In the last Report of the Factory Department, out of 145,411 factories, the Factory Inspectors dealt with 19,582 matters of sanitation, whereas out of 128,793 registered workshops, district councils dealt with almost 40,000 matters of sanitation. If the Secretary of State, therefore, proposes to maintain the same standard of work as has been held in the past, and do the work through the Factory Department, a large and unnecessary increase of the staff of factory inspectors will ensue. The Secretary of State mav delegate certain duties now being taken from them to the district councils, and if he does so, I have no doubt that the officers of local authorities wiil be willing to help him, but the Secretary of State must remember that he is not Parliament, and district councils as a whole have no great love for the delegated duties of Cabinet Ministers.
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It is interesting to note that previous factory legislation so long a g o as in the Act of 1878, rejected the procedure which the present Bill attempts to resuscitate, the Factory and W o r k shops Act of 1878 repealing certain words in Section 91 (6) of the Public Health Act, 1875, so as to make the sub-section applicable to factories and workshops under the Factory Act and to be administered by the local authority, The experience of fifty years in this procedure does not, t think, warrant the reversion to the older and inadequate methods. The present Bill, in pursuance of the course it sets out on, proposes to delete the words " factory, workshop or " from the sub-section just mentioned, but this amendment is futile, as much more profound alteration is necessary to prevent the Public Health Act, 1875, being applicable to factories. Very difficult positions will be apt to arise if the arrangements forecast in the Bill become law, and only by the greatest care and consideration on the part of both the Factory Department and Local Authorities can these unnecessary difficulties be overcome. The Secretary of State will have great difficulty in determining whether a district council is able or wiiling to undertake the duties of enforcing sanitary provisions, and when he does so determine, he will not be able to delegate under the Bill certain provisions which should necessarily be delegated to them; thus, for e x a m p l e , the lighting of workshops and the prevention of spitting in workshops and bakeries--important matters which must remain in his own hands. It is unnecessary to stress this matter further, but it is possibly wise to point out that the reports of the Factory Department have not shown any great degree of success of that department in dealing with sanitary matters. This is easily understood when it is appreciated that this department has not had the training, experience or opportunity for doing sanitary work of the nature they may now be required to undertake. In the first part of the Bill, Clauses 10 and 11, giving power to act in default of a district council, look well on paper, but it is impossible to put them into operation, and it is difficult to see why they are repeated from the 1901 'Act. Clause 12 gives power to the Secretary of State, in consultation with the Minister of Health, to order special medical supervision of the workers in particular circumstances This should b e an important
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new power, but the clause is weakly drafted, and will be difficult to operate, as such medical supervision may be refused by the workman, and the reasonable provision which an employer may make for this purpose might be regarded by the Secretary of State as very far from reasonable. The second part of the Bill deals with questions of safety, and does not at the moment call for special comment ; this is also true with respect to the third part, dealing with welfare, incorporating the powers with respect to special welfare orders under the Police Factories, &c., Act, 1916, which is in part repealed. In the fourth part of the Bill, Clause 43 prohibiting spitting in Factories has already been referred to. Clause 47, prohibiting heavy lifting by women and y o u n g persons so as to cause injury, )s a power which is very difficult to put into operation, as weight lifting depends very largely on individual physique and condition, and Factory Inspectors who would have to administer the Clause would on this account be slow to put it into effect, as they would not be sure of their ground. Clause 52 deals with underground rooms, and so far as they affect workshops, provision should be made for delegating the powers it gives to the district council, otherwise one may have a local authority saying that an underground room is, under the Health and H o u s i n g Acts, uninhabitable, and the factory inspector certifying it as fit for work to be carried on or v i c e v e ~ ' s a . Clause 53 deals with basement bakehouses, the term " bakehouse " in this Clause being quite different from that in the general interpretation clause, under which the storage rooms are not regarded as part of the bakehouse, and the definition thus becomes distinctlydefective. The position of bakehouses in this Bili is peculiar. It is not clear whether all are factories or not, but in the fourth schedule of the Bill, the provisions of the Factory and W~orkshop Act, 1901, are re-enacted to be administered by district councils. Here, however, the question arises as to whether Clause 2 (a), requiring regular cleansing, operates, and if so, whether the factory department or the local authority are to administer it. This is a point which requires to be made clear if this Bill is being proceeded with. Part V. deals with accidents and industrial disease, and contains no new features of
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interest, but Part VI, dealing with the employment of women, y o u n g persons and children, contains, in Clause 86, a provision which requires young 'persons under the age of 16 years to be examined bv " the appointed doctor " and certified as fit for employment within a short time of their entering a factory. This Clause applies to factories under the new definition, but provides that the Secretary of State may exempt from its operation factories where mechanical power is not used. In the present law, the examination and certification for workshops is optional upon the occupier, so that the change forecast is an improvement. The term " appointed doctor " takes the place of " certifying surgeon in the present law, but it does not mean the same thing, as " an appointed doctor " is appointed to act for the purpose of a definite provision of the Act, so that for different provisions, different " appointed doctors " may be appointed. This Clause goes on to give considerably more power to the appointed doctor than was previously given to the certifying surgeon. He may give his certificate in respect of a particular factory or group of factories, and in respect of particular work or processes, and he may require physical defects to be remedied and re-examination to be done at specified intervals, and when he does impose conditions in his certificate, these must be observed. Further, the Secretary of State, in consultation with the Minister of Health, may by order transfer to the County Council the duty of arranging for the medical examination and certification of young persons under this Clause. VVhen this is done, the appointed doctor for this purpose is to be appointed under Clause 112-by the local authority; what " l o c a l a u t h o r i t y " means here, I will not attempt to define. It is the duty of the local education authority under Clause 86 to arrange for the production of the child's school medical record for the confidential information of the appointed doctor, and rules may be made by the Secretary of State and the Minister of Health to this effect. Further, the Secretary of State may make rules governing the kind of examinations, the forms of certificate, the facilities for examination, and any other matters. The whole of this Clause is good so far as it goes, but it all depends upon what the Secretary of State does. In it a long step is taken towards meeting the present day objections to the medical examination and certification of young persons. By it the "
Secretary of State would be able, in consultation with the Minister of Health, to set up such a system as would sufficiently protect those children noted as physically defective in their school life from entering upon factory employment unsuitable for them. Of course, this can only refer to factor~' employment, and the circumstances of these children illustrate welt the inadequacy of dealing with employment hygiene in a sectional manner. Clause 87 is a repetition of Section 67 of the Act of 1901, a section which, because of a minor defect, has not given tile benefit expected from it. This defect is repeated here, and it is one difficult to obviate. The clause provides that when a y o u n g person is employed in a fashion prejudicial to his health, a factory inspector may by notice require medical certification and examination. It is easy to understand that a factory inspector will be very slo.w in putting such a power into operation, especially when a certificate of fitness has already been given. This Bill, if it becomes law, will only be administered for the benefit of the people by the closest and most friendly co-operation between the Factory Department and Local Authorities. This co-operation has existed in the past, and despite the severe trial which this Bill wilt put upon it, the officers of local authorities generally will endeavour to see that it is continued in the future. LIEUT.-COL.
F. E.
FREMANTLE.
1 will endeavour to make my points separately, and leave it to others to clear up the contrast between them and those of" Dr. Buchan, if there is any contrast. Dr. Buchan suggested that the Bill was little more than a consolidating Bill. It is true that in many respects the changes are only of degree, and may seem to us minor in character, but it is the fact that they are definite provisions for improvement, which makes it so difficult for employers in industry to accept them at a time when industry is very hard put to it to make both ends meet. Industry is afraid of harsh administration purely in regard to the letter of the law, and without regard to the practical difficulties that face them. Therefore, a great deal depends upon how far we expect the administration t o b e reasonable, and in accordance with ordinary British administration. I should like to mention several points which, if not directly in the line of health, do closely affect the health of the worker.
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WelJare.~To deal with smaller questions first, the Welfare provisions (Clauses ;H/41) are negligible. Two important matters are altogether omitted, the supply of washing accommodation and of means of keeping and drying clothing. Neither of these need be elaborate, and in the small workshop, all you want is a tin basin and a row of hooks over one of the hot water pipes. No. doubt the larger works would provide a proper drying room, but the girls must have some means of drying their wet clothes---otherwise they put them on wet in the evening. FVeights (Clause 47).--This probably is right, but the people who really want protection are boys (who are not covered by the Clause), much lnore than women and girls. W o m e n are reluctant to move heavy weights, for they know the "danger, but boys take a pride in carrying weights of 100 lbs. or over. Hm~rs (Part V I ) . - - T h e only restrictions imposed by the Bill are on women and y o u n g persons, that is, between 14 and 18. The hours of men are not restricted, and never have been restricted in Factory Acts. The hours of women and y o u n g persons are not to exceed ten a day, or forty-eight a week, and the period of employment, that is, the time passed in the factory, including both work and meal times, is not to exceed twelve hours a day. 1 will deal with the normal hours firsl, before going on to the more flagrant case of overtime. Nine or Ten Hours D a y . - - A good deal of controversy will arise on the question whether the hours worked should be ten, as in the Government's Bill, or nine, as in the Labour P a r t y ' s Bill of 1924. Be it noted that in neither case can the total weekly hours exceed forty-eight, and there is something to be said for both. The case for ten hours is that it enables a five-day week to be worked, leaving both Saturday and S u n d a y free. This cannot, of course, be done on a nine-hours' day. Some trades prefer the five-day week, and work ten hours a day on Monday, Tuesday, Wednesday and Thursday, and eight hours on Friday, thereby not only getting Saturday and S u n d a y free, but coming home two hours earlier on Friday night. The free Saturday is much appreciated by the working w(~man for washing, etc. The case against ten ho~ars is that the period of employment is too long. Let it be remembered that we are talking of women and
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young persons only, and that under Clause 6(i, I, c. they cannot be worked for more than ,4~ hours without a meal interval. Therefore, the ten-hour worldng day really means a period of employment of at least 11{ hours, for to the ten hours' work must be added two meal intervals, say one hour for dinner, and half-an-hour for tea. This is not the case with a nine-hours' day, for the employees would only have their dinner at the works and their tea at home. Such is the case, and, while admitting that there are arguments for ten hours, I believe that nine hours is better, at any rate, for y o u n g persons. For women, there may be a case for the ten-hour day. For them, to have Saturday free may be a boon. But for y o u n g persons, boys and girls from fourteen to eighteen, it is better to spend a shorter time in the factory, even at the expense of working a few hours on Saturday. The arguments in favour of the five-day week for women do not apply to them. There are no special educational facilities on Saturday, and the girls would undoubtedly be made to work at home. I suggest, therefore, that the nine hours' day (and ten hours' period of employn:ent) be restored, at any rate, for young persons. If any concession has to be made, possiMy young persons between sixteen and eighteen m i g h t be allowed to work the ten hours' day or eleven and a half hours' period of employment, though I am doubtful even about this. But I have no doubt at all that it is better to keep boys and girls of fourteen and fifteen at work for a few hours on Saturday rather than subject them to a period of employment of eleven and a half hours. Remember ~hat you must add to the eleven and a half hour day the time of getting to and from the factory, so that the total time that they are occupied becomes so.mething tmpleasant to contemplate.
Overtime (Clause 67).--These provisions are so remarkable, and fly in the face of our industrial history to such an extent that they must be treated at length. The Bill introduces two new principles, first, permission to work y o u n g persons overtime, and, secondly, the extension of general overtime to all trades, and not only to the seasonal ones. Broad " 1y speaking, overtime for y o u n g persons is at present illegal. Moreover, no overtime is at present allowed in textile factories, either for y o u n g persons or women,
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beyond the legal week of fifty-five and a half hours, and no woman or y o u n g person can be employed for more than ten hours a day. In certain non-textile trades thirty davs' overtime is allowed in the year, and fifty for certa4n perishable trades. Under the Bill, overtime may be worked in any factory, whether a seasonal trade or rlot, and without special circumstances or special order, for 100 hours in the year, or six hours in any week. Therefore, for the first time, y o u n g persons can be worked overtime, a thing not possible before, except on rare occasions. Also the overtime for women in textile trades is extended. Further, the Home Secretary may, in the case of seasonal trades, or to meet a sudden and unforeseen pressure, allow a further fifty hours a year, or three hours in any week, for women and for y o u n g persons from sixteen to eighteen (not from fourteen to sixteen). The total hours worked, however, must not exceed eleven a day. Just see what this means. Eleven hours' work carries with it two meal intervals, say half an hour for dinner and half an hour for tea, which brings the total period of employment up to twelve hours a day. Moreover, the forty-eight hours' week can be raised to fifty-four hours for all trades (forty-eight hours plus six hours overtime), and to fiftyseven for some (fifty-four hours plus three hours extra overtime), provided the total working hours do not exceed eleven a day, and this may be the case for seventeen weeks in the year. In the Act of 1901, the maximum week was sixty hours (in fact, the sixty hour week dates, from 1.847), and the reduction from sixty twenty-five years ago to-fifty-seven to-dav is a poor thing for a party which calls itself progressive to enact. Indeed, the fiftyseven hour week is not far off the sixty hour week of eighty years ago. Of course, fifty-seven hours cannot be worked all the year through, as sixty hours could in 1847, but fiftv-seven hours is too long. In a recent report of the Chief Inspector of Factories it is stated that the forty-eight hours' week is practically universal, and therefore, the Government Bill lags behind the general practice of the country, and not only behind the better employer. At the same time, we must regretfully recognise that some permission for overtime for adult women may have to be conceded generally, and not only in the scheduled trades. This should not extend to young
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persons; at any rate, those under sixteen. But we ought to fight hard against a general allowance of overtime with a special addition on the top of it, and, in a n y event, the total number of overtime hours should n6t exceed 100 a year, general and special combined. In fact, I feel doubtful whether it should go as far as this. To this concession should be attached a proviso that the hours worked should not exceed ten in any day, with an extension to eleven in scheduled factories, or factories working a five-day week. Fo.r young persons, no overtime above the forty-eight hour week should be allowed, certainly none for those below sixteen, and, if allowed for those between sixteen and eighteen, only by special exception. It sho.uld be added that the Bill gives special conditions for fish c u r i n g a n d jam making, in which cases the H o m e Secretary can fix any working day he pleases. This is probably right, for those are trades carried on at great pressure during a few weeks of the year, but the existence of the exception reinforces the argument for a reduction of general overtime. Special emergencies are met, and rightly so, and if, in addition, the long overtime in the Bill is allowed to stand, it really means an increased working week.
Certification of Fitness ]or Employment, Cl. 86 (4).--This may be entrusted to the County Council. The existing Certifying Factory Surgeons, men in private practice, appointed by the Secretary of S t a t e - - m a n y of whom have had long experience and intimate knowledge of factory processes---should be retained unless there is good reason to the contrary. There is no reason why they should not serve under a County Council instead of, as hitherto, under the remote supervision and guidance of the ~Vhitehall inspectorate. Attention is drawn to Clauses 86 and 112 by which : ...... (a) Certifying Factory Surgeons are to be called " appointed doctors " - - a bad innovation for which " medical officers " might well be substituted ; (b) their certifying duties may (here it is provided) " after consultation with the Minister of Health " be transferred to the County Council--who would naturally appoint their Medical Officer of Health or School Medical Officer (generally the same person) or his Assistants. Attention is also called to Clause 91, by
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which certain Institutions may :--(a) submit to the Secretary of State for approval t h e i r own scheme for regulation of hours of emplo.yment, etc., as an alternative to the provisions of the Act ; and (b) appoint their own medical officer to be the " appointed doctor " for the institution. Administration.--Under the 190iAct a large measure of local devolution was secured, bringing the administration of public health in industry into relation with the general administration of public health, e.g., the sanitary provisions with regard to workshops and workplaces were thereby to be administered by the Local Sanitary Authorites. By the present Bill, except for small factories attached to a dwelling-house or shop (C1. 9), these provisions are to be enforced by Home Office Inspectors. The Secretary of State may arrange with a District Council for the enforcement of these provisions; but the scheme in general remains one of re-centralisation uncler Whitehall instead of progressive de-centralisation under Local Authorities. It should be considered whether the Society of Medical Officers of Health cannot press for a medical department under a chief medical officer at the H o m e Office, the chief medical officer being directly responsible to the Secretary of State. At present, the medical inspectors are under a Chief Inspector of Factories, a l a y m a n ; and much of the policy and administration, vitally affecting the health of the workers, including even the decision as to need of re-examination for fitness of individual workers, is decided without medical advice. This is not the case in either the Ministry of Heahh or Board of Education; and until the responsibility for medical advice is laid on medical shoulders in the Home Office there can be no confidence in the improvement in industrial health under the Home Office. Factory legislation being a vital par¢ of health administration, covering the life of a majority of the population during the greater part of every working day, it should be closely associated with health administration under the Ministry of Health and Board of Education. The effort to establish the Ministry of Health in control of all measures now, or in future, knit up with the work of every Department of State failed in the Ministry of Health A~t, 1919. But the practical result of experience in so far as health in Schools is concerned has been the establish-
¸1t8
ment of an official liaison between the medical department of tile Board of Education and that of the Ministry of Health, the Minister ot Health giving the responsibility for advising as to the health policy of the Board of Education. Similar liaison should be established in the matter of Industrial H y g i e n e between the Home Office and the Ministry of Health. The present Bill should be used as an opportunity for urging the linking up of every measure affecting the health of the people in close and effective relationship with the Ministry of Health, and no decision on matters of policy affecting" health should be made by the Home Secretary except " after consultation with the Minister of H e a l t h . " If the proposal of the present Bill (CI. 9) is retained, to resume direct responsibility by the Home Office for the health supervision of Workshops and Workplaces, except where he is satisfied that it '' will be satisfactorily performed bv a District Council," the concurrence of the Minister of Health is essential.
I) I S C U S S I ON. Dr. A. H. Bygott (County Medical Officer of Health, VvTest Suffolk) urged the necessity for the taking over of all health functions of the Home Office by the Ministry of Health. A Ministry of Health had been formed for that very purpose, and the work of the Home Office in that respect could, and ought, to be transferred at once. It was interesting to note that two of the Bills had been produced by different political parties, but that the differences in them were not great. T h e y differed on the question of cubic space, one specifying 400 cubic feet in newly constructed factories, and the other a lower figure. No one, he felt, ought to be allowed to work in a space of tess than 400 cubic feet. There was provision in the Bill under discussion that a factory for certain purposes must be heated to a temperature of 60°F.; in D r . B y g o t t ' s opinion 85 ° would be ample. Overtime by young people should be prohibited except in the case of breakdowns, or other extreme emergency. School medical inspection should be coordinated with the work of examination and certification by factory doctors, who ought to be officers of a local authority and possess some specialist qualification. T h e reason that the Home Office had the supervision of factories was that it had started many years ago when there was no other authority to deal
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with them. The work could now be done by counties and large county boroughs very much better than it was being carried out at present. The Bill ought to pass because it was a measure of reform. Dr. Cyril Banks (Medical Officer of ttealth, Halifax) said that it would be greatly deplored if medical officers of health were to be deprived of the limited powers they possessed at the present time in regard to factories. As local people they had greater powers of influencing owners to carry out improvements, and the owners realised that in the striving after efficiency the officers of the local authority could be reasonable in their demands. Dr. Stella Churchill, L.C.C., asked whether the time had not arrived for the inclusion of provisions for y o u n g people engaged in offices. In regard to hours of employment in factories, to expect any y o u n g person to work forty-eight hours a week, with a possibility of overtime, was preposterous, especially in view of the amount of unemployment that existed. Dr. Churchill also referred to the need for preventing the use as workshops of dwellinghouses, many of which were unsuitable for the purpose. The appointment by an employer of his own medical officer was a dangerous procedure for the reason that the medical practitioner so engaged would not feel so free to say what he thought if his employment depended upon the will of a'private employer. The Chairman (Dr. E. H. Snell, Medical Officer of Health, Coventry) said that the small amount of time given to factories by factory surgeons made the service a mere make-believe, and it was unlikely that the factory surgeon would claim that it was anything else. On the question of the appointment of factory medical officers, surely such officers were required inside the factories and workshops to study the conditions of the work in relation to the employees. Dr. J. J. Buchan, in reply to various points raised, claimed that Col. Fremantle's suggestion for the setting up of a medical department under a chief medical officer at the H o m e Office, responsible to the Secretary of State, could justifiably be taken tip b y the Council of the Society. On the whole, Dr. Buchan expressed agreement with the views of Col. Fremantle. The objection to Clause 47 with respect to the lifting of weights by women and young persons, was that the matter was one for medical opinion, and not for a factory inspector. In regard to factory inspectors in
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general, Dr. Buchan said that they were an extremely able and efficient body Of men, and were far better than the general opinion the public had of them. Employers should be encouraged to engage their own doctors, but in the official arrangements the appointed doctor should be someone appointed by an independent authority and be able to go into the factory to see that matters were right. Dr. Bygott had got to the root of the matter when he had said that all questions of health in factories ought to be dealt with by the Ministry of Health. Finally, Dr. Buchan said it was necessary to think of the child in school, and what it was going to do afterwards, whether in factory, office or other occupation, and the whole subject had to be considered not only from the public health, but from the educational point of view.
DR. G. W . FLEMING, of Swindon, has received the appointment of Medical Officer of Health and School Medical Officer for the borough of Todmorden. The salary is ~800 per annum. THE subject given by the Royal Sanitary Institute for essaysincompetition f o r t h e H e n r y Saxon Snell Prize in 1927 was " Sanitary Accommodation, Appliances, and Fittings for Hotels and Flats, with suggest-ions as to proper placing, arrangement, ventilation, and lighting, particularly where there are no external walls in which windows can be placed." Eight essays were received, including one from India. Acting on the advice of the adjudicators, the council have awarded the prize of 50 guineas and the silver medal of the Institute to Mr. H e n r y H. Clay, A . R . S a n . I . (St. Marylebone), writing under the motto " Equipoise." ThE M . B . E . conferred on Mrs. Florence Elizabeth Pearse, inspector of midwives and superintendent of health visitors at Oxford, is a well-deserved recognition of a valuable branch of the public health service. Another honour in the New Year list that has been thoroughly well earned is the O . B . E . awarded to Miss Jeannette Halford. As Founder and H o n o r a r y Secretary of the National League for Health, Maternity and Child Welfare, Miss Halford has given years of unselfish labour for the advancement of welfare schemes.