SEASONAL FACTORIES. 
RY 
ginneries in particular areas, where their number exceeds the require- 
ments of the industry. This may result in a factory remaining 
closed for several years and then being brought into sudden use 
without any adequate overhauling. In consequence, a number of accidents 
have oceurred in at least one province within the last few years, 
including one in 1928, in which the roof of a ginnery, previously closed for 
Some years, collapsed within a few hours of the machinery being restarted, 
killing five and injuring seven of the workers. We are of opinion that, 
with the necessary initial control of stability which we have recommended 
and the powers already conferred by section 18A of the Factories Act, 
the increased inspection of seasonal factories to which we refer subse- 
quently should minimise this danger. 
The Certification of Children. 
The provisions relating to the control of child labour have ap- 
parently been framed with the larger factories in view. These are mostly 
situated in towns where official part-time or whole-time certifying surgeons 
are available, and the system gives rise to no serious difficulty in such 
cases. In seasonal factories situated far from headquarters of any size, 
its working is not so smooth. An inspector may find children who 
are clearly under 15 years of age working adult hours, or even children 
under 12 so employed. He is not authorised to expel a child except on 
the ground of physical unfitness and he may not expel an adult in any 
circumstances. If his belief that a child is under 15 years is questioned, 
it would seem doubtful if he can take the child from the factory, but even 
if no objection is raised to his doing so, he cannot do more than take him to 
the local doctor and this in practice has not always been found satisfactory. 
Further, we understand that the certification of children by local doctors 
is not always reliable, but no others may be easily obtainable. We hope 
that, with the employment of medical inspectors which we have recom- 
mended, the necessity of employing non-official practitioners will disappear 
or be greatly reduced. But we also recommend as a further safeguard that 
provincial Governments should have the power, for any orall classes of 
factories, to prescribe standards corresponding to the normal height of 
children of 12 and 15 years of both sexes and that, when such standards 
have been prescribed, the employment of a child who is either under 
the prescribed age or under the prescribed height should be illegal. We 
further recommend that the law should empower inspectors to exclude 
and to arrange for examination by the nearest surgeon qualified to 
grant a certificate, any uncertified person whom he has reasonable ground 
for believing to be under 15 years until the age of that person and his or 
her fitness for employment have been duly certified. This last provision 
should be equally useful in the case of the smaller and more isolated 
perennial factories and should, therefore, apply to all factories coming 
under the Factories Act 
Difficulties of Inspection. 
The inspection of seasonal factories presents special difficulties. 
The bulk of them are widely scattered in rural districts, thus involving