SEASONAL FACTORIES. 89
of the grade of deputy collector or sub-divisional magistrate be given
a short intensive training and then employed in districts where factories
of the type we have mentioned are to be found. Here they would form
part of the magisterial and revenue staff and would be required to devote
only part of their time during the appropriate season to factory
inspection. Officers below these grades, such as Industrial Surveyors
who are employed as Factory Inspectors in the Punjab and Delhi,
should not be used for this work as they frequently lack the necessary
authority and status to give them standing in the eyes of the employer.
Moreover, the performance of their other duties may be made difficult
where punitive action has been taken as a result of contraventions of
the Factories Act. We suggest the omission of the tea factories of
Assam and Bengal from this system as we have made special recommend-
ation for the former elsewhere and the latter are best dealt with, as at
present, by a full-time officer in the season.
Control of Inspection.
A necessary corollary to the efficient working of this system is the
laying down of definite standards of inspection, both as regards the
number of visits to be paid during the season and the type of report to be
submitted to the factory inspection department. For the latter purpose
regular forms should be carefully prepared by that department for issue
to all ex-officio inspectors and a copy of the report of each inspection made
by such officers should be submitted to the Chief Inspector of Factories.
We see no objection to the District Magistrates retaining powers as
Inspectors of Factories, but ordinarily they cannot and need not be re-
quired to act in that capacity if the recommendations made above are
carried out. A certain degree of supervision of the part-time inspectors
would be a useful service on their part.