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74
a building, and in one occupation, is regarded by the Home Office to be a factory
or workshop as the case may be; offices and other rooms in which work is carried
on, except where certain specified exemptions have been allowed, could therefore
be dealt with as being parts of a factory or workshop and subject to the same
requirements.
Presumably the intention of the provision quoted above is to require ventilation
to the external air direct, but in some instances where these conditions are met
with the ventilating openings are situated in, or so near to the ground level in the
form of pavement ventilators, gratings in stall-boards and the risers of entrance
steps, that quantities of dust and other impurities gain access to the rooms they
serve which is extremely undesirable. On the other hand in workrooms where the
means of ventilation are not in direct connection with the open air (and the intention
of the Act, therefore, not complied with) sufficient air may be introduced
and diffused to meet the requirements of the workers and be minus the gross impurities
already mentioned. This would be preferable perhaps to an admittedly undesirable
method of "direct" ventilation.
In a basement, air usually enters the room just above head level, and in cold
weather the workers find this objectionable, close the ventilating opening, and
consequently ventilation is not maintained.
Another aspect may be considered. Where mechanical means of ventilation
by extraction fan have been installed in basements it is found that care has often
been taken to select an outlet at some convenient point, but the incoming "fresh"
air is drawn, frequently, not from special suitably selected points to ensure purity
and freedom from dirt, but from any openings or spaces in aerial communication
with the system, including other rooms, and not always direct from the external
air. In such cases only a mechanical system which is principally indirect ventilation
exists.
These points render it difficult to say whether the provision of direct ventilation
to the external air can be enforced and even if so, whether it is advisable to do
it in every case.
Factors which should not be ignored when considering means of ventilation
are the close relationship it bears to means of heating, also that which the position
of the ventilating openings bears to both. More adequate means of ventilation
become necessary if the heating apparatus vitiates the air than would otherwise
be required. The intense dislike sedentary workers have of a draught of cold air
necessitates care in the use and position of windows and other openings if they are
to be of any value for ventilating purposes, otherwise they will be kept permanently
closed.
It is noteworthy that offices, which are considered to be workplaces, are not
legally, under the Factory and Workshop Act, required to be either adequately
lighted or ventilated. The weakness of the Act is still further exemplified by Section
157 in which men's workshops are exempted from various requirements,
among which is included "means of ventilation." The Public Health (London)
Act, however, gives some power in this connection in workshops and workplaces,
but only where "gases, vapours, dust or other impurities generated in the course of
the work carried on therein that are a nuisance or injurious or dangerous to health "
are found, and perhaps also under Section 2 (a) which refers to any premises in
such a state as to be a nuisance or injurious or dangerous to health.
An effort was made in 1913 to introduce legislation affecting underground
workrooms in certain trades under which occupation of all such rooms was prohibited
unless certified by the Local Authority as suitable for the purpose. Adequate
lighting and ventilation were, amongst other requirements, specified as conditions
to be complied with before the certificate was to be granted. The Secretary
of State was to be empowered to make regulations for lighting and ventilation.
The definition of underground room was to be held to mean any room any part
of which is so situated that half or more than half of the whole height from floor to
ceiling is below the surface of the footway of the adjoining street. The Bill did not
become law. I referred to this fact in my Annual Report for 1913.
Difficulty is sometimes experienced where a basement under a shop becomes
used as a workroom connected with the business carried on above, the direct