found, the agent makes no further inquiry; if not found, he asks the child's age and address and the name of the school last attended. Later he ascertains the correct age of the child from the school or from the files in his own office. Whenever he finds a child who appears to be certainly under 16 years of age working without a certificate he instructs the foreman or employer to cease employing the child until the correct age is established and tells the child to come to his office with proof of age. If the agent does not find a child for every certificate on file, he makes inquiry at the office as to the missing children, and if he finds that a child has been dismissed and no termination notice sent to the State board he requires the employer to make out the termination notice before he leaves the premises. The agent also instructs employers to take no risks when in doubt as to the ages of children applying for work without employment certificates, but to send them to his office for statements of age. The agent makes no inquiry as to hours, character of work, or labor conditions.

In a large establishment the agent generally makes his tour of the workrooms without the certificates, but speaks to and writes down the names of all the children who appear to be under 16 years of age. Later he compares the names and the certificates in the main office. Sometimes the employer summons all the children together and the agent checks them up by the certificates. By this method, however, it is impossible for the agent to detect the child who is not 16 years of age but who because claiming to be is not told by the employer to appear, and for this reason he usually makes a tour of the establishment. In all other respects the procedure is exactly the same as in small establishments.

Whenever an agent inspects an establishment he records the results on a card,' which gives, in addition to the name and address. of the firm, the business in which it is engaged, the name of the superintendent, the number of hands employed, the number of girls and boys between 14 and 16 years of age, the number working without certificates, and the number employed under 14 years of age. The agent keeps this card, but the information is transferred to another. blank, which is sent to the State board at Hartford. This latter blank, it should be noted, is now filled out only in part, as its questions were made to fit inspections under the old law and cover some questions, such as those relating to hours and wages, which the agent can not now legally ask. The agent also keeps a list of inspections. as a guide to future work, and the State board makes up, from the reports which it receives, a record of the history of inspections3 by establishments. This last form, it is said, has not proved entirely satisfactory, as it does not show on what date the information was gathered and has to be supplemented by notes on the back.

1 Form 23, p. 68.

Form 24, p. 68.

Form 25, p. 68.

SUMMARY.

To sum up, the principal duties of the agents of the State board of education, who are primarily responsible for the enforcement of the employment certificate law, are (1) to issue certificates; (2) to inspect manufacturing, mechanical, and mercantile establishments in their own districts and see whether certificates are on file; (3) to assist from time to time in special canvasses of their own or other districts; (4) to report to the State's attorney and to act as prosecuting witnesses in cases of violation of law, whether by employers or parents; (5) to follow up employers who fail to send in commencement or termination notices; (6) to follow up in large towns all children from 7 to 16 years of age who have dropped out of school or who, having applied and not been given certificates, can not be located by the local attendance officers; (7) to follow up in small towns all children from 7 to 16 years of age who have dropped out of school or have applied and not been given certificates; (8) to follow up children of school age who are not in school but have been located by the annual school census; (9) to see that children who have been employed on summer-vacation certificates return to school in the fall; (10) to report to school boards, superintendents, or teachers the names of children who have applied for certificates, with the disposition of each case; and (11) to follow up children who have been employed but are out of work.

The agents make monthly reports1 of the number of towns visited, the number and kind of establishments inspected and the results, the number of special cases investigated, the number of applications for certificates, the number of certificates issued and refused, the number of notices to attend school and of statements of age issued, the number and the results of prosecutions, the number of copies of certificates (subsequent certificates) issued, the number of letters written, and the number of days occupied in issuing certificates. From these reports the State board can make out monthly statements for the entire State. The agents also have monthly meetings in Hartford, when they compare notes, discuss doubtful cases, and receive instructions.

RECORDS.

The records kept of the administration of the employment certificate law are of three classes-those relating to the State as a whole, those relating to the Hartford district, and those relating to districts outside of Hartford. Both the State and the local Hartford records are kept in the State capitol building at Hartford, and the local records of other districts are kept in the offices of the State agents for those districts.

These records are as follows:

1 Form 26, p 69.

STATE RECORDS.

1. Alphabetical file of State board copies of all certificates in force in the State, each certificate accompanied by commencement and termination notices and subsequent certificates for that child. (Forms 7, 8, 9, 12, pp. 60, 61, 62.)

2. Similar file of expired certificates and of statements of age. (Form 14, p. 64.)

3. Similar file of vacation certificates. (Form 13, p. 63.)

4. Correspondence file of form letters to employers, parents, etc., and other correspondence. (Forms 20, 21, 22, pp. 67, 68.)

5. Memoranda of attendance notices given parents of children refused certificates, pasted in books by months. (Form 19, p. 67.) 6. File of agents' reports of inspections. (Form 24, p. 68.) 7. Historical records of inspections of each establishment. (Form 25, p. 68.)

8. Monthly reports of State agents. (Form 26, p. 69.)

HARTFORD DISTRICT RECORDS.

1. Alphabetical file of information cards for all applicants, including both those refused and those granted certificates, and also information cards for children over 16 who have received statements of age. (Form 1, p. 56.)

2. Alphabetical file of evidence of all kinds warranting the refusal or the granting of certificates, including evidence of age, examination papers, transcripts of school records, and employment tickets. (Forms 2, 3, 3a, (back), 4, 5, pp. 56, 57, 58, 59.)

3. Information cards for continued or pending cases. (Form 1, p. 56.)

4. Memoranda of agents' reports of inspections. (Form 23, p. 68). In Hartford the duplicate memoranda of attendance notices (Form 19) are sometimes destroyed and are sometimes given to a State agent or to the local attendance officer. Parents' copies of subsequent certificates (Form 12) are either destroyed or exchanged; in the latter case the old parent's copy is destroyed. Employers' copies of statements of age (Form 14) are sent to the employers. LOCAL RECORDS KEPT BY STATE AGENTS OUTSIDE OF HARTFORD DISTRICT.

1. Alphabetical file of information cards for children granted certificates, parents' copies of subsequent certificates with the names of the employers inserted by the agents, and employers' copies of statements of age for children over 16, together with information cards for such children. (Forms 1, 12, 14, pp. 56, 62, 64.)

2. Alphabetical file of information cards for children refused certificates. (Form 1, p. 56.)

3. Alphabetical file of all documents accepted as evidence of age, and of examination papers. (Forms 2, 3, 3a, 3a (back), pp. 56, 57, 58, 59.) Transcripts of school records and employment tickets are destroyed from time to time.

4. Duplicate memoranda of attendance notices.

(Form 19, p. 67.)

5. Information cards for continued cases. (Form 1, p. 56.) 6. Memoranda of agents' reports of inspections. (Form 23, p. 68.) 7. List of inspections-kept in a book.

8. Teachers' attendance reports for all children in small townskept until unexcused absences have been investigated.

CONCLUSION.

The most striking features of the administration of the employment certificate system in Connecticut are its centralization and its consequent uniformity in procedure. The law is short and on many points, such as the evidence of age to be accepted, specifies no details of procedure; but it is so drafted as to give the State board of education power to make rules and regulations relating to these details. This is done not by any formal delegation of authority, but simply by placing the whole matter in the hands of the secretary and agents of the State board who, though they can not issue certificates to children who do not meet the requirements laid down in the law, are alone responsible for determining whether or not these requirements are met. The law does not make the issuing of certificates mandatory upon the secretary and agents of the State board. In other words, the child is not given the right to demand a certificate upon producing certain documents, but before issuing the certificate the agent must be satisfied of the truth of the facts to which he personally certifies.

This shifting of emphasis from the child's right to an employment certificate to the power of the secretary and agents of the State board to use their discretion under the law in issuing such certificates makes it possible to establish a uniform system of rules and regulations governing details which in many States are specified in the law itself. Such rules and regulations could not be enforced if local officials issued the certificates without central control, and such a method of issuing them under a law of this kind would lead to wide differences in actual standards throughout the State; but this possible danger appears to be entirely obviated by the fact that the State board is able to keep the issuing of certificates entirely in the hands of its own agents, over whom it has complete control.

Similar uniformity exists in most of the methods by which the law is enforced. The taking of the school census and the following up of the truants from school in places where there are local truant officers

are practically the only functions of the enforcement system which are not performed under the direct unifying supervision of the State board of education.

METHOD OF SECURING CERTIFICATES.

In spite of the fact that instead of definitely giving children the right to demand certificates the law gives the secretary and agents of the State board of education the power to issue them, the necessary procedure for obtaining certificates seems to involve almost as little hardship to children as is consistent with the proper protection of their interests which is the main purpose of the law. Though there may seem to be some hardship in the rigid requirement that one of the parents must be present in person, his presence is required only once, and experience, it is claimed, has demonstrated that this is desirable. That the child shall bring a promise of employment is essential if an employment certificate is to be in reality what its name implies and not merely a permit to leave school for any purpose whatever. If a child has actually secured a position this requirement does not commonly make necessary a second trip to the agent's office before getting a certificate, for employers generally understand that they must give the child such a promise, and any signed statement of the kind is accepted. On the other hand, if the child has no position promised this requirement prevents him from getting out of school merely to roam the streets. In any event the child goes away from the first. interview with full instructions as to what he must bring next time in order to secure a certificate.

The procedure of obtaining a subsequent certificate, or a copy of the original certificate for a new employer, is as simple as it could well be made. The child, the parent, or the employer may apply in person or by letter or postal card, and without further formalities the copy is sent. Inconvenience to the child in securing a new position and going to work at once is obviated by the fact that, pending receipt of a copy reading to his new employer, he may work for a week on the authority of the parent's copy of his original certificate.

EVIDENCE OF AGE.

The evidence of age required seems fairly conclusive, though it might be improved in some cases if the agents knew and gave positive instructions as to the official from whom foreign-born children could secure copies of their birth records. If this were done and proof, such as a receipt for a registered letter, were produced at the office showing that the parent had actually attempted to obtain such a record, it might be possible in cases where the child appeared to be certainly over 14 years of age to relax somewhat the requirement that a child must wait weeks on foreign mails before getting his employment cer