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UNITED STATES DEPARTMENT OF LABOR
F rances Perkins, Secretary

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C H ILD R EN ’S BUREAU

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.

Katharine F. Lenroot, Chief

Occupational Hazards
to Young Workers
R

eport

N o. 1

THE EXPLOSIVES-MANUFACTURING
INDUSTRIES

M

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P

u b l ic a t io n

N o. 273

UNITED STATES
GOVERNMENT PRINTIN G OFFICE
WASHINGTON : 1942

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OCCUPATIONAL H AZARDS TO YOUNG W ORKERS
Report No. 1.—The Explosives-Manufacturing Industries, Publica­
tion No. 273.
Report No. 2.—Motor-Vehicle Drivers and Helpers, Publication
No. 274.
Report No. 3.—The Coal-Mining Industry, Publication No. 275.
Report No. 4.—The Logging and Sawmilling Industries, Publica­
tion No. 276.
Report No. 5.—Woodworking Machines, Publication No. 277.

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CONTENTS
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Page

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Letter of transmittal______________________________________________________________
Introduction____________________________________________________________________
Method and scope of study___________________________________________________
Definition of explosives________________________________________________________
Nature of the explosives industries and their hazards_______________________
Size and location of plan ts.
____ ;_„________________________________
Processes and hazards.___________________________________________________
Special hazards to minors________________________________________________
Statistical measures of hazard_________________________________________________
Industrial-injury rates____________________________________________________
Experience under workmen’s compensation_____________________________
Employment of minors in the explosives industries_________________________
State standards______________________________________
Report of Advisory Committee on Employment of Minors in Hazard­
ous Occupations, 1932__________________________________________________
N . R . A. codes_______________________________
Industry policies_________________________________________
1930 census data______________________________ ____________________ ;_______
Attitudes toward an 18-year minimum-age standard__________________________
Conclusions______ _ _.------------------------ ----------------------------------------------------------------Appendix A— Legal basis for the investigation_________________________________
Appendix B— Principal articles classified as explosives by the Interstate
Commerce Commission_____________
Appendix C— Number of explosives-manufacturing plants in specified
States and their chief product____________________________ — ___________ _
Appendix D — State minimum-age standards for explosives manufacturing
and for general manufacturing________________________________________________
Appendix E-—Provisions in State laws establishing minimum-age standards
for work in connection with explosives, January 1, 1939_________________
Appendix F— Hazardous-Occupations OrderN o. 1______________________________

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LETTER OF TRANSMITTAL
U nited S tates D epartment op L abor,
C hildren’ s B ureau ,

Washington, June 17, 194-1There is transmitted herewith a report on the occupa­
tional hazards to young workers o f employment in the explosivesmanufacturing industry. This study is the first o f a series made
by the Children’s Bureau to guide the Chief of the Bureau in deter­
mining occupations that are particularly hazardous for young work­
ers and therefore subject to an 18-year minimum age under the
child-labor provisions o f the Fair Labor Standards Act o f 1938.
The data in this report formed the factual basis for HazardousOccupation Order No. 1, effective July 1, 1939, which declared all
occupations in or about plants manufacturing explosives or articles
containing explosive components to be particularly hazardous for
minors 16 and 17 years o f age. A copy of this order appears in
the appendix.
The report was originally published in mimeographed form on
March 15, 1939, when the proposed order was issued. In this printed
bulletin the information presented is that which appeared in the
original mimeographed report, without the addition o f figures that
have since become available.
The study was planned and carried on under the general direc­
tion of Beatrice McConnell, Director of the Industrial Division
o f the Children’s Bureau. The research was conducted and the
report written by Elizabeth S. Johnson, then specialist in hazardousoccupations research.
Respectfully submitted.
K atharine F. L enroot, Chief.
M

adam

:

H on . F rances P erkins ,

Secretary of Labor.


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Occupational Hazards to Young Workers

The Explosives-Manufacturing Industries
The Fair Labor Standards Act of 1938 recognizes the need to
protect young workers 16 and 17 years o f age against unsafe and
unhealthful working conditions. Under the child-labor provisions
o f this act, the basic minimum age for general employment is 16
years, but there is an 18-year minimum age for occupations declared
by the Chief of the Children’s Bureau to be particularly hazardous
for young workers.
The present investigation of the hazards o f employment in the
explosives-manufacturing industries was undertaken to guide the
Chief o f the Bureau in determining whether or not occupations in
these industries should be declared particularly hazardous for minors
16 and 17 years of age under the Fair Labor Standards Act. The
need to investigate the hazards to young persons of work in explo­
sives factories was indicated by the danger from explosions which
exists in such plants despite all safety precautions. Although acci­
dents of this type may happen infrequently, they are likely to assume
the proportions of a major disaster when they do occur, killing or
severely injuring a number of workers at one time.

METHOD AND SCOPE OF STUDY

1

V

In this investigation published and unpublished material has been
used, including reports of the United States Bureau o f Labor Sta­
tistics on industrial accidents and on employment in the explosivesmanufacturing industries and statistics on workmen’s-compensation
costs compiled by agencies which set insurance rates for workmen’s
compensation.
The experience o f persons directly connected with the industries
manufacturing explosives, including articles containing explosive
components, has been extensively drawn upon. The persons con­
sulted included trade-association officials, employers, representatives
o f organized-labor groups, and safety experts with specialized knowl­
edge o f the manufacture and handling o f explosives. These persons
provided valuable information on hazards and employment practices
in these industries and gave their opinions regarding the need o f for­
bidding employment of minors under 18 years of age in plants manu­
facturing explosives.
Extensive investigation of conditions now existing in individual
plants was not deemed necessary in view of information and advice
received from employers and workers in the industries and from
the safety and explosives experts consulted. However, a few plants,
including one fireworks factory and one ammunition plant, were
visited, and the occupations and plant lay-out were observed.
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OCCUPATIONAL HAZARDS TO YOUNG WORKERS

DEFINITION OF EXPLOSIVES
In general, the term “ explosives” means any chemical compound or
mechanical mixture which, upon the application o f fire, friction,
shock, or detonation, will generate gases capable o f causing destruc­
tive pressure upon surrounding objects.
The term “ explosives” is customarily used to refer to compounds
or mixtures that are explosive, such as dynamite, black powder,
smokeless powder, and fulminate of mercury. Manufactured articles
containing explosive components are not commonly spoken of as
explosives, even though they are technically so classified. However,
in the Transportation o f Explosives Act1 and regulations o f the
Interstate Commerce Commission issued thereunder, ammunition,
blasting caps, fireworks, primers, detonating and time fuses, and
many similar articles as well as the basic explosive compounds and
mixtures are classified as explosives for the purpose of regulating
their transportation in interstate and foreign commerce.2 A list of
the principal articles in this classification is shown in appendix
B, page 14.
The term “ explosives” as used in this report—for example, in the
references to explosives industries, explosives manufacture, or ex­
plosives plants—means any goods classified as explosives in the
regulations o f the Interstate Commerce Commission.

NATURE OF THE EXPLOSIVES INDUSTRIES AND
THEIR HAZARDS
Size and location of plants.

Explosives manufacture embraces several distinct industries with
different types of products. These products are divided by the
Census o f Manufactures into three groups: (1) ammunition and
related products, (2) explosives, and (3) fireworks and allied prod­
ucts. The 1935 Census of Manufactures reported a total of 11,757
wage earners and 139 establishments in these groups, as follows :
Number of
establishments
Ammunition and related products
(including blasting caps)---------------13
Explosives1------------------------------------------74
Fireworks and allied products---------52
Total _______________________________

Number of
wage earners
( average for year)

139

5,590
4, 570
1,588
11,757

1 “ E x p lo siv e s ” is u sed b y th e C ensus o f M a n u fa ctu res to m ean b a s ic e xp lo s iv e com p ou n d s
a n d m ix tu res on ly .
S o u r c e : B ien n ia l C ensus o f M a n u fa ctu res, 1935, pp. 607, 658, 671.
th e Census, W a sh in g ton , 1938.

U. S. B u rea u o f

These figures are probably understatements both of the number
of establishments and of the number of wage earners, since the
Census of Manufactures reports only establishments with products
valued at $5,000 or more during the given year. A larger number of
1 A c t o f M a rch 4, 1921 (4 1 S ta t. 1 4 4 4 ).
2 R e g u la tio n s f o r T ra n s p o rta tio n b y R a il o f E x p losiv es and O th er D a n g e ro u s A rtic le s in
F re ig h t, E xp ress, a n d B a g ga ge S ervices, D ock et 3666, as a m en ded. In te rs ta te C om m erce
C om m ission , W a sh in g ton .


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EXPLOSIVES-MANUFACTURING INDUSTRIES

3

plants (151) was reported in February 1938 by the Bureau of Ex­
plosives of the American Association of Railroads, an agency inspect­
ing for compliance with the Interstate Commerce Commission regula­
tions for the transportation o f explosives. This number presumably
includes all plants shipping in interstate commerce by rail, regard­
less o f value of product.1 These plants were distributed by type of
product as follows:
Number of
plants
Amm unition__________________________________________ .____________
11
Blasting caps_______________________________________________________
3
Basic explosivecompoundsand mixtures_________________________
61
Fireworks________________ __________________________________________ 73
Other and type notspecified_____________________________________
3
Total------------------------------------------------------------------------------------------151

This source gives no information on the number o f employees.
Neither these figures nor any others on number, size, and location
of explosives plants given in this report include arsenals or other
establishments operated by the United States Government.
Explosives plants are scattered over the United States. Despite
their comparatively small number, they are found in 29 States.* The
largest number is m Pennsylvania, the most important mining State
in the United States, where 27 plants were reported by the Bureau o f
Explosives. The other States which lead in number of plants are
Ohio (18), New Jersey (16), Illinois (15), and California (10). The
distribution of plants throughout the country is shown in appendix
C,page 15.
The plants tend to be small except in the ammunition industry.
According to the Census of Manufactures, plants manufacturing basic
explosive compounds and mixtures employed on an average 60 wage
earners each during 1935. Those manufacturing fireworks and allied
products employed even fewer, averaging 30 wage earners each.
Establishments manufacturing ammunition and related products, on
the other hand, employed an average of 431 wage earners during the
same year.
Processes and hazards.

Basic explosive compounds and m ixtures.—The two chief types
of basic explosive compounds and mixtures are high explosives and
black powder. High explosives, such as dynamite and picric acid,
are manufactured by chemical processes. In the case o f dynamite,
this involves first the making of nitric and sulphuric acid and then
the nitration process, in which glycerin is combined with nitric and
sulphuric acid to produce nitroglycerin, the explosive base o f dynamite.
Other supplementary processes include the preparation o f a dope
(that is, an absorbent carrier for the nitroglycerin), the making of
paper shells, and the packing of appropriate quantities of dynamite
into the shells. The manufacture of black powder, on the other hand,
involves chiefly a pulverizing and mixing process. The essential
1 L is t o f M a n u fa ctu re rs o f E x p losiv es, com p ile d b y th e C h ie f In s p e cto r, B u rea u o f E x ­
p lo sives, A ss o cia tio n o f A m erica n R a ilro a d s, N ew Y ork . F eb ru a ry , 1938.
2 T h e B ien n ia l C ensus o f M a n u fa ctu res, 1935, an d th e B ureau o f E x p lo siv e s b o th g iv e
th is to ta l num ber o f S tates, a lth ou gh th ere w as a s lig h t v a ria tio n in th e States and in the
d istrib u tio n o f p lan ts.


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OCCUPATIONAL HAZARDS TO YOUNG WORKERS

ingredients o f the powder are saltpeter, charcoal, and sulphur, which
the manufacturer procures as raw materials.
Plants manufacturing basic explosive compounds and mixtures are
usually small, so that losses in case o f explosion may be minimized, and
they are usually located near the place where the product is used.
However, the demands for technical skill in manufacture and for
capital investment are considerable. These requirements have con­
tributed to the integration o f ownership and management that char­
acterizes the industry. Three companies employ about three-fourths
o f the wage earners in the manufacture of high explosives and about
one-half of the wage earners in the black-powder branch of the
industry.*
The grave danger o f explosions has given rise to elaborate pre­
cautionary measures for promoting safety in manufacturing opera­
tions and in the handling o f materials. These include the use of
small separate buildings for various operations, the control of
some processes from a distance in order to remove the worker from
the immediate scene of danger, avoidance of open fires and of
mechanisms or tools capable o f generating sparks, and limitation
o f quantities o f explosive materials kept in one place at any time.
Storage o f explosives, whether at explosives-manufacturing plants
or elsewhere, is also governed by carefully developed standards.
Highly developed safety programs characterize the large com­
panies operating several plants. Furthermore, methods of safe
practice and safe construction and operation of plants have been
prescribed by State authority in important explosives-producing
States through special codes or laws applying specifically to plants
manufacturing or using explosives. Several important explosivesproducing States, including Massachusetts, New Jersey, Pennsyl­
vania, and Washington, have codes regulating the manufacture of
explosives in addition to others regulating the storage and use of
explosives in manufacturing plants and elsewhere.
The manufacture of explosives is characterized not only by the
danger o f explosion but also by danger of poisoning from the acids
and other chemicals used in some processes, as in the manufacture
of nitroglycerin, fulminate of mercury, and picric acid.4 Several
States have special codes or laws providing for the protection o f
workers from the injurious effects of nitro-amido compounds
contained in many of the explosives.
Fireworks <—The fireworks industry has three divisions, according
to*product: The commercial division, producing fireworks for the
open market; the display division, producing fireworks for special
displays; and the fusee division, producing flares, fusees, and
torpedoes for signals on railways and highways.5
Fireworks manufacture, particularly m the commercial and dis­
play divisions, requires relatively little capital, uses chiefly hand
processes, and is highly seasonal. The peak season is just before
* E a rn in g s a n d H ou rs In th e E x p lo siv e s In d u stry , O cto b e r 1937. M o n th ly L a b o r R eview
V o l. 47, N o. 2 (A u gu st 1 9 3 8 ), pp. 378—392. B ureau o f L a b or S ta tistics, U. S. D epartm ent
o f L a b or, W ash in g ton .
4 O ccu p a tio n H a za rd s a n d D ia g n o s tic S ign s, b y L o u is I. D u b lin a n d R o b e rt J. V an e.
B u lle tin N o , 582, p. 7 , U. S. B u rea u o f L a b o r S ta tistics.
* E a rn in g s a n d H ou rs in th e F ire w o r k s In d u s try , O ctob e r 1937. M o n th ly L a b o r R eview ,
V ol. 46, No. 4 (A p r il 1 9 3 8 ), pp. 9 4 2 -9 5 5 .


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EXPLOSIVES-MANUFACTURING INDUSTRIES

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the Fourth o f July, and lesser seasons precede special holidays or
festivals celebrated by the use o f fireworks. The industry has many
S1? aS °Perators a.nd is highly competitive. An important feature
^reworks industry, from the point of view o f employment
o f young workers, is the presence in the commercial ana display
divisions of very small enterprises carried on intermittently in the
proprietor s dwelling, instead o f in a permanent place o f business.
The small concerns which make up this unstable fringe of the indus­
try are commonly referred to as family enterprises, but it is probable
that many o f them employ neighbors and relatives as well as
members o f the proprietor’s immediate family, and that they come
under the jurisdiction o f the Fair Labor Standards Act if they ship
in interstate commerce.
J
*
The seasonal nature o f the industry and the small size and insta­
bility of many concerns contribute to the hazard to the workers.
Lack of technical knowledge on the part o f the proprietor, lack of
proper equipment, and the periodic recruiting o f inexperienced
workers unfamiliar with the precautions essential for safety in the
industry increase the danger of explosion, even though the quantities
o f explosive materials handled are not nearly so large as m plants
manufacturing basic explosive compounds and mixtures. The haz­
ards o f fireworks manufacture are recognized by State safety codes,
in addition to the State codes governing the manufacture, storage
and use o f explosives in general, at least four States have special codes
setting forth the requirements and precautions which must be ob­
served m fireworks factories (Massachusetts, New Jersey Ohio
Pennsylvania).
’
’
Fireworks manufacture comprises chiefly hand-work operations,
ih e most hazardous occupations are the mixing o f the powders and
other ingredients for explosive and color effects and the loading
i
mgre.dients into cardboard shells or other containers. Much
o f the work is in the assembling and decorating o f parts after the
loading, and it is at these light hand-work tasks that young persons
are likely to be employed.
Ammunition.-—The manufacture o f ammunition is quite different
from the. manufacture of fireworks or o f the basic explosive compounds and mixtures. It is essentially a fabricating industry using
highly mechanized processes and is conducted in a few large operating
units. The processes are chiefly the forming and shaping of metal or
metal-and-paper shells, o f primer parts, of bullets, and o f shot, and
the loading and assembling of these parts. Many of the parts are
metal and are fabricated by the use o f power presses, chiefly punch
stamping, and drawing presses. Private concerns make mainly smallarms ammunition, although they may also manufacture some bombs
tear-gas cartridges, and similar articles.
The major types of occupations involved in the making of smallarms ammunition are:
»
Forming parts by machine before they are primed or loaded.
(2) Manufacturing primers, which involves the handling o f ful­
minate o f mercury or other initiating or priming explosive.
(3) Loading primed shells with powder much o f which is done bv
machine.
J
2 0 0 6 0 4 °— 42--------2


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OCCUPATIONAL HAZARDS TO YOUNG WORKERS

(4) Forming and assembling parts by machine after they are
primed or loaded with explosive materials.
(5) Inspecting and packing, practically all of which is done after
the parts or products are primed or loaded.
Almost all the opportunities for employment in the industry in­
volve either work on machines (chiefly power presses) or work in
handling explosives in large or small quantities.
The hazard from explosion appears to be definitely less in many
occupations in ammunition manufacture than in the manufacture
of fireworks or of basic explosive compounds or mixtures. The most
dangerous part o f the manufacture o f small-arms ammunition is
the making o f primers. The fulminate used is an industrial poison,
and it or other initiating or priming explosives used in the primer
are set off chiefly by shock or impact. In many occupations the
amount o f explosive in the parts being handled is relatively small,
so that explosions in ammunition factories are less likely to spread
than in other types of explosives plants. Furthermore, the powder
used in ammunition is for the most part smokeless powder, which is
less readily ignited than black powder.
Most ammunition plants have well-developed safety programs.
No special State codes have been issued for ammunition manufacture,
but general codes on the storage and use o f explosives apply to plants
manufacturing ammunition as well as to other plants.
Blasting caps.—A blasting cap is a small device consisting of a
metal container and a quantity o f an initiating or priming explosive,
such as fulminate of mercury or lead azide. It is used in setting off
a charge o f dynamite or other explosive in blasting.
The processes o f manufacture are similar to those in the making
o f ammunition, but on the whole they are more hazardous since pro­
portionately more explosive material is used and since the con­
struction o f the cap is such that it is more readily set off than ammu­
nition. The manufacture o f blasting caps and the manufacture of
ammunition are carried on in separate plants and are considered to
be separate industries.
Special hazards to minors.

Work in the manufacture o f explosives, including articles con­
taining explosive components, is hazardous, particularly for the
young worker, who is characteristically curious and irresponsible. A
young person cannot be expected to exercise at all times the good
judgment and caution which are required in this work; nor can he
be expected to recognize conditions that may call for special atten­
tion to prevent an explosion, even though he has been told o f the
principles and rules tor safe practice. Also^ he is very likely to
venture about the plant and handle objects in an unsafe manner,
whether or not he nas been given proper instructions or has been
forbidden to enter certain parts o f the plant.

STATISTICAL MEASURES OF HAZARD
Industrial-injury rates.

Nation-wide figures on accident rates in explosives manufacture
are available for 1936 for a sample group o f establishments reporting


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EXPLOSIVES-MANUFACTURING INDUSTRIES

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to the United States Bureau o f Labor Statistics.1 These show for
33 explosives-manufacturing establishments2 a high severity rate
of disabling injuries, though a low frequency rate. The severity
rate (that is, the number o f days lost per 1,000 employee-hours
worked) was 4.34 for explosives industries, compared with 2.08 for
all manufacturing industries combined.3 These figures indicate
that explosives manufacture was twice as hazardous as all manufac­
turing industries combined, in terms of severity of injuries. Ex­
plosives ranked sixth in severitv among the 66 manufacturing
industries for which the Bureau o f Labor Statistics published injury
rates for 1936. On the other hand, the frequency rate (that is, the
number of disabling injuries per 1,000,000 man-nours worked) was
6.61 for explosives manufacture, compared with 16.61 for all
manufacturing industries combined.
This low frequency rate doubtless reflects the safety consciousness
o f the explosives industries and the general effectiveness o f their
safety programs. The high severity rate, on the other hand, re­
flects the hazards inherent in these industries, which result in a
high total injury cost despite all the precautions taken.
No comparable figures are available for earlier years. For 1937,
preliminary figures are available for explosives plants but not for
all manufacturing industries combined. The frequency rate of dis­
abling injuries in explosives industries in 1937 (6.30) was about the
same as in the preceding year (6.61). The severity rate
(2.36) was lower than in 1936 but was nevertheless higher than
the 1936 severity rate for all manufacturing industries (2.08).4
Unfortunately, no figures are available showing injuries to minors
only.
Experience under workmen’s compensation.

Another statistical measure o f hazard is workmen’s-compensation
costs in relation to pay rolls. In order that premium rates for work­
men’s-compensation insurance may bear a relation to the costs in­
curred in a particular industry, rate-making agencies tabulate insured
pay-roll and compensation losses for specific industry and occupation
classifications for use in arriving at the premium rates to be charged
for workmen’s-compensation insurance in each classification. The
pure premium (that is, the rate of compensation loss in relation to
insured pay roll) for explosives classifications is available for 34
States and the District of Columbia combined from the National
Council on Compensation Insurance, an organization serving insur­
ance companies by preparing workmen’s-compensation premium
rates.® Similar figures are available for Pennsylvania from its sepa1 In d u s tria l I n ju rie s in th e U n ited S ta tes D u rin g 1936, M o n th ly L a b o r R e v ie w , V o l. 47,
No. 1 (J u ly 1 9 3 8 ), pp. 1 8 -3 0 .
2 M o s t o f th ese e sta b lish m en ts m a n u fa ctu re b a s ic e x p lo s iv e co m p o u n d s a n d m ix tu res.
8 I n ca ses o f te m p o r a r y d isa b ility , th e tim e lo ss rep resen ts a ctu a l d a y s o f d isa b ility . I n
cases o f fa ta l o r p erm a n en t in ju rie s , th e tim e loss is com p u te d a cco r d in g t o th e A m e rica n
sta n d a rd s ca le o f tim e c h a r g e s ; d ea th a n d p erm a n en t t o ta l d isa b ility , f o r in sta n ce , a re
ch a rg e d a s 6 .0 0 0 d ays.
(A m e r ic a n S ta n d a rd M eth od o f C o m p ilin g In d u s tria l I n ju r y
R ates, p. 6. A m e r ic a n S ta n d a rd s A s s o c ia tio n , N ew Y o r k C ity , 1 9 3 7 .)
* P re lim in a ry figu res fr o m th e U. S. B u rea u o f L a b o r S ta tistics.
* W ork m en ’ s C om p en sa tion E x p e rie n ce C om p iled in 1987. N a tio n a l C o u n cil o n C om p en sa­
tio n In su ra n ce, N ew Y ork . A ll S ta tes a re rep resen ted e x c e p t A rk a n sas. D ela w a re. F lo rid a ,
M ississip p i, N evada, N ew H a m p sh ire, N orth D a k ota , O h io, O regon , P e n n sy lv a n ia , S ou th
C a ro lin a , W ash in g ton , W e st V ir g in ia , W y om in g .


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OCCUPATIONAL HAZARDS TO YOUNG WORKERS

rate rate-making agency, the Pennsylvania Compensation Rating and
Inspection Bureau.6
Figures for 34 States and the District of Columbia, based on the
5 policy-years 1930-34, show a pure premium of 4.25 (that is, $4.25
per $100 o f pay roll) for explosives classifications, about three and
one-half times the average for all manufacturing classifications
(1.24).7 For Pennsylvania the pure premium for explosives manu­
facture, based on $1,750,000 o f pay roll during the 5 policy-years
1932-36, was 1.38, two and one-half times the average for all manu­
facturing classifications in the State (0.54).8
These figures on compensation costs show the explosives industries
to be even more hazardous, relative to all manufacturing industries,
than do accident statistics. This is probably due in part to the fact
that the reports of rates prepared by the insurance rate-making
agencies do not include the experience of firms that are self-insuring
under State workmen’s-compensation laws. These firms are the ones
most likely to have highly developed safety programs, and they are
well represented in the accident figures o f the Bureau of Labor
Statistics, which are based on a voluntary reporting system.
As a measure o f hazard, compensation costs in relation to pay roll
are themselves subject to distortion because factors other than extent
o f disability enter into their determination. Differences in wage
levels affect comparisons between industries and between States, and
differences in benefit provisions of workmen’s-compensation laws, as
well as differences in method and standards of administration, like­
wise affect comparisons between States or regions. However, in the
case of the explosives industries, which are scattered geographically
and which as a group have a wage level apparently not far from
the average for all manufacturing, it is believed that the figures on
compensation costs are significant as an indication of relative hazard.

EMPLOYMENT OF MINORS IN THE EXPLOSIVES
INDUSTRIES
State standards.

Work in connection with the manufacture of explosives is recog­
nized as hazardous for young workers under the laws o f 22 States.
O f these States, 11 prohibit such employment for all minors under
18 years of age, 1 for minors under 17 years, and 10 for minors under
16 years. In 1938, 65 of the 151 plants reported to be engaged in the
manufacture o f explosives were located in States with an 18-year
minimum age for work with explosives (including Pennsylvania and
Ohio). One plant was in a State with a 17-year minimum age for
such employment. Twenty-three plants were located in States where
a 16-year minimum age applied either by specific provision or by
provision for general manufacturing. The remaining 62 plants were
located in 13 States that permitted employment in explosives plants
at 14 years of age. (Appendix D, p. 16.)
• C la ssifica tion E x p erien ce P o lic y Y ea rs 1932 T h r o u g h 1930. P e n n sy lv a n ia S ch ed u le Z ,
vol. 1. P en n sy lv a n ia C om p en sa tion R a tin g an d I n s p e ctio n B u rea u , H a rrisb u rg.
T W ork m en ’ s C om p en sa tion E x p erien ce C om p iled in 1937, pp. 185—188. N a tio n a l C ou n cil
o n C om p en sa tion In su ra n ce, N ew Y ork .
See a lso th e C o u n c il’s C ircu la r L etter^ N o v
10 1937
4 C la ssifica tion E x p erien ce P o lic y Y ea rs 1932 T h rou g h 1936, v o l. 1, pp. 99, 100T T h e
a vera g e fo r a ll m a u fa c tu rin g cla ss ifica tion s w as com p u ted fro m s ta tis tic s co n ta in e d in
th is rep ort.


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EXPLOSIVES-MANUFACTURING INDUSTRIES

9

The State minimum-age provisions for work in the manufacture
or handling of explosives vary in application with respect both to the
occupations and to the types of explosives covered. (Appendix E,
p. IT.) For the most part the proivsions are broad in coverage so
far as occupations are concerned, applying in many States to any
work “ in or about establishments where * * * explosives are
manufactured, compounded, or stored.” The provisions ox some States
are narrower, applying either to work “in the manufacture, pack­
ing, or storing” of explosives or to the handling or use o f explosives.
The range o f products covered varies to some extent, and the lack of
definition of such terms as “explosives” or as “ other dangerous ex­
plosives” means that the exact coverage is not always clear. How­
ever, when the provision relates to any work in or about plants where
explosives are compounded or stored as well as manufactured, at
least part o f the explosive materials handled in the plant would
probably be within the coverage o f the provision, ana the entire
manufacturing plant would therefore be affected by the minimum-age
requirement.
Report of Advisory Committee on Employment of Minors in
Hazardous Occupations, 1932.

This committee, appointed by the Chief o f the Children’s Bureau
in 1932 on the recommendation of the White House Conference on
Child Health and Protection, recommended a list of specific occupa­
tions that should be prohibited to minors under 18 years o f age. This
list included among the occupations involving mechanical hazards any
employment “ in the manufacture, transportation, or use of explosives,
or explosive or highly inflammable substances.” 1 The recommenda­
tions o f this committee served as the basis for recommendations made
by the Labor Advisory Board to N. R. A. code authorities regarding
lists o f occupations hazardous to minors. The establishment o f such
lists was provided for by many of the N. R. A. codes.
N. R. A. codes.

When the National Recovery Administration set up minimum-age
standards in the industry codes, some recognition was accorded the
hazardous nature o f work in explosives plants. A flat 18-year mini­
mum age was provided in the code for the pyrotechnic-manufacturing
industry (fireworks) from the outset. However, work in explosives
plants was not definitely recognized as requiring a higher standard
than the basic 16-year minimum in the other two codes governing ex­
plosives industries—that is, the codes for the manufacture of small
arms and ammunition and for chemical manufacturing. The latter
code, however, contained a provision to the effect that any higher mini­
mum age set by State law should be observed. The former contained
provision for an 18-year minimum age in hazardous occupations to
be listed by the code authority, but no list of such occupations was
set up.2
1 R e p o rt o f th e A d v is o r y C om m ittee on E m p loy m en t o f M in o rs in H a za rd o u s O ccu p a tion s.
M o n th ly L a b or R eview , V ol. 35. No. 0 (D ecem ber 1 9 3 2 ), pp. 1 3 1 5 -1 3 2 2 .
* H is to ry o f the C ode o f F a ir C om p etition fo r th e Sm all A rm s and A m m u n itio n M anu­
fa c t u r in g In d u s try , pp. 45, 4 8 -4 9 . D iv is io n o f R eview , N a tio n a l R e co v e r y A d m in is tr a tio n .
(M a n u scr ip t on file w ith th e N . R . A . R e co rd s S ection , U . S. D e p a rtm e n t o f C om m erce,
W a s h in g t o n .)


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10

OCCUPATIONAL HAZARDS TO YOUNG WORKERS

Industry policies.

A ll persons representing management, either as officials o f trade
associations or as employers, who were consulted in the course o f
this study stated that it was the policy o f the concern or concerns
they represented to hire only persons 18 years o f age or over for
work in or about explosives plants. Indeed, many said that no one
under 21 or even under a higher age was permitted to work at the
more hazardous occupations m the plants, such as mixing powder.
Although observing an 18-year minimum age in general, one ammu­
nition plant reported that it made an exception m the case o f mail
boys, using boys between 16 and 18 years to carry mail and messages
through the plant (including some workrooms where the explosive
materials were handled).
Several persons representing the industries involved and others
familiar with various branches of explosives manufacture reported
that so far as they knew minors under 18 were employed in such
manufacture only by small fireworks concerns not represented in
the trade association o f the fireworks industry.
1930 census data.

Unfortunately, no current data are available regarding the number
and ages o f children in the explosives industries. Figures from the
1930 Census o f Occupations probably represent a maximum estimate
o f current employment. In 1930, 584 minors under 18 years o f age
were reported as operatives or laborers in explosives, ammunition,
and fireworks factories. These 584 comprised about 5 percent o f the
10,951 workers o f all ages (10 years and over) in these occupational
groups. No break-down is given for the 3 types of explosives
manufacture, but it is probable that the vast majority of the young
workers included in the following figures were in the fireworks
industry:

10
14
16
18
20

Age of worker
Number
Total _________________________________________ 10,951

Percent
100.0

4
26
554
956
9,411

Í1)
.2
5.1
8.7
86.0

to 13 years_____________
and 15 years__________
and 17 years---------------and 19 years--------------years and over________

1 L ess th a n o n e-ten th o f 1 p ercen t.
S o u r c e : F ifte e n th C ensus o f th e U n ited S ta tes, 1930.
P o p u la tio n , v o l. V , ta b le 6,
pp. 1 2 2 -1 2 5 , a n d ta b le 10, pp. 8 5 3 -3 5 4 . U. S. B u rea u o f th e Census, W ash in g to n , 1983.

ATTITUDES TOWARD AN 18-YEAR MINIMUMAGE STANDARD
A ll persons consulted regarding an 18-year minimum age for work
in or about explosives plants, including representatives of employers
and of labor and safety experts, were of the opinion that a general
18-year standard is desirable for employment in explosives indus­
tries. From the point o f view o f employers, the most important
reason for this opinion appeared to be the need of the industries


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EXPLOSIVE S-MANUFACTURING INDUSTRIES

11

for steady, mature, and responsible employees in a working environ­
ment entailing many hazards and requiring strict observance of many
rules of safe practice for the protection o f life and property.
Some persons questioned the desirability of applying the order to
office workers, including mail boys. However, others regarded office
and errand work at explosives plants as occupations that should be
declared hazardous for minors under 18. With this one exception,
the persons consulted during the investigation were in agreement that
a hazardous-occupations order relating to explosives manufacture
should apply to any work in or about the plant.


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CONCLUSIONS
1. Workers in plants manufacturing explosives, including articles
containing explosive components, are especially' subject to accident
hazards from explosion despite the progress made by manufacturers
in developing safeguards.
2. The accident severity rate for explosives manufacture was about
twice as great as the average for all manufacturing industries in
1936, on the basis o f available but incomplete figures. The accident
frequency rate was not high, but injuries due to explosion are very
likely to be serious or fatal. Workmen’s-compensation experience
likewise shows a high injury cost for explosives manufacture.
3. Occupations in explosives-manufacturing plants are especially
hazardous for young persons, who are characteristically curious and
irresponsible, because they cannot be relied upon to exercise caution
and good judgment in observing the many necessary safety pre­
cautions in conducting themselves about the plant and at their work.
This obviously concerns not only the safety o f the minor but that
o f his fellow worker as well.
4. The unsuitability for young persons o f work in establishments
manufacturing or handling explosives has been recognized by 22
States in setting a higher minimum age for work in connection with
the manufacture or use of explosives than for other employment.
Eleven States at present prohibit the employment o f minors under 18
years o f age in connection with explosives manufacture, including
Pennsylvania and Ohio, two o f the most important explosives-manu­
facturing States.
5. It is the policy o f leading manufacturers operating explosives
plants to observe an 18-year minimum age regardless o f the State
o f operation. A t the present time the only type o f work in ex­
plosives manufacture in which any substantial number o f minors
under 18 years o f age appear to be engaged is in small fireworks
factories not represented by the trade association o f the fireworks
industry.
6. The term “ explosives” should be understood to include ammuni­
tion, black powder, blasting caps, fireworks, high explosives, primers,
smokeless powder, and all goods classified and defined to be explosives
by the Interstate Commerce Commission in Regulations for Trans­
portation by Rail o f Explosives and Other Dangerous Articles in
Freight, Express, and Baggage Services, as amended, Docket 3666,
issued pursuant to sec. 233 of the Act o f March 4, 1921 (ch. 172, 41
Stat. 1445, U. S. Code, ti. 18, sec. 383).


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Appendix A.—Legal Basis for the Investigation
This investigation has been conducted by the Industrial Division
o f the Children’s Bureau pursuant to the regulation entitled “ Proce­
dure Governing Determinations of Hazardous Occupations,” 1 issued
by the Chief o f the Children’s Bureau on November 3, 1938, pursuant
to the authority conferred by section 3 (1) of the Fair Labor Stand­
ards Act of 1938 (Act of June 25, 1938, ch. 676, 52 Stat. 1060, U. S.
Code, Supp. IY , ti. 29, sec. 201), hereafter referred to as the Act.
This subsection, which defines oppressive child labor as that term
is used in the Act, provides in part as follow s:
(1) “Oppressive child labor” means a condition of employment under which
(1) any employee under the age of sixteen years is employed by an employer
* * * in any occupation, or (2) any employee between the ages of sixteen
and eighteen years is employed by an employer in any occupation which the
Chief of the Children’s Bureau in the Department of Labor shall find and by
order declare to be particularly hazardous for the employment of children
between such ages or detrimental to their health or well-being; * * *.

For the purpose of establishing an orderly procedure for deter­
mining and declaring occupations to be particularly hazardous for
the employment of minors 16 and 17 years o f age or detrimental to
their health or well-being, the Chief of the Children’s Bureau issued
the regulation, Procedure Governing Determinations of Hazardous
Occupations, the first section of which provided in part as follow s:
Sec. 421.1. Investigation and conference.— Preparatory to the making of a
finding by the Chief of the Children’s Bureau that an occupation or a group of
occupations is particularly hazardous for the employment of minors between
16 and 18 years of age or is detrimental to their health or well-being, a study
shall be made of information obtained by the Bureau, or submitted to it with
respect to the hazardous or detrimental nature of such occupation or occupations.
Conferences may be held with representative employers and workers in the
industry, experts in industrial health and safety, and others for the purpose
of discussing the nature and characteristics of the occupation or occupations
under consideration. A public hearing may be held upon reasonable public
notice of the time and place thereof whenever such action is deemed by the
Chief of the Bureau to be expedient for the purpose of obtaining such evidence
with respect to the nature and characteristics of such occupation or group of
occupations. A transcript of the proceedings of any such hearing shall be made
and filed with the Bureau. A report of facts and conclusions with respect to
the hazardous or detrimental nature of the occupation or occupations under
consideration shall be prepared upon the basis of such information and evidence.

In accordance with the provisions of the Act and the regulation
referred to above, the Chief of the Children’s Bureau instructed the
Industrial Division of the Bureau to conduct an investigation with
respect to the hazardous or detrimental nature o f occupations in plants
manufacturing explosives, including articles containing explosive
components, with special reference to young workers, and to con­
sider the problems involved in drafting an order under section 3 (1)
o f the Act.
1 P ro c e d u re G ov ern in g D eterm in a tion s o f H a za rd ou s O ccu p a tio n s, T it le 29— L a b o r,
ch . I V — C h ild ren ’s B ureau— C hild L a b or— pt. 421. F ed era l R e giste r, v o l. 3, p. 264 0 D I,
N ovem b er 5, 1938.

13


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Appendix B.—Principal Articles Classified as Explosives
by the Interstate Commerce Commission1
Ammunition for cannon with explo­
sive projectiles,
including
gas,
smoke, and incendiary projectiles.
Ammunition for cannon without ex­
plosive projectiles, or without pro­
jectiles.
Ammunition for small arms with ex­
plosive bullets.
Black powder.
Blasting caps.
Bombs, explosive.
Boosters.
Cartridge shells, primed, empty.
Chemical ammunition containing ex­
plosive components.
Combination fuzes.
Combination primers.
Cordeau détonant.
Delay electric igniters.
Detonating fuzes.
Diazodinitrophenol.
Electric squibs.
Empty cartridge bags— black-powder
igniters.
Fireworks.
Fulminates.
Fuse igniters.
Fuse lighters.

Grenades, explosive, including hand
and rifle grenades.
Grenades, primed, empty.
Guanyl nitrosamino guanylidene hy­
drazine.
Guanyl nitrosamino guanyl tetrazene
(tetrazene).
High explosives.
Instantaneous fuse.
Lead azide.
Lead styphnate.
Low explosives.
Mines, explosive.
Nitro mannite.
Nitrosoguanidine.
Pentaerythrite tetranitrate.
Percussion caps.
Percussion fuzes.
Primers.
Projectiles, explosive.
Safety squibs.
Small-arms ammunition.
Small-arms primers.
Smokeless powder for cannon.
Smokeless powder for small arms.
Tetrazene.
Time fuzes.
Torpedoes, explosive.
Tracer fuzes.

1 R eg u la tion s fo r T ra n s p o rta tio n b y R a il o f E x p lo siv e s a n d O th e r D a n g e ro u s A r tic le s in
F re ig h t, E xp ress, a n d B a g g a g e S ervice. D o c k e t 3666, pt. I, p ars. 51, 52, pp. 25, 26, an d
S up p lem ent N o. 1, p. 2.

14


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Appendix C.—N u m b e r of Explosives-Manufacturing
Plants in Specified States and Their Chief Product
Plants operated b y private concerns
Plants
operaied b y
U. S.
Other
Govern­
Am­
and type
ment
m uni­ Blast­
not
tion ing caps specified

Chief product
State
Total

United States........................
Alabama________
Arizona..........................
Arkansas.............. .........
California______________
Colorado______________
Connecticut________
Delaware_______
District of Colum bia........
Illinois........................
Indiana______ ____
Kansas______________
K e n tu ck y ...............
M aryland...........................
Massachusetts.....................
M ichigan_____________
M innesota____________ .
M issouri________ __________
Nebraska___________ .
N ew Jersey___________
N ew Y ork ____________
Ohio__________________
Pennsylvania...........................
South Carolina......................
Tennessee...............................
Texas...................................
U tah......... .....................
V irginia..............................
Washington_____________
West Virginia________________
Wisconsin___________

Basic
explosive
compounds Fire­
works
and
mixtures

151

61

3
1
1
10
1
5
1
1
15
4
3
2
i
4
5
2
1
7
1
16
8
18
27

3
1
1
4
1

13

3
1
1

i

7
1
1

5
i
i

6
2
1
2
1
1
2
3
4
i

2

73

11

3

16

5

1

2
i

1

5
2
2

1

1
1

4
4
4
1
10
0
10
12

1

1

1

1
1

1
1
1
2

spedfieddeS 2 PlaDtS manufacturing eordeau detonant and safety fuse and one plant with product not
of manufacturers of explosives, compiled b y Bureau of Explosives, American Association
r?vis,ed
1938»,New York. This list Includes all plants known to ship in interstate
commerce products classified as explosives b y the regulations of the Interstate Commerce Commission.

15


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Federal Reserve Bank of St. Louis

A p p e n d i x D.—State Minimum-Age Standards for
Explosives M a n u f a c t u r i n g and for General
Manufacturing
States with minimum-age
standards
Minimum-age standards applicable to work in explosives manufacture
Num ber

M inim um age specified for work with explosives:*

N o minimum age specified for work with explosives but minimum age
set for general manufacturing:

Number
with ex­
plosives
plants

Number
of plants

49

29

151

*11
»1
no

10
1
4

65
1
22

*3
624

1
*13

1
62

i Appendix E , gives the exact coverage of these provisions.
__ ■
a Arizona, Delaware, Indiana, Maryland, Massachusetts, Michigan, N ew M exico, Ohio, Pennsylvania,
Virginia, Wisconsin. Explosives plants are located in all these States except N ew Mexico.
« Connecticut, Iowa, Missouri, Nevada, N ew Y ork, North Carolina, Oklahoma, Rhode Island, Vermont,
W yom ing. Explosives plants are located in Connecticut, Iowa, Missouri, and N ew York.
* Montana, South Carolina, Utah. Only Utah has an explosives plant.
. ,.
.
* In a few of the 24 States exemptions are found permitting employment of children under 14 years of age
^ ^ A tob a m a ^ A rk a n ^ lca h fO T ^ a fM ora d o, District of Columbia, Illinois, Kansas, Kentucky, Minnesota,
Nebraska, N ew Jersey, Tennessee, Washington.

16


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Federal Reserve Bank of St. Louis

Appendix E.—Provisions in State Laws Establishing
Minimum-Age Standards for Work in Connection
With Explosives, Jan. 1, 1939
Provisions

States

M inim um
age

In or about establishments where nitroglycerin, dyna­ N evada.................... . . .......................
mite, gunpowder, or other high or dangerous explo­ Arizona, Delaware, Indiana, M ary­
sives are manufactured, compounded, or stored. (D e l­
land, Massachusetts, Michigan,1
aware and Massachusetts laws om it “ stored.” Some
Ohio, Wisconsin.
States list a few other explosives, such as dualin and
guncotton.)
In establishments where explosives are manufactured, Pennsylvania *.
handled, or stored, as follows: Black powder (all va­
rieties), dry guncotton, nitroglycerin, dynamite, chlo­
rates, fulminates, picric acid, fireworks, and any other
substances which are subject to expansion b y the aid
of shock, friction, spark, or heat. (Smokeless powder,
wet guncotton, and wet nitrostarch, while not properly
classed with the above as explosives, are also included.)
In the manufacture, packing, or storing of powder, dyna­ Connecticut, Missouri, N ew M ex­
mite, nitroglycerin compounds, fuses, or other explo­
ico, N ew Y ork, Oklahoma,
sives. (N ew Y ork: “ manufacture, packing, or storing
R hode Island.
of explosives.” )
In connection with the manufacture, transportation, or North C a rolin a ..____ ___________
use of explosives or highly inflammable substances.
In the handling of explosives___________________________ (Verm ont.
(Virginia—
A n y work in which the handling or use of gunpowder, Iow a____
dynamite, or other like explosive is required.
A t or about any place where explosives are used. (Texas: (Texas______
“ In any place.” )
[New Mexico.
In operating any place where gunpowder, dynamite, or W yom ing___
other dangerous explosive is manufactured, stored, or
compounded or in handling in any manner any danger­
ous explosive.

16
18

18

16
16
16
18
16
17
18
16

1 Established b y regulation in accordance with authority granted b y the State child-labor law.

17


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Appendix F.—Hazardous-Occupations Order No. 1
May 18, 1939.
Occupations Particularly Hazardous for the Employment of
Minors Between 16 and 18 Years of Age or Detrimental to
Their Health or Well-Being

Sec. 422.1. Occupations in or about plants manufacturing ex­
plosives or articles containing explosive components.— (a) Finding of
fact.— By virtue of and pursuant to the authority conferred by section
3 (1) o f the Fair Labor Standards Act of 1938 (52 Stat. 1060) and
pursuant to the regulation prescribing the Procedure Governing
Determinations of Hazardous Occupations; 1 an investigation having
been conducted with respect to the hazards for minors between 16
and 18 years of age in occupations in or about plants manufacturing
explosives or articles containing explosive components; a report of the
investigation having been submitted to the Chief o f the Children’s
Bureau showing that, despite progress in the promotion of safe work­
ing conditions, the manufacture of explosives and articles containing
explosive components is hazardous in nature, that according to avail­
able figures the accident severity rate for such manufacture has been
higher than the average for all manufacturing industries, that work­
men’s compensation experience likewise shows a high injury cost for
such manufacture, that employment in plants manufacturing explo­
sives or articles containing explosive components is especially
hazardous for young workers who are characteristically lacking in
the exercise of caution, that in recognition of the particular hazards
for young workers o f employment in connection with explosives, 22
States have set a specific minimum age for such employment, higher
than for other employment, and that the policy of many manufac­
turers of explosives or articles containing explosive components is to
employ no minors under 18 years o f age in their plants; a public
hearing having been held with respect to a proposed finding and
order based upon the said report and all parties appearing at the
hearing having been given opportunity to be heard, to question wit­
nesses, and to file briefs and additional statements subsequent to
the hearing; the record o f the hearing having been duly considered
and certain changes having been made in the proposed finding and
order in accordance with suggestions made at the hearing; oppor­
tunity having been given to all interested parties to file objections
within 15 days following publication in the Federal Register2 of
the proposed finding and order, as revised, and no objection disclosing
just cause for further revision thereof having been received; and
sufficient reason appearing therefor,
Now, therefore, I, Katharine F. Lenroot, Chief o f the Children’s
Bureau o f the United States Department o f Labor, hereby find that
all occupations in or about plants manufacturing explosives or
1 Issu ed N ovem b er 3, 1938, p u rsu a n t t o th e a u th o rity c o n fe rre d b y se ctio n 3 ( 1 ) o f th e
F a ir L a b or S tandards A ct o f 1938 (5 2 S tat. 1 0 6 0 ), published in th e F ed era l R egister,
v o l. 3, p 264 0 D I. N ovem b er 5, 1938.
a T h e F ed era l R eg ister, v o l. 4 , p. 175 8 D I , M a y 2, 1939.


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19

EXPLOSIVE S-MANUFACTURING INDUSTRIES

articles containing explosive components are particularly hazardous
for the employment o f minors between 16 and 18 years o f age.
(b) Order. Accordingly, I hereby declare that all occupations in
or about any plant manufacturing explosives or articles containing
explosive components are particularly hazardous for the employment
of minors between 16 and 18 years of age.
Definitions. For the purpose o f this order—
(1) The term plant manufacturing explosives or articles containing explosive
components means the land with all buildings and other structures thereon
used in connection with the manufacturing or processing of explosives or
articles containing explosive components.
(2) The terms explosives’ and “articles containing explosive components’’
mean and include ammunition, black powder, blasting caps, fireworks, high
explosives, primers, smokeless powder, and all goods classified and defined as
explosives by the Interstate Commerce Commission in Regulations for Trans­
portation by Rail of Explosives, et cetera, as amended, Docket 3666, issued nursuant to the Act of March 4, 1921 (ch. 172, 41 Stat. 1444, U. S. Code, ti 18.
sec, 382).

This order shall become effective on July 1, 1939, and shall be in
force and effect until amended or repealed by order hereafter made
and published by the Chief of the Children’s Bureau.
K

a t h a r in e

F.

L

en root

,

Chief of the Children's Bureau.


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