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and public holidays, and is to be limited to two hours a

day on school days or holidays.

or

The most comprehensive Minimum Age Convention (138) was adopted in June 1973. Each ratifying state undertakes to

formulate a national policy to abolish child labour. The

minimum age for employment is set at not less than 15 years, or 14 years in special cases where national economies and schools are at a low level of development. The minimum age

for work dangerous to health, safety or morals is 18 16 in special cases. Underdeveloped countries are allowed to limit the scope of application of the convention initially, provided certain types of heavy or dangerous work are not excluded. Ratifying countries may allow children aged at

least 14 years to work in carefully controlled training or

educational establishments, and children of between 13 and 15 years (or 12 to 14 in underdeveloped countries) to work at light tasks which do not hurm their health or development,

and do not prejudice their schooling.

By March 1978 only eight countries (Costa Rica, Cuba, Finland, Germany, Libya, Netherlands, Rumania, Zambia) had

ratified this convention.

NATIONAL LEGISLATION

This body of international legislation on child labour

has been taken up with varying degrees of success in national legislation. One of two approaches is followed. The first is

to set a single minimum age applicable in principle to all types of work; the second is to establish different minimum ages for particular jobs.

Industry is the most widely covered and strictly regu- lated category of employment. In 1972, 54 ILO member states had fixed minimum ages for industrial employment at 14 years; a higher age, 15 or 16 years, had been adopted in 45 countries, including most European states as well as some third world countries. In over a dozen countries, mainly in North Africa and the Middle East, the minimum age for employment in industry

1 was lower, at either 12 or 13 years. This national legislation

1. ILO, 1972, p 9 ff.

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