tional difficulties exist in regard to the procedure of ratification, that condition of things should, if possible, be considered at an early date by the League of Nations, with a view to uniform procedure being adopted in harmony with the scheme of the Treaty of Peace.

A further question has emerged in regard to the time of ratification. If a member State adheres to a convention, that involves two things, first, ratification after, in most cases, the authorisation of Parliament has first been sought and given, and, secondly, revision and amendment of existing national legislation touching the subjectmatter of the convention so as to bring it into accord with the provisions of the convention. The amendment of existing legislation that is involved may be very considerable and far-reaching, and member States have to ask themselves this question: Should the act of ratification precede the legislative changes or should the latter be effected before ratification? Putting the same question in another form, should member States place themselves under international obligations to other member States to reform home industrial conditions until they have ascertained whether public opinion in their own country will permit them to effect the necessary modifications of their existing national laws to remedy those conditions? The view of the International Labour Office on this increasingly important and essentially practical question is that domestic legislation should be first brought into consonance with the convention, and that when that reform is effected there should follow the formal ratification of the convention. That would seem unquestionably-apart from the delay-to be the right procedure, otherwise member States may find themselves in the position of having ratified a convention and then being unable to give full effect to it, which in itself would be a breach of the Treaty. In such circumstances it is extremely doubtful what view the Permanent Court of International Justice could or ought to take. The Court would really not be dealing with a legal issue, but would in practice be placed in the position of having to consider what it could or would have done if it had been acting in the place of the Government of the defendant member State, and responsible for the legislation and administration of the country in question-an impossible position.

There is another matter of importance which is arising in connection with ratification. The official languages of the Organisation are French and English, and many member States, when approaching consideration of the question whether they will or will not ratify a convention, desire to know the full intention of terms and phrases

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in the conventions. To obtain such a decision may well be essential before they can decide in what particular respect or to what extent they will be called upon to amend their own domestic legislation. There is no effective procedure provided in the Peace Treaty for giving "interpretations" on international labour conventions under those circumstances, though anyone conversant with labour legislation, and especially with labour agreements, knows how the whole peace and harmony in an industry may turn upon some subtle shade of meaning intended by the parties to be attributed to an industrial word or phrase. The International Labour Office has no authority and does not claim to exercise any right to give "interpretations" of conventions to member States who ask for them. What it very properly does is to refer the member State which desires an 'interpretation" to the way in which the convention is being carried out in other countries where it has been applied, or to the condition of things in a member State where there was already in existence before the convention what is prescribed by the convention. At the same time the office makes the fullest reservations as to the authority of any opinions expressed or implied in such an answer. Here again there is need for some amendment in the constitution and procedure of the International Labour Organisation which will enable authoritative "interpretations" to be given of conventions and, indeed, of recommendations. The necessity for this will grow rapidly as conventions hasten to come up for ratification by member States, or recommendations for incorporation in domestic Acts of Parliament. Experience in most organised industries in Great Britain, where working rules have been adopted by agreement between employers and employed, has shown the urgency for the existence of an authoritative and experienced tribunal to give decisions from time to time as to the intention of the rules. International labour conventions stand equally in need of a similar tribunal; and such interpretation, if we may call it that, is really not a suitable matter for a purely judicial decision.

Anything approaching relative uniformity in the industrial codes or industrial administrations of different countries seemed, before the establishment of the International Labour Organisation, to be an impracticable ideal. How great is the measure of uniformity that is being now achieved can best be appreciated by reference to the actual provisions of the draft conventions and recommendations adopted by the three International Labour Conferences at Washington, Genoa, and Geneva. These should be read in full-either in the

English version from the three booklets issued by the British Ministry of Labour and published by the British Stationery Office, or in the French and English versions as published together by the International Labour Office in Geneva. We can only say in passing that at Washington draft conventions were adopted in respect of (1) an 8-hour day and a 48-hour week; (2) unemployment; (3) the employment of women before and after child-birth; (4) the employment of women during the night; (5) the minimum age for admission of children to industrial employment; (6) the night work of young persons employed in industry; and recommendations in respect of (1) unemployment; (2) reciprocity of treatment of foreign workers; (3) prevention of anthrax; (4) protection of women and children against lead poisoning; (5) establishment of Government health services; (6) application of the Berne Convention of 1906 prohibiting the use of white phosphorus in the manufacture of matches. At Genoa, draft conventions were adopted in regard to (1) the minimum age for admission of children to employment at sea; (2) unemployment indemnity in case of loss or foundering of the ship; (3) establishment of facilities for finding employment for seamen, and recommendations concerning (1) hours of work in the fishing industry and in inland navigation; (2) the establishment of national seamen's codes; and (3) unemployment insurance for seamen.

After securing adoption by the Conference of conventions or recommendations, the next important matter is the extent to which member States ratify those conventions and accept the recommendations. Great Britain so far has formally ratified the Washington conventions in regard to unemployment; the employment of women during the night; the minimum age for admission of children to industrial employment, and the night work of young persons employed in industry, and also the Genoa conventions in regard to the minimum age for admission of children to employment at sea. These were either covered by existing British legislation and administrative practice, or were expressly put into force by the Women, Young Persons and Children (Employment) Act of 1920. The British Government refused to ratify the Washington convention in respect of the 8-hour day and 48-hour week because the rigid terms in which that convention was drawn would have conflicted with agreements concluded between the Government and the railwaymen in regard to hours of work and also with important collective agreements between employers and employed in other industries. The British

Government also refused to ratify the Washington convention in regard to the employment of women before and after child-birth, because again the inelasticity of the provisions would have cut across the administrative practice under the Factory and Insurance Acts, and thereby occasioned very considerable dislocation of a code of law which, although requiring some amendment, it could hardly be said needed to be entirely superseded by a different régime.

On pages 48-53 of the Report of the Director of the International Labour Office, to which reference has already been made, several illuminating tables are printed showing the action taken by different member States to give effect to the conventions and recommendations of the Washington and Genoa Conferences. If, for example, we take the Washington convention in regard to hours of work, it will be seen that Czecho-Slovakia, Greece, India, and Roumania have ratified that convention; and that the Governments of Argentine, Austria, Belgium, Brazil, France, Germany, Poland, and Spain have recommended to their respective legislatures its ratification, and have taken steps to submit the necessary Bills to their Parliaments for that purpose. When one comes to consider the cases in which the convention has been actually put into operation, we find that Belgium and the Province of British Columbia in Canada have passed Acts of Parliament enforcing the provisions of the convention, and that the Governments of Argentine, Chili, Denmark, Germany, India, Italy, and Luxemburg have deposited in their various legislatures or governing bodies Bills for Acts to apply those provisions. Further, we find that the Government of South Africa at present is engaged in drawing up such a Bill.

Each one of the Washington and Genoa conventions and recommendations is treated in M. Thomas's report in a similarly comparative way, and in the text of the document very full explanations are given of the constitutional and industrial circumstances in each country affecting its ratification or its application. These tables show conclusively the success which in the first three years of its existence has already attended the efforts and operations of the International Labour Organisation.

We can summarise the position by stating that the decisions adopted at the Conference at Washington have led to the adoption of 40 acts or other legislative measures, 32 of which are concerned with the draft conventions and 8 with the recommendations; and to the preparation of 101 Bills, 80 dealing with draft conventions and 21 with recommendations. The decisions of the Genoa Conference

have led already to 3 Acts of Parliament relating to conventions and to the preparation of 23 Bills, 12 of which deal with conventions and II with the recommendations. Two of the Washington conventions, the one relating to the hours of labour and the other to unemployment, came into force on July 1, 1921; the other four Washington conventions and the three Genoa conventions will come into force on July 1, 1922.

The machinery provided by the Peace Treaty for dealing with member States who neglect or refuse to submit the draft conventions and recommendations to the competent authority, or which, having ratified the conventions or adopted the recommendations, refrain from putting them into active operation by Act of Parliament, administrative order or otherwise, is delicate in the extreme. It involves a certain measure of control by the International Labour Office, or it may be the Permanent Court of International Justice, of the domestic industrial affairs of member States, and raises interesting questions of constitutional procedure and international law. Those questions must, however, await discussion on some future date.