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Some aspects of child care and protection; a comparative study of six phases of care and protection… Shook, Vernon Phray 1949

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SOME ASPECTS ..OF CHILD CARE AND PROTECTION A, Comparative Study of Six Phases of .Care and Protection of Children in Canada, Denmark, Greece, I taly and the United States. Vernon Phray Shook Thesis Submitted in Pa r t i a l Fulfilment of the Requirements for the Degree of MASTER OF SOCIAL WORK In the Department of Social Work J.949 £he University of B r i t i s h Columbia ABSTRACT This study i s concerned with the evaluation and comparison of a portion of the laws and practices relating to the care and protection of children in five nations: Canada, the United States, Denmark, I t a ly , and Greece. The sub-jects discussed include administrative d i f fe r -ences, compulsory education, chi ld labour reg-ulations, adoption, the welfare of handicapped and crippled children and grants to needy dep-endent children. To some extent i n the evaluating and in the comparing processes, the factors causing differences in standards of care and protection of children are brought to l i g h t . Comparisons have been made in two ways, e .g. , by measuring one nation's laws -and practices against another, and by measuring the standards of each nation against international standards and pr inciples . Although i t has been found that a l l f ive nations have weaknesses in these provisions for the protection of children, a vast difference of strength i s shown between Canada, Denmark, and the United States on the one hand -and Greece and Italy on the other. It i s the conslusion of the author that these differences show the necessity for international action and help for nations unable to provide adequately for their children without outside help. Considerable d i f f i cu l t y was experienced i n finding material for research. Generally, four sources were used for the compilation of re le -vant information. These were: The University Library, national and international agencies and offices, friends working i n the f i e l d of soc ia l work in the countries studied, -and an amount of material and information gathered by the writer while working in three of the count-r ies involved. ACKNOWLEDGMENTS The writer wishes to acknowledge with gratitude the patient and kind' assistance generously given by Dr. Leonard Marsh, Associate Professor, University of B r i t i s h Columbia, De-partment of Social Work. For their contributions and keen interest from the f i e l d , thanks and asknowledgments are tendered to Mr. Glen Leet, United Nations Advisor to the Greek Government for Social Welfare; Mr. Viggo Olsen, Welfare Supervisor, County Council of Copenhagen, Denmark; Mr. Micheal Shapiro, formerly UNRRA Welfare Officer in I ta ly . Speical thanks are given to Miss Kalet Smithe of the United States Children's Bureau for her generous assistance i n obtaining material for the present work. TABLE OF CONTENTS Chapter 1. Introduction Chapter 2. National Differences in Administration The United States, Canada, Denmark, I ta ly , Greece. Chapter 3. Protection of Children "by Child Labour and Com-pulsory School Attendance Legislation Denmark: compulsory education, organization and system, chi ld labour protection. The United States: public schools, compulsory ed-ucation, enforcement, regulation of chi ld labour, systems of control, enforcement. I ta ly : compulsory education, enforcement, chi ld labour l eg i s l a t ion . Canada: chi ld labour regulations, compulsory ed-ucation, f a c i l i t i e s of education,, enforcement. Greece: chi ld labour regulations, control, enforce-ment, "compulsory school attendance, education f a c i l -i t i e s , Comparisons among nations. Chapter 4. Protection of Children through Adoption The United States: who may adopt, requirement of consents, probationary—period required, l ega l effects of adoption. Denmark: who may adopt, who may be adopted, con-sents required, legal effects of adoption, revocation of adoption, supervision of adopted- children. Greece: who may adopt,, who may be adopted, con-sents required, legal effects of adoption, revocation of adoption, probationary period. I ta ly : who may adopt, who may be adopted, consents required, date -adoption becomes effective, legal ef-fects of adoption, inventory required, rights of suc-cussion, revocation of -adoption, investigations, pub-l i c i t y . Canada: who may adopt, who may be adopted, consents required, probationary period, legal effects of adop-t ion , appeals, administrative authority. Summary and comparisons. Chapter 5. Protection and Care of-Handicapped and Crippled Children Canada: crippled children, handicapped children, ins t i tu t iona l care. The United States: crippled children, agency programs, provisions for the handicapped, the socia l worker's ro le . Denmark: finding procedure, ins t i tu t iona l care, of the handicapped, care of crippled children, the role of the socia l work -agency, care of the blind children, care of deaf-mutes. Greece. I t a ly . Comparisons between nations. Chapter 6. State Grants to Dependent Children The, United States: Federal l eg i s la t ion , those who may receive grants, amount of g-rants, extent of grants', how grants are made, methods of deter-mination. Denmark: Amount of grants, how grants are made. I t a ly . Greece: determination of need, extent of grants. Comparisons between nations. Chapter 7. Comparison with International Standards Evaluation of provisions for administration. Evaluation for chi ld labour regulations. Evaluation for compulsory education, Evaluation of provisions for adoption. Evaluation of grants to dependent children. Appendices Bibliography. CHAPTER I INTRODUCTION A nation's children i s i t s most important asset. Because of recognition of this fact , almost every nation has from time to time f e l t the need to review i t s own leg is la t ion and prac-tices i n securing the welfare of i t s children. This has re-sulted sometimes i n comprehensive studies "being published. Studies of more specific problems of children have been made from time to time, usually as these specific problems have become disturbing enough to warrant an attempt at resolution. It i s necessary that this be done before any advance may be made toward the goal of rea l security and sound development i n a l l phases of children's l ives which are normally subject to the influences of the environment. In general, this goal • has been, i n one degree or another, accepted as desirable in order to offer the greatest opportunity for children to a-chieve -a well-balanced adulthood, the benefits of which may easily be visual ized as far as the individual nation i s con-cerned. From this point many have moved to the a l lur ing thought: suppose a l l the children in a l l the nations could be given an environment such that they would be assured of the maximum opportunity to achieve well-balanced adulthood... Here we reach such a stage in our wishfull thinking that we may speculate to our heart's content upon the b l i s s f u l state the world would enjoy. The world i s far from this idea l : but i t i s encouraging to. note the progress that has been made toward this goal in 2 the l a s t ' h a l f century. There i s no doubt that i n an indirect way, the las t two wars have brought to bear greater attention to the problem by focusing efforts upon the resultant suffer-ing of innocent children. There has been some post-war think-ing and acting along the l ines of international regulation of the environment. At least i n chi ld welfare national sover-eignty i s moving over to make a place for international sov-ereignty. Researchers i n chi ld welfare are becoming in ter -nationally minded. At the present time there i s an acute awareness of the need for international sharing of resources for the in ter -national good rather than for the national good. A search for correlated studies relating tq^the laws and practices pertaining to chi ld welfare i n various nations has revealed very l i t t l e which had been completed or published. Thus, the world has yet to f i x international standards and goals on which to base international sharing for chi ld welfare. As the welfare of children i s an inseparable part of socia l work i t i s l og ica l to expect social workers to as-sume increasing leadership in international a f fa i rs . I t was encouraging to note the attendance of interested people at the International Conference of Social Work of 1948 at Atlant ic City and at New York Ci ty , and the emphasis which was placed upon the welfare of children. It has been the business of such national agencies as the United States Children's Bureau and international agen-cies such as the International Labor Organization, the Food and Agricul tural Organization, the World Health Organization, 5 the Preparatory Commission for the International Refugee Organization, the International Children's Emergency Fund, the United Nations Educational/ Scient i f ic and Cultural Organization to collect information relat ive to the laws and practices of various countries i n the f i e l d of ch i ld welfare; Much of the material referred to for this study has been supplied through these sources. So far , to the wri ter ' s knowledge, there has been no compilation of the laws and practices of the various nations for the purpose of comparison. In their effort to draw up a declaration of the rights of the ch i ld the United Nations secretariat of the Social Commission was requested to prepare documen-tation on the or ig ina l Declaration of Geneva (1924). In i t s study of the Declaration, the secretariat has uncovered not only several governmental and non-governmental organ-izations actively interested in this international document, but the need for comprehensive studies of the laws and pro-visions for chi ld welfare made by each nation. In this way i t i s hoped that suitable principles and standards may be set and a good understanding obtained of where each na-tion stands i n relat ion to them. Twenty-five years ago when she was the Chief of the Children's Bureau, of the United States, Grace Abbot ex-pressed the hope that " i f for a generation a l l children were assured^that the rights which the Declaration of Geneva gays should be theirs , we should- have a different w o r l d . . . . The value of the Declaration of Geneva i s that i t looks forward to -a world i n which the ci t izens of a l l nations, each strong 4 i n their own self-respect, w i l l he trained to respect the 1 rights of others." I t i s log ica l therefore in the quest for a statement of international principles on chi ld welfare -and par t icular-ly those subjects covered in this thesis to study the dev-elopments which had their beginning in the Declaration of Geneva. The or ig ina l "Children's Charter", drawn up by the B r i t i s h "Save the Children Fund® contained a preamble and twenty-eight general principles which were condensed i n 1924 by the League of Nations into what i s now known as the "Dec-larat ion of the Rights of the Child" or the Declaration of Geneva. I t was adopted by the League of Nations i n September 26, 1924 i n the following form: "DECLARATION OF GENEVA "By the present Declaration of the Rights of. the Chi ld , commonly known as the Declaration of Geneva, men and women of a l l nations, recognizing that mankind owes to the chi ld the best that i t has to give, declare and ac-cept as their duty that, beyond and above a l l consider-ations of race, nationality or creed: I . The chi ld must be given the means requisite for i t s normal development, both materially and s p i r i t u a l l y . I I . The chi ld that i s hungry must be fed; the chi ld that i s sick must be nursed; the chi ld that i s backward must be helped; the delinquent ch i ld must be reclaimed; and the orphan and the waif must be sheltered and succoured. 5 I I I . The chi ld must be the f i r s t to receive r e l i e f i n times of distress. IV. The chi ld must be put i n a position to earn a JLivelihood and must be protected against every form of exploitat ion. V. The chi ld must be brought up i n the conscious-ness that i t s talents must be devoted to the ser-vice of i t s fellowmen." The Declaration of Geneva was warmly accepted and given general approval by prominent individuals and organizations a l l over the world. Statesmen and heads of states specified the Declaration as the basis for their future systems of chi ld welfare. This resulted i n the application of i t s p r in -ciples to new leg is la t ion i n many countries after studies had been made to find the extent to which the principles had 1 applied. During World War I I international action i n this f i e l d was for a time, almost paralyzed. During the later years of the war, however, chi ld welfare matters resumed the place of importance from which they had been expelled by the disrup-t ion of international relationships and war catastrophes. In 1942, for example, an In ter -a l l ied Conference of Edu-cational"" Experts was held i n London, England, and the Eighth Pan-Amer-ican Child Congress was held in Washington, D.C. 1 This and much of the information regarding the dev-elopment of the United Nations Charter of the Rights of the Child has been adapted from United Nations, Economic and Social Council Document E/CN.5/44 19 February, 1948, Social Commission, Third Session, Lake Success, 5-23 A p r i l , 1948 pp. 40-53, item 6 (c) . 6 After the termination of h o s t i l i t i e s , the International Labour Organization, considering the gravity of the s i t u -ation, so far as children were concerned, revived the ques-t ion of establishing standards for chi ld welfare by adopt-ing, at i t s f i r s t post-war conference, a comprehensive res-olution concerning the protection of children and young 1 workers. Since 1924, several declarations and charters on the rights of the chi ld have been formulated by international •and national bodies. Thus, for example, apart from the ILO resolution mentioned above, the"White House Children's Charter3* was adopted by the White House Conference on Child Health and Protection in 1950; while i n 1942 there were no less than three: namely, the "Children's Charter for the Post-War World", adopted by the In ter -a l l ied Conference of Educational Experts held i n London, England, mentioned above; the "Declaration of Opportunity for Children" adopted by the Pan-American Child Congress, mentioned -above; and?, the "Children's Charter i n Wartime", adopted by the United States Children's Bureau Commission on Children i n Wartime. These documents appear to accord major significance to principles additional to those emphasized in previous dec-clarations, e.g. , (a) chi ld welfare as an integral part of any general 1 ILO: Record of Proceedings of the Twenty-seventh Ses-sion of the International Labour Conference (Paris 1945) pp. 241, 365, 456. 7 1 socia l security scheme; (b) home and family environment in respect of the dev-2 elopment of the ch i ld ; (c) the protection of the personality of the c h i l d , - . .particularly protection against p o l i t i c a l abuse; (d) preventive as preferable, or at least complement-ary, to curative care i n respect of disease or delinquency; (e) extension of the non-discrimination clause to i n -clude "sex" and "Social position" (Children's Charter for the Post-War World), or "family c i r -cumstances" (ILO Resolution), and not to "race, nationality or creed" alone. In compliance with the resolution concerning the Dec-larat ion of Geneva adopted by the Social Commission at i t s last session requests for comments and suggestions on the subject have been transmitted to those of the specialized agencies that are concerned with the various aspects of chi ld welfare dealt with in the Declaration (ILO, UNESCO, FAO, the Interim Commission of WHO, the Preparatory Commission for IRO), and to the International Children's Emergency Fund. 1 This was a major principle of the ILO resolution, and one of the bases for i t s provisions concerning income sec-u r i t y , family allowances, the dis t r ibut ion of the cost of the maintenance of children, health, and socia l services, etc. ; and, a prerequisite for the aboli t ion of ch i ld labour. 2 A l l but one of the f ive statements mentioned above em-phasize the des i rab i l i ty of parent education, and the pre-ference for foster care as against ins t i tu t iona l care of homeless children. 8 Similar requests have been transmitted to the two internation-a l non-governmental organizations that represent the o r i g in -ators of the Declaration of Geneva (the International Union for Child Welfare and the International Council of Women), and to the American International Institute for Child Welfare as the o f f i c i a l organ of the Pan-American Child Congress, which la t te r was the f i r s t inter—governmental agency to adopt the Declaration. Of the specialized agencies, only FAO has transmitted -any definite suggestion. This i s in the form of a short draft resolution as follows: "The United-Nations reaffirm the five principles l a i d down in the Geneva Declaration of the Rights of The Child in 1924. They solemnly declare their inten-t ion of applying these principles in their domestic policy "They recognize, however, that economic and other d i f f i cu l t i e s may make i t impossible for some countries to implement a l l these principles immediately and sim-ultaneously at the present time. They agree that in this situation the f i r s t endeavour should be to ensure that expectant and nursing mothers and children are pro-perly fed so that the new generation may grow up, healthy in body and mind and f i t to meet the demands of l i f e . " The Interim Commission of the World Health Organization and the International Labour Organization have expressed a general interest i n the project, but have not as yet been able to present any definite suggestions or comments. No reply has so far been received from any of the remaining United Nations'specialized agencies, nor the International Children's Emergency Fund. The American International Institute for Child Welfare has referred to the terms of the "Declaration of Opportunity for Children" adopted by the Eighth Pan-American Child Con-gress, as expressing most appropriately i t s opinion on the subject. The International Union for Child Welfare has tran mitted a revised draft, as follows: "By the present Declaration of the Rights of the ch i ld , commonly known as the 'Declaration of Geneva', men and women of a l l nations, recognizing that Man-kind owes to the Child the best that i t has to give, declare i t to be their duty to meet this obligation  i n a l l respects: I . The Child must be protected beyond and above a l l  considerations of race, nationali ty or creed. The Child must be given the means requisite for i t s normal development, materially, morally and s p i r i t u a l l y . The Child must be protected within the framework  of the family unit and according to the require-ments of socia l security. The chi ld that i s hun-gry must be fed; the chi ld that i s sick must be nursed; the chi ld that i s physically or mentally  handicapped must be.helped; the erring chi ld must be reclaimed; and the orphan and waif, must be shel 1. The underlined parts show suggested amendments. I I . I I I . 10 tered -and succoured. IV. The Child must be the f i r s t to receive r e l i e f i n times of distress. V. The Child must receive a training which w i l l en-able him, at the right time, to earn a l ive l ihood, and must be protected against every form of ex-p lo i ta t ion . V I . The Child must be brought up in consciousness that i t s talents must be devoted to the services of i t s fellowmen." The International Council of Women, without proposing an -actual text, has suggested amendments on the follow-ing points: (a) amplification of the non-discrimination clause to include -also "sex" and "soc ia l position" (ref. "Children's Charter for the Post-War World", Pre-amble) ; (b) emphasis on the interrelat ion between family and chi ld welfare (ref. "White House Children's Charter", Ar t i c l e 15); (c) rewording of Ar t i c l e 3 of the Declaration of Geneva to reflect recent experiences (ref. "Children's Charter i n Wartime")." Taking these suggestions into account, the secretariat decided, i n view of the rapid developments which had taken place i n the f i e l d of chi ld welfare since the adoption of the Declaration of Geneva, that a mere reaffirmation of the Dec-laration would hardly seem adequate when considering the creation of a United Nations Charter of the Rights of the Chi ld . In addition to the above, the International Associa-t ion of Governmental Labour Off ic ia ls have set down major standards of Child Labour Laws for the United States which are part icular ly relevant to the present study. These standards are as follows: I . Minimum age: 16 years, i n any employment inaa factory, 16 i n any employment during school hours; 14 i n non-factory employment outside school hours. I I . Hazardous Occupation: Minimum age 18;. i n a considerable number of hazard-ous occupations state administrative agency author-ized to determine occupations hazardous for minors under 18. I I I . Maximum daily hours: Eight hour day for minors under 18 for any gainful occupation. IV. Maximum weekly hours: 40 hour week for minors under 18 i n any gainful oc-cupation. V. Work during specified night hours prohibited: 18 hours of night work prohibited for minors of both sexes under 16 i n any gainful occupation; 8 hours of night work prohibited for minors of both sexes between 16 and 18 in any gainful occupation. 12 The above w i l l be used i n this study as an internation-a l standard for chi ld labour for purposes of comparison with provisions made by the f ive countries under consideration. For comparison on the subject of economic need, we have arranged the foregoing concepts as follows: Provisions and regulations of nations for the pro-tection of dependent children against economic need w i l l provide, 1. Pr ior i ty for the needs of children i n times of d i s -tress. 2. Adequate measures to assure that no discrimination w i l l be made on account of sex, socia l posi t ion, family circumstances, race, nat ional i ty, creed; or p o l i t i c a l a f f i l i a t i o n . 3. Assurance of protection, i n so far as possible, within the framework of the family unit and accord-ing to the requirements of social security. 4. Administration through a national agency. 5. A chi ld should be given the means requisite for i t s normal development both materially and s p i r i t u a l l y . For the purpose of examining nations' laws and practices from the point of view of compulsory education, use w i l l be made of the International Union for Child Welfare suggestion: "The Child must receive a training which w i l l enable him, at the right time, to earn a l ive l ihood. The following, also suggested by the IUCW, w i l l be used as the standard for comparing adoption laws and practices: 15 "The Child must he protected within the framework of the family unit- and according to the requirements of socia l security. . . the orphan and waif must he shel-tered and succoured." For the comparison of laws and practices relat ive to care and protection of hanidcapped children, the following points w i l l come under consideration: 1. The chi ld must he given the means requisite for i t s normal development, both materially and s p i r i t -ual ly . 2. The chi ld must receive training which w i l l enable him at the right time to earn a l ivel ihood and must be protected against every form of exploitat ion. 3. Preventive as preferable or complementary to cura-t ive care. 4. Non-discrimination as to race, sex, p o l i t i c a l af-f i l i a t i o n , creed, etc. 5. The chi ld that i s physically or mentally handicap-ped must be helped. The present study attempts only a small section of the kinds of survery proposed by the secretariat of the Social Commission of the United Nations. Having i n mind their d i f -ferences of background, of present day law and practices, the nations of Denmark, Canada, the United States, Greece and I taly were selected.for study. As i t i s not possible to include a l l laws conceivably pertinent to chi ld welfare, those laws which could most easily be adapted to the study and which are indicative of the protection and care of ch i l d -14 ren have been selected. These laws and practices, reviewed in separate chapters are: ( l) compulsory education and child, labour; (2) those relating to -adoption;(3) handicapped and crippled children; (4) state grants for protection against economic need. In the treatment of the subject of state grants for the protection against economic need, although some mention w i l l be made of grants to a l l children regardless of their status of dependence, the chief concern w i l l be with grants to de-pendent children. It i s argued that dependent children are in greater need of protection than children whose parents are capable of providing for their economic needs, and that any organization engaged in setting up international stan-dards and regulations should give f i r s t consideration to the economic needs of dependent children. Some nations such as Canada and Italy have provided family grants for the purpose of helping to share the expen-se of rearing children. As a basic purpose these family grants have not been designed speci f ica l ly for the protection of children, therefore i t has not been regarded as necessary to give them importance in this study. It i s deemed impor-tant, however, that some nations have provided against econ-omic need by manifesting the states' obligation toward the chi ld whose security i s threatened through no fault of i t s own. It i s significant of the need for international help, that some nations are unable to meet the responsibi l i ty they profess, either because of inadequate l eg i s l a t ion , insuf-f ic ien t funds, or i n a b i l i t y to set up adequate administrations. It i s appropriate that international social workers should note these differences between nations, and to investigate them analy t ica l ly with an eye to international action aimed at adjustment. Adoption has been selected as one of the topics for study because this subject helps to indicate the degree to which nations assure the chi ld of a family unit as the most normal environment for his development. I t a lso helps to give some understanding of practices such as appertain to the subjects of custody, guardianship, rights of children and parents, and the status of i l legi t imate children. I t i s within the area of this subject that the history of the law, the influences of the customs of the country, and the traditions and the economic status of the nation play a part in the present day practices. Since World War I I , adoption has gained increased im-portance owing to a re la t ive ly large number or orphaned children which have suddenly been cast upon the already burdened and distressed world. The study of the two categories—child labour laws and compulsory education was combined because in most coun-tr ies these laws grew up together and i n most eases there i s a considerable amount of in ter re la t ion. There has been a trend i n some nations where laws pertaining to these sub-jects have been considered more progressive, toward the u -t i l i z a t i o n of soc ia l workers as a part of the working force dedicated to the task of protecting children against harm-f u l employment, exploitation, and educational handicaps. The treatment of handicapped and crippled children over many years has been ins t i tu t iona l i n character. There i s today s t i l l a great necessity for ins t i tu t iona l care and treatment. However, recent trends have been for out-patient and home treatment of some cases adaptable to these methods. It i s also a modern trend to make extensive use of socia l workers due to increased awareness of important socia l fac-tors involved i n the treatment of both problems. The extent to which nations have put to use socia l work resources and services as wel l as the extent to which sc ien t i f ic knowledge and standards of technical treatment have been applied i s again significant of the degree of need for outside help. CHAPTER "II NATIONAL DIFFERENCES IN ADMINISTRATION The United States Programs for the care and protection of children are •administered in a variety of ways, dependent upon the kind of agency involved. As this study i s primarily concerned with governmental provisions, the f i e l d may be narrowed to ^Federal, State, or county administration or a combination! of these 'three. U n t i l the inauguration of the Federal Social Security Act in 1935, Federal-provisions had been chiefly designed to extend counselling services to the States for their respective programs. An example of this type of service may be seen i n the functions of the United States Children's Bureau, ant agency unique among nations. The t rad i t ional issue of "States Rights" has created a situation in which caution has been used to avoid assump-tion by the Federal government of d i c t a to r i a l powers in any program which might be considered a State prerogative. This may be noted i n the provisions of the Social Security Act, which, under T i t l e IV has provided cooperative funds for use by States complying with certain Federal conditions for programs granting aid to dependent children. Similar pro-vis ion i s made in the Federal Act under T i t l e V for other chi ld welfare services. States complying with these Federal conditions admin-is ter programs of aid to dependent children and services to 17 crippled and physically handicapped children under the joint Federal-State plan. State agencies have i n some instances further delegated administrative responsibi l i t ies to count-ies i n what have become known as "county administered State programs". One of the conditions l a id down by the F'ederal law i s that a State must provide funds which are to be used jo in t ly with Federal funds i n carrying out the State plan. It i s within this framework that the United States adminis-ters programs for the Welfare of Children. It may be added here that programs for the regulation of chi ld labour, com-pulsory education and adoption are administered by State agencies or under State supervision. Canada Like the United States, Canadian programs for Child Welfare have been conditioned by t radi t ion and in Canada's case by the constitution of the federal government i n such a way that the administrative prerogatives have been l e f t chiefly to the provinces. Canadian administration of these programs have not experienced development at the National leve l to the extent that i s found in the United States. It i s to be expected, as a consequence that greater variations exist i n the legis la t ive provisions for the administration of these programs from province to province. A further dev-elopment in some provinces has been the f inancia l and admin-is t ra t ive cooperation between provincial government and mun-i c i p a l i t i e s . In Canada an administrative problem to be coped with which i s somewhat different than those of other countries under study, i s the extremely large areas of thinly populated land, largely undeveloped. This problem enters in a variety of ways into the administrative decisions and, in some cases, even the legis la t ive considerations as the reader can easi ly understand. The administration of programs providing grants for dependent children i s i n the hands of provincial governmental departments of welfare extablished for this and other purposes Programs for, adoption are, as a ru le , also administered un-der the same departments of welfare i n conjunction with the courts. Other provincial governmental agencies administer programs dealing with ch i ld labour, compulsory education and handicapped children. Services for crippled children, a l -though to some extent financed by government funds, are chiefly administered by private agencies and organizations of nat-ional character. Denmark The administration of Danish chi ld welfare i s in the hands of communal Child Welfare Committees which were estab-lished as a result of soc ia l l eg is la t ion of 1955. Due to the smallness of the country, county and communal adminis-tration i s made much easier than i n larger countries such as the United States and Canada. The efficiency with which National programs can be administered at communal l e v e l and yet be supervised and regulated at the federal l e v e l has had i t s effect i n the smooth operation of these programs today. 20 The communal Child Welfare Committees are responsible for placement of children for adoption, care of dependent children, supervision of such children as those who are crippled a^nd handicapped, and certain children who are in the process of adoption. These committees are composed of representatives of the commune, school teachers, clergymen, physicians and lawyers. (The la t ter usually act as chairmen.) A national supreme board i s responsible as an appeal board to act i n the f i n a l adjudication of disputes arising in the course of the work done at the communal l e v e l . The adminis-trat ion of programs regulating compulsory education i s nat-ional in character but delegated to the communes. The same i s true for the administration of programs regulating chi ld labour. Care and training of handicapped and crippled c h i l d -ren i s on a national basis of administration which makes pos-sible the efficient use of funds provided for these purposes. I ta ly The Opera Naxionale per l a Protezione de l la Maternita e d e l l Infanizie, (National Office of Maternal and Child Welfare"), a government agency of national scope, began to function i n 1926 and was s t i l l functioning at the close of 1948, but.with very limited- resources and modified respon-s i b i l i t i e s . The Office formulates pol ic ies and has had gen-eral direction of the services for mothers and children throughout'the country. The organization and functions of the National Office of Maternal and Child Welfare i s regulated by the law of 21 of 1925 and Its subsequent amendments. The National Office i s administered by a central coun-c i l of thirteen members. According to the law, four of these members are o f f i c i a l s in charge of specified government bu-reaus; four others are o f f i c i a l s in charge of specified gov-ernment bureaus; four others are appointed by. the Prime Min-i s t e r ; and the remaining f ive are selected by the Minister of the Interior among persons active i n welfare work, ped-i a t r i c s , otrstetrics, and public health. These las t f ive members are appointed for four years and can be reappointed. The.central council has a president selected from among i t s members by the Minister of the Interior for a term of four years; he can be reappointed. Two of the members of the council are appointed as vice-presidents. The central council includes an executive committee of five members a l l -appointed by the Minister of the Interior . The Office of Maternal and Child Welfare had general supervision of health and welfare services for needy mothers, for needy children under s ix years of age, and of welfare work .for children between six and fifteen years of age who were physically or mentally defective, "physically or mor-a l ly neglected, wayward, or delinquent". Among the specific functions assigned by law to the of-f ice were the following: 1. Establishment of various agencies and ins t i tu t ions 1 U.S. Children's Bureau Report, National Office of Mat- ernal and Child Welfare in Italy."May, 1943, pp. 1-12. Other sources used were, UNRRA, I ta ly : Welfare Services Welfare Divis ion, European Regional Office, TWE/E45/Studies 5, Edition No. 1, March, 1945, pp. 18-26. for mothers and children, supervision and coordin-ation of their work, and dis t r ibut ion of Government appropriations among them; 2. Taking measures for the prevention of tuberculosis and other diseases among children; and for promoting among the people a knowledge of hygiene through pre-natal c l i n i c s , courses on chi ld care in public schools, and popular lectures on the hygiene of mothers and children, and; 3 . Enforcement of laws for the protection of mothers and children. The pract ica l work of the Office was done by i t s a f f i l -iates in the provinces and communes. Although the I ta l ian system of administration at the present time i s severely handicapped by lack of funds and disorganization due to the aftermath of the war, i t i s said to have functioned successfully before the war. This method of administration on a national basis i s noteworthy in that i t makes use of several.privately sponsored' agencies, each interested i n special parts of the whole f i e l d of welfare. I t i s unfortunate that i t i s not functioning at i t s best at the present time as i t i s fel t , that much could be learned from such a system as th i s . Greece At the present time Greece i s engaged in a c i v i l war. This situation has been a continuous one almost since the end of World War I I , beginning with the attempt by the so-called le f t wing to take over the government i n the la t ter part of 1944. The beginning episode i s referred to by Greeks as "The" Trouble". Since that time, and with an increasing tempo of h o s t i l i t i e s , certain parts of Greece have been set apart as "Insecure Areas". Within these areas i t has been almost impossible to set up or to maintain a normal govern-mental organization le t alone a system of public welfare. Very shortly after "The Trouble",.however, UNRRA began to function in f u l l force. Previously to th i s , and even be-fore enemy forces had completely evacuated the country, Mi l i ta ry Liason and UNRRA cooperated to bring emergency sup-plies to those parts of Greece where transport allowed d i s -t r ibut ion. Plans had been wel l l a i d i n advance of the be-ginning of f u l l scale operations so that by the beginning of 1945, the Welfare Division of UNRRA had already begun to work with a very unstable government in strengthening the ministry of Welfare and i n creating modern legis la t ion to the end that a Public Welfare organization v/as not only in existence but operating with a great deal of vigor and ef-ficiency befae UNRRA withdrew early in 1947. (Compared with th is , the ,UNRRA welfare program in Italy did l i t t l e to build up the organization which had existed, but- concentrated upon supplying r e l i e f through what remained of i t . ) The organization for public welfare i s , in structure, so highly decentralized a program that f i e l d operations ex-plain i t best. The country i s divided into regions, Nomi, communes and parishes. Applicants make their requests for public assistance of one sort or another to parish committees 24 composed usually of the parish pr iest , a business man who i s a leader in the community, a pepresentative .of the associa-t ion of labour unions, a lawyer, and_if possible a medical doctor. In case, as happens in many small ru ra l v i l l ages , there may be no person on the parish committee who i s l i t -erate, the services of a school teacher or a school chi ld are drafted. Sometimes this person would be"a member of the and sometimes he or she i s used as the secretary and merely does the writing according to the wishes and directions of the chariman and the members of the committee. Records of applications, of public assistance granted, and the anticipated need and other information are maintained by the Parish committees made periodically and as demanded, to the Welfare Center of the Nomos. Welare Centers, being an intregal part of the government under the administrative jur i sd ic t ion of the Nomarch(govern-mental head of the N omos), are Nomi administrative headquar-ters for the welfare program. They are responsible for : (a) a l l matters of welfare within the Nomos and.have administrative responsibi l i ty for the action and succes of the parish committees; (b) a degree of influence over private and other govern-ment sponsored welfare agencies; (c) receivSHg reports of the Parish Committees, advising and assisting in a supervisory capacity; (d) teeiaagopoints of integration between the Ministry -and workers i n the f i e l d who are members of the Parish committees. The Regional F ie ld Representative of the Ministry of Welfare carries information from the Ministry of Welfare to the Welfare Centers; interprets the meaning and intent of new leg is la t ion ; assists i n maintaining standards in the a.p-'pl icat ion of the law. The Minis t ry 's responsibi l i ty as a part of the National government i s very broad. Speci f ica l ly , i t i s empowered with the formulation of new leg i s la t ion ; suggests modification of existing legis la t ion as needed;; administers established welfare programs; and organizes and administers new programs of soc ia l welfare as these are adopted or created by the National Government. Administration -and supervision of the t o t a l welfare program i s carried out through direct contact with the Welfare Centers, through indirect contact by the use of Regional Representatives, and through the Ministry of Coordination which i s responsible for Nomos government and therefore direct ly responsible for the work of the Nomarchs. CHAPTER I I I PROTECTION OF CHILDREN BY CHILD LABOUR AND COMPULSORY SCHOOL ATTENDANCE LEGISLATION Compulsory education and chi ld labour leg i s la t ion have histories which are closely entwined. Concern for the pro-tection of children from hazardous employment and from ex-ploi ta t ion has developed along with the desire to give them a training i n their early years which would make them more useful cit izens of their country. Taking children out of employment and putting them into school has had a revolu-tionary effect upon the school programs. The larger num-ber of children demanding education gave impetus to the dev-elopment of public school systems. I t i s the purpose of this chapter to show the extent to which each of the five nations under study have (a) pro-vided rules for compulsory education, (b) kept children out of employment which i s hazardous to their health and normal development, (c) enforced these rules, and (d) provided f a c i l i t i e s by means of which enforcement i s made effective. DENMARK Compulsory Education The public elementary school was founded i n 1739, when a compulsory school-age from the sixth year to the age of confirmation of the chi ld was constituted for the f i r s t time. In the year 1814, however, the most important event in the development of the public elementary school took place by 26 the issuing of Frederick VI statutes, according to which e l -ementary schools were to "be established i n a l l towns and ru ra l d i s t r i c t s . These statutes, for more than a century, became the foundation of popular education i n Denmark. The next event of importance was the passing of the National Ed-ucation Act of 1937. The b i l l was brought into parliament i n January 1934 by the Minister of Education, but was not passed u n t i l i t had been discussed during four sessions. Organization and System According to the act of 1937, which i s s t i l l i n effect (today, compulsory instruction begins at the age of seven and ceases at fourteen. Provisions are made, however, for a v o l -untary extension of school age possible beyond the l i m i t of fourteen. N The elementary school has two main types: one for towns -and another for ru ra l d i s t r i c t s . The public elementary school i s the responsibi l i ty of the l oca l authority. The municipal council i n towns and the parish council in rura l d i s t r i c t s must provide the buildings and their equipment,, aided by a grant from the state with regard to premises and equipment. They must also pay the greater part of the teachers' salaries, the state paying the remainder. For a long period, the public elementary school has been an ins t i tu t ion of high quality as regards both buildings and staff. Instruction alone, not school-attendance i s compul-sory in Denmark, Parents may choose to send their children to private schools, or they may teach their own children at home. Yet about 90 per cent of the children between se^en and.fourteen years of age frequent the public.elementary school. The children come from a l l social strata. Thus, education i s given on a markedly democratic basis . Child Labour Protection Danish "Worker's Protection Legislation" recognizes the necessity of setting up various requirements for the protection of children and young persons under eighteen. Powers are given to the authorities for prohibiting the employment of young people at work of a par t icular ly dangerous, strenuous, or unhealthy character, and i t i s l a i d down that during rest intervals and meal-times these young people must not be occupied or stay i n any room be-longing to the factory or workshop where work i s going on; there i s also a provision that the employer must keep a register of a l l people under eighteen who are employed at the establishment. Consideration for "the young, however, i s expressed part icular ly i n an act of A p r i l 1925 on the work of c h i l d -ren and young persons. Only children of over fourteen who have lawfully le f t school may normally be employed in Industr ial establishments. Exceptions are made for those engaged in agriculture, (including gardening), forestry, shipping and f isher ies . The act also contains a prohib-i t i o n , of somewhat different wording for the various trade against night work, as well as provisions governing work-ing hours and their arrangement, the effect being that the 29 hours must not exceed those normal for the trade. Young persons under eighteen must have -a to ta l of twenty-four hours free in the week, and when individuals of this age group are employed in factories or bakeries, they must be medically ex-amined within four weeks in order that the employer may be sure that their physical development or state of health i s such that i t is N no obstacle to the performance of the work 1 for which they are engaged. I t i s the wri ter ' s understand-ing from information from socia l workers in Denmark that these laws are s t r i c t l y enforced and the there i s close ad-herence i n practice to both the le t te r and principle of the law. THE UNITED STATES Public Schools Free public schools were established i n the United States in the early decades of the nineteenth century. Com-pulsory education legis la t ion came l a t e r . Public authori-t ies found i t d i f f i c u l t at f i r s t to supply the f a c i l i t i e s for those who wanted to go to school without concerning them-selves about those who did not want to attend. The feeling soon grew that i n a democracy a l l the ci t izenry should be ed-ucated i n order to participate in te l l igen t ly i n the affairs of government. This was evidenced in many States by the or-igination of State funds to be distributed to schools for 1 W.E. Calvert, Transl . , Social Denmark. Socialt Tidsskr i f t , Copenhagen, Denmark, 1945. 30 aiding them i n providing adequate educational opportunities. With the growth of the State's interest in education to the point that i t invested money to support the efforts of l o c a l schools there arose the -questions as to how such funds were to be distributed and how the State might real ize i t s aim for an educated ci t izenry by bringing a l l children into school. The later question was answered in two ways. F"irst by enacting laws compelling children of certain ages to at-tend school. Secondly, by placing legal prohibitions upon the employment of children of specified ages. The school census grew out of the need for some basis upon which to plan school f a c i l i t i e s . At f i r s t this census was simply an instrument requiring loca l authorities to l i s t children of certain ages within the d i s t r i c t ' s ju r i sd ic t ion . Later, more detailed and accurate information was found to be needed before State funds could be ef f ic ient ly d i s t r i -buted and before school f a c i l i t i e s could be properly plan-ned. Today the school census in' many States i s the most im-portant instrument for determining;. (1) the to t a l population for whom education opportunities are to be provided, taking into consideration not only the present but the future;. (S) provisions for educational f a c i l i t i e s in accordance with the shifts i n population; (3) fa i lures of individuals to comply with the requirements relat ing to education;. (4) the number of individuals whose handicaps make them subject to special provisions; and (5) the apportionment of certain State funds 1 Maris M. Proff i t and David Segel, School Census. Com-pulsory Education. Child Labour. States .Laws ana iiictucation Bu l l i t en 1945, N o i l , Federal Security, U.S.Office of Education. 31 a^mong the schools of the State. Compulsory Education Laws on compulsory attendance are found in. a l l States. The ages at which pupils must attend and the number of days necessary to attend ea,ch year differ by States ^ Enforcement of compulsory attendance laws varies greatly by States, due partly to differing interests in education and partly i n d i f -ferences in the laws and regulations governing enforcement. Exemptions from attendance are universal. The States do not as yet accept the f u l l responsibi l i ty of seeing that a l l children go to school at a certain age. Exemptions at certain ages, for example, due to the need for working, are found in pract ical ly a l l States. However, i t may also be said, that ^after the differences have been pointed out, laws and regul-ations concerning compulsory school attendance show a definite common pattern. The ages most common for compulsory attend-ance are seven to sixteen (twenty-four States). The other pr inc ipal variations in compulsory attendance age range are eight to sixteen (in nine States), and eight to eighteen (in three States). For ages fourteen to sixteen or fourteen to eighteen there are, eacept for four States, regulations 1 covering both school attendance <and employment. Exemptions from compulsory attendance apart from the need for employment are most commonly based on (a) physical and mental d i s a b i l i t y , 1 Attendance officers are generally provided for by State department, by County boards of education, by County Superin-tendents of schools, or by school d i s t r i c t s i n conjunction with other educational organizations or for certain schools such as c i ty schools and d i s t r i c t s where there are a large number of children of school age. 32 (b) distance from school, and (c) attendance at private school and private instruction. Enforcement There i s pract ical ly no uniformity in the qualifications set up by legislatures for attendance off icers . Most States either do not have any specified qual i f ica t ions , such as i s the case i n th i r ty States, or i t i s le f t to the State dep-artment of education to set up the qualif ications as in s ix States. Laws i n the other States present various methods for qualifying attendance off icers , for example: C e r t i f i -cation by State and county boards of education, Cal i fornia ; A discreet person of good moral character, Idaho; Of good attainment, versed in the principles and methods of educa-t ion , familiar with public-school work, and competent to v i s i t schools, I l l i n o i s ; etc. Attendance officers by law and by defini t ion have had to do with the enforcement of the attendance laws. This en-forcement usually carries police power, that i s , the power to pick up children, prepare cases for court, and to pros-ecute cases i n court. Sometimes the prosecution i s l e f t for the county attorney or some other o f f i c i a l . Attendance officers are also frequently given the power of entering factories or other places of employment to see i f children working have employment cer t i f ica tes . Because of the growth in understanding of the causes of truancy, attendance officers i n some States have become school and home adjustment counselors or workers. That i s , 33 attendance officers in some States and places have the duty to investigate the causes of absence of individual truants -and attempt remedial action. This duty i s a part of the to ta l pupi l adjustment work of a school system.. Many school systems have created new positions for doing home and school adjustment work which may or may not cover the legal phases of school attendance work. The duties of such positions always include, however, the cooperation with persons having legal authority in the compulsory school attendance area. Regulation of Child Labour Provisions governing chi ld labour had their beginnings i n the United States i n the l imi t ing of the number of hours per day children of specified ages could work i n certain oc-cupations, especially i n factories . Statutory measures came into existence which not only restr icted the employment of children, but also required that they should have achieved certain educational status before they could be employed. At f i r s t the enforcement machinery was inadequate as to com^ pleteness and specif ic i ty of provisions. Old laws were con-stantly changed or were replaced by new laws due to increas-ing public awareness of chi ld welfare. In the course of time legal provisions have become quite definite i n the des-ignation and the creation of f a c i l i t i e s and personnel for en-forcement, more res t r ic t ive -as to hours of labour, more ex-panded as to prohibited employment, more specific as to auth-orized and required cooperation of education and labour of-f i c i a l s for the enforcement of lega l prescriptions, more mandatory as to inspection of places of employment for as-,34 certaining v io la t ions , and more precise as to o f f i c i a l exam-inations to determine physical fitness for employment. Systems of Control As the age for compulsory education has moved up and the enforcement of attendance laws has become f a i r l y general, the relat ion of schooling to chi ld labour has assumed consid-erable importance. A chi ld has to be either i n school or at permissable work. Much effort i s sometimes necessary to bring the chi ld Into adjustment with either one or these en-vironments. Education departments have the prime responsibi l i ty to see that pupils are either in school or at work, whereas Labour or Welfare departments have the responsibi l i ty to see that the conditions of work are suitable for youth. There i s however, considerable overlapping i n these responsibi l-i t i e s . Idaho and South Carolina are the only States in which there are no reporting procedures to determine whether youth should be i n school or a t work. No employment cert i f icates are issued i n these States. In most States the employment cert i f icates are issued by c i ty or county superintendents of schools or other school personnel designated by them or by the loca l boards of education. In a few of these States other o f f i c i a l s may also issue employment cer t i f ica tes . For. example, employment cert if icates may be issued i n Washington by superior court judges. In seven States, various State o f f i c i a l s or l oca l labour representatives are the issuing off icers . In Connecticut the State department of education issues the cer t i f ica tes . In North Carolina, Wisconsin, and Wyoming, the l o c a l labour board representatives Issue work permits. The law i n these States does not rule out the poss ib i l i t y that school o f f i c i a l s may be appointed as the Labour Department representatives. In Mississippi the employment cer t i f icate i s simply an a f f i -davit as to the age of the chi ld and his school status signed and sworn to by the parent and the superintendent of schools.' Employment cert if icates are . in general of four different types. One type i s that furnished children who desire to work before or after school and on Saturdays. These permits are often restricted to the so-called "street trades." A second type of employment cer t i f icate i s the vacation work permit which allows children of school age to work during the summer while school i s not in session. A third type—the most com-mon—is one which gives the ch i ld permission to work during regular school hours. In some States the chi ld may s t i l l have to attend school for a specified number of hours per week. The ' fourth type i s an age cer t i f icate which the ch i ld , who has attained an age at which he does not need <an employ-ment cer t i f ica te , uses to show employers when he i s seeking a job. Evidence of age i n forty-three States, and of education i n twenty-nine of the States are among the items most often required for the issuance of employment cert i f icates to pupils A- somewhat smaller number of States require evidence of phy-s i c a l fitness for work(twenty-five States) and a direct offer of employment (twenty Stated. The personal appearance of the 36 parent or guardian i s necessary i n eight States. Enforcement The enforcement of child-labour laws insofar as they pertain to hours of labour, conditions of labour, and types of work i s generally in the hand os the Labour or Welfare department of the State. The schools usually cooperate with the Labour department i n checking on the violat ions of the compulsory school law through the employment of children. Legislation usually directs the attendance officers to make complaints and prosecute cases where the compulsory school law i s concerned. Violations of the labour laws not concern-ed with v io la t ion of the compulsory school law are invariably a responsibi l i ty of the Labour or Welfare departments of the States. Both school representatives and labour department representatives usually have the power to inspect factories, offices, and other places where children might be employed and to examine the employment r o l l s . ITALY Compulsory Education " A law of 1859 made popular education compulsory in I ta ly . However, the nation, at the beginning of the present century had a high rate of i l l i t e r a c y among the great nations of Western Europe. The statute book contains many laws on the subject of education during the f i f t y years of I ta l ian government during the Parliamentary regime of United I t a ly . But not a l l were 37 obeyed or carried into operation by the l oca l authori t ies , who were exceedingly reluctant to spend the l oca l funds upon education, the value of which they did not appreciate. As 1 a result , large numbers of children fa i led to attend school. A compulsory school attendance lav/, s t i l l in effect, was published in the Gazetta Uff ic ia le ( o f f i c i a l Gazette), on December 31, 1923 which provided for compulsory school at-tendance between the ages of six and fourteen years. This lav; made the parents, or guardians, and employers respon-sible for the ch i ld ' s school attendance. Parents who de-sired to teach their children outside of public school were required to prove that they were able to do so. In such cases the children were given examinations at the age of fourteen to assure that the teaching had been sufficient to meet the public school instruction standards. Under the 1923 lav;, bl ind and deaf mute children were also required to attend-school: the la t ter u n t i l they reach-ed the age of sixteen years. Special schools were to be es-tablished for both of these groups. Enforcement The mayor of each community was required to prepare a yearly l i s t of children of school age and post i t i n a l l public places one month before the beginning of the. school year. After opening of the school the l i s t was to be com-pared with the school r o i l s . A fine was to be prescribed 1 Harold Goad and Michele Gatalano, Education in I ta ly , published i n Rome, 1939, p.9. 38 for parents or guardians f a i l i n g to make satisfactory ar-rangements for their children's education. Truancy was also punishable by f ine . Child labour Legislation i n Italy The law of 1934, which i s s t i l l i n effect, applies to women and children workers in indus t r ia l and other occupa-t ions. Exemptions are made for those i n domestic service, agriculture, and indus t r ia l home work those employed in government establishments (for whom other provisions are made), and relatives (of a "specified degree) of the emloyer, i f they l i v e i n his home. The minimum age for employment i s fourteen years. A minimum age of 16 years i s prescribed for employment i n harmful, dangerous, or hazardous work; for example, work underground in f ines 'and quarries, and l i f t i n g heavy weights. Employment in the making of motion pictures, i n public theat-• r i c a l performances, or street-trades i s also forbidden for children under sixteen. A minimum age of eighteen i s pre-scribed for employment i n the r e t a i l sale of alcoholic drinks. However, children may be employed at the age of twelve, provided i t i s considered that the work i s not l i k e l y to affect adversely their health or morals, and provided they have a cer t i f icate of physical fitness and have finished the f i f t h grade, or the lower grade i t i s i s the highest i n the l o c a l school. Boys under 15 and g i r l s under twenty-one may not be employed without a cer t i f icate of physical f i tness . If a 39 young person i s not f i t for -a l l the kinds of work allowed by-law, the cer t i f icate must state the work at which the young person may not be employed. Such cert if icates are issued by physicians in public service. Work-books are required for boys under fifteen and g i r l s under twenty-one. The cer t i f icate of physical fitness must be reproduced i n the work-book. Night work (10 p.m. to 5 a.m.) i s prohibited for boys under eighteen and women a l l ages employed in indus t r ia l establishments and those connected with them. The lav/ pro-vides that this prohibition may be extended by a royal decree (now void) to other kinds of employment. Boys over sixteen may be employed i n such industries as manufacture of iron and steel , reduction of gold ore, glass works', and paper and sugar m i l l s . Work i s also permitted i n case of a serious emergency due to natural forces. Daily hours were set i n 1937 at 40 hours per week for workers irrespective of age, i n indus t r ia l occupations. Rest periods are provided by the law of 1934, after s ix hours of work, for children under f i f teen. Rules are given for the' cleanliness and safety of the places of work. Employers are required to provide periodic physical examinations for boys under f if teen and g i r l s under twenty-one employed i n establishments to be specified by subsequent regulations. The examinations, which are free of,charge to the workers, are to be made "^ y physicians i n the employers' service. The purpose i s to find out whether the worker i s physically f i t to do his work. A re-examin-40 ation i s to be make by -a physician appointed by the inspect-ion -authorities. If a worker i s found unfit to do his work his employment must he discontinued. Penalties are prescribed for violat ions of this law. A law of 1940 authorized the Minister of Corporations, during the period of the war, to grant to his specified sub-ordinates, the power to exempt employers entirely or partly from compliance with the provisions of those sections of the 1954 law which relate to the prohibition of night work of children. The exemption does not apply to children under sixteen. The same law provided for the suspension of the Satur-day half holiday and the 40-hour week. The clause of the law of 1954 on the employment of women and children which permits temporarily a ten-hour day for children under 15, and which prescribes a rest period for children under fif teen and g i r l s and women of -any age after six hours of work, may be suspended entirely or par t ly . The minimum age for em-ployment remained unchanged. CANADA Child Labour Regulations In 1873 Nova Scotia prohibited the employment of boys under ten i n or about mines-and l imited those under thirteen to ten hours i n a day or sixty hours in a week. Four years later B r i t i s h Columbia fixed the"inaaatiinum age for boys below ground at twelve and the maximum weekly hours for those under fif teen at t h i r ty . Other provinces one by one established 41 minimum ages for work above and below ground and limited the hours for young workers i n mines. In 1879 a factory B i l l was presented to Parliament proposing ten years as the minimum age for workers in fact-ories . This B i l l would have required factory children under thirteen to attend school part-time. I t also would have l i m -ited the hours of young persons. This and several la ter B i l l s of similar character fa i led enactment by Parliament owing to the conclusion of that body that the dominion had no power to enact factory l eg i s l a t ion . In 1884 Ontario passed an act establishing the minimum age of twelve for boys and fourteen for g i r l s and res t r ic t ing the hours of boys under fourteen and of g i r l s to ten a day and sixty a week. Under certain circumstances, however, the factory inspector was empowered to permit these classes up to twelve and a half hours i n a day and seventy-two and a half in a week on not more than th i r ty - s ix days in a years. Certain general provisions were included which were designed to ensure health and safety. This law was taken from the English factory law of the time. Quebec passed a. similar law in 1885. In Ontario i n 1888, the working hours of g i r l s under sixteen and boys under fourteen in shops were restr icted to twelve hours in a day, fourteen on Saturday, and seventy-four i n a week. This standard was raised s l igh t ly by Nova Scotia in 1895 making the weekly l i m i t seventy-two hours. In 1900 B r i t i s h Columbia further improved on this standard by pro-- h ib i t ing employment of children under sixteen for more than eleven hours i n a day, thirteen on Saturday and s ix ty-s ix 42 1 and a half hours i n a week. Amendments to these acts, and new leg is la t ion in a l l other provinces have brought Canada to the point, where to-day a l l provinces have fixed by law the minimum age at -which a chi ld may be employed. The minimum age for employment, except i n agriculture, where no l imi ta t ion has been estab-l ished, varies according to vprovince and type of work, from fourteen to fifteen years, except in certain hazardous oc-2 cupations. Recent legis la t ion (1946) in Saskatchewan raised the minimum age for factory work to sixteen years, but a revised chi ld welfare Act lowered the age from sixteen to thirteen under which employment i s forbidden between ten p.m. and six p.m. In the same year New Brunswick added such establish-ments as dry cleaners, laundries, hotels, restaurants, shops, places of amusement and office buildings as applicable under the factories Act. The minimum age for a l l these establish-ments i s fourteen years, unless permission i s obtained from the Minister of Labour. Compulsory Education A l l provinces of Canada possess leg is la t ion requiring compulsory -school attendance. Children are required to at-tend school u n t i l the age of fourteen in Nova Scotia, New 1 Adapted from Legislation Branch Department of Labour of Canada, Labour Legislation i n Canada. August 1945, Ottawa, pp. 13-15 2 Adapted from United Nations, Dept. of Social Affa i r s , Annual Report on Child and Youth Welfare, based on information received from member governments between 1 A p r i l , 1947 and 31 March, 1948, pp. 64-65. 45 Brunswick, .Quebec, and Manitoba. For the province of Ontario the age has been set a t sixteen and for a l l other provinces the age under which children must attend school has been es-tablished as f i f teen. School attendance laws have effected employment i n mines and factories but children can be employed about shops, • places of •amusement and other work places before and after school hours i f there i s no definite prohibition of such work by provincial l eg i s l a t ion . Except for Nova Scotia, where the 1946 amendment voided the exemption clause, a l l provinces permitted poverty as a legal cause for exemption for attendance at school, i f the specific ground for ex-emption i s the need for the ch i ld ' s services, or for his earnings. The exemption requires, however, the sat isfact-ory completion of certain school work. Other exemptions -are made for school attendance such as in Prince Edward Island where attendance in rura l d i s t r i c t s i s required for only 75 per cent of the term. In four provinces children under the minimum school-leaving age may be exempt for not more than six weeks i n -a term. (There are usually three terms in a school year.) In two provinces-a similar exemp-tion applies only for s ix weeks i n a year. B r i t i s h Columbia makes no provision for exemption on the basis of poverty but provides that i t i s a defence to prove that the chi ld was prevented from -attending school by -any "unavoidable cause". There i s no information that this has been construed to include the poverty of the family. 44 F a c i l i t i e s for Education A shortage of teachers i s prevalent i n most provinces of Canada. The fact that comparatively few pupils are without a l l educational f a c i l i t i e s and few schools remain closed for lack, of teachers i s due to the transportation of pupi l to neighbouring schools and use of correspondence courses. Teach-er supply has been a serious problem for some time and w i l l 1 probably continue as such for the next few years at least . The need for new school buildings of the new "function-a l " type i s acute. Recent plans of a national educational association include features for the adaption and proper use of such educational aids and devices -as radio, te levis ion , and motion pictures in the school curriculum. There i s l i t t l e doubt that recent leg is la t ion such as the Family Allowances Act of Canada, improvements in Mothers Allowances Acts? and Social Assistance laws have favourably influenced school attendance. Enforcement School attendance laws i n a l l provinces provide for the enforcement of the regulations related to compulsory attend-ance. Truancy and absences from school are investigated by specially appointed attendance off icers , or persons acting as such. These officers are generally employed by the mun-i c i p a l i t i e s . I t i s the usual case, however, that a provin-1 Teacher Supply, Canada Year Book. 1947, pp. 278-281 45 c i a l officer i s appointed to coordinate reports and ac t iv i t i e s of the loca l off icers . GREECE Child Labour Regulations The most recent legis la t ion protecting children in this 1 area was enacted in 1912. The law prohibits the employment of children "who have not completed their twelfth year of age" either as workers or as apprentices in the following occupations: (a) indust r ia l and handicraft factories and workshops; (b) quarries, mines and other mineral excavation work; (c) building construction and other similar open a i r work; (d) enterprises dealing with transportation by land or water; (e) commercial shops of a l l kinds including restaurants, and confectioneries; (f) hotels. Exception i s made for children over ten years of age who are employed by their own parents or guardians and where the only other employees are members of the ch i ld ' s immediate family. This exception does not -apply where the work may be c lass i f ied as dangerous or harmful. The laws describe harm-1 Law DKO delating to the employment of minors and women, published in the Government Gazette 46 on the 7th day of February, 1912. 46 f u l and dangerous employment as work "disproportionately-heavy as compared with their strength or dangerous to their health, or their moral or physical^integrity". This danger-ous or harmful employment, the law states "may be prohibi t -ed" by royal decree issued upon the proposal of the Minister of National Economy- and after consultation of the High Labour Council. Children between the ages of ten and twelve years of age working for their parents or guardians, may. not be employed more than three hours daily and this employment must not i n -terfere with their school attendance. Orphanages and other philanthropic establishments pro-viding vocational training to their wards may not occupy them in such training for more than three hours da i ly . The lav/ provides that five years after i t s publication i t s provisions were to have been extended to include c h i l d -ren over twelve but under fourteen years of age who had not 1 completed their primary education. Working hours are l imited to six hours daily for c h i l d -ren less than fourteen years of age. For young persons under eighteen years of age, ten hours per day was set as the maximum, except for Saturdays and the eves of holidays when working time was l imited to 8 hours. Rest periods were 1 The.school system in Greece, known as the "Old Bavarian Plan", includes Primary School for children between the ages of six and ten, Middle School between ten and thirteen, Gym-nasium between fourteen and eighteen, and University after eighteen years of age. The system has been c r i t i c i z e d as re-quiring too many hours for instruction and reci tat ion and as being complicated and out of date. Ref: Florence Wilson, Near East Educational Survey. European Center of the Carnegie ^uaowment, Hogarth Press, 1927. 47 provided for, and under most circumstances Sunday was set aside as a holiday. Children under eighteen years of -age were not permit-ted to work i n factories, construction work, or shops between 9 p.m. and 5 a.m. During the same hours children under four-teen were prohibited employment in restaurants, coffee-shops wine-shops, confectionaries and hotels. I t i s significant from the point of practice that this law prohibited children under fourteen years of age from en-gaging i n the sale of goods of any kind in the streets, squares or public areas. In practice today children of a l l ages may be found either sel l ing or aiding in the se l l ing of goods i n a l l the places mentioned in the. law. Control A system of work-cards was provided for by the law of 1912 wherein persons under sixteen years of age were required to present to employers work-cards showing physical capabil-i t y . Public health doctors were required to issue these cer-t i f ica tes free of charge and to cert ify that the chi ld was healthy, had been vaccinated and was able to carry on in the particular job he was applying for without injury to health or physical growth. This card was inserted i n -a "Labour-Book", which algo contained the ch i ld ' s b i r th date, address, natations regarding dates of employment and the signature of the Mayor of the community. Employers were prohibited by law from hi r ing -any chi ld not holding a Labour-Book and work-card. He was also required to subpit to the police authority a l i s t 48 of a l l employees, noting those who had submitted Labour-Books as evidence of e l i g i b i l i t y for employment. With this l i s t of employees, the employer submitted a;.statement of the work conditions in his establishment. Enforcement It was the duty of the police authority to check the l i s t of employees against the stated conditions of work, as wel l as against the Mayor's l i s t of names of those for whom he had signed work-books. In this way i t was possible- to discover violat ions of the law. Transgressions of this law were pro-secuted by direct summons, or upon assignation of labour i n -spectors, labour supervisors, police services, or any trade union. Fines were imposed upon those found gu i l ty of v i o l a -t ion of the law, and i f a repeti t ion of the v io la t ion was discovered within a year the fine was doubled. Imprisonment from three weeks to three months was meted out to those v i o -lators unable to pay the f ine . Compulsory School Attendance Existing regulations require attendance of children at school for a period of s ix years starting at the age of sev-en. The administration of the law i s the responsibi l i ty of the Ministry of Education. Due to the present d i f f i c u l t c i r -cumstances i n Greece, the enforcement of this law i s so lax., that i t i s effective only i n l imited areas. Preoccupation with more alarming problems related to children of•school age has decreased the interest and attention of harrassed off ic ia ls , who otherwise would have more time to "spend upon the improve-49 ment of outmoded school attendance regulations. Because of this preoccupation and the fact that the law i s somewhat ob-scure with age and lack of use, i t has been exceedingly d i f -f i c u l t to obtain detailed information relat ive to i t s content. Educational F a c i l i t i e s ; Other Problems If modern compulsory school attendance laws were now put into effect in Greece, that nation would find i t s e l f hard-put to carry out the intent of the law. Due to the great destruc-t ion of the war and the subsequent loss of f inancia l resources with which maintenance and reconstruction might have gone ahead, the present condition of schools i s discouraging. A number of schools were destroyed, others have fa l len into ru in . School furnishings mostly suffered the same fate. As an ex-ample i t may be pointed out that of 722 schools i n Epirus, the northwestern region of Greece, 198 were burned down and 1 182 were destroyed and in need of wholesale repairs. Greece i s , at present, primarily concerned with the health condition of the children of school age. It i s also greatly concerned with the effects of the war on"their physical, men-t a l and moral condition. At the same time, i t i s faced with the very serious problem of ways and means (part icularly the la t ter) of doing something about these conditions. . . In a report by the School Health Board of the Ministry of National Education to the United Nations Department of 1 United Nations, Department of Social Af fa i r s , Annual  Report on Child and Youth"Welfare. Based on information re-ceived from Member Governments between 1 A p r i l , 1947 and 31 March, 1948, Lake Success, New York, 1948, p. 126. 50 Social Affa i r s , the overwhelming problem of health was pointed out i n the following terms: "As i t has not been possible to undertake systematic medical examinations of the 1,800/300 school children either during the occupation or after the l ibera t ion , the present health condition of children of school age cannot be s t a t i s t i c a l l y determinded. The increased morbidity, the greater prevalence of tuberculosis, par t icular ly in ufcban centres, and of malaria in rura l areas, as wel l as the fEequency of malnutrition, are, however, matters of common observation. Among the ailments affecting Greek schoolchildren, malnutrition, tuberculosis and malaria are viewed with the most concern, as they are seriously undermining the health of large numbers of schoolchildren; trachoma, scabies and nervous disorders, however, also take a leading place." The writer can verify this alarming situation in Greece from personal observation while in Greece i n the employment of UNRRA. This international organization did a great deal to a l leviate the widespread conditions of malnutrition among children by distr ibuting foodstuffs to children i n schools, nurseries, camps, and any place where they were, being cared for , including their own homes. Programs of public health, p o l i c l i n i c s , medical a id , dis t r ibut ion of vitamins in var-ious forms, e tc . , were a l l an important part of UNRRA's wel-fare program. 51 The Ministry of National Education reports further that, due to the lack of f inancia l resources, no leg is la t ive meas-ures for the protection of children of school age have been enacted since the l iberat ion and up to 1947. I t must also!be recalled that since 1944, Greece has been disturbed by c i v i l war. This state of affairs has had no l i t t l e effect upon (protection of) children i n the ru r a l areas di rec t ly i n f l u -enced by the occupation by rebel forces. Indeed, both d i r -ectly and ind i rec t ly , i t has had a very serious effect upon the circumstances of most of the children of Greece i n a l l areas. One of the reasons for the lack of f inancia l means to improve and to enforce protective legislation.such as chi ld labour and compulsory education laws has been the d iv-ersion of a great part of what was available into mi l i tary channels, (directed toward putting down the revolution). In one of the vi l lages i n the Pindus mountains, at that time.a so-called ^insecure area", one half (112) of the pop-ulat ion of the v i l l age were children. None of these children could attend school because no school teacher could be induced to come to the v i l l a g e . The only instruction these children obtained was given by their parents, who were 98 per cent i l -l i terate , and the v i l l age pr iest , also i l l i t e r a t e . Out of the 112 children, 63 were quite apparently suffering from enlarged spleens due to malaria. A l l of the children showed definite evidence of malnutrition. The nurse, who was with the exped-i t i o n , discovered five eases of scabies and two cases of t r a -choma upon a very cursory examination. The to t a l wealth o f the people of this v i l l age . was accounted for in two oxen 52 (then being used i n repayment of a v i l l age debt), 1000 strem-1 ma of land, (inaccessible to the owners for the past two and a half years by reason of the c i v i l war), three sheep per family, five chickens per family and one pig for every five famil ies . At the time of the v i s i t , the only available foods were quinces, walnuts, almonds, a few eggs, -and a small a-mount of maize. Roads into the area were blocked by the rebels and no government supplies could be brought into i t . On the other hand, the inhabitants could not obtain supplies by carrying them in themselves because they had ho money to pay for supplies and could not obtain credit from the govern-ment which suspected the v i l l age to be "Communist", accord-to the story of i t s residents. This was typ ica l of numerous v i l lages throughout Greece where the rebels were known to be located. It i s not surprising then that reports such as the following excerpt from the United Nations annual report previously quoted: "Even before the war i t was calculated that about twenty per cent of Greek schoolchildren suffered from malnu-t r i t i o n . Today the proportion i s estimated to be at least f i f t y per cent. I t i s illuminating that an i n -vestigation carried out in 1946 among the schoolchildren of Piraeus (the port c i ty of Athens) showed that 15-year-old schoolboys, for instance, were almost 10 cm (ap-proximately 4 inches) shorter than the indigenous school boys examined before the war, and 15 cm. shorter than 1 13.2 pounds, one kilogram being 2.2 pounds. 55 "schoolchildren in Central Europe; for school g i r l s of the same age the figures were almost 6 cm. and 12 cm. respectively. Also, the weight of the 15-year-old hoys was 6 kilograms (15.2 pounds, one kilogram "being 2.2 pounds) less than that of the pupils examined before the war and 13 kilogrammes below that of Central Europ-ean children; for g i r l s the la t ter figure was 10 k i l o -grammes." The practice of chi ld labor i s nearly everywhere appar-ent to the casual observer i n Greece; Children who'have be-come "professional beggars" are unavoidable on the streets of the c i t i e s . Children handle t rave l le r ' s baggage in push carts along with the men at disembarkation points. Child workers who normally should be expected to be in school are to be found at a l l hours of the day and night i n restaurants, boot-black stands, taverns, the variety of shops on the streets and other places. "Of course, i t i s not to be over-looked that some of these children are working as apprentices and that their work i s considered as a part of their instruc-t ion . For example, one usually finds one or more youths working with a fishing crew, and ta i lo rs usually have boys learning the trade in their places of business. Even the problem of clothing the needy children of Greece i s placed i n -a secondary position of importance by the govern-ment authorities, who say in their report to the United Nations: "Large numbers of small schoolchildren go about unshod and clothed only i n rags. It i s superfluous to ins i s t on the urgent need of assistance in providing the children with, clothes and shoes." COMPARISON AMONG THE NATIONS A l l f ive nations have enacted compulsory education laws as wel l as legis la t ion prohibiting children from engaging i n certain kinds of employment and prohibiting children of cer-tain ages to engage i n employment. These laws, in effect, have been prescriptions for the protection of children i n two ways: f i r s t , to turn the chi ld away from employment and toward school where he might secure the knowledge which would help to mold him into a better, more productive, more useful c i t i zen ; secondly, the chi ld would be protected from harmful employment. Due to the f i r s t method of protecting the ch i ld , i t was inevitable and necessary that laws on compulsory ed-ucation and laws on chi ld labour become integrated. This i n -tegration may be clearly seen in the history of the develop-ment of these laws in the United States. I t i s less clear, but no less pronounced in Canada. Denmark's laws appear to have been developed separately but with a gearing of the two in such a way that when a chi ld i s seen out of school i t may be assumed that that chi ld i s lawfully employed or over the age of those required to attend school. In I taly and Greece the integration of these laws i s more obscure. In fact , insofar as effect in practice i s concerned, both countries might be said to lack laws protecting the chi ld from harmful employment and from i l l i t e r a c y almost ent i re ly . * —t Although the lay/ pertaining to chi ld labour i n I ta ly i s exp l i c i t enough, i t i s so encumbered with exceptions which 55 are questionable in their protective effect, and the machin-ery for enforcement i s so dependent upon the smooth working of other divisions of public administration, that the result i s almost to t a l ineffectiveness today. Both laws, compulsory school attendance and chi ld labour, are badly i n need of mod-ernization in these nations. The d i f f i cu l t i e s of Greece leaves l i t t l e doubt that national leg is la t ive provisions are urgently required for the protection of children in this area of need. It i s 'also clear that the enactment of leg is la t ion alone w i l l not be enough. Desperate need for help in providing the means to apply the rules thus established i s apparent beyond question and should not be confused with p o l i t i c a l issues by those who would render such help. In tBrms of the effect of compulsory school attendance laws upon the protection of children by keeping them out of hazardous employment, or of the benefits of education alone, a glance at the percentages of i l l i t e r a c y for the f ive count-r i e s w i l l be enlightening. Unfortunately the exact figures are not available for a l l countries and those figures which are available are not recent ones. For example, the 1930 census for the United States gave the figure 4.3 per cent i l l i t e r a c y of persons over ten years of age; for Canada, the 1930 figure was 5.7 per centj Denmark was certainly below 10 per cent and Greece was unreported. It was estimated how-ever, that the rate of i l l i t e r a c y i n Greece would come to nearly 50 per cent of those ten years old and over. The per-56 centage of i l l i t e r a c y for I taly was reported to be between UO percent and 30 per cent. Although a comparison between Denmark and the two American countries cannot be made from the above figures, i t seems safe to assume that Denmark's rate would be quite low and might be actually lower than either Canada or the United States. S t i l l another point which i s le f t for assumption i s the effect recent leg is la t ion has had upon the percentage of i l l i t e r a c y . Prom the continuous downward trend in the United States, and due to the opportunity for instruction during the war, as well as the recent emphasis upon adult education and "Americanization" programs, i t i s f e l t that the trend w i l l have continued downward. The same thing may be said for Canada. There has been no marked relaxation of the enforcement of the rules for education i n Denmark, except perhaps to some minor degree during the World War I I . I t i s not to be expected that an increase of - i l l i t e r acy has occur-red i n the last nineteen years i n that country. This i s not so for either I taly or Greece. Both countries are faced with severe problems resulting from the war. The l ax i ty i n the control of the existing leg is la t ive pronouncements may certainly be said to be part ly, i f not to a large extent, due to the preoccupation of the governments of these two count-r ies with" problems gravely concerning the national economy, rebuilding, and rehabi l i ta t ion of industry, etc. Greek and I ta l ian people are struggling bravely to solve these problems which are .so numerous and almost so over-whelming that i t i s d i f f i c u l t to determine which are the 57 most serious or most important. It seems significant to note the exemptions made for certain children i n the chi ld labour laws of the various countries. In Canada, exemptions are made for children in •agricultural work. In the United States there -are no true overal l exemptions. A sl ight lowering of the standards i s done in some States during the school vacation period, part-i cu la r ly for agr icul tural work. A careful control i s exerted over the number of hours of work carried by children who work during the school period and who are of a proper age for em-ployment as stipulated by the statutes. Danish rules exempt children in employment i n agriculture, forestry, shipping and f i sh ing . I taly exempts domestic service, agriculture, home industry, those employed by the government, those employed by relat ives of-a specified degree. The minimum age for employ-ment i n Italy i s fourteen years, except for harmful or danger-ous work. The minimum -age i s raised to sixteen i n such cases. Another two years i s added to the minimum where the ch i ld i s employed in the r e t a i l sale of alcoholic drinks. However, the age l imi ta t ion drops to twelve for a l l children who -are employ-ed i n any Occupation which i s considered not l i k e l y to -affect their health and morals adversely. I ta ly also allows for ex-emptions by the provision of work-certificates to those who are physically f i t and have finished the f i f t h grade or any lower grade provided i t i s the highest in the loca l school. With this l ax i ty one can readily understand the reason for the appearance of so many chi ld workers i n almost any occupa-58 t ion i n I t a ly . .„ There also seems to be either a lack of w i l l -ingness or an incapabil i ty to enforce the laws such as those preventing employment i n the making of motion pictures, in public theat r ica l performances, or i n street trades. The tourist i n Italy nearly always carries away with him mental pictures of children performing i n the street or se l l ing cigarettes and many other commodities at every corner. In v i s i t i n g Cine C i t a , the f i l m center of I ta ly , the writer en-countered at least twenty children engaged in the making of a f i lm then i n production. In Greece there i s no effort at concealing the fact that children are engaged in a l l kinds of employment regardless of the harm or the fact that the chi ld i s not i n school. At least such children may be earning something with which to buy a peice of bread, without which they would be unable either to work or to attend school. I t i s noteworthy that Denmark makes instruction rather than school attendance compulsory, thus placing the onus of responsibi l i ty upon the community as a whole rather than up-on the chi ld for his school attendance. The I ta l ian law places the responsibi l i ty for educating the ch i ld upon the parent. In the United States and Canada leg is la t ion insofar as the compulsory attendance laws are concerned places the f i r s t responsibi l i ty upon the c h i l d . Practice and recent trends tend to include the parents. Other laws concerned with rights and duties of parents and children place the responsibi l i ty to educate the ch i ld with the parent, whether that parent be the natural or the adoptive parent. In Greece the responsibi l i ty according to law and practice i s placed upon the parents. However, this law i s not effectively en-forced except by t rad i t ion . CHAPTER 17 PROTECTION OF CHILDREN THROUGH ADOPTION Most countries have long recognized the family unit; as basic to society and that this unit i s the most suitable en-vironment for satisfactory development and protection of most children. It i s preferable that children remain within the families to which they naturally belong. Many laws have been enacted in an effort to preserve this s i tuat ion. When this i s not possible, an environment closely simulating the the ch i ld ' s natural family unit i s sought for him. Thus, laws pertaining to the custody of children and adoption have been enacted. These laws protect the chi ld in two ways; f i r s t , by the lega l establishment of the rights and obliga-tions of natural parents, guardians, and adopting parents toward their natural children, wards, or adopted children respectively; secondly, providing a way by which children lacking homes and families may have some compensating or equivalent advantages. THE UNITED STATES. The Federal Social Security Act of the United States provides for Federal Government part icipation in aiding the several States in the promotion of chi ld welfare ser-vices . These services include the finding of adoption homes, and the sc ient i f ic placement of adoptable children 60 61 with suitable adopting parents. The legal adoption by one person of-the offspring of another was unknown to common law even in England u n t i l the enactment of an adoption statute i n 1926. Since i t was un-known to the common law, adoption exists in the United States only by virtue of statute. Such laws, some of which have been on the statute books for nearly one hundred years, vary widely i n the different States. Massachusetts, whose j u r i s -prudence i s based on the common law, f i r s t enacted statutes relat ing to adoption in 1851. The provision of adequate safe-guards through legal measures in the various States has, un-t i l the past ten years, l e f t much to be desired. During this decade, some improvements have been made in forty out of the forty-eight States. Most States require that adoption sha l l be by j u d i c i a l proceedings in -a court of competent ju r i sd ic -t ion . A few States provide for adoption by deed or declara-2 t ion . Who May Adopt In thirty-eight State.s, socia l investigation and a re-1 "For the purpose of enabling the United States, through the Administrator, to cooperate with State Public Welfare a -gencies in establishing, extending, and strengthening, espec-i a l l y in predominantly ru ra l areas, publie-weIfare services . . . for the protection and care of homeless, dependent and neg-lected children, and children in danger of becoming de l in -quent, there i s hereby authorized to be appropriated for each f i s c a l year, beginning with the f i s c a l $ t e a r ending June 30, 1936, the sum of | 3 ,500 ,000 . . . » Compilation of the Social Security Laws, T i t l e V, Part I I I , Sec. 521, p. 40. 2 An authoritative review of adoption in the United States i s given in the Social Work Year Book published by the Russell Sage Foundation, and this source i s the basis for the above summary. 62 port to the court i s required after the pet i t ion for adop-tion i s f i l e d . Twenty of these States designate the State Department of Public Welfare as the authority to make or arrange for the investigationj i n fourteen States the court i s to make or arrange for the investigation; in four States an investigation i s discretionary with the court. In the majority of the States, the protection of the chi ld being adopted i s thus assured against the hazards of indiscriminate adoption practices. Adoptive parents may be selected or Rejected by the court according to their sui ta-b i l i t y as parents for the particular adoptable children. Most States, through their statutes, require a certain minimum standard which i s l a i d down in terms of moral back-ground, f inanc ia l ab i l i ty , probable future income, and age difference between prospective parent and chi ld to be adopted. The degree of su i t ab i l i t y of the adoptive parent may then be established and ruled upon by the court i n each case where, •a pet i t ion for adoption has been f i l e d . In making i t s dec-is ions , the court i s able to use the help of experts who can provide objective information on a sc ien t i f ic basis, re la t ive to the su i t ab i l i t y of the chi ld for adoption, of the adopter's su i t ab i l i t y as a parent, and of the home as a satisfactory environment for the c h i l d . Requirement of Consents Unless the rights of the natural parents of the ch i ld have been terminated by court order, the State laws generally require that they give their consent to the adoption. This 63 they do either through formal relinquishment to an agency or by direct consent to the adopting parties. Some State laws permit adoption without the consent of -a parent i f he or she: (a) i s insane or otherwise incapacitated for giving consent; (b) i s imprisoned; (c) has wi l fu l l y deserted and neglected to provide proper care and maintenance of the ch i ld , or; (d) for other specified reasons. If the parents of a ch i ld have been divorce, this does not, as" a rule , do away with the necessity for securing the consent of both parents. When -a ch i ld has no parent or guardian legal ly capable of consenting to adoption, in f ive States consent must be given by the State Welfare department; the laws of four States do not require i t , but provide that consent may be given by the State Welfare department; -and one State pro-vides that the State Welfare department or an agency appoint-ed as "next friend" may' give consent. Probationary Period Required Thirty-two States and the Di s t r i c t of Columbia now re-quire a probationary period of placement i n an adoptive home before a chi ld may be adopted. This period varies from three months to a year, but the most frequently required period i s s ix months. In Indiana the period i s d iscret ion-ary with the court. Supervision during the period of pro-bation i s required i n a number of other States, and some provide "for good cause" as being sufficient reason for the probationary period to be waived or reduced by the court. 64 Legal Effects of Adoption As -a result of the establishment of a new lega l re la t ion-ship between parent and c h i l d , the ch i ld usually takes the name of the adoptive parents; the adoptive parents are en-t i t l e d to the ch i ld ' s custody and to his "services and earn-ings" during his minority. The ch i ld , i n turn, i s ent i t led to support, care, and education from the adoptive parents; and the chi ld and adoptive parents may inheri t each from the other. A few States expressly provide that adoption sha l l not prevent a chi ld from inherit ing from his natural re la t ives . However, i t i s the general rule that natural parents do not inheri t from a chi ld who has been adopted by another,' DENMARK Adoption has long been recognized in Denmark. Its legal provision dates from 1683 when the law permitted adoption to "persons having no descendants i n direct l ine having obtained permission from the King". Adopted persons, i n this way, acquired the right to "Inherit the property of the adopter and the right to take his name, yet reserved a l l his rights in his o r ig ina l family. The law was obviously designed for the preservation of t i t l e s . A law of 1895 made i t necessary for the person being adopted to give his consent i f he were more than eighteen years of age and gave him the lega l status of a legitimate c h i l d . In 1923, as a result of the findings of a commission entrusted with the drafting of uniform leg is la t ion in the 65 Scandinavian countries, a law on adoption came into effect. This law i s today the regulator of a l l adoption practice i n Denmark. Who May Adopt In Denmark a person adopting -a chi ld must be at least twenty-five years of age. Joint adoption i s permitted only i n the case of a married couple but i t i s permissable for only one partner of a marriage to adopt a chi ld i f the other i s feehle-minded, insane or has disappeared. One of the marital partners may, with the consent of the other, adopt the other's natural or adopted c h i l d . The father of a ch i ld horn out of wedlock may adopt his ch i ld , but the mother of an i l legi t imate chi ld may not adopt her c h i l d . I f the adop-ter has children or other descendants permission may be given to adopt only for important reasons. Who May be Adopted, Consent Required A person may not be adopted by two people at the same time unless the two persons are marital partners. I f the adopted i s under twenty-one years of age, the consent of his parents, or, i f they are dead, of his guardian must be given, and his consent i s required i f he i s over fourteen years of age. If the adopted i s married, the consent of his or her marital partner i s required. If one of the parents has died, has disappeared, i s insane, feebleminded, or has no parental authority, the consent of the other i s suff icient . The. adop-tion of a legal ly disabled person i s permissible only 66 with his guardian's consent. I t i s fundamental that a l l adoptions are to be made with the welfare of the adopted chi ld as the most important factor for consideration. Only i n exceptional cases are adoptions permitted i f the adopted chi ld has not spent a reasonable probationary period i n the home of the adopter, or i f he i s not going to l i v e there after the adoption. Before granting permission to adopt, i t must be ascertained whether one of the parties has paid, or w i l l pay, for the privilege of adopt-ing the c h i l d . If this i s the case, the amount of the compen-sation must be made known. An aff idavi t from a l l parties con-cerned may be required. I f the adopter was to receive pay-ment, permission to adopt may be given on the condition that the compensation w i l l be used entirely or partly for the ben-ef i t of the adopted person. Legal Effects of Adoption The chi ld being adopted takes the surname of his adopting parent unless there are special reasons against i t , or i f i t has been stipulated i n the authorization that he reserves his own name or takes both names together. Legal authority of the parent over his chi ld i s transferred to the adopter. The adopted has the same rights of inheritance from the adopter as i f he were a chi ld born in wedlock. However, on request, i t may be stated in the authorization that no res t r i c t ion be placed on the adopter's rights to w i l l his property. If the adopter leaves a natural hei r , the adopted person's share i n the inheritance may be taken only from the disposable part 67 of the inheritance. If an adopted person leaves no family or marital partner enti t led to inher i t , i t i s the adopter who inher i t s . However, these provisions of the law do not r es t r i c t the right of the adopted chi ld to dispose of his property by w i l l . A person adopting -a chi ld horn out of wedlock acquires the lega l status of the mother i n regard to support, which must be paid by the father of the c h i l d . Except i n such a case, the adopter cannot demand payment from the natural parents for the expenses caused by the ch i ld . Parental authority and guardianship by the ch i ld ' s nat-u ra l parents are abolished by the adoption. The -adoption does not create a lega l family t i e between adopting parent and the family and the marital partner of the adopted c h i l d . In the same way, no lega l t ies are created among the adopted children by the process of adoption. Unless otherwise provided by law the rights and duties existing" between the adopted chi ld and his- natural family continue. Revocation of Adoption Adoption may be revoked by agreement between the parties to i t ; as wel l as a result of a serious misdeed committed by one party towards the other or by his near relatives;, or, i f one of the parties i s shown to lead a l i f e of vice or crime. Adoption may also be revoked as -a result of marriage-between the two parties. In such a case the adoption may be consid-ered as annulled. Should the two parties agree to revocation, the decision 68 i s announced either by the Ministry of Just ice, or by the court. Court proceedings may be started by an interested -party, by the adopted ch i ld ' s guardian, his adoptive parents, or by a public authority. The court must ask the opinion of a l l those persons who were consulted before the adoption, before revocation proceedings are completed. A l l the lega l effests of adoption cease to exist after i t s recovation. The adopted loses the adopter's name unless special permission i s given by the Ministry of Justice or by the court. Adoption by a married couple may be,revoked only jo in t ly 1 by them. Supervision of Adopted Children The" Communal Child Welfare Committee may, when required for the welfare of the c h i l d , ins t i tu te supervision of a -dopted children, i f the adoptive parents have received or receive payment for the adoption, including a f f i l i a t i o n maintenance payments by the putative father of an i l l e g i t -imate c h i l d . GREECE The f i r s t modern lav; making direct mention of adoption -and requiring the recording of cases of adoption on the reg-i s te r of v i t a l s ta t i s t ics was enacted in Greece in 1856. Long before th i s , however, the practice of adoption had been 1 The above material was obtained largely from a trans-la t ion , of [^Marc Ancel, L'Adoption dans les legis la t ions mod-ernes. L ib ra i r i e du Recueil Sirey, Paris , 1943, p. 2 1 2 . O b -tained through the courtesy of the U.S. Children's Bureau, Washington, D.C. 69 known i n this country., A law of 1920 regulated the rights of inheritance of the adopter &s we l l as the adopted. Detailed leg is la t ion on adoption i s given in the C i v i l Code enacted i n Greece in 1940 and effective since June 1, 1941. Who-May Adopt Adoption i s permitted, only to a person who has no chi ld born in wedlock, Is more than f i f t y years of age, and i s "legally competent". Parents, may adopt their chi ld born out of wedlock. No person may adopt a second person during the lifetime of the f i r s t . However, i f i t i s the wish of the adopting parent to adopt brothers or s is ters , or more than one chi ld at one time, he may do so by including a l l of the names in the or ig ina l adoptive pe t i t ion . A guardian may adopt his ward only after he has presented his f i n a l account. The chi ld being adopted may not be adopted by another person during the l ifet ime of the adopter and as long as the adop-tion i s in effect. The exc,eption_to this rule i s the case wherein the adopter i s married and the spouse joins i n the adoption. Although the consent of only one marital partner i s necessary i f the other has been adjudged insane or un-available, i t i s the rule otherwise that the consent of both marital partners must be obtained. The adopter must be eigh-teen years older than the adopted. Adoption with reserva-tions or with subject to delay i s not permitted. Adoption takes place by court decision and the adopter must be pre-sent i n court to give his consent. 70 Yftio May be Adopted: Consents Required A married p>erson may not be adopted without the consent of his or her marital partner. The consent in such eases must be given by a notarized act or by a statement made in court during the adoption procedure. In a l l cases the adop-ted must give his consent personally i f he i s eighteen years old or older. If the chi ld being adopted i s under eighteen years of age, the consent of parents, present in court, i s necessary and the consent of one of the parents i s sufficient i f the other i s unable to manifest his w i l l because of mental incompetence or for^any other cause. I f the adopted person has no parents i t i s necessary that the consent be given i n court by the guardian or property administrator, authorized by the family counsel. The adoption.is .announced by the court, which also i n -vestigates whether the requirements of the law have been f u l -f i l l e d , and whether the adopter's character and f inanc ia l status are such as to make adoption an advantage to the adop-ted. Legal Effects .of Adoption From the time of adoption the adopted person acquires the status of the adopter's legitimate c h i l d . The one adop-ted by a married couple i s considered as their common and legitimate c h i l d . The same rule applies i f one of the mar-i t a l partners adopts the chi ld of the other. The descend-ants of the adopted, born after adoption, have the status of legitimate descendants of the adopter. However, there i s no l i n k of relationship between the adopted and the par-ents of the adopter and vice versa. The adopted person assumes the name of the adopter but he has the r ight to add his own name to that of the l a t t e r . The rights and duties resulting from the realtionship be-tween the adopted person and his natural family remain un-changed, unless otherwise provided by law. From the- time of adoption the parental authority of the natural father or the guardianship over the adopted are replaced without fur-ther action by the parental authority of the adopter. I f , during the adopted person's minority, the adopter's paren-t a l authority or guardianship have ceased to exist for any reason whatsoever, this parental authority i s not returned to the natural parents; but the la t ter have i n such cases the right to care for the -adopted person. The duty to main tain the adopted chi ld f a l l s f i r s t of a l l on the adopter, in his absence, on the natural parents. Revocation of Adoption Adoption may' be revoked by court decision as a result of a request presented either by the adopter or by the adop ted, i f there i s a circumstance justifying disinheritance. Adoption may be revoked also i f , contrary to the law, mar-riage took place between the adopter and the adopted. Probationary period No probationary period i s required by Greek law and no supervision of adopted children i s provided for . The entire adoption procedure i s under- the jur i sd ic t ion of the 72 court-and there i s no provision for the Welfare Minis t ry 's organization to become an interested party to adoptions. ITALY Adoption as -a pEactice has been known for a long time i n I t a ly . The procedures used i n that country today are provided in the I ta l ian C i v i l Code, T i t l e VI I I , which he-came effective July 1, 1939. Who May Adopt Adoption may be effected by a person who has no legi t - , imate or legitimated descendants, i s over f i f t y years of -age, and i s at least eighteen years older than the person whom he intends to -adopt. When exceptional circumstances render i t expedient, the Court of Appeal may authorize -adoption i f the adopter i s a t least forty years of -age and i f the difference in age between the -adopter and the adop-ted person i s at least sixteen years. No one may adopt more than one person unless the c h i l d -ren in question are adopted under the same instrument. I taly thus provides for the adoption of brothers and sisters by one person, or by one set of parents, in order that these children might not be separated unnecessarily. A guardian may not adopt his ward unless he has render-ed account of his admini-strationy has handed over any pro-perty concerned, has discharged" any obligations he has i n -curred, or has given appropriate security for the discharge of his obligation as a guardian. 75 Who May be Adopted Children born out of wedlock may not be adopted by their parents. However," i f the adopted person's status as a ch i ld • born out of wedlock was not established by acknowledgement or by a j u d i c i a l declaration, the adoption may not be con-tested. No one may be adopted by more than one person, except i n the case where the two adopters are husband and wife. Consents Required The consent of the adopter and that of the person to be adopted i s necessary to complete adoption. I f the person to be adopted i s over twelve years of age, he must be per-sonnaly consulted, and i f he i s under twenty-one years of age, the consent of his legal representative i s also neces-sary. If the person to be adopted or the adopter has a spouse l i v i n g , the assent of the la t te r i s necessary-in every case. The assent of the parents of the person to be adopted i s a lso necessary. Date Adoption Becomes Effective . Adoption takes effect as from the date of the decree by which^it i s pronounced. So long as the decree has not been issued, both the adopter and the person to be adopted may withdraw their consent. -If the adopter dies after giving his consent and before the issue of the decree, the acts necessary for the adoption 74 may "be completed. The heirs of the adopter may submit to the court written statements and observations in opposi-t ion to the adoption. If the adoption i s allowed, i t takes effect as from the time of the death of the -adopter. This provision i s probably meant to avoid inheritance disputes. Legal Effects of Adoption The adopted person assumes the surname of the adopter and may add i t to his own surname. If he i s -a chi ld born out of wedlock and has not been acknowledged by his own par-ents, he assumes only the surname of the adopter. Acknowledg-ment subsequent to adoption does not make i t necessary for the adopted person to assume the surname of the parent who has acknowledged him, unless the adoption i s subsequently revoked. If adoption i s effected by both spouses, the adopted person assumes the surname of the husband. — If adoption i s effected by a married woman, the adop-ted person, i f he i s not the chi ld of the husband, assumes the surname of the woman's family. The adopted person retains a l l his rights and duties i n respect of his own or ig ina l family. The adopter JLS. bound to support the person adopted and to bring him up and provide him with an education in accord-ance with the law relat ive to the education of children. Adoption does not give r i se to any c i v i l relationship between the adopter and the family of the person adopted, nor between the person adopted and the relatives of the 75 adopter. Should a wife adopt the chi ld of her own husband, the r ight to the exercise of paternal power sha l l belong to the husband. In a l l other cases, paternal power over the person adopted belongs to the adopter. Should the adopted person possess property of his own, the right to the administration of i t , during the minority of the adopted person, belongs to the adopter, who i s not enti t led to the profits or benefits of the property. The income, however, may be applied by the adopter for the pur-pose of meeting the cost of support, upbrining, and educa-tion of the minor ch i ld , and the surplus income must be invested in a remunerative manner. Inventory Required The adopter must make an inventory of the property of the adopted person, i f the la t te r i s a minor, and transmit i t to the guardianship judge within one month of the date of the decree of adoption. An adopter who omits to make the inventory within the specified period or who makes an i n -accurate inventory may be deprived of the administration of the property by the guardianship judge, without prejudice to the obligation to make good any losses. Rights of Succession Adoption does not confer any right of succession to t i t l e on the adopter. The rights of the adopted person in respect of the succession of the adopter sha l l be determined 76 by the rules relat ing to succession. Revocation of Adoption Adoption may be revoked only in the following cases: 1. I f the adopted person has made an attempt on the l i f e of the adopter or of the l a t t e r » s spouse or his (or her) descendants or l i n e a l ascendants. 2 . If the adopted person has committed a.gainst those named above, any offence punishable with a mini-mum penalty involving loss of personal l iber ty for not less than three years. 3. If the adopter may be shown to be disqualif ied -as an adopter by non-conformance with the lega l require ments. 4 . I f the Public Prosecutor applies for revocation of the adoption on the grounds of immBsrality. The effects of the adoption cease when the judgment i n favour of revocation has acquired f i n a l effect. If , however, the revocation i s pronounced after the death of the adopter, on the ground of an act committed by the adopted person, the •adopted person and his descendants are excluded from the suc-cession of the adopter. Marriage between persons bound by the t ie of adoption terminates the effects of the adoption. Investigations The court (called the court of appeals), after procuring the necessary information and after hearing the parents of 1 Ti t les of nob i l i ty are s t i l l being, used in I t a ly . the person to he adopted, must ascertain: 1. Whether a l l the conditions prescribed by law have been f u l f i l l e d ; 2. whether the person who wishes to be the adopter i s of good reputation; 3. whether the adoption i s to the advantage of the person to be adopted. Publ ic i ty After the decree of the court has been pronounced in favour of the adoption or the revocation of the adoption and the subsequent, necessary registrations have been completed, the j u d i c i a l authority may furthermore order the publication of the decree pronouncing in favour of adoption, or of the judgment for the revocation, in whatever form i t may deem f i t t i n g . CANADA Canada, l i k e the United States, provides for legal adoption by the statutes of the individual provinces since adoption was unknown to common law. Adoption, as •% practice, has been known in Canada for some time. However, many re-visions of the provincial statutes have been made, part icu-l a r l y since 1900. The present statutes are culminations of modifications over the period of years which have been due to the need for control over new and changing situations during this time. 78 Who May Adopt Persons wishing to adopt a chi ld must f i l e a pet i t ion in an appropriate court. In most provinces, the husband and wife are required to apply jo in t ly for the adoption of a chi ld i f the petitioner i s a married person. Most provinces re-quire that the adopting person or persons be over twenty-one, or that they be adults. Quebec law stipulates "such consorts as may be l i v ing together". However, also in Quebec, a widow or widower over twenty-one years of age may apply for the adoption of a ch i ld , and an unmarried person may adopt a chi ld providing i t i s of the same sex. A l l provinces require that the adopting person be of the same re l ig ion (Catholic or Protestant) as the person being adopted. Ontario requires that the adopter as wel l as the adopted be residents within the province. Who May be Adopted In a l l provinces except Quebec, the judge may not grant a f i n a l adoption order u n t i l the Children's Aid Society or the provincial Child Welfare authority has reported on the s u i t a b l i l i t y of the home. In practice, the sui tabl i ty of the chi ld for adoption in most provinces must be cer t i f ied by a medical report. The report of the provincia l ch i ld welfare authority to the court handling the adoption makes known to the court what other factors may be considered in favour or against su i t ab i l i t y of the chi ld for adoption. In -Quebec, "La Loi d'Adoption" l imi t s those who are adoptable to orphans, homeless or i l legi t imate children, and those 79 whose.parents are insane. Consents Required Both parents, i f l i v i n g , must give their consent. The consent of the c h i l d , over a specified age, i s required i n seven provinces. The ages indicated range from ten to four-teen years. If one spouse petitions for adoption, the con-sent of the wife or the husband must be obtained. In one province, the Director of the Child Welfare d iv is ion must sign the pe t i t ion . Most provinces require the lega l guar-dian to give consent, and the ch i ld welfare authority must do so i f the chi ld i s the ward of the authority. Quebec law provides that the consent of the father or^the mother i s re-quired i f he or she i s the only l i v i n g parent. Quebec also provides that the consent of an ins t i tu t ion must be obtained i f the chi ld i s the ward of the ins t i tu t ion and i f the par-ents are not available. Probationary Period Adoption in a l l provinces i s usually preceded by a pro-bationary period, extending i n one province to two years, in the prospective adoption home. Legal Effects of Adoption A l l provinces include the regulation within their stat-utes, that the adopted chi ld has the same relationship to the adopters as i f he were their natural chi ld born in wedlock. Manitoba stipulates that i f the parents of an adopted chi ld marry after his adoption, this makes no difference to the status of the adopted c h i l d . A l l provinces, with the excep-t ion of New Brunswick have ruled that the adopted retains the right to inheri t from his own parents. Appeals A l l provinces provide for appeals. Some stipulate l i m -i ted periods of time from the date of adoption within which appeals may he made. For example, Nova Scotia provides for -appeals within one year from the date of the adoption order. Quebec makes provision for annulment i f this i s due to "grave causes". Administrative Authority Petitions for adoption are made to the appropriate courts The decision and f i n a l order of adoption i s carried out by these courts. However, the chi ld welfare authorities are re-quired i n a l l provinces to pbserve and report on the adoptive home and on the su i t ab i l i t y of the c h i l d . These reports are submitted to the court and i t i s the practice that the court gives great weight to them in making decisions for or against adoption. It may, therefore, be said that although the prime authority i s the court, functionally the-administration i s a joint one between the court and the chi ld welfare authority in the province. SUMMARY AND COMPARISONS In consideration of the adoption laws of the five nations the writer has been primarily concerned with the protection these laws provide for the ch i ld . Without adequate lega l pro-81 tection i n this phase of chi ld welfare work, the exploita-t ioh of children has come about. This may have been one of the reasons for,recent improvements in State and provincial statutes relat ive to the adoption of children. One can easily r e c a l l having read of scandalous "baby-selling" and "baby markets" in various parts of both countries within the past decade. Such practices, along with the infamous acts of blackmailing unmarried parents, or others involved, are v ic ious , and are highly detrimental to the welfare of the chi ld concerned. In Greece and I ta ly , due to the inadequacy of the law, i t i s doubtful that the practice of adoption lends i t s e l f to r ea l protection for the children being adopted. It seems doubtful, for example, that a chi ld would be in a better en-vironment in the home of an adopting parent who must be, as required by law, over the age of f i f t y , than he would be i f the adopting parent were more youthful. Furthermore, i t i s questionable whether the stipulations in their laws that the adopters sha l l be economically capable and morally f i t i n -the eyes of the court, are sufficient to assure the chi ld of capable and reasonably good parents. Neither country pro-vides probationary periods wherein the chi ld i s placed in the adopter's home under supervision and observation. In general, provisions of the laws of ganada, the United States and Denmark, where they are concerned with persons who may adopt, are s imilar . The same may be said In regard to rules about who may be adopted. The provisions for consent are also similar and provide suitable safeguards for the 82 chi ld as well as for his own and his adopting parents. While i t i s s ignif icant , and a r ea l safeguard that a l l f ive nations provide i n their laws and statutes that the welfare of the chi ld i s of f i r s t importance in the adoption procedure, i t i s also to he noted that the laws of Greece and Italy are part icularly concerned with transferrence of property and t i t l e s of nob i l i t y . A l l countries make provision i n their laws to control the use of money or property of value paid as compensation by ortm the adopting parents. Some States and some provin-ces of Canada prohibit this expressly. Denmark provides that the amount of any compensation must be made known and the use of i t i s thenceforth controlled by the administrative authority. The laws of a l l countries, except I ta ly , are similar with respect to the effects of -adoption. I ta l ian law differs in that the parents of the chi ld must resume -his support i f the adopting parent should discontinue support. The I ta l ian law -also provides, in respect to the legal effects, that the a-dopted person retains a l l his r ights and duties re la t ive to his o r ig ina l family, while other countries effect severance from previous family t ies by the act of adoption. It i s noteworthy from the point of view of practice that the situation in the f ive countries studied, differ vast ly in one respect. In Canada and the United States, -as wel l as in Denmark, the experience has been that there are more pros-pective adoptive homes than there are children to be adopted. In Greece and I ta ly , part icularly since the war, there are considerably more children in need of adoptive homes than there are homes avai lable. CHAPTER V THE PROTECTION AND CARE OF HANDICAPPED AND CRIPPLED CHILDREN From the standpoint of practice, the chi ld who suffers an impairment of hearing, speach, or sight to such an extent that he w i l l not be capable of receiving instruction i n the ordinary public schools i s termed a handicapped c h i l d . In some areas, the mentally subnormal chi ld has been added to this c lass i f i ca t ion , and governments have to one extent or another provided for the special training of these children i n order that they might better be able to f i t into society as independent individuals capable of earning their own l i v e -lihood without becoming a public l i a b i l i t y or charge. Although a crippled chi ld i s certainly a handicapped ch i ld , i t i s generally the practice in the various nations to treat his condition in a different way. Usually the crippled chi ld i s considered one who can benefit from the instruction given i n the ordinary schools and thus the treat-ment given him i s on the basis of medical treatment for his crippling condition. Some nations have taken over a portion of the responsibi l i ty for the treatment of crippled children from private agencies, clubs and other organizations which have pioneered programs both for the prevention and treatment of crippling conditions. Programs for both the handicapped and the crippled chi ld i n such European countries as I ta ly and Greece have been found 84 to be inadequate to meet the increased needs since the war. CANADA Crippled Children :.: Half a mi l l ion dollars annually i s provided by the Sar-t iona l government to ass is t the provinces with programs fee* the prevention and treatment of crippling conditions i n chi ld ren and for the rehabi l i ta t ion and training of crippled chi ld ren. In many respects, this i s the Canadian counterpart of the federal grant program administered by the Children's Bu-reau of the Federal Security Agency i n the United States. Before these grants were made available i n 1948, efforts in this f i e l d were carried on largely by voluntary -agencies, such as the Canadian Council for Crippled Children, the Jun-ior Red Cross and the service clubs of Canada, e .g. , the Shriners. The provinces have to some extent entered the f i e ld , usually on a very l imited basis because of the cost-liness of these services. The new program, which i s not yet in f u l l swing due to need for further planning and organiza-tion by the provinces, in no way relieves the voluntary agen-cies of their important ro le . Rather, i t i s intended to strengthen their resources on a broader front. With the federal funds available the provinces can develop an integrated program under which the resources of governmental and voluntary agencies can be united i n reducing the incidence of disabling i l lness in childhood, as well as in providing a training and rehabi l i ta t ion pro-cess for crippled children. Handicapped Children Where a substitute for the home i s required,.the trend has been away from ins t i tu t iona l care and increasingly to-ward placement i n supervised foster homes or in adoption homes. On the other hand, for the chi ld with mental or physical handicaps or personality problems, specialized i n -s t i tu t iona l care adapted to his individual needs i s consid-ered the more desirable form of treatment. In Canada the,care, treatment, and education of hand-icapped children has been carried out on the i n s t i t u t i ona l basis by the various provinces without federal part icipat ion or regulation. Each province has provided ins t i tu t ions for the training of deaf, deaf-mute, and bl ind children. The type of training given in these inst i tut ions i s geared to meet the needs of each chi ld i n such a manner that he w i l l be capable at a certain age of becoming employed at l imited occupations and to adjust, with his handicap, within society without becoming a public charge. Inst i tu t ional Care Two provinces, Prince Edward Island and New Brunswick, have no schools for the b l ind , deaf, or mentally defective. An arrangement i s made whereby these provinces use the fac-i l i t i e s of other provinces. In a l l other provinces i n s t i t u -tions specializing in the training of this c lass i f ica t ion 1 Joseph Wil lard , The Canadian Health Grant Program, Canadian Welfare. V o l . XXIV, No.5, October 15, 1948. 87 of children had an enrollment i n 1945 of a to ta l of 4,811. Of these, B r i t i s h Columbia had 101, Saskatchewan 141, Alberta 292, Nova Scotia 528, Manitoba 516, .Quebec 1,119, and Ontario 2,314. 1 In Canada, unlike the United States, programs for the crippled chi ld and for the handicapped chi ld are not t ied closely to public welfare agencies. In some provinces where -a general assistance program has been developed, -special provisions have been made for allowances over the maximum grants in cases needing special medical services such as might be the case with children having'certain crippling conditions. Of course, referrals to proper agencies are made when the need i s found for their services. In this way socia l workers act to some extent as a finding service for the agencies under other administrations than their own. THE UNITED STATES Crippled Children Crippled children have engaged the interest of govern-mental and voluntary agencies for many years. Before the enactment of the Federal Social Security Act in 1955, how-ever, re la t ive ly few States had developed a comprehensive program of services on a Statewide basis. During the past decade federal aid to the States for services to crippled children authorized under the provisions of a section of 2 the Act has made possible the development of -a nation-wide 1 Enrolment in Educational Inst i tut ions, by Provinces, School Year 1944-45, Canada Year Book. 1947, p. 285. 2 Social Security Act, T i t l e V, Part 2 . program of medical, surgical , and after-care services for the physical restoration and socia l adjustment of crippled children. Responsibility for administering this part of the Act i s vested i n the Children's Bureau of the Federal Security Agency. State programs are now i n operation in each of the forty-eight States. Since 1936, State and t e r r i t o r i a l agencies administer-ing services for crippled children have maintained registers l i s t i n g children under twenty-one years of age residing i n the State and for whom a diagnosis has been made by a l i c e n -sed physician as having a crippling condition as defined i n the State law or administrative ruling."*" Except for certain congenital defects, the causes of crippling or the physical handicaps that result are to some extent preventable. In the majority of instances proper treatment, promptly given, w i l l result in physical restor-2 ation or w i l l materially reduce the ch i ld ' s handicap. Agency Programs Various private agencies and fraternal organizations have done pioneer work i n the interest of crippled children i n the United States. The International Society for Crippled Children, founded i n 1931, has given leadership i n directing 1 These registers contained the names of 404,500 crippled children as of December 31, 1945. 2 Among the pr incipal causes of::crippling l i s t ed on State registers are infant i le paralysis, cerebral palsy, clubfoot, osteomyelitis, congenital malformations, r ickets , spinal cur-vatures, and tuberculosis of bones and joints . Types of crippling conditions among children for which l i t t l e or no provision for care has been made include d i s a b i l i t i e s a r i s -ing from impaired v is ion and hearing, rheumatic heart d i s -ease, diabetes, and epilepsy. 89 public attention to the needs of crippled children, i n spon-soring legis la t ion in their behalf, and'in urging appropri-ations from public funds for the extension of State services. In 1939 the-National Society for Crippled Children and Adults was f i r s t organized as successor i n this country to the i n -ternational organization. This national agency has stimulated the development of many voluntary State societies, which in turn have organized county committees that provide assistance and promote public understanding of the soc ia l , educational, and medical needs of physically handicapped children. Each year since 1934, nation-wide celebrations of the birthday of Franklin D. Roosevelt have been held to raise money for the fight against infant i le paralysis. Before 1938 the proceeds were used to support the Georgia Warm Springs Foundation. In 1938 the funds were transferred to the National Foundation for Infantile Paralysis, organized in that year for the express purpose of leading, direct ing, and unifying the fight on every phase of infant i le paralysis . This Foundation has stimulated the organization of l o c a l chap-ters covering most of the 2,050 counties. With the increasing interest i n the welfare of the chi ld with rheumatic fever and heart disease, the American Heart Association during 1944 took leadership in planning the form-ation of the American Council on Rheumatic Fever which func-tions as an integral part of the Association. The Council concerns i t s e l f with the promotion of special studies to i n -crease basie knowledge of the disease, professional aducation, and methods for increasing public awareness of the problem. 90 The recently created National Advisory. Council on Cer-ebral Palsy, a National Cerebral Palsy Fund, and the estab-lishment of a cerebral palsy d iv is ion i n the National Society Society for Crippled Children and Adults ' central headquar-ters office have a l l directed considerable effort toward extending and developing services for the cerebral palsied. Numerous other organizations such as the Elks , Shriners, Junior League, Rotary, Kiwanis, American Legion, and Lions carry on independent service programs i n behalf of crippled children. O f f i c i a l State agencies administering services for crippled.children include th i r ty departments of health, ten departments of public welfare, four departments of ed-ucation, five crippled children's commissions, and three State university medical schools or hospitals. There has been a trend toward transfer of administrative responsib-i l i t y to health agencies, showing an increasing recognition, as in Canada, that the program i s one primarily involving medical care. The State plans provide for the locating of crippled children and for sk i l l ed diagnostic services. In a l l States any chi ld i s e l ig ib le for admission to a diagnostic c l i n i c in order that his needs may be ascertained. Treatment ser-vices by qual i f ied special is ts , such as orthopedic surgeons and pediatricians, are provided, in approved c l i n i c s and hospitals, for children found to be i n need or care. Pro-visions are also made for convalescent care and other after-care services such as the furnishing of necessary -appliances 91 -and. for follow-up services by the attending special is t or other professional worker. 1 The plan in operation usually ca l l s for the services of the chi ld welfare worker and the public health nurse for the finding and reporting process; the diagnostician and the therapist for the next step; and the chi ld welfare worker and public health nurse again for the aftercare. Provisions for the Handicapped  The Deaf Residential schools for the deaf -are provided i n a l l States except Delaware, Nevada, New Hampshire, and Wyoming, which send their deaf children' to neighboring States to be educated. Twenty-five of the States also have public day schools for the deaf, supported either by the State or by l o c a l communities; but these are not evenly distr ibuted, the numbers per State ranging from one each in Oklahoma, Tennessee and West Vi rg in ia to 15 i n Ohio, 16 in Michigan, and 18 in Wisconsin. In January, 1946 'there were 17,674 deaf children being educated in 64 public res ident ia l schools, 113 public day schools, and 20 denominational and private schools. This number may be contrasted with 20,171 l i s t ed as attend-ing schools for the deaf in 1943. This decrease of over 12 per...cent in three years may be accounted for chiefly by the fact that the greatly increased employment opportunities offered the deaf during the war drew many young men and women from the schools. 1 Social Work Year Book. 1947, Russell Sage Foundation, Russel H. Kurtz, Editor, pp. 138-144. 93 Training for the Deaf The instruction provided in the different schools for the deaf differs with respect to age of admission, extent of academic instruction offered, amount and kind of vocation-a l training provided, and means of communication used. Speech i s taught in a l l the schools, but i t i s not consis-tently used as the vernacular, the pupils in many schools being allowed to use finger spelling and the sign lang-uage during a large part of the day. There i s a very old divis ion of opinion among educators of the deaf as to the importance of speech i n the curriculum. Some hold that, since the acquisition of spoken language and i t s corollary l i p reading, i s slow and d i f f i c u l t , and the speech of the deaf i s always more or less a r t i f i c i a l , i t i s not worth the time and effort i t requires. Others believe that speech, however imperfect, i s an important asset i n preparing deaf persons for l i f e i n the hearing world. It has been proved that a large percentage of deaf children have usable residual hearing; and i n some of the schools, notably the Pennsylvania School at Mt. Airy and the Lexington School in New. York Ci ty , from 40 per cent to 50 per cent of the pupils receive instruction through elec-t r i c a l amplifiers, thus being helped to develop their speak-ing vocabularies. ^ The age of admission to schools for the deaf i s gradu-a l ly being lowered. Some States, including I l l i n o i s and New York, accept children at three years of age and provide nur-sery t ra ining. Since this tends to accelerate the education process, the schools are being faced with the necessity of providing more advanced instruction for the older pupils . A few schools, such -as the Iowa, School and the Rochester School i n New York, have accredited high school departments. Most of the other schools, part icular ly in the c i t i e s , deaf pupils are graduated into regular high schools where they take their training along with the pupils of normal hearing. Many private c l in i c s and schools in the United States are experimenting on methods of educating the deaf. Some of these efforts have been rewarded with remarkable success. Noteable among these i s the John Tracy C l in i c which provides an experimental school to demonstrate that early instruction and home training w i l l largely bridge the educational gap between the deaf and the hearing. The correspondence course for parents of preschool deaf children provided by this c l i n -i c i s in great demand. More than 700 deaf babies and their parents, located in a l l parts of the United States, have been instructed by this course since i t was f i r s t d i s t r i -buted in 1945. The Blind Although the number of young bl ind persons i s re la t ive ly small in comparison with those of advanced years, this group was the f i r s t to attract attention i n this country. In 1784 a movement for better in s t i tu t iona l care with an education-a l objective had begun in Par is . Valentine Hauy, aroused by the derision directed at bl ind musicians in a cafe, founded -a school for the bl ind and developed an embossed type for 94 their instruction. Dr. John D. Fisher, a.young Boston phy-s ic ian , came in contact with this school while in France and resolved to develop a similar program for the bl ind in his own country. Enl is t ing a group of friends, he secured a charter from the Massachusetts Legislature in 1829 to found a school, which has since developed into the Perkins I n s t i -tution and Massachusetts School for the B l i n d . Similar p r i -vate schools for the bl ind were soon chartered i n New York and Philadelphia. From the pioneer work of these three schools, interest in the blind has extended u n t i l there are now 58 res ident ia l schools for the b l ind , most of which are state-maintained. The f i r s t State supported school was founded in Ohio i n 1837. Twenty-two c i t i e s now provide B r a i l l e classes i n their public schools. Enrollment in these schools and classes was 5,831 as of January, 1, 1946. Of this t o t a l , 559 were i n B r a i l l e classes. Training for Blind Children Pract ica l ly a l l of the res ident ia l schools begin at the kindergarten l eve l , although there has been a recent tendency in a few schools to accept pupils of preschool age. The ap-proved practice now i s to keep preschool children in their homes or i n foster homes with f i e l d supervision. Adequate educational opportunity i s provided i n a l l the res ident ia l schools through the grades and, in most of the schools, through high school. In a few schools pupils are sent to near-by high schools for instruction in the upper grades, the school for the blind providing residence, books, appliances, and tu-95 t o r i a l assistance. Opportunity i s provided for outstanding students to go to regular colleges, there being no special for the b l ind . Superior bl ind students may go on to pro-fessional schools. Blind students are able to carry on reg-ular college work but they need reading service for texts not available i n B r a i l l e . There has been -an increase i n the number of "talking books", and the use of recording dev-ices i s proving beneficial to some students. Sixteen States provide State fund? for the payment of readers. Under Public Law 113 many bl ind persons are -able to secure f inanc ia l a id through the rehabi l i ta t ion departments of the States. This service includes readers, guidance, counseling, t raining, and placement. Prosthetic devices may also be provided. The same provision i s made for World War I I veterans under Public Law 16. The Social Worker's Role In respect to these handicapped children and youth, many States place a responsibi l i ty for a portion of the f i e l d work, the v i s i t i n g and consulting and counselling with the handicapped i n their own homes, to be done by the soc ia l workers attached to the departments of public welfare. - DENMARK * Special regulations are provided i n Denmark for the category comprised of lunatics, feeble minded, epi lept ics , the crippled or deformed, the b l ind , and deaf-mutes. This group i s treated under the program designated as "Special Care. * 96 The Poor Law of 1891 provided certain exceptions to the general rule that a l l public r e l i e f was to be regarded as poor r e l i e f (which entailed certain consequences in respect to c i v i l r igh ts ) . Public funds for edudation, support and maintenance of the b l ind , deaf-mutes, imbeciles and lunatics-, were not to have the effect of poor r e l i e f , provided that the persons concerned were placed i n state inst i tut ions or in inst i tut ions that were state approved. In 1901 this regul-ation was widened to embrace epi lept ics , the crippled or de-formed, the mutilated, and tuberculous patients. In 1908 the exemption from the legal effects of poor-relief was extended to include a plan of boarding-out under the supervision of a state ins t i tu t ion or a state approved ins t i tu t ion . F i n a l l y i n 1914 public r e l i e f to the poor among the bl ind was placed in the same category. The Public Assistance Act of 1933 introduced a further: development of the regulations as to Special Care. A l l aid given to people under the heading of Special Care i s , by vir tue of this Act, regarded as Special Public Assistance and therefore entails no lega l effects for the recipient . The state has, moreover, undertaken the cost of i n s t i t u t ion -a l care for this category except i n the case of tuberculo-s i s , cancer and lupus patients. Within the principles of the Danish Special Care pro-gram, i t i s the duty of the state to take a lead i n develop-ments economically and otherwise. Great importance i s at-tached to a positive conception of this r e l i e f , whereby every endeavour i s made for people i n the public 's care not only 97 to be cured of their infirmity, where there i s such -a possib-i l i t y , but also to be trained and educated to enable them to occupy a place in the ordinary 2iife and work of the commun-i t y . Finding Procedure Everything i s done -as far as possible to contact a l l persons needing Special Care. This i s aimed at in one way, through reports, concerning both the destitute and the non-destitute. The Act charges the l o c a l Social Committee with the duty of: (a) reporting to inst i tut ions concerned a l l men-t a l l y defective children who are, to a marked degree, unable to benefit from the normal schooling; (b) - a l l children who are bl ind or whose v is ion i s so reduced that i t prevents their following the instruction at the ordinary infants ' school or at special schools for weak-sighted; and (c) a l l children who are deaf or whose sense of hearing i s so poor that they would be unable to follow the instruction at the ordinary infants school or at special schools for such sufferers. Furthermore, every physician who, i n the course of his prac-t i ce , observes instances of mental deficiency, blindness or deafness among children under sixteen must report them to the Social Committee. The same duty rests with principals of state and municipal schools and of private educational establishments. F ina l ly , under the Danish National Insurance Act a l l physicians are requested to report to the Inval idi ty Insurance Court any persons under the age of th i r ty with af f l ic t ions which they consider have caused, or in the near future w i l l cause considerable, long term reduction of their working capacity, This duty also devolves upon schools in respect to scholars of school age, and i t comprises every kind of disabling a f f l i c t i o n . These regulations as to n o t i -f ica t ion apply both to people who are destitute within the meaning of the Public Assistance Act and also to those who are not. I f a person i s destitute, the Social Committee, as soon as i t i s requested to look after a Special Care pa-t ient , or the Committee i t s e l f considers there i s reason to do so, must immediately see that a medical examination i s undertaken for the purpose of deciding whether i t would be improper not to allow the patient to have specia l . Ins t i tu t ional Care of Handicapped The form under which the positive work of Special Care proceeds i s voluntary i n pr inc ip le . Just as public assis-tance in general cannot be forced upon anybody, but presup-poses an application by people who are in need, so i t i s with Special Care. No person can be compelled to accept i t against his w i l l . Should i t happen that i t i s considered necessary to place a person under the Special Care author i -t ies for his own sake and i n the interests of the public, the only procedure, as a ru le , w i l l be, i f he refuses, to peti t ion the courts to declare him incapable of managing his own affairs. The Act of 1936 made i t the duty of parents of deaf or bl ind children to have them educated at the state deaf-and dumb inst i tut ions and bl ind ins t i tu t ions , where, under the 99 guidance of the state, they receive both education and t r a in -ing. As a rule the children l i ve at the ins t i tu t ions , so that the parents are compelled to send them from home. The Public Assistance Act also provides that the Child Welfare Committee w i l l decide on the removal of a chi ld under eigh-teen from his home i f , on account of physical or mental defects he needs special care which cannot be administered i n his home, and the parents or guardians themselves do not take steps to ensure that the chi ld i s placed under the nec-essary Special Care. Whereas the ordinary hospital system i s the affa i r of the towns and counties, the various insititutiions under the Special Care system are financed, as mentioned, by the state. The small size of the country, -as a result of which several branches of the Special Care system need only a very few inst i tut ions covering large parts of Denmark, makes i t nat-u r a l that this aspect of the medical service should be a state affair and not, as i s commonly the case in other count-r ies a local-government one. Care of Crippled"Children The ra t ional care of cripples i n the modern sense began i n 1872 i n Denmark, when the private ins t i tu t ion "Samfundet og Hjemmet for Vanfore" (The Society and Home for Cripples) was founded by the Rev. Hans Knudsen, who at that time l a i d down the principles according to which the modern care of the crippled i s practised a l l over the world under the name of "The Danish system". . The system ca l l s for everything being done f i r s t to treat the a f f l i c t i o n and i t s consequences. Thereafter—if necessary hand i n hand with continued remedial treatment—the cripple i s given such special education -and training as may be required to enable him to support himself and his dependents in the same manner as other people. . The care of the crippled and mutilated to this day i s mainly in the hands of the state-approved private ins t i tu t ion "Samfundet og Hjemmet for Vanfore", which, as has been i n -dicated, undertakes remmedial treatment for every kind of physical defect as well as schooling and training for cripple _whc> because of their inf i rmi ty , are unable to attend the or-dinary schools or work places. The ins t i tu t ion owns two orthopaedic hospitals, one in Copenhagen and the other in Aarhus, with about 3£0 beds. The hospitals have their own appliance departments with workshops of various kinds working for the hospi tal and also for other hospitals and private persons. A very large number of the patients need only out-patient treatment, and therefore the hospitals are equipped with large p o l i c l i n i c s . In addition to medical attention and surgical appliances the patients here receive careful instruc t ion regarding socia l l eg i s la t ion , schooling and choice of career, etc. This department also investigates and considers whether more far-reaching soc ia l measures should be taken, for instance education or training in suitable ©ccupations, either i n the ins t i tu t ion ' s own schools and workshops or outside under private instructors. In addition to the "Samfundet" there are two children's homes for the care of children whose a f f l i c t i o n i s such that 101 they are pract ical ly helpless. Treatment of Speech-defective Children It was only towards the close of last century that soc-iety recognized the fact that defective speech represented a soc ia l problem which should be solved with the aid of the public . The problem was taken up chiefly because a Berman professor presented to the Danish government his method for the cure of stammering, and the government instructed the head of the Royal Deaf and Dumb Institute in Copenhagen to make use of the method in practice. In 1898 the state opened i t s Institute for Defective Speech, i t s object being to cure children and unmarried young people, chiefly those whose c i r -cumstances or those of their parents or guardians were strait-ened. Since then the care of such people has developed con-siderably. At the Inst i tute 's two centers at Hellerup (Copenhagen) and Aarhus, which can accommodate about 170 pupils in a l l , instruction i s given to children and adults suffering from cleft palate, stammering, faulty a r t icu la t ion and other defects of speech. The operative treatment of cleft palate and hare l i p i s centralized, a l l operations being performed at Diakonissestiftelsen, in Copenhagen. As i t i s of importance for the successful treatment of clef t palate ajtid hare l i p that the defect i s recognized as early as possible (operations for hare l i p should be performed in the f i r s t year of a ch i ld ' s l i f e , and for cleft palate at the end of the second year), the Ministry has circular ized physician, midwives and nurses, asking that they report any 102 cases of the d i s ab i l i t y which they may encounter in their professional a c t i v i t i e s . The Role of the Social Work Agency For those suffering from defective speech—as for the other branches of Special Care—the Public Assistance Act contains regulations as to the duty of the Social Committees to ensure that medical examinations be made in order to de-cide whether such people need treatment. If necessary the l o c a l Child Welfare Committee can determine the removal from the home of a chi ld under eighteen suffering from defective speech. If Special Care i s then to be applied, the Social Com-mittee must notify the State Institute for Defective Speech, which thereafter decides whether the treatment i s to be given in the ins t i tu t ion or outside i t . In the la t ter case the cost i s defrayed by the l o c a l authority concerned i f the patient i s destitute, unless he i s ent i t led to help under the National Insurance Act. In necessitous cases the cost of ins t i tu t ion treatment i s paid'by the state, or i t i s de-frayed under the National Insurance Act i f the circumstances satisfy the requirements of the Act . Owing to the fact that there are only a few teachers of speech outside of Copenhagen and one or two large provincial towns, i n s t i tu t iona l treatment, has become the form of public care most frequently resorted to. These provisions have created a poss ib i l i ty of estab-l ishing rea l ly effective care for speech-defectives, whereby 103 many individuals "who formerly had. d i f f i cu l ty in managing for themselves can become useful cit izens in the Danish Commun-i t y . Care of Bl ind Children The care of the bl ind in Denmark was in i t i t a t ed by a private philanthropic society which in 1811 opened a bl ind ins t i tu te , by royal permission called the "Royal Institute for the Bl ind" and receiving an annual grant from the Treas-ury. It was not u n t i l the Act of 1857 came into force, con-cerning the establishment of -a new bl ind inst i tute, that the state undertook the education of bl ind children. The present system i s based on the Act of 1926, according to which every chi ld who i s b l ind or whose v is ion i s so reduced that he or she i s unable to benefit from the instruction at the ordin-ary infants ' school or at special schools for the weak-sight-ed, must from i t s eighth year receive instruction at the State Institute for the Bl ind or the Preparatory School for the B l ind , unless the education of the chi ld i s provided for i n another manner.: satisfactory to the l o c a l school authori-t i e s . The compulsory instruction period i s normally ten years. In order to ensure the observance of this rule the Social Committee must notify the Central Record Office of the state inst i tutes for the blind of a l l cases of blindness and weak sightedness. As a consequence, nearly a l l b l ind children come in contact with the public authorities for the care of the b l ind , i n their later years receiving a certain amount of training under the same authorit ies. 104 This care of the bl ind i s exercised chiefly through two state ins t i tu t ions: The Royal Institute for the Bl ind at Copenhagen and the Royal Institute for the Blind on Refsnaes. The lat ter functions partly as a nursery school and partly as an elementary school for about 120 children tetween seven and fifteen years of age, who receive instruc-tion i n the usual elementary school subjects. At the age of 14 to 16 the scholars are transferred to the Institute in Copenhagen i f their mental powers are normal. In addition to the regular subjects taught in the schools for the b l i nd , the inst i tut ions teach extensive courses in arts and crafts to both sexes in order to prepare them to better earn a lying within the range of their l imi ta t ions . Care of Deaf-Mutes In Denmark i t was the state which in 1807 took the i n -i t i a t i v e in the care of deaf-mutes by opening the Royal Deaf and Dumb Institute in Copenhagen, and ten years later educa-tion for deaf-mutes was made compulsory. Institutes for the deaf and dumb were opened at Fredericia and Nyborg in pur-suance of the Acts of 1880 and 1890 respectively. By the Act of 1926, which forms the basis of the present arrangement of deaf-mute children's education, i t i s l a i d down that they must attend one of the state inst i tut ions or some private form of instruction for the compulsory period, usually nine years. This system of compulsory education presupposes that the state i s notif ied -ef a l l deaf and dumb children. The usual requirements, as discussed previously, 105 for this reporting, are encumbent upon'the Social^Committee and a l l physicians and school teachers, who, i n the course of their duties, find any children under sixteen who have defective hearing. When the chi ld reaches the compulsory school age i t i s summoned for instruction to a state ins t i tu t ion or private establishment. In the great majority of cases, however, the children go to the state ins t i tu t ions . Instruction i s given by the ora l method, though the manual method i s employed for the mentally weak. At the end of the educational period at the deaf and dumb ins t i tu tes , efforts are made in various ways to,continue the training of the pupils with the assistance of grants from the Treasury or the >funds of the Inval idi ty Insurance organization. Some are apprenticed-as craftsmen, especially-as t a i l o r s . They are indentured i n the same manner as ordinary apprentices, but the master receives a certain sum in remuneration for the additional trouble i t takes to teach a deaf-mute. Assistance i s also obtainable, especially towards clothing and mainten-ance, i f .the. deaf-mute i s unable to l i ve at home. Others are placed on farms after having taken a two-year course at a state agr icul tural colony. For the -assistance of the deaf i n general two special offices have been opened with state support: the Trade and Advisory Bureau for the deaf and dumb, and the Trade and Ad-visory Bureau for the hard of hearing. I The source of a large part of this information relat ive to Denmark was: Calvert, W.E., Translation from the Danish, Social-Denmark. Socialt Tidsskr i f t , Copenhagen, Denmark, 1945. 106 GREECE Provisions for the care and treatment of handicapped and crippled children by the government of Greece are almost to ta l ly inadequate for a variety of reasons: lack of pro-fessional personnel;, re la t ive ly large numbers of children needing help (their numbers having been increased to a con-siderable extent by damage done during the war); lack of physical f a c i l i t i e s such as suitable buildings, equipment, etc. ; and lack of funds to carry out the rather costly pro-grams of treatment, education, t raining, and general care. A certain amount of treatment has been given to c r i p -pled children i n a recently established orthopaedic hospit-a l i n Athens under the auspices of the Near East Foundation. The waiting l i s t for this"hospital i s long and discouraging. Treatment and care of "the handicapped i s l e f t almost entirely to private organizations such as the Church, the Red Cross and Greek War Relief Association. Some handi-capped children are given care and whatever training and ed-ucation, might be available in state and local-government operated orphanages. A large number of these children, however, are le f t to their own or their parent's or guard-ian 's devices, such as they may be, for protection, care, and instruction. Many are to be seen on the c i ty streets begging for their l i v i n g . These, i t i s reported, do not do badly because of the superstitious custom of not passing by such an unfortunate person without sharing with him a small portion of the substance of one's greater fortune, les t 107 similar misfortune should strike the donor. The increase i n nervous disorders among the children of Greece i s alarming, even though i t i s to he expected. The reasons why, since the war, many children -show signs of d i s -ordered nerves are numerous. During the occupation, some children of school age, starving, feeble, lacking clothes and boots, shivering from cold, did not attend school. Others did some sort of work to earn their l i v i n g and many of those who attended school showed an i n a b i l i t y to remember, weaker powers of concentration and less inc l ina t ion to work. Fur-thermore, i t should be borne in mind that when a ch i ld i s continually experiencing hunger, cold, hardships, worries, suffering, etc, moral principles lose their meaning for him with the result that can be expected, when, for long periods, children have undergone the cruelest treatment, suffered the hardships of war, witnessed a to t a l lack of respect shown for human l i f e , often the uprooting of their families, i t i s not surprising that many of them manifest, as they do today, d i s -orders of mind and body. It has, however, not been possible to ascertain the exact number of these cases among school-children.''" ITALY There appears to have been no fixed public responsibi l i ty for the care of mentally and physically handicapped children 1 Adapted from: United Nations, Department of Social Af-f a i r s , Annual Report on Child and Youth Welfare. Lake Success, 1948, New York, pp. 134-129. 108 i n I ta ly . As the ONMI was concerned only with protecting and developing "useful® cit izens and those who could become healtbg productive : members of society by the time they were 18 years of age, i t provided care di rect ly only for those mentally or bhysically handicapped children who were considered curable or capable of benefiting by education and t ra ining. This or-ganization was required by law to care only for those who showed a capacity equal to more than f i f t y per cent of the normal average after a few years instruct ion. The basis on which such decisions were taken i s unknown. In the case of serious deficiencies or d i s a b i l i t i e s , the Provincia l Federations or Communal Committees often assumed responsibi l i ty . These cases were usually referred to some charitable ins t i tu t ion operated by private -agencies for c h i l d -ren of this type. If the chi ld could not be admitted' free of charge, the ONMI might request the assistance of the l o c a l groups or refer the case to the Prefect of the province. In the case of incurables they were l i k e l y to be placed i n insane -asylums without regard to their special needs. The ONMI. claimed to have developed special methods of training and protecting the handicapped, according to which the type of training given was adapted to the temperament, soc ia l environment and apparent capacity of each c h i l d . A l -though the chi ld might be below the average i n l o c a l public schools, the 0NM1 provided direct assistance as long as the chi ld improved even s l i gh t ly . Mentally deficient children and children with handicaps such as cr ippl ing , mutilation, deaf-mutism, blindness, e tc . , 109. are said to have heen provided with special schools but i t i s doubtful whether the f a c i l i t i e s were adequate to the need, since only 29 of these schools have been ident i f ied . One of these was the Gaetano Negri Centre i n Milan, of which the government was part icular ly proud. This school housed 230 children in 1930. It offered education, including vocation-a l t ra ining, medical treatment, surgery, hospi tal izat ion, special gymnastics, physiotherapy, and dental service. The following were special schools for handicapped children: 10 schools for the blind at Bologna, Florence, Genoa, Naples, Padua, Regie Emil ia , Rome, Trieste (not now a part of Italy) and Turin; 15 schools for the deaf and dumb at Bologna, Florence (2), Genoa, Turin (g, one of them a g r i -cul tura l ) , Venice (females) and Verona (males); Milan, Modena, Palermo, Rome, Siena, Trento (males only); and three schools for the feeble-minded and mentally abnormal at Florence and Turin (2). In 1940, 2,975 persons including children, are said to have benefitted from inst i tut ions for the deaf, dumb, and b l i n d . 1 Generally, due to the disorganization caused by the war and the subsequent occupation of I taly by the A l l i e s , together with the flooding of the country by foriegn as wel l as Italian displaced persons, the treatment of handicapped children i n inst i tut ions such as those mentioned above has not been re-established at the same scale that was achieved before the 1 UNRRA: European Regional Office (Welfare Divis ion) , Italy-: Welfare Services. TWE/E45/ Studies 5, 1945. war. Today the protection, care and treatment', of the hand-icapped chi ld in Italy i s largely dependent upon regional interest . Comments by persons who have recently v i s i t ed some of these inst i tut ions indicate that treatment on any sc ient i f ic basis i s pract ical ly unknown. COMPARISON BETWEEN NATIONS In this area of chi ld protection and care, as in those covered i n previous chapters, a vast difference i s to be noted in the standards of leg is la t ion and practice between Italy and Greece on the one hand and the United States, Canada and Denmark on the other. It would seem almost a* v a l i d c r i te r ion of the quality and scope of the measures taken for the protedtion of the children to use the volume and de ta i l of information regarding care and protection of children as -a measurement of the degree of responsibi l i ty taken by each nation. Thus we would have the United States and Denmark contending for the place of f i r s t among the f ive nations, Canada following, and Italy and Greece lag-ging far behind. From the description and information at hand, Canada has to a great extent followed i n the foot-steps of the United States, profi t ing by the mistakes and., successes of that country. The magnitude of the work done by private agencies in the United States i s far greater i n proportion to the population than in Canada*. The amount of governmental funds appropriated and expended per capita i s s l ight ly higher i n the United States than in Canada. The eyes in interested Canadian people are continuously focused upon experiments i n the treatment of - handicapped and c r i p -pled children taking place in the United States, which has become the proving ground for new methods in the f i e l d of prevention as wel l as treatment. Due to a different form of government, and difference in structure of the consti tu-tion i t has not been as easy for Canada to regulate provin-c i a l programs from a national l eve l , as i t has been for the federal government of the United States to regulate and i n -fluence State programs. The role of the socia l worker i n the United States i s definitely concerned with the care, treatment, and preven-tion of crippling conditions among children as well as with their socia l affairs , par t icular ly those of welfare for hand icapped children. It has been said that the trend in the United States i s toward administration of the treatment of handicapped and crippled children by medical agencies rather than welfare departments and other commissions. In Canada the socia l worker and welfare departments -are not d i rec t ly concerned with the administration of programs favouring these children. Whereas the United States and Canada have more or less separated the care -and treatment of the handicapped c h i l d -ren from programs concerned with crippled children, Denmark has by law and rule drawn the two together under one system, known as the Special Care system. Like the United States but unlike Canada, i t has made good use of i t s socia l worker in the finding of both handicapped and crippled children as 112 wel l as their supervision i n certain instances. Denmark i s fortunate i n that i t i s a small country, and i s not handi-capped by large geographical areas, which are d i f f i c u l t to manage under a federal system. It has, therefore, a very closely kn i t , smoothly operating, ef f ic ient ly organized federal control over a l l phases of the program involving the special treatment of i t s children who are handicapped or crippled. The costs to the government of Denmark are similar to those of the United States for the in s t i t u t ion -a l i za t ion and out-patient care of persons benefiting from i t s program for the aid of handicapped and crippled c h i l d -ren. Upon analysis, although the methods are to some ex-tent different, the services rendered are quite similar to those of the United States. Both of these countries indulge in the use of out-patient service to a i f a r greater extent than Canada, where ins t i tu t iona l care, par t icular ly for the handicapped i s the.general ru le . Due to the effects of the war, both Greece and Italy show very low standards in the protection, care and treat-ment of handicapped and crippled children. Both countries are so preoccupied with their baffling and discouraging milieu of s t r i f e , deprivation, and straitened economical circum-stances that these problems become just another straw in the haystack. Although in neither country are modern methods used, nor are f a c i l i t i e s in anyway adequate to meet the exis-ting problems presented by crippled and handicapped children, Italy appears to have gone farther i n the preparation for 113 ins t i tu t iona l care, as well as providing means by lav/, than has Greece. Both countries are i n desperate need of greater outside assistance and advice in order that they might bui ld from what they have or strengthen existing plans to meet the basic needs of these children. Both countries are bene-f i t i n g to some extent both d i rec t ly and indirect ly from private international agencies and foundations, but the ef-forts of these bodies i s only sufficient to scratch the sur-face of need. CHAPTER VI STATE GRANTS TO DEPENDENT CHILDREN It has been recognized for many years by several nations that same children without sufficient means of parental sup-port are a responsibil i ty of the state. Such nations, have, therefore, made legislative, provision for the f inanc ia l , i n s t i -tu t ional , foster parent, and other care of these children. These may be, and have been in some cases, c lass i f ied as dep-endent children. Some nations, such as Canada and I taly have gone a step further in their assumption of responsibi l i ty , providing grants for a l l children who can qualify as residents and ci t izens of that nation. It appears that these nations-have in this way attempted to circumvent the recognized need for payment of supplemental wages to employed persons with dependent children rather than to meet specifical^y the needs of children dependent upon the state or to supplement other grants made to such dependent children. While some nations have dealt with this in the above manner, other nations have met the problem in different ways. Greece, for example, taxes bachelors. The United States uses the income tax, im-posing a higher rate upon persons with fewer dependents. Only such methods as those: used in Canada, which involve direct payment by the government for the children of that country w i l l be discussed here to any extent. In considering economic security, i t must be borne i n mind that many services and resources may be available to 114 115 the children of a country which have the effect of supple-mentation to state grants in the f inancia l support of the ch i ld . Some of these extra resources w i l l be touched upon br ie f ly i n order that each national situation may be pre-sented more c lear ly . THE UNITED STATES The United States, being in greater affluence than other countries studied, has had greater opportunity to meet more adequately the t o t a l economic needs of i t s dependent children. Supplemental services extended to children in need of economic assistance are on a re la t ive ly high l e v e l . Although.it cannot be said that a l l dependent children are being adequately provided for in a l l parts of the United States, resources of one sort or another are usually pro-vided to relieve their f inancia l distress. Chief among these resources are the programs for aid to dependent c h i l d -ren which are in operation in a l l States. Federal Legislation Embodied within the Federal Social Security Act i s the provision under T i t l e IV which extends f inancia l assistance from joint Federal-State funds to dependent children. Those Who May Receive Grants Children who may receive aid in the United States are described i n the -Federal Act as follows: "The term 'dependent c h i l d ' means a needy chi ld under the age of sixteen, or under the age of eighteen i f 116 found by the State agency to be regularly attending school, who has been deprived of parental support or care by reason of the death, continued absence from the home, or physical or mental incapacity of a parent, and who i s l i v i n g with his father, mother, grandfather, grandmother, brother, s is ter , stepfather, stepmother, stepbrother, stepsister, uncle, or aunt, i n a place of residence maintained by one or more of such relat ives as his or their own home.1 Amount of Grant: Portion of Federal Government The Federal Government's portion of grants made by the State i s three-fourths of the f i r s t twelve dollars and one-half of the balance, this being computed on the basis of pay-ments of twenty-seven dollars for one chi ld and eighteen do l -lars for each additional chi ld in the family. The computa-tions are not made by the States for each individual family but on the overal l basis. Therefpre, because some fami l ies ' needs are lower than the twenty-seven dollars and eighteen dol lars , and some are greater, the State may pay the re-quired amounts and s t i l l receive matching Federal money for both, i f a l l grants together average no more than the twenty-seven dollars and eighteen dol lars . Extent of Grants More than a mi l l ion children in nearly 400,000 families were receiving ADC grants i n the United States in June, 1947. The children on the r o l l s comprised 23 per 1000 of the to t a l 1 Social Security Act. T i t l e IV, Sec. 406 (a), p. 35. population under 18 years of age. In Oklahoma the rate was nearly four times, and in Missouri and New Mexico approx-imately twice the national rate. On the other hand, i n Delaware and New Jersey, both highly indus t r i a l States, the rates were less than half that for the United States as a whole. In addition to ADC grants, a Federal-State socia l i n -surance program, known as "Old Age and Survivor's Benefits'", has added to the to ta l source of income of dependent children In June 1947 the number of children receiving benefits under old-age and survivors' insurance, exceeded the number re-ceiving Aid to Dependent Children grants under State-Federal programs in Cal i fornia , Delaware, New Jersey, -and Ohio. In contrast, i n twenty-four other States the number of ch i ld beneficiaries of this socia l insurance plan was less than half the number of recipients of aid to dependent children i n these States. These data understate the extent to which the insurance program i s replacing the assistance program as a major resource for survivor children, since fewer than half the children receiving aid to dependent children are orphans. Variations from State to State i n the concentra-t ion of indus t r ia l and commercial workers, and hence in the number of children protected under the insurance program, account in part for State differences i n the proportion of the chi ld population receiving aid to dependent children. On the other hand, i t should be pointed out that the insur-ance benefite, in the absence of other income, are Insuffic-118 ient to meet minimum needs of chi ld beneficiaries. The increased cost of l i v ing since the war's end has made i t necessary for a growing number of beneficiary families to apply for supplementary assistance unde the aid to depend-ent children program. Assistance paid to dependent children in the country as a whole averaged $61.68 per family in June, 1947. In two States with high per capita incomes, California and Washington, the average monthly payment for each family was $100 or more. In five other States, payments averaged from $90 to $99 per family. In sharp contrast, Miss iss ippi , South Carolina, and West Vi rg in ia made payments averaging less than $30 to a fam-i l y , and eleven States made average payments of $30 to $39. While these figures represent some rea l geographical differences they are not fu l ly representative, since the number of children aided per family varies from State to State. In June, 1947 the number of children assisted was 2.6 per family in the country as a whole, and ranged from 3.0 i n the Dis t r i c t of Columbia and Hawaii, to 2.3 in New York. The average amount of assistance per chi ld reflects more sat isfactor i ly the differences of standards and incomes among States. In June, 1947 the national average monthly rate of assistance per chi ld v/as $24..21. States averages ranged from about $43 to a l i t t l e less than ten dollars or more; in fourteen States i t was under fifteen d o l l a r s . 1 1 Annual Report of the Federal Security Administration. 1947, Section I , Washington, 1948, Federal Security Agency. 119 With one exception, (Nevada), a l l States, the Di s t r i c t of Columbia and Alaska participate in the Federal Social Security Act, T i t l e IV1 How Grants are Made In, a l l States, grants are paid by cheque mailed to the parent or guardian of the dependent c h i l d . The amount of this cheque i s that amount which the caseworker has been able to establish as the need of the chi ld or of the chi ld and his parent or guardian; or, i f the need i s more than the State maximum allowable, (in those States which have es-tablished maximums), the cheque i s for the amount of the allowable maximum. It i s usually, not possible to differen-tiate, these cheques from others issued by the State, or one of i t s p o l i t i c a l subdivisions for other purposes. As a resul t , recipients of public assistance in this category may not easily be distinguished by those cashing their "cheques. Methods of Determination Need i s determined by a socia l worker, usually at the time of a v i s i t to the applicant's home. A budget method i s used, varying from State to State. Some States use a system by which, as mentioned above, a maximum i s established beyond which no grant may go, maximums varying upward as the number of dependent children in the family increase. Some States use a minimum system of budgeting. This being the case, each item of expense allowable has had a minimum es-tablished. When actual expenses are below this set minimum 120 the minimum figure i s used in the computation of need rather than the actual expense. In s t i l l other States, a pa r t i a l minimum system i s used. In these areas minimums are set for part of the allowed expenses while actual ex-pense figures are used in other allowed items of expense. Some States have a combination of the maximum and minimum or pa r t i a l minimum systems in operation. This contributes to the variations of grants between the States as has been noted. DENMARK Grants are made in Denmark to needy orphans, children of widows and of widowers. On the grounds that i n many cases a widow w i l l be In great need of help for the care of her children, Danish leg is la t ion since 1913 has conferred upon widows without means the right to an annual public grant for the support of their offspring. Amount of Grant The contributions (in 1944) amounted to 420 kr . (about $120) per annum per chi ld in the cap i ta l , 360 k r . (approxim-ately $100) in the other towns and 300 kr . (approximately $84) in the rura l areas, and payment of the f u l l amount i s restr icted to those widows whose income does not exceed the amounts of 2,740 k r . ($767), 2,325 k r . ($650) and" 1,825 kr . ($510) always provided that the chi ld has no income or cap-i t a l of i t s own sufficient for i t s proper maintenance. The widow must also satisfy certain personal conditions. These contributions are without obligation or legal effects on the widow or the c h i l d , and they are paid u n t i l the chi ld reaches the age of eighteen, though as a rule they are halved at the age of fourteen, and indeed, may even by reduced by half before then i f the greater part of i t s maintenance can be paid for from the ch i ld ' s own income. According to the same principles , contributions may also be paid to widowers to help towards the support of their children. F i n a l l y , when a widow or a widower dies and leaves c h i l d -ren under the age of eighteen unprovided for , a person taking these orphans into his care i s ent i t led, regardless of his income, to a public annual grants of 630 k r . ($176) i n the capital, 540 k r . ($157) in the other towns and 450 kr . ($125) in the rura l areas. Payment of grants for children of widows and for or-phans does not depend upon the state of need i n each case. In this sphere the Public Assistance Act i s based on the principle of r ight , so that when the conditions stipulated in the act are sat isf ied, the person enti t led to the money receives i t wholly or in part according to whether personal income l i e s under or over the l imi t s fixed by the a c t . 1 How Grants are Made The rules concerning contributions to widowed or single breadwinners were framed for the purpose of ensuring that the money i s paid to the person providing for and fifing with the ch i ld . But in addition, the public i s of course in ter -.. 1 Much of this information has been taken from: W.E.Calvert trans., S M i a l Denmark. Socialt Tidsskr i f t , Copenhagen, Denmark, 1945 pp. 136-144. 122 ested in seeing that the contributions are employed for the benefit of the c h i l d . In order to make sure of th i s , a l l children to whose support the public contributes are i n c l u -ded under the supervisory program administered by the Child Welfare Committee. Advance contributions are normally paid half yearly, but i f the commune considers that i t w i l l be an advantage to the ch i ld , i t can decide to pay monthly. If the Child Welfare Committee receives a report from the inspector that the ad-vances are not being used i n the best interests of the ch i ld , i t can instruct the recipient as to their proper use. If these instructions are not complied with, the Committe can draw the contributions and pay i t out i n small installments or apply i t for the ch i ld ' s benefit i t s e l f . ITALY As I taly today provides no effective grants-in-aid to children on a national scale, i t s national rating i s n i l when an attempt i s made to compare the I ta l ian program with those of the other nations studied. Hov/ever, the economic needs of children are met to some extent by various groups and agencies both of I ta l ian and international o r ig in . The assistance given children in Italy by these groups and agen-cies i s mostly limited to aid of other kinds than that of money. Some provide food, some clothing, some ins t i tu t iona l care, some education in the nature of vocational t ra ining, etc; Minors who are in a "state of misery and who have no relatives obliged by law to support them" are provided with 123 an order for committment to an ins t i tu t ion by the Minister of the Interior. To apply for assistance under this ru le , the ch i ld , or anyone else in his behalf, must submit identifying information to the Ministry of the Interior > , ,, (Prefect's Of-fice) . The National Office of Maternal and Child Welfare has responsibi l i ty for general health and welfare services for needy mothers and for needy children binder s ix years of age. However, the amount of funds to carry out this responsibi l i ty has been exceedingly small since World War II. and has not allowed for a program of money grants to needy dependent children. GREECE The term "needy dependent children," i f applied to the Greek si tuation, should be used in the broadest sense, owing to wide-spread poverty, and conditions within the country which have created situations of need and dependency that are not factors of importance or concern in normal society. There i s need in Greece for assistance to children whose parents have no means of supporting them;, children who are dependent although their parents are s t i l l l i v i n g and are not separated from them. The numbers of orphans, both f u l l and half, have been swollen as a result of World War I I and the present c i v i l war. Programs now i n effect attempt to help these children in inst i tut ions and in "children's towns'". Lack of funds and supplies are always a serious handicap in these efforts. 1 2 4 Determination of Meed: During the years of 1945 and 1946, the chief problems confronting the Welfare Centers was the determination of need, the organization of the Parish Committees, the establishment of the various programs under the direction of the Ministry of Social Welfare, and the training of personnel. „ At the end of this period, these tasks had, for the most part been completed and the programs, including a chi ld welfare plan, had been put into operation. Welfare Center l i s t s of unpro-tected children were being used by a l l re l ie f -g iv ing agencies which had been recognized by the government. Due to the poyerty of the masses of people in Greece, these l i s t s were quite long and the standards of the mean-tests were extremely low in comparison with the United States, Canada, and Denmark. The f i r s t standard used in the means-test was, for example, one-fourth and under, of the amount necessary to purchase the required food to sa t is factor i ly sustain the members of the household. Later this was increased to one-half the amount required to purchase the necessary foodi On the low standard, approximately thirty-three per eent of the t o t a l population were found to be indigent and on the higher stand-ard, nearly f i f t y per cent were found to be e l ig ib le for public assistance. It was estimated that i f the standard of one-hundred per cent were used that-nearly ninety per cent of the to ta l population would be defined as indigent. Chi ld -ren from these families of e l ig ib les were those considered as e l ig ib le for assistance in various chi ld welfare programs. 125 Extent of Grants Due to the C i v i l War in Greece and the diversion of funds and energies to resistance of the forces opposing the government, progress has been almost completely arrested in the application of the leg i s la t ion for public assistance to children i n economic need. As the structure for carrying out this assistance s t i l l exists , i t i s anticipated that the program w i l l be firmly established with outside help when peace again comes to this country. The existing plans, functioning with very l imited means, serve to meet only part of the needs of some of the children. There are no s ta t i s t i cs available which would indicate the exact number of children assisted or the extent to which their needs are met. It w i l l suffice to say that the needs are very great and that the present program i s administered with the prayer that the help given w i l l preserve l i f e un-t i l i t w i l l be possible to consider the finer points of chi ld care and protection. CANADA Canada, as wel l as other countries, has more than one law which bears upon the r e l i e f of economic insecurity of children. The nation has recognized through the Dominion Family Allowances Act that families with children are at a disadvantage as compared with childless or dependentless families when considering the general demands made upon the income of breadwinners. These grants must be considered as a supplemental resource to dependent children. Supple-mental grants are also made in certain cases to dependent children through Mother's Allowances Acts and other s imi-lar leg is la t ion on the Provincia l l e v e l . Other plans which might benefit children i n need in some instances, and i n an indirect manner, are -Industrial Accident provisions and Unemployment insurance. As the la t te r plans are not d i r -ectly or speci f ica l ly directed toward protection of children and as the protection afforded to children through the ap-pl icat ion of these plans i s incidental rather than of reg-ular importance, they are not considered major contributions to the protection of children against economic need. Some provinces, in addition to the above, have s t i l l a further method of supplementation. These, as in B r i t i s h Columbia, are Social Assistance measures. Generally speak-ing, these measures may be supplementary only in special needs, e.g. those for tuberculosis and other special medical aid cases. The Federal Act of Canada known as the Family Allowance Act, which i s mentioned above, makes i t possible from Federal Government funds to grant to children, who are under 16 years of age and who can qualify as residents and c i t izens , the following sums on a monthly basis: 0 to 6 years of age $5.00 - 6 to 10 years of age $6.00 10 to 13 years of age $7.00. 13 to 18 years of age $8.00 As grants to dependent children'are not provided for by 127 National government l eg i s la t ion , but "by the leg is la t ion of each province separately the operations i n this f i e l d may best be demonstrated by consideration of the s imi la r i t i e s and differences between provinces. M anitoba was the f i r s t to enact leg is la t ion providing grants to mothers who were widowed or for other reasons were without means of support, i n 1916. Five other provinces f o l -lowed with similar leg is la t ion between 1917 and 1920? The Nova Scotia and -Quebec Acts came into effect i n 1930 and 1938 respectively. A New Brunswick statute of 1930, pro-claimed in effect in 1943, was replaced by a new Act in 1944. Except i n Alberta, where twenty-five per cent of an allowance i s borne by the municipallity, the whole cost i s provided from provincial funds. In Quebec, not more than five per cent of the amount of the allowances paid may be imposed on municipalities but no levy had been made under this provision. E l i g i b i l i t y Each Act stipulates that an applicant must be a resident of the province and, except in Alberta, have resided there for a certain period. Alberta merely requires that the hus-band should have had his home in the province at the time of his death, committal to an ins t i tu t ion or desertion of his wife. In New Brunswick an allowance was paid for the chi ld of a member of the Forces during the Second World War i f such a member resided i n the Province when he enlisted and I This material was' adapted from the Panada Year Boole  for 1947. the chi ld was resident there. Each Act stipulates that the mother must he a i B f i t and proper Person". Allowances are paid to mothers of one or more children, except i n Manitoba and Nova Scotia, where one chi ld may benefit only i f the mother i s incapacitated. Provision i s made in every province for at least some of the following cases: widows, deserted wives and those who are legal ly separated from their husbands or divorced, and wives of husbands who are mentally incapacitated, perman-ently disabled, in a sanatorium for tuberculosis or i n a penal ins t i tu t ion . In most provinces foster-mothers of children whose parents are dead or disabled are also e l i g i b l e . In some provinces, legal ly adopted children and children of un-married mothers are also e l ig ib le under certain conditions. With two exceptions, the applicant or her chi ld must be a B r i t i s h subject. The age-limit for children i s usually sixteen although i n several provinces i t may be extended to eighteen years under certain circumstances. Amount of Grants Rates of benefit vary considerably from province to province. In some provinces, the maximum rates are deter-mined by statute while in others the administrative author-i t y fixes the rate. In a l l provinces, except Ontario, Quebec and B r i t i s h Columbia, there i s a stipulated maxi-mum amount that may be paid out to any family. In some provinces provision i s made for winter fuel and emergency 129 assistance where need i s evidenced. During 1946 the average monthly amount paid per family ranged from $35.21 in Quebec to $61 in Manitoba. Nova Scotia paid an average monthly amoung of $50.35, B r i t i s h Columbia $46.28 and Ontario $42..81 while the other provinces paid approximately $37.00 monthly per family. The higher monthly averages i n Manitoba and Nova Scotia are accounted for i n part, at least , by the fact that leg is la t ion in these provinces excludes one-child cases except under certain circumstances. 1 Extent of Grants In 1946, Nova Scotia assisted 1,615 families with 4,474 children; New Brunswick assisted 1,207 families with 3,308 children; Quebec assisted 13,685 families with 41,055 c h i l d -ren; Ontario assisted 8,092 families with 15,976 children; Manitoba assisted 613 families with 1,855 children; Saskatch-ewan assisted 2,117 families with 4,992 children; Alberta assisted 1,559 families with 3,275 children; and B r i t i s h Columbia assisted 905 families with 2,132 children. COMPARISONS BETWEEN NATIONS Denmark outranks the other nations in the matter of the extent of i t s assistance to dependent children in need of economic a id . The leg is la t ion of Denmark emphasizes that i t i s the community's duty to help the mother with her c h i l d -ren. By the extensive use of l oca l committees this duty has 1 Adapted from Annual Report on Child and Youth Welfare, Lake Success, New York, United Nations Publications, 1948, W.6, pp. 62-63. 150 become more of a personal trust in the eyes of each c i t i z en . The legis la t ion of the United States and Canad-a provide the means by which help may be obtained. The application for assistance i s a r ight of the mother, and i f she wishes to exercise this right and i s found to -qualify in accordance with the rules of e l i g i b i l i t y she may receive aid'. Greece and Italy lag far behind due to lack of funds. It i s estim-ated that the one i s about as far behind as the-other because neither nation provides money grants to needy children at present. However, Greece has a better organizational struc-ture with which to carry out a program i f outside help were given for this purpose. In the amount granted toward meeting the dependent ch i ld ' s to ta l needs, the present Federal laws of the United States provide for considerable l i b e r a l i t y on the parts of the several States. Existing plans and proposals indicate even greater leeway. Denmark compares favourably in this consideration owing to the manner in which it- establishes e l e g i b i l i t y due to need. Canada s t i l l uses the maximum budget system which i s overly res t r ic t ive when considering the meeting of needs of children, while Greece has, among the five nations the greatest percentage of children in ex-treme need of f inanc ia l assistance, i t also has the greatest amount of outside help. In Denmark, Canada and the United States, l eg i s la t ion and practice are closely drawn together. It would be a very d i f f i c u l t task to prove which of these three nations 131 outranks the others in this matter. Minor differences' be-tween the established law and the practice do appear because of interpretation, by reason of special circumstances in certain cases and even because of the need for amendments and repeals. In most cases where differences have been found practice i s usually ahead of the law and tends to point the way for better l eg i s l a t ion . Greece and Italy experience vast differences between legis la t ion and prac-t i c e . In Italy this i s true mainly because of lack of funds but partly because of imcomplete legis la t ive remodel-ing since the war. In Greece the greatest d i f f i cu l t y i s presented by c i v i l war and lack of a b i l i t y to reach areas where needy children exis t . Legislation has not presumed a normal society, but has been overhauled since 1944. CHAPTER VII COMPARISON WITH INTERNATIONAL STANDARDS A small but significant portion of the laws and prac-tices of f ive nations have now been described. To some ex-tent, the comparison of these reflect fundamental d i f f e r -ences between countries in their economic and socia l re-sources. It i s possible, however, to measure the -laws and practices of the five nations against international stand-ards. As suggested in Chapter I , standards and pr inciples , which- have been warmly accepted in the past, are today considered outmoded and insuff ic ient . The work of redraft-ing these principles and standards has not yet been com-pleted. However, i t i s reasonable to select portions of those principles and standards which have, thus far , been proposed for adoption by the United Nations as that organ-iza t ion ' s charter of the rights of children. It seems l i k e l y that the United Nations special Commission for the study of these proposals will-consider them as having rea l value as international measuring sticks for each nation when their provisions for the care and protection of c h i l d -ren come up for review. EVALUATION OF PROVISIONS FOR ADMINISTRATION Cri ter ion: A nation should provide for a national ch i ld wel-fare department or agency, one of the responsibi l i t ies of which w i l l be the administration of a program for the pro-132 133 tection of dependent children against economic need. CANADA provides grants to a l l children under eighteen years of-age on a federal plan. These grants are not i n -tended to meet subsistence needs but to supplement earnings of heads of households to compensate for increased cost of supporting families with children. Althodgh these grants are not limited to dependent children, they do supplement the" income of families with dependent children. In this way they become national grants available for the protection of dependent children against economic need. Other schemes for granting assistance to needy dependent children are not administered from the national but the provincial l e v e l . Each province except one has provided for grants to dependent children Jby law which i s closely followed through by practice. THE UNITED STATES complies with this c r i te r ion i n that i t has national agency administration of grants to dependent children. This administration i s an indirect one providing grants-in-aid to the several States which have placed the administration of the plan in the responsible hands of a single State agency i n each State. By virtue of the fact that the United States program for Aid to Dependent Children i s a Federal-State cooperative plan, i t can be said to com-ply with the requirements for national administration. Grants made to children under this plan are extended to families with dependent children in a l l States except one, where the State plan does not make use of the opportunity 134 of federal cooperation. DENMARK provides grants to needy orphans, and the c h i l d -ren of widows and widowers, under a national law. Although the plan i s a national one, i t i s administered l o c a l l y , with national control maintained only in cases where questions have arisen and appeals are made to national boards or courts. Denmark's plan, therefore, cannot be said to comply completly with the cr i te r ion that administration should be by a nat-ional agency or department. Nevertheless, i t comes very close to compliance, due to the fact that the program i s national in character through practice and law. A national regulatory body has been provided, but national administra-tion has not. ITALY complies with the cr i ter ion by the provision of a national agency, the ONMI, vested with the authority and responsibi l i ty for the protection of dependent children against economic need. If adequate funds were available, i t i s conceivable that this agency, with some strengthening reorganization, could-carry out the responsibi l i t ies given i t . GREECE, with i t s organization under the administration of the Ministry of Welfare, including a plan for the protec-tion of dependent children against economic need, complies with the cr i ter ion requiring a national department or agency. Here, as in I ta ly , the funds requisite to the satisfactory functioning of the plan are lacking. EVALUATION FOR CHILD LABOUR REGULATIONS C r i t e r i on : Minimum' age set at sixteen years i n any employ-ment i n a factory, sixteen in any employment during school  hours, fourteen in non-factorv employment outside school  hours. Those nations complying with this standard are: Canada, except for agr icul tural work for which no age l i m i t i s set, and twenty-eight of the States in the United States. Denmark and Italy f a l l short of the minimum age requirement by two years and Greecy by four years. Cr i ter ion: Minimum age of eighteen years i n a considerable  number of hazardous occupations. None of the five countries maintain of provide this standard by law. Cri ter ion: Maximum of not more than eight hours dai ly em-ployment for minors under eighteen years of age. In the United States fourteen States comply for both sexes and seven States provide this maximum for dai ly hours for g i r l s only. Denmark complies for some trades but not for others. I taly provides for a weekly maximum of forty hours but not a maximum for dai ly hours for this age group. In v,<3&Bada most provinces provide for an eight hour day for a l l ages. Greece provides a maximum of ten hours for children under eighteen and of six hours for children under fourteen. 156 Cri ter ion: TMnteen hours night work prohibited, for "minors under sixteen in any gainful occupation. Eleven States in the United States include this as a provision of their law. Denmark's rules do not comply with this standard except for -certain trades which are treated separately. In Canada, a l l provinces provide that some hours are prohibited for children doing night work but none measure up to this c r i t e r ion . I ta l ian leg is la t ion f a i l s to prohibit nightly hours in this number and Greece's pro-visions prohibit children under eighteen from employment i n factories, construction work and shops between 9 P.M. and 5 A.M. EVALUATION OF PROVISIONS FOR COMPULSORY EDUCATION Cri ter ion: The chi ld must receive a training which w i l l  enable him -at the right time to earn a l ive l ihood. Greece requires attendance at school for six years starting at the age of seven. I taly provides for compul-sory school attendance between the ages of six and fourteen years. Canada requires children to attend school from six to fourteen in four provinces, to sixteen in one province and to f i f t een in the remaining four provinces. State laws of the United States provide for compulsory school attend-ance between seven -and sixteen years of age in twenty-four States, between eight and sixteen in nine States, and between eight -and eighteen in three States. It i s the usual prac-t ice for children to start to school at the age of s i x . Denmark requires school attendance between the ages of seven and fourteen years. In practice the law of Greece f a i l s in many instances to he enforced, and the resultant high degree of i l l i t e r a c y i s an obvious handicap to the ch i ld who must earn a l i v e l i -hood la te r . The same situation exists i n I t a ly . The s t r i c t enforcement of the laws in Denmark i s shown by the extremely low rate of i l l i t e r a c y . The laws of Canada and the United States are re la t ive ly wel l enforce, bringing about a basis for the compliance with this c r i t e r ion . EVALUATION OF PROVISIONS FOR ADOPTION C r i t e r i o n : The chi ld must be"protected within the frame-work of the family unit and according to the requirements  of socia l s e c u r i t y . t h e orphan'"and waif must be sheltered  and succoured. The laws of a l l f ive countries provide for the adoption by one or more persons of the offspring of another. These laws make possible the provision of a home within a family unit for children who otherwise might not have such a home. Therefore i t may be said that a l l f ive countries meet this standard. The f a c i l i t y and degree of widespread use of these laws, the stipulations within the laws which made for a normal home environment, and the legal effects that are created for the chi ld who i s adopted, are a l l factors which must be measured before a true comparison of the nations' provisions with this c r i te r ion may be"completed. It has been pointed out, for example, that i n the United States, Canada and Denmark, provision has been made 138 for an investigation of the homes of adopting persons and their su i t ab i l i t y as adopting parents, prior to the adoption decree or order. Such protective measures are not provided for i n Greece or I ta ly . It appears unlikely that a "normal home situation" could be provided for an infant who i s adopted in Greece or I ta ly , by a person who must he f i f t y years of age or over. I ta l ian law makes i t possible for an adopted chi ld to retain legal responsibi l i t ies or rights tying him to both his adopted parents and his natural parents. In the other countries complete severance from his own parents and family takes place, except for the provision in most instances of the r ight to inheri t from his natural parents. Greek and I ta l ian law l imi t s the use of the practice of adoption by the stipulation that only persons having no ch i l d -ren of their own may adopt. I t further l imi t s use of the practice by preventing the -adoption of more than one chi ld by adopting parents unless more than one are -adopted at the same time. Ccanada, the United States and Denmark a l l provide for the adoption of more than one chi ld in the be l ie f that this practice i s conducive to the normal development of the c h i l d . Their l imitations as to the differences in ages between the adopter and adopted are such that the age ranges within the family unit are more l i k e l y to approximate a normal family. EVALUATION OF PROVISIONS FOR THE PROTECTION AND CARE OF CRIPPLED AND HANDICAPPED CHILDREN 139 Cri ter ion: The chi ld must "be given the means requisite for  i t s normal development, both materially and s p i t i t u a l l y . The ins t i tu t iona l form of care and treatment for hand-icapped and crippled children i s the usual practice in the countries studied. The United States seems to be most out-standing in experimenting in other forms of treatment. It i s doubtful that the .means requisite for their normal devel-opment are provided in any country to the greatest extent possible. Recent achievements through experimentation with various types of treatment, indicate that at least a portion of the children given care and training in inst i tut ions might benefit " • • " i t * to a greater degree from treatment, care -and training within the environment of the normal home. The national program of chi ld welfare in the United States which includes.a plan for crippled children i s outstanding among nations for programs of this kind. This.program i s noteworthy par t icular ly from the standpoint of i t s finding service as wel l as for the u l t -imate combining of diagnostic, medical and surgical treatment, nursing, and soc ia l work services. No other country studied -appears to have approached the problem of care and treatment of crippled children by the uniting of available resources such as has been done in the United States. Denmark also approaches the fulf i l lment of the require-ments of this standard. Teachers and medical practitioners are required by law to report a l l cases of crippling condi-tions within certain categories. The Danish law also pro-vides for medical and surgical treatment of these conditions. 140 In Canada crippled children are benefitted through treatment and services provided by private agencies, clubs and organizations.' To a small extent I ta l ian handicapped children are given treatment by church organizations, the National Office of Hygiene and the Provincial Anti-Tubercular Association (Conzorzio Provinciale Anti-Tuberculare). Greece provides for i n s t i t u t iona l care of handicapped children to a small extent in comparison with the need, and private organizations render -a re la t ive ly small amount of treatment to handicapped children. It may therefore by said that nose of the nations studied measure up completely to this standaid, but that the United States and Denmark most nearly comply. Canada follows, having a greater number of improvements to make before compliance is obtained; and that Greece and Italy w i l l require considerable review and strengthening of their programs for the care, treatment and training of this category of children. In a l l countries, to one extent or another, training i s given to those children in care due to handicaps, such as deafness, deaf-mutism, and blindness. As pointed out in the preceeding paragraphs, the extent of care given handi-capped children i s greater in the countries of Canada, Den-mark and the United States. In these three countries a great deal of attention has been placed upon the training of r children with these handicaps. It i s significant that i n s t i -tutions i n a l l of these countries are administered by Depart-141 merits of Education. Not only does the handicapped chi ld receive a training which helps him to earn a l ive l ihood, hut organizations of a national non-governmental character have been formed i n these three countries, which have assumed a responsibi l i ty for the placement of handicapped persons i n certain positions of work in which they may more easily adapt themselves. Both Greece and Italy are more in arrears in providing training than they are in providing care. Modern methods of training or of treatment are prac t ica l ly unknown in I ta ly , and Greece finds training programs costly, requiring special-ized personnel and other f a c i l i t i e s , which they are not i n a position to provide. P rograms for the care and treatment of crippled ch i l d -ren in Canada, Denmark, and the United States generally leave the training of these children to the normal education-a l system. Treatment i s usually carried out over re la t ive ly short periods of time, allowing after care to take place in the home under the supervision of trained personnel. c r i t e r ion : Preventive as preferable or complementary to  curative care. A l l nations carry out preventive programs of one sort or another. Notable among other efforts are those of the large private organizations of a national character i n the United States and Canada such as -are dedicated to the search for preventive measures and treatment of poliomyelit ies. Many other large organizations, par t icular ly within the 142 United States, are dedicated to similar tasks related to other crippling diseases. Statutes -and labour laws in both countries are geared to the prevention of indus t r ia l accidents or labour conditions which might cause crippling of workers of a l l age groups. In Denmark emphasis i s also placed upon prevention, and the labour laws assist in the avoidance of labour conditions which might lead to crippling accidents. In Greece a great deal of interest has been displayed in providing children with a summer holiday as a preventive measure for handicapping and crippling conditions. It has been found that conditions causing trachoma, malnutrition, tuberculosis, and general deprivation causing debi l i ty may be controlled more easily when underprivileged children are given a period in special camps i n the country, during the summer. In I taly a program for the prevention of handicapping and crippling of children would have nearly v i rg in s o i l on which to being i t s work. Cri ter ion: Non-discrimination as to race, sex, p o l i t i c a l  a f f i l i a t ion . -c reed , etc. National legis la t ion and provisions for programs of care and protection for handicapped and crippled children i n a l l countries studied, i s directed toward non-discrimination. However, in practice, the evidence infers some discrimina-tion as to race, par t icular ly in the United States, and to p o l i t i c a l - a f f i l i a t i o n in Greece. I t . i s quite l i k e l y that some discrimination does exist either through the'weakness 143 of the law or the bias of those who enforce or carry out the intention of the law. The situation i n a l l countries could be reviewed with profit under this c r i t e r ion . Cr i ter ion: The chi ld that i s physically or mentally handi-capped must be helped. The writer feels upon review of the information turned to l igh t during this study that added emphasis should be placed upon this cr i ter ion and that i f i t were to be restated the word "must" should be emphasized to an even greater ex-tent. Throughout the entire study i t has been demonstrated that the three countries; Canada, the United States and Denmark,, more nearly f u l f i l l the requirements of those international standards set down here, and that Greece and Italy are inadequate in almost every case. Due to the interest displayed, resulting in far-reach-ing programs dealing with handicapped and crippled children, i t appears that Canada, the United States, and Denmark have for some time been imbued with the meaning of this c r i t e r -ion/ and that Greece and Italy are so overwhelmed with i n -determinate numbers of "musts" that they cannot decide which one to act upon f i r t s . EVALUATION OP GRANTS TO DEPENDENT CHILDREN Cri ter ion: afce"afl§u3ance of protection, in so far as possible  within the framework of the family unit and according to the  requirements of social security. I taly and Greece, because of the almost complete lack 144 of a functioning program, do not measure up to this standard. The provisions and requirements set down in their laws ind ic -ate the des i rab i l i ty of rendering assistange i n such a manner that the chi ld w i l l be maintained i n his own home. In fact one purpose or intent of the law i s to avoid the break-up of families which might occur as a result of economic need, or i n a b i l i t y of parents to provide for their children due to lack of finances. Canadian, Danish and United States laws also contain statements relating to the application of grants to maintain dependent children in their own homes. The Danish law at the present time l imi t s grants to widows and-widowers with dep-endent children and to orphans who may be maintained in the homes of persons selected by the Child Welfare Committee. The history of grants to dependent children in both Canada and the United States indicates that grants in these countries were f i r s t made to widows with dependent children by reason of death of their husbands, or by reason of desertion or d iv-orce. In some cases grants were made to mothers with c h i l d -ren who were dependent because of the mental or physical i l l ness of the father. The purpose of these grants was to enable the mothers to maintain their children by the sub-s t i tu t ion of a State or County grant (Provincial or Munic-i p a l in the case of Canada) for a portion of the husband's earnings. Present laws and practices of these countries have added persons other than mothers, such as father, broth-er, s is ter , grandparents, as persons e l ig ib le to receive grants for dependent children, in order to maintain them in 145 their own homes. In pr inciple , therefore, Denmark, Canada and the United States compare favourably in law and in practice to this standard. When i t becomes possible for the United Nations to complete the study of the provisions for the new "Children's Charter" and to evaluate the laws of a l l member countries in terms of this charter, a great step forward w i l l have been taken. Much work, however, w i l l s t i l l remain to be completed. The raising of national standards, and therefore world standards of chi ld welfare i s a tremendous task which emphatically needs doing. We cannot have a normal world u n t i l we have a "normal society". Where else i s i t better to begin the development of these than with the application of our best knowledge about chi ld welfare? BIBLIOGRAPHY Adoption I t a l y - C i v i l Code. Geneva, League of Nations Child Welfare Information Centre, 1940, Legislative and Administra-t ive Series No. 166, C..Q.S./P.E./C.I . /182. Johnson, Wendell F . , "Why Babies Are Bootlegged*', Survey  Midmonthly. Vol LXXVII No. 6, (June 1941), p. 176. Ancel, Marc, "Law on Adoption in Denmark", L'Adoption dans  les legislat ions modernes, L ib ra i r i e du Recueit Sirey, Paris 1943, p. 212. Morlock, Maud, "Babies on the Market", Survey Midmonthly, V o l . LXXXI, No. 3, (March, 1930), pp. 67-69. Smith, Evelyn, "Adoption", Reprint from Social Work Year  Book, 1947. Washington, U.S. Government Print ing Office, 1948, Reproduced, with permission by Federal • Security Agency, U.S. Children's Bureau. Compulsory Education "Enrollment in Educational Inst i tut ions, by Provinces, School Year 1944-45", Canada Year Book. 1947. Goad, Harold and Catalano, Michele, "Compulsory School Attendance Law,of December 31, 1923", Education in I ta ly , Rome, Gazette Uff ic ia le No. 28, 1924, published in Rome in 1939. P ro f f i t t , Maris M. and Segel, David, School Census. Com-pulsory Education, Child Labor: State Laws and Regu-lat ions, Washington, Federal Security Agency, U.S. Office of Education, 1945, Bu l l e t in 1945, No. 1. "Teacher Supply", Canada Year Book. 1947. Wilson, Florence, Near East Educational Survey, European Centre of the Carnegie Endowment, Hogarth.Press, 1922. Child Labour "Chi ld Labour Legislation in I ta ly" , Bol le t t ino Uf f i c i a l e , Rome, Ministero d e l l ' Educazione Nazionale, May 1929-1934, Difesa Sociale, October 1940. Labour Legislation in Canada. Ottawa, Legislation branch Department of Labour of Canada, August, 1945. 147 "Law DK9, Relating to the Employment of Minors and Women", Government Gazette. Rome, 19IS. Manning, Lucy and Diamond, Norene, State Child-Labor Standards, Washington, U.S. Government Printing Off-ice , U.S. Department of Labor, Child Labor and Youth Employment Branch, Child-Labor Series No. 2, 1946. Record of Proceedings of the Twenty-Seventh Session of the International Labour Conference (Paris 1945). Montreal. International Labour Office, 1945. United States, Department of Labor, A Guide to Child Labor  Provisions o'f the Fair Labor Standards Act (the Fed-"eral Wage and Hour Law). Washington, U.S. Government Printing Office, 1948, Child-Labor Bu l l e t in No. 101. United States, Department of Labor, The States and Chi ld -Labor - 1947. Washington, U.S. Government Printing Office, 1948, Reprinted from Labor Information B u l l e t i n . Grants in Aid Marsh, Dr. Leonard C , "Family Allowances in Canada", Proceedings of the Pacif ic Northwest Annual Conference  on Family Relations. Pullman, Washington, A p r i l 1948, (.Marvin J . Taves, ed.) United States, Federal Security Agency, Annual Report of the Federal Security Agency for the F i s c a l Year 1947. Washington, U.S. Government Printing Office, Social Security Adminstration, 1948, Section One. " United States, Federal Security Agency, Compilation of the  Social Security Laws: Including the Social Security  Act -as Amended and Related Enactment through March 1. --1947, Washington, U.S. Government Printing Office, 1947. United States, Federal Security Agency, 1948 Amendments  to the Social Security Act Affecting Public Ass i s -tance: Background Statement for General Information  Use,Washington. U.S. Government Printing Office, July 1948. United States, Senate, 80th Congress, 2d Session, Public  Assistance: A Report to the Senate Committee on F i n -ance from the Advisory Council on Social Security, Washington, U.S. Government Printing Office, 1948, Document No. 204. 148 Handicapped and Crippled Children Best, Harry, Deafness and the Deaf in the United States. New York, Macmillan Company, 1943. Bluett , Charles G. and H i l l , Ada Morgan, "Report of the Employment Survey Conducted by the American Society for the Hard of Hearing", Hearing News. March, A p r i l and May, 1946. Van Horn, A . L . , "Crippled Children", Reprint from Social  Work Year Book. New York, Russell Sage Foundation, 1947, Reproduced with permission by Federal Security Agency, U.S. Children's Bureau, Washington, 1948. Wil lard , Joseph, "The Canadian Health Grant Program", Canadian Welfare. V o l . XXIV, No. 5, 1948. Welfare Services: General Canada, Summary"of the Laws of Canada and her Provinces as Affecting Children, Ottawa, the Canadian Welfare Council, Council House, March 1944. Calvert, W.E., trans., from Danish, Social Denmark. Copenhagen, Socialt Tidsskr i f t , 1945. Coutsis, Sophy and Pandalean, A . , Child Protection in Greece, Athens, United Nations Welfare Mission, 1948, Basic Circulars of the Ministry of Welfare, 1945-1948. I ta ly , "National Office of Maternal and Child Welfare in Italy^ I ta ly : Opera National per l a Protezione de l la  Matern-ita e d e l l ' Infanzia. Rome, Origine e Sviluppi , 1936, United States Children's Bureau, May 1943.. I ta ly : Welfare Services. European Regional Office, March 1945, Welfare Division UNRRA Edition No. 1, TWE/E45/ Studies 5. Lundberg, Emma 0 . , 3 7Child, Welfare", reprint from Social  Work Year Book, Washington, U.S. Government Printing Office, 1947. Reproduced, with permission by Federal Security Agency, U.S. Children's Bureau. Lundberg, Emma 0 . , Our Concern - Every Chi ld . Washington, U.S. Government Printing Office, 1944, U.S.Children's Bureau Publication 303, (reprinted 1948.) United States, Federal Security Agency, Child Welfare Moves  Forward. Washington, U.S. Government Printing Office, 1947, U.S. Children's Bureau Child Welfare Reports, No. » . 149 United States, Federal Security Agency, Children's Services  in the Public Welfare Agency. Washington, U.S. Govern-ment Printing Office, 1948, U.S. Children's Bureau Child Welfare Reports, No. 3; United States, Federal Security Agency, Public Social Services to Children: a Decade of Progress. Washington, U.S. Government Printing Office, 1946, U.S. Children's Bureau, Child Welfare Reports, No. 1. International Welfare Annual Report on Child and Youth Yfelfare. Lake Success, New York, United Nations Department of Social Af fa i r s , 1948. Charnow, John J..The International Children's Emergency Fund. Washington, United States-United. Nations Infor-mation Services, Department of State Publications 2787. International Child Welfare Review: Work of the Internation-Union for Child Welfare from 1946 to 1948. Geneva, International Union for Child Welfare, 1948, V o l . I I , Special Number. United Nations, Economic and Social Council, Comments on Agenda Items with Relevant Progress Notes. Lakes Success, New York, Secretariat Division of Social A c t i v i t i e s , A p r i l 1948, Social Commission Third Session, document E/CN.5/44, February 1948. United Nations, Economic and Social Council, Report of the Social Commission, Lake Success, New York, 1948, O f f i c i a l Record, Third Year, Seventh Session, Sup-plement No. 8. 

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