information and direction not only as to what the various laws administered by the Department require, but as to how such requirements can be met in a practical way, or better still, how even more than the strict letter of the law demands may be done with advantage to all concerned. This is the plain intent of such a provision in the law as that requiring the Division of Industrial Hygiene to "prepare material for leaflets and bulletins calling attention to dangers in particular industries and the precaution to be taken to avoid them." In line with what has just been referred to, there is a kind of educational work, aside from that connected with the publication of bulletins or leaflets for general information, which should be developed, and which it is believed would go far to facilitate observance of the law which the Department has to enforce. This is in connection with the issuance of orders by inspectors or by the Department. Heretofore the practice has been in effect to issue an order simply in the form of a direction to comply with the law as to a particular subject at a particular place, as, for example, "guard circular saw," or "guard gears on planer on fourth floor." Now the great defect here is that the employer is not told how to guard, and it is certainly not a dreamer's view of the matter to hold that when the Department issues an order it should be able to, and should, give expert information at the same time as to how the order can be complied with in a practical way. Two means of compassing this suggest themselves. One is the codification of orders on the various subjects dealt with and their formulation so that they shall be at once a command to comply with the law and at the same time a direction as to how this is to be done. The development of detailed regulations by the Industrial Board, to carry out the present more general requirements of law, should both facilitate, and would seem to make necessary some such system of codified orders. Doubtless on many subjects it is impracticable to put in the form of an order all the information needed, but for such there should be developed leaflets for that purpose to accompany the orders. Supplementary to such codification of orders there should be provided, and should be continuously developed by revision, enlargement and improvement, a manual of instructions and information for inspectors. Here again, the more de

tailed regulation of industry which from now on must obtain makes such a manual essential both for the information of inspectors and through them for the instruction of employers.

To the same end another means may profitably be employed and has indeed already been inaugurated. This is conferences of the higher inspection and other officials of the Department for interchange of experience and ideas, whereby development in uniformity and the raising of all work to the standard of the best intelligence in the Department may be secured. Such regular monthly conferences have already been begun, and are held at a time so that conferences with the Industrial Board can be had at the same meeting, and are to be a permanent feature of our work. Carried out earnestly they must inevitably promote individual intelligence and more effective team work in the Department.

But there is educational work for the Department in a larger field than that represented by the laws which are committed to it for enforcement. By the explicit terms of the law (see section 63 of the Labor Law) it is the business of the Department to supply "such information and statistics as the Commissioner of Labor may direct for the purpose of promoting the health, safety and well being of persons employed at labor." I conceive this to mean that the Department should be an active agent to point out the lines of constructive progress on any and every subject connected with the welfare of wage earners, which is a matter of public concern. This does not mean that the Department is to be a partisan or a propagandist, but it does mean that it should be an educator by means of impartial information on all labor problems. I wish to emphasize that this work should be definitely designed to promote practical progress. This aim should be the guide in such work more than has been the case either in this State or elsewhere. Mere recording of the past with no regard to what such records may be worth for future guidance may be interesting, but represents about the least that can be done in this field. Records of the past ought to be considered in such work only with a view to what light they may throw on present or future problems, and especially ought always to be so interpreted when presented. But far more than to analysis of the past, work in this field should be devoted to investigation, analysis,

and marshalling of evidence concerning the situation which now confronts us, and concerning the lines of progress which lead out from the present. In other words, practical investigation of the practical problems of to-day conducted in a scientific spirit is here the ideal.

There is no lack of work of this kind at hand. It is only necessary to look about a little at conditions here and elsewhere, and at current discussion of these problems to discover certain subjects which loom up just at present. Aside from the great fields of health and safety, and industrial relations, heretofore adverted to, four general subjects may be mentioned as particu larly demanding attention just now. One of these is unemployment, forcibly brought to view by the state of the labor market during the present winter. Another is minimum wages, concerning which there is much public discussion and pressure for action. A third great subject is that of social insurance. The new Workmen's Compensation Law has brought New York to an advanced position in the social insurance field so far as accidental injuries are concerned. But still demanding study are the vicissitudes of sickness, old age and unemployment, against which the wage earner most of all has difficulty in insuring himself. In the fourth place may be noted a problem less definite in its scope, but of far-reaching significance, that of immigrant and unskilled labor. Here the matters which are dealt with by the Bureau of Industries and Immigration, and which have been mainly those concerning just treatment of aliens, or in other words, the conservation of their rights, are not meant, so much as the deeper question of the place of crude labor in industry, and especially its effect upon existing agencies or methods for improving the condition of labor generally.

On all these great questions which look to the future, the Department should be an active agent of progress by investigation and educational work, nonpartisan indeed, but none the less authoritative by reason of the fullness and accuracy of its information.

This brings me to a question which it seems in order to discuss at this time the relation of the Department to special commissions dealing with labor problems. The Labor Department is the proper agency to do much of the work which has been from

time to time assigned by the Legislature to special commissions. This is certainly true for all such work which is in the nature of the collection of data on the basis of which questions of public policy are to be determined. It may not, indeed, comport with the proper functions of the Department to take the responsibility of settling questions of public policy on labor problems, but it is its explicit business to furnish data on such problems as an aid to their solution. If this be true, the question becomes simply one of the relative efficiency and economy of the Department as compared with a special commission for the collection of data. On this question it would seem that there could be little doubt that every advantage lies with the Department, granted that it is properly equipped to do the investigation work which it is directed to do. For there is the obvious difference in such case between an agency with a permanent and experienced staff and equipment, and with intimate knowledge of and connection with the field, ready for work at once, as over against an agency which must first build up all this. It is true that the occasion of special commissions is often some special subject pressing for attention in a larger way than could be at once handled by the Department without seriously interrupting work in hand. But a temporary addition to its equipment could easily be made at a cost far below that necessary for a commission, and with a complete saving of delay in organization, which would meet such situations. This is simply an expression of my views as to the proper functions of the Department of Labor as the most effective mode of securing the general end sought.

A further suggestion along this line is also here made, which to my mind accords with the best modern ideas and practice and is entirely feasible. As set forth above, one limitation upon the Department as a substitute for special commissions is the need. frequently for a broader representation of the public for the determination of questions of public policy. But there is nothing that will prevent the securing of the same end, as well as other incidental advantages, by means of advisory committees to the Department, whereby the Commissioner of Labor may call into service the best outside counsel, or secure the opinions of interested persons, to supplement the technical work of the Department. These would be essentially like the British departmental

committees which have been so signally successful as a means of progress in labor legislation and administration in Great Britain. Furthermore, they would be precisely the same as the advisory committees which the Industrial Board has already organized to assist in its work. Essentially, it is here proposed only that the method provided in connection with the Industrial Board for the field of health and safety should be applied also to other fields under the jurisdiction of the Department, for it is along such lines that the best practice and progress elsewhere point the way. The development of one permanent State agency for the handling of all matters relating to labor, and for continuous and progressive work thereon, in place of disconnected, periodical, or temporary agencies, is the goal toward which we should move, and into such an agency the Department should be further developed. Recapitulating this announcement of program for the Department, the policy of this administration is to be especially

(1) To push constructive investigation work by the Division of Industrial Hygiene as a basis for legislative regulation by the Industrial Board;

(2) To increase the work of law enforcement by revision of methods, so as to improve both quantity and quality of inspection work;

(3) To enlarge the function of friendly mediation in labor disputes and to use the power of public investigation fearlessly when needed;

(4) To overhaul and systematize Departmental business methods with a view to greater efficiency and economy;

(5) To make the Department a leading educational factor by information and investigation work at once scientific in spirit but practical in purpose.

Lest anything in this report should be misunderstood, I assert that it is farthest from my mind to imply any criticism of the past in what has been said. On the contrary, I have discussed policies only with an eye to the future, intending to indicate in larger outline what a new administration, building upon the experience of the past, hopes to achieve in the larger opportunities vouchsafed to the Department by the amended laws.

All of which is most respectfully submitted,

JAMES M. LYNCH,

Commissioner.