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In April and October the usual half-yearly bakehouse
inspections were made, and it was found necessary to serve
notices to enforce compliance with the Factory and Workshop
Act and the Public Health Act in 12 instances in April, and
in 29 instances in October.
The Factory and Workshop Act, 1901, contains the
latest of a long series of enactments for the sanitary regulation
of bakehouses. The first of these was the Bakehouse
Regulation Act of 1863, which brought the sanitation of
bakehouses under the control of the sanitary authorities. It
would appear, however, that the sanitary authorities were not
particularly zealous in carrying out their duties in this
connection, and by the Factory and Workshop Act, 1878,
the sanitary control of bakehouses was transferred to the
Home Office. The latter arrangement was no more successful
than the former, as the small staff of factory inspectors was
found to be unable to cope with the heavy additional duties,
and the Factory Act of 1883 restored to the sanitary authorities
their former powers, which were increased by the Factory
Act of 1891. In the Factory Act of 1895, which was in many
respects a notable landmark in the ever-increasing field of
industrial legislation, a definite step was taken to limit the
number of underground bakehouses. Section 27, Sub-Section
3 provided that: "A place underground shall not be used as
a bakehouse unless it is so used at the commencement of this
Act," i.e., January 1st, 1896. This sub-section obviously
made it illegal to open as a bakehouse an underground place
which had not before been used for that purpose, but it was
hoped that it would also have the effect of enabling sanitary
authorities to close insanitary underground bakehouses as the
premises were vacated. This hope was disappointed by the
decision of the High Court in the case of Schweitzerhof v.
Wilkins, where it was held that temporary closing did not
necessarily constitute disuse. Mr. Schweitzerhof was the
occupier of certain premises in Winstanley Road, which had
been occupied by another tenant as an underground bakehouse
from 1879 down to October 1895. The premises were then
closed while the owner carried out certain repairs, and