dwellings, for some reason not very well explained it prohibited the articles from being manufactured in buildings where three or more families live independently of each other and do their cooking upon the premises. The act also required that the local board of health should approve the license where children's or infants' apparel was manufactured.

I have thought for a long time that the primary or fundamental reasons for discouraging employment of this character were not so very well understood by the great mass of people, and that the time is at hand when we should recognize and declare that the real purpose in prohibiting this sort of employment is not the fear that disease and contagion will be spread if factory set-ups are permitted to be established in homes, but rather that this kind of employment has subversive economic features that strike at the very heart of decently run industry. Where home owners have desired to bring machines and equipment into their homes and employ labor under factory conditions, the department has found little or no difficulty in discouraging the attempt. We have insisted that building exits shall conform to factory regulations, that illumination shall be provided in accordance with the standards enforced in manufacturing establishments, and that sanitary accomodations shall not violate the code enforced by the State department of labor. Furthermore, the department would require that any person going into this kind of industry should provide workmen's compensation insurance coverage for employees. These establishments would not be licensed by the department of labor, but would be considered strictly from a factory viewpoint and all laws regulating thereto strictly enforced. For that reason we have had no difficulty with this kind of employment, although at times there have been violations of the law.

I have in mind an instance that occurred a few weeks ago, when a district factory inspector discovered a home worker located in a coal cellar in a basement. Six machines manufacturing clothing were in operation. The ventilation was so poor and the air so stagnant that the young people who were operating the machines found it very difficult to keep awake. While this occurrence furnished good newspaper copy because of its dramatic and appealing circumstances, it is in no wise representative of the worst features of home manufacturing in the State of New Jersey. This kind of violation is easily corrected. It cannot continue over a long period of time, for someone is sure to report it, and the isolated cases are easily stamped out. The punishment for violations is swift, incisive, and discourages future attempts.

Recently I read a United States Women's Bureau Bulletin (No. 135) on The Commercialization of the Home through Industrial Home Work. To preamble of this article declared that "The home has been the family shelter through the centuries. The prevent the distortion of its social function through use by profit-making industries

is the responsibility of society." This is the special feature of industrial home work that appeals to me as a citizen and a well-wisher for the future of our country. My primary interest is in preserving for women and children the home and its influence for good for future generations, and I am confident that this purpose cannot possibly be served by the passage of any so-called regulatory legislation. I know that a legislative program was recommended by the International Association of Governmental Labor Officials in 1926, which included. certain regulatory features concerning licensing, cleanliness, abolition of child labor, illumination, etc., and declared that adequate staffs should be provided State departments of labor for periodic home-work inspections. I have also considered the conclusions of the committee on industrial home work appointed in 1934, that declared, "That abolition of home work is the only way to control its growing evils." As between regulation and abolition, I am strongly for abolition. There are many reasons for this conclusion.

The evils that have resulted from the practice of employers or contractors sending work out of factories into the homes of people have been brought so prominently before the eyes of the general public that it should not require much argument to convince fair minds that this kind of sweatshop labor is a real social menace. Recently I read an article by Rose G. Feld entitled, "Sweat Shops, Model 1935", which described general home-work conditions in such clear language that I became convinced that nothing short of its complete elimination will correct the evil attendant upon it. In New Jersey some years ago a women's bureau was established, the principal work of which was to investigate home-work conditions and to try to regulate this insidious competitive trade practice. Beyond the fact that thousands of licenses were issued by the State and many thousands of homes were examined by our investigators, the regulatory practices attempted made absolutely no impression upon the home-work evil. It may be argued that regulatory methods of this kind will insure a cleaner product and less likelihood of the dissemination of disease. The sanitary features of this campaign are not the important ones. Some years ago the department of labor consulted eminent health authorities on the question of sanitation and its relation to home work, and almost without exception we were unable to find any authority that considered home work dangerous from his point of view. The real menace that comes from home work is economic and not hygienic. The real evil that comes from home work is the long hours; the hours that make the "Song of the Shirt" ring in the ears of the poor. To real disaster is the starvation wage and living conditions resulting from them that pauperize and fairly sp at the very roots of their strength.

It has been said that some European countries have been successful regulating home work. I have grave doubts about the value of

this kind of procedure. I think it would be just as sensible to attempt to regulate yellow fever or some other contagious disease as it would be to regulate an economic practice that is so at variance with our ideas of citizenship and a decent standard of living. Our fight should be for the passage of laws that will make it unprofitable to parcel out work in homes. Take the profit out of this kind of white slavery and you destroy the incentive for exploitation. Do not let us becloud the issue with hygienic terms and make it appear that if homework goods are manufactured under healthful conditions the public is protected thereby. Our experience has been that the people who are doing this work are quite as clean and hygienic as any other group and need no Pardiggles or others of that ilk to pry into their affairs, under the delusion they must be regimented, examined, and inspected to make them clean. The bureau of women and children of the department of labor prepared the following memorandum on homework activities in New Jersey. I think it will be of interest.

7,479 licenses were issued for fiscal year 1930-31. 6,904 licenses were issued for fiscal year 1931-32. 3,772 licenses were issued to December 1932.

3,248 licenses were issued for that part of the fiscal year ending June 1934. 1,400 licenses were issued during the fiscal year 1934-35 on work not prohibited by any N. R. A. code.

During that year 342 N. R. A. permits for home work were issued.

During the fiscal year July 1, 1935, to June 30, 1936, 231 distributors, and 4,045 home workers were licensed.

It is a matter of growing concern to all of us who are engaged in the administration of labor laws that this type of industry is increasing and presents such unfair competition as to demoralize factory production. It appears from experience that State laws are no longer an effective curb and that recourse must be made to Federal action if complete abolition is to be insured. A steady stream of these products flows from the metropolitan area into the rural and mountain sections and even far away into our colonial possessions. Under such circumstances I think it is a waste of time to give much consideration to State activities; rather, we should confine ourselves to finding a way in which the Federal Government can intervene.

Mr. LORENZ. New Jersey has a problem due to its geographic location-between New York on the north and Pennsylvania on the south. These two large metropolitan areas send out an immense amount of home work to New Jersey. Beyond the formality of a cursory investigation and inspection of premises for ordinary health, in pursuance of an application for home-work license, New Jersey does not do anything that would otherwise curb or render home-work activity unprofitable either to manufacturers or contractors, as compared with those who maintain premises and plants.

New Jersey sponsored a bill in the legislature recently requiring a tax on pay rolls of manufacturers and contractors on home work. The interested persons immediately got to work on the senators and suggested a straight tax to be levied on the manufacturer or distributor according to the number of home workers engaged. It was to be, I believe, a dollar or two per license. The matter was brought to the attention of the sponsors by Senator Walburg, who was so active in the State labor compact and who was most friendly to the idea, and the Consumers' League took the suggestion under advisement. It was understood that it was to take either the counter proposal or nothing at all. The Consumers' League answered that there were already too many laws pertaining to labor that were either half enforced or not enforced, and that it would not be a sponsor of any new legislation that would not cure the evil. So it turned down the counter proposal and the bill was defeated. The situation continues as before, with the exception that, as Miss Miller stated, there is an interchange of information through Washington on home work, particularly with reference to distributors and manufacturers.

The department of labor is most anxious to secure amendments to the existing law, and would recommend an amendment that would abolish home work entirely if such a thing were feasible. I remember the discussion that ensued in the New Jersey Senate on this bill. (The lower house passed it without any opposition.) One senator wanted to know whether the dressmakers of the senators' wives would be required to take out licenses to sew dresses. On the answer which he received he based his argument against the bill. Because of the tenseness of the situation other senators fell for his argument. The bill was defeated. It was then discovered that the senator who made the argument had before him the first printing of the original bill, and had not consulted the committee substitute, which took care of the difficulty. It was too late to call for reconsideration and the situation is as it is. The Consumers' League will this year sponsor this legislation once more, and I believe the department of labor will lobby for it, because the proposed change will not only absorb the differential between home work and ordinary industry but will also bring in revenue to the State which will enable the State to make the enforcement of that bill self-supporting.

Chairman FLETCHER. The question is now open for general disenssion.

Mr. CRAWFORD (Ontario). In Ontario we have no special act zoverning home work, but at the last session of the legislature the factory act was amended, under which the chief inspector is required to issue a permit to every employer giving out home work and to every home worker. The permit will not be issued to an employer until the in-pertor is satisfied that the employer is complying with the law in all

respects. The wage rates paid must have the approval of the minimumwage board. There are penalties attached and records are required. Every employer is required to keep a separate sheet, drawn up in the department, for each home worker, showing amounts of work, dates, amounts to be paid, amounts actually paid, when goods were returned, etc., and the signature of the home worker to such statement. That takes care of work ha..ded to the individual and could not possibly cover work given out by mail. It is only a beginning. The purpose was not so much to eliminate home work as to get a certain measure of control, so that we will be in a position in a year or two to take steps either effectively to abolish that part of it which is bad or to introduce legislation which will effectively regulate it within the Province. To date we have issued permits to approximately 100 employers, covering hundreds of home workers. We have also refused to issue permits to a number of firms on the ground that the rates being paid were less than the rates being paid in factories. That is a definite policy.

Our real difficulty is with work which has never been done in factories, or with sections of work, part of which is done in factories and part in the home. We have a manufacturing firm which exports dolls to all parts of the world and which employs from 300 to 500 home workers making the dolls' dresses. This firm has been built up recently and has considerable capital invested. It employs a large number of workers in the factory. If we were suddenly to prohibit the dolls' dresses being manufactured in homes, it would put that industry out of business, and so we have granted permits for the manufacturing of dolls' dresses at rates which are considerably lower than the rates we demand for workers in factories. That is in line with our policy. We intend to take a year or two with the problem before we really decide what we are to do with it.

Until last year the only control we had was that the home worker must secure a permit from the chief factory inspector, which was issued after a careful investigation as to whether the premises were sanitary. That permit remained effective indefinitely. What I would like to know is how to deal with a case such as I have cited, or how to deal with work which has never been done in a factory--knitting, for instance. What we did in that connection was this-we called a conference of the employers giving out that type of work. First we assured ourselves that the work was not being done in any factory. Then we examined the prices paid-we visited homes and found out from the women what they were earning. The estimates varied from 5 cents to 30 cents an hour. We selected some home workers, brought them into the office, and had demonstrations. On the demonstrations given in the office we proceeded to fix prices. We found, I am sorry to say, that we had to approve 10 cents an hour in some cases, because our experience is very limited.