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58
Clause 8 of the Bill contemplated certain regulations which could be made by order
of the Secretary of State, in reference to the structure of underground rooms to which
the Act would apply, and the provision and use as regards such rooms of means of
securing the maintenance of:—
1. Reasonable temperature;
2. Proper lighting and ventilation;
3. Freedom from damp, dust, effluvia and exhalations;
4. The carrying off of dust and fumes, and
5. For otherwise securing the health of persons employed in such rooms.
It was intended that different regulations should be made as regards the different
processes and occupations of the rooms in use when the order came into effect, and
rooms not so used.
When the regulations in question became operative, the underground workroom
would not be certified by the District Council unless such Council were satisfied that
the regulations which apply to such rooms were complied with, and the certificate given
would be made conditional on the provision of and use of the means prescribed for
securing the maintenance of the five provisions referred to above.
Although the occupation of a workshop is notified to the Factory Inspector, and
by him to the Local Authority, there is no requirement of registration for underground
workplaces. A workplace used in contravention of the provisions of the Bill, could
only be dealt with summarily as one of non-compliance with the law relating to
nuisances. It would, therefore, appear to have been possible for an underground
workplace to be occupied without being certificated until it was discovered by your
Officers, and as I understand nuisance procedure, no punishable offence would have
been committed until the occupier had tailed to comply with the terms of the notice
which would be served upon him. This, in my opinion, was a serious defect, and it would
have been an improvement if it had been made illegal for an underground workplace,
which came within the provision of the Bill, to be occupied without the granting of the
certificate by the Local Authorities.
Clause 10 defines an underground workroom as "any room any part of which is
"so situate that half or more than half the whole height thereof, measured from the
"floor to the ceiling, is below the surface of the footway of the adjoining street, or of
"the ground adjoining or nearest to the room.'' This definition in my opinion leaves
something to be desired, and an underground workroom should be defined in more
definite terms, such for example as obtained in the case of an underground bakehouse in
the Factory and Workshop Act, which is described as one in which the surface of the
floor is more than 3 feet below the surface of the footway. A similar definition is used
in the case of an underground room in the Public Health (London) Act, 1891, and I
would have preferred to see an underground workroom defined in the Bill under
discussion as one the floor of which is a certain number of feet below the surface of the
adjoining ground even if the minimum were extended beyond that prescribed by the
two definitions referred to above, and made 4 feet or 4 feet 6 inches.
On the whole the Bill would have marked an advance in Public Health
Legislation, and it is to be regretted that pressure of other work prevented its being
fully considered.