exceptional in the extent to which its vacation practices apparently remain influenced by the once generally accepted tradition that the annual vacation for a salaried, white-collar worker should substantially exceed that granted to a manual worker.

10. The Netherlands

The Netherlands, unlike most Western European nations, has no general vacation law. Workers are expected to rely primarily upon their unions to bring them the benefit of a paid vacation. However, the Dutch Government has provided, by decree, that those workers not covered by collective bargaining agreements-a relatively small minority of manual workers-must receive at least 1 week's paid vacation (6 days) per year. In effect, therefore, an annual vacation is ultimately guaranteed by governmental authority to Dutch workers. Collective bargaining agreements in the Netherlands typically provide a 3-week annual vacation. For workers with long service, they often specify 2 or 3 additional days. Dutch unions have thus deviated-but by no means so far as American unions-from a policy of an identical length of annual vacation for all workers, regardless of their accumulated years of seniority.

11. No way

Norway's general vacation law, passed in 1947, provided a 3-week annual vacation. Successive amendments in the postwar period, the latest in 1964, have lengthened the vacation period to 4 weeks (24) days). Norway is thus a leader among European countries in the movement to assure an extended annual vacation to almost every worker.

The Norwegian law covers all wage and salary earners in private employment, including agricultural workers and domestic servants. As is characteristic of Scandinavian vacation legislation, the law specifies a "holiday season"-from May 16 through September 30-and requires that at least 3 weeks of vacation be given in one consecutive period during this season. The remaining week (6 days) must also be given at one time. As usual, however, exceptions are allowed. In agriculture and other industries with a seasonal peak in the summer, the worker is usually guaranteed only 2 weeks of his vacation during the May 16-September 30 period. Unions are also legally free to make collective bargaining agreements which schedule vacations for their members outside the holiday season, although few would have reason to do so.

Until recently, vacation pay was at the same rate as for time worked. It is now to be somewhat above this rate, since the 1964 amendments stipulated that as of May 1967, a worker will receive approximately 412 weeks' regular pay for his 4-week vacation. For employees-such as many domestic servants-whose compensation includes room and board, a "reasonable allowance" must be paid in addition to the cash wage rate for those vacation days taken away from the employer's establishment.

Like Denmark, Norway has established a system under which the employer may have a "holiday book" for each of his employees-a booklet into which he affixes "holiday stamps" at least once a month. The employer purchases these stamps from the post office, and the worker cashes the stamp book in at the post office at the time his vacation begins. This system, of course, protects the owrker who

loses a job or changes employers, since the employer must turn the partially filled stamp book over to the worker, when the employment relationship terminates. The worker is thereby guaranteed pro rata vacation pay for time worked during the year. In contrast to the Danish practice, however, the "holiday stamp" method of payment is not normally applicable to regular, full-year-round employees-who usually draw their vacation pay directly from the employer at the commencement of the vacation.

An "annual holidays fund" has been established in Norway to administer the "holiday stamp" scheme. To discourage employers from making arrangements with their employees to bypass the annual vacation, the law requires that any vacation pay to which an employee is entitled, but which he does not draw because he forgoes all or part of his vacation, must be paid in by the employer to the annual holidays fund. The employee forfeits any part of his vacation-and the employer must correspondingly make payment to the fund-which he does not take within the "holiday year" (the 12 months beginning May 16) after he qualifies for it. If an employee dies, any accrued vacation pay must be paid to his estate.

Collectively bargained vacation plans, as an alternative to the statutory requirement, are explicitly recognized by the Norwegian legislation. The Government, at its discretion, may exempt from any or all provisions of the general law any group of employees covered by a collective bargaining agreement which gives them "at least as favorable" terms as the statutory minimum.

12. Sweden

The Swedish vacation law, like the Norwegian, provides a relatively long annual vacation. The law was passed in 1945, and its latest amendment-in 1963-increased the vacation period from 3 weeks. to 32 weeks (in 1964) and 4 weeks (beginning in 1965). The law covers all public and private employees, but the Government may make special regulations for certain groups of employees, in lieu of the provisions of the general law.

The employee is entitled to 2 days' vacation, during the current calendar year, for each month worked during the preceding calendar year. He earns the full 2 days' credit for any month in which he performed work on at least 15 days.53 He receives one day's credit for any month in which he works at least 8 days, and no credit for less than 8 days' work.

The Swedish law calls for the 4-week annual vacation to be granted in one continuous period-but allows workers to agree with their employers to waive this rule. "As far as possible," the vacation must be given during the summer.

Upon termination of his employment, for whatever reason, a Swedish worker is entitled to receive payment for all days of accrued vacation. If, for example, he leaves his job after 6 months, the employer must pay him 2 weeks (12 days) wages or salary as compensation for the vacation he has earned.

Vacation pay in Sweden is at the same rate as the regular wage or salary, for any employee whose wage or salary is specified by the week, or a longer time period. Essentially, the same rate is also required for a worker who is paid by the hour or day, or on a piecework or com

53 The employee does not, in all cases, actually have to be at work on at least 15 days. Days of annual vacation are counted as days "on which work has been performed", and so also are days of absence from work on account of illness or pregnancy (up to 90 days in a year.)

mission basis. He is entitled to vacation pay, in the current calendar year, equal to 9 percent of his total straight-time earnings-exclusive of overtime premiums during the preceding calendar year."

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The Swedish law states that "the employer shall decide when annual leave is to be taken"-a subject to the qualification that it shall be taken during the summer, so far as possible. In practice, the scheduling of vactions is commonly determined by employer negotiations with unions. Many manufacturing plants now follow the practice of closing down for the entire month of July. Reportedly, Swedish manufacturers have found an annual shutdown more efficient and manageable than the alternative of staggering 4-week vacations for their work forces throughout the summer months.

13. Switzerland

Effective February 1, 1966, Switzerland replaced her old federal factory law with a new federal work law. This added to the Swiss Federal Code of Obligation, a new article, guaranteeing everyone employed in Switzerland at least 2 weeks of paid vacation, annually. Apprentices under the age of 20, and all other young workers up to age 19, must receive 3 weeks of vacation.

This law replaces both the old law, which applied only to rail, transport, and communications workers, and also conflicting cantonal legislation. However, the cantons may require longer periods of vacation than the 2 weeks required by the federal law. At least four cantons, including the Canton of Geneva, now require at least 18 days of vacation, or 3 weeks. Longer periods may also be set by collectively bargained agreements.

The 2-week vacation must actually be taken, not just paid for. The law also requires that the vacation period be in consecutive days, not divided and taken at different times through the year. The new law affects an estimated 1.7 million workers, compared to the 760,000 who were under the previous law.

14. Australia

Although Australia has no general vacation law, its people place a high social value upon vacation time. Through collective bargaining or by unilateral employer decision, paid annual vacations are almost universally provided.

Many of the current vacation plans covering unionized Australian workers were initially established, or have been modified, by the national conciliation and arbitration commission. Australian law requires compulsory arbitration for labor disputes that unions and employers fail to resolve through negotiations, and during the postwar period the commission has handed down numerous arbitration awards concerning vacations. Initially, in 1945, the commission's awards established a pattern of 2 weeks' annual vacation, with 3 weeks for certain groups of white-collar workers and some manual workers with unusually long workweeks. In recent years, the pattern of arbitration awards has been shifting toward a general 3-week vacation and 4 weeks for special categories of workers. In 1963, for example, the commission awarded such a vacation plan to the metal trades unions,

54 An employee who receives board as part of his compensation is also entitled to a "reasonable" amount in lieu of board for each vacation day he spends away from the residence provided him by the employer. For purposes of this calculation, vacation pay is not counted as part of the earnings in the preceding calendar year. If, then, a worker receives 9 percent of his total earnings for 48 weeks (52 weeks less 4 weeks of vacation), his vacation pay will be approximately equal to 414 weeks' average earnings.

representing one of the most important groups of unionized Australian workers. Government employees (commonly represented by unions in Australia) have also been generally awarded 3 weeks of annual paid vacation.

A unique feature of Australian legislation-which provides a large supplement to the total vacation time, during their working life, received by most workers-is the legally required "long service leave." Under National and State laws, as well as through decisions by the Conciliation and Arbitration Commission, the prevailing practice is to give this leave to a worker upon his completion of 15 or 20 years' continuous employment. The period of leave is normally 13 weeks (3 months) for workers in private employment, and 6 months for those employed by the Commonwelath (National) and State Governments. This "long service leave" plan gives the worker, at a point approximately one-third to one-half way through an average working career, an unusually long period of freedom from his work routine.56

15. New Zealand

Unlike Australia, its neighboring state in the British Commonwealth, New Zealand has a general vacation law. Its Annual Holiday Act, passed in 1944, guarantees workers a minimum of 2 weeks' annual paid vacation.

In contrast to most of the European countries surveyed, New Zealand has not amended its law in the postwar period to lengthen the required minimum period of vacation. However, the 2-week vacation no longer generally prevails. Through collective bargaining, unions in many industries have won 3 and 4 weeks' annual vacations for their members, 56

New Zealand is closer to the United States than to most European countries with respect to the privileged vacation status provided the long-service worker. It is a widely followed practice to increase the worker's annual vacation after he has accumulated a certain number of years of continuous employment.

16. Canada

Canada enacted an Annual Vacations Act in 1958, but its coverage is confined to employees of the National Government and to some categories of workers in the transportation and communication industries. This act provides 1 week of annual paid vacation during the employee's first year of service and 2 weeks thereafter.

Despite the national law's limited coverage, the large majority of Canadian workers are legally guaranteed an annual vacation. Of the Provinces, eight have enacted vacation legislation. Coverage under these laws varies from Province to Province. Farmworkers are excluded in every Province. Domestic servants have the benefits of the vacation laws in Manitoba and Saskatchewan, but not in the other Provinces. In addition, each Provincial law has its own exclusions

In the United States, to date, the closest approach to the Australian "long service leave" is found in the collective bargaining agreements negotiated by the United Steelworkers Union in recent years, which provide "sabbaticals" for long-service workers. These agreements typically call in each year for a stipulated proportion of the high seniority workers to be given approximately 3 months' leave with pay. After a worker has accumulated enough seniority to qualify, he will usually receive such a "sabbatical" about once every 5 years.

se The 4-week vacation in New Zealand has most commonly been established for workers with exceptionally long workweeks, and for workers-such as busdrivers and firemen-whose jobs keep them on call or subject to work at irregular hours.

from coverage for example, janitors in Quebec, professional workers in Ontario and British Columbia, and salesmen in Alberta.

The Canadian Provincial laws also vary in the minimum period of annual vacation they prescribe, with the Western Provinces being substantially more liberal than the Eastern. In Nova Scotia, New Brunswick, Quebec, and Ontario, employers are legally required to give only 1 week of annual paid vacation. In British Columbia, Alberta, Saskatchewan, and Manitoba, the minimum vacation is 2 weeks. Saskatchewan, moreover, increases the worker's annual vacation to 3 weeks, after he has put in 5 years of continuous service with one employer.5

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The vacation law in Alberta makes specific provision for workers in industries characterized by irregular or discontinuous employment-in particular, the construction industry. Employers in such industries are required to give their workers "vacation pay credit" stamps at the rate of approximately one working day's vacation earned per month of employment. Even though he moves from one employer to another, a worker may thus accumulate enough "vacation pay credit" stamps in the course of a year to receive an annual paid vacation about equivalent to that of the worker in the full year-round service of one employer.

ANNUAL PAID VACATIONS IN WESTERN EUROPE AND THE BRITISH COMMONWEALTH: A SUMMARY VIEW

This survey of 16 nations has shown a widespread adoption of legislation which guarantees workers a minimum period of paid vacation each year. Of the 11 continental European countries studied, all have made it mandatory for employers to provide annual vacations, 58. The legally required vacation is not so overwhelmingly prevalent among the other five nations, in this survey, but it predominates in this group also. Three of the five-Ireland, and the Commonwealth nations of New Zealand and Canada-have vacation legislation of broad coverage. And each of the remaining two has a not insignificant proportion of its workers under vacation arrangements established with legal sanctions: Australia, through its "long service leave" legislation and awards of the Conciliation and Arbitration Commission; Great. Britain, through orders of the wages councils appointed for numerous industries.

In the continental European countries, the modal vacation now appears to be 3 weeks, and the average vacation somewhat longer. Two countries-Norway and Sweden-are in the vanguard, with broad coverage laws requiring 4 weeks of vacation. Four-Austria, Denmark, France, Finland-have legal minimums of 3 weeks. Another-Western Germany-guarantees a majority of its workers, by law, at least 3 weeks of vacation. Belgium does not prescribe as much as 3 weeks in its vacation law, but its highly centralized collective bargaining system has recently made 3 weeks the prevailing vacation. period. Only in three countries-Italy, Belgium, and the Netherlands

57 As in the United States, of course, many workers in Canada are covered by collective bargaining agreements-usually negotiated by the same unions that represent American workers-which provide vacations of 3 or more weeks per year for high-seniority employees.

58 Neither Italy nor the Netherlands, it is true, has a general vacation law. But the Netherlands, by Government decree, requires that workers not covered by collective-bargaining agreements be given at least 1 week's annual paid vacation. Italy, in its Constitution, proclaims the right of all workers to paid. vacations, but does not specify a minimuin period to be generally observed.