2 DECEMBER 1911, Page 29

[To THE EDITOR 07 THR "SPECTITOR.") SIR,—As employers have now

been definitely refused repre- sentation on the governing bodies to be set up under the National Insurance Act, it is essential in the interests of the industries which they represent that even at this late stage such alterations and amendments shall be made as will protect them from the anomalous positions which will be created by the Act if it passes in its present form. Seeing that the time allotted for the Report stage in the House of Commons is totally inadequate for the proper discussion of the Govern- ment amendments, notice of which has been given, the only hope of alteration lies with the House of Peers ; and in order that the hands of that Chamber may be strengthened, I write to solicit your support for the following :- 1. Employers will be, in a great many cases, under a common law liability to pay wages or other remuneration to their employees during their contract of service, although such employees are unable by reason of sickness to render any service, and are actually in receipt of benefit under the Act in consequence of such sickness. This difficulty might be remedied either by—(a) the deletion from the Bill of the clause which states that the receipt of benefits under the Act will not be taken in whole or partial discharge of any other liability of employers to those they employ, and the substitution for it of a clause providing that the receipt of benefits under the Act shall be taken as a pro tante discharge of other liabilities ; or (b) a provision that where employers pay to the persons they employ, during sickness, wages or other remuneration equal to, or in excess of, benefits receivable by such persons under the Act such benefits shall be payable to the employers.

2. It should be made clear in the Act itself, and not left to be settled by regulations of the Commissioners, that the contributions from employers are to be reckoned as daily and not weekly charges, and that no contributions shall be payable by employers in respect of holidays and other periods of temporary unemploy- ment.

3. Definite provision should be made for appeal against the decisions of persons appointed to hold inquiries under Clause 46.

4. It should be provided that before Part II. of the Act comes into operation sufficient time shall be allowed for the submission of questions by employers to the Board of Trade, and for answers being received from that Authority as to the incidence of Part II. of the Act on trades which are not definitely either included in or excluded from its scope.