EHS 2018 special: Upstairs, downstairs? Experiences of female servants in England, 1550-1650

Charmian Mansell (University of Exeter)

 

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Servants in London, 1600. Available at <https://www.pinterest.co.uk/pin/413979390718750087/?lp=true&gt;

Despite women’s increased participation in the workforce, women in 2014 still carried out on average 60% more unpaid work (including cooking, cleaning and childcare) than men. The gender division of labour attracts considerable attention today and the domestic nature of women’s work is assumed to have a longstanding history. Cleaning, cooking, washing clothes and childcare are thought to have made up the bulk of women’s paid and unpaid work.

 

This conception of women’s work is tied to ideas of female economic and social vulnerability and oppression in the past. The female domestic servant depicted in televised historical dramas like Downton Abbey and Upstairs, Downstairs corresponds with this view of women’s work. We picture her moving silently around the household of her upper-class employers, lighting fires, making beds and doing laundry, and confined to a life below stairs.

My research shifts the focus to sixteenth and seventeenth century service and to servant-employing households of various levels of wealth. It shows a very different pattern of female service. Around 60% of 15-24 year olds were employed in rural and urban, rich and poor households across the country in exchange for wages, bed and board.

Domestic tasks were a more prominent feature of service in the households of the wealthy, where specific roles such as dairymaid, cook and chambermaid were more common. But in smaller households, there was less requirement for such specialisation or for this type of work.

The workloads of most English women in service between 1550 and 1650 were not made up of what we might classify as domestic chores. Witness statements from early modern church courts detail female servants reaping barley, brewing beer or ale, picking apples, fetching wood and running countless errands. One servant was even involved in the sale of pigeons in Basingstoke in 1631.

As evidence of these work activities suggest, service was an experience that did not confine women to their employer’s homes. Female servants spent only around 50% of their time inside the home. Their working and social lives took them into the streets, fields, marketplaces and a variety of other spaces.

These women were not simply employees – they were also important members of the communities in which they lived. In addition to the work tasks they performed outside of their employers’ homes, they visited their neighbours and friends, attended parish events such as markets and fairs and were embedded in community affairs.

While some women faced vulnerability and subordination within their employer’s households, other servants enjoyed the support and friendship of their neighbours. This was by no means a golden age for women in service; but my research demonstrates the need to assess women’s work in the past on its own terms.

‘Quakers, Coercion and pre-modern Growth: Why Friends’ Formal Institutions for Contract Enforcement Did Not Matter for Early Modern Trade Expansion’

by Ester Sahle (University of Bremen)

barclays_bank_limited_signIn the wake of the Libor scandal in 2012, Barclay’s bank suffered severe reputational damage. In response, its CEO promised a return to the bank’s Quaker roots. With this he referred to Barclay’s history as a Quaker-founded bank, and the proverbial Quaker honesty. The idea of the honest Quaker businessman is part of popular culture and historians have argued that honesty in business was an inherent trait of Quakerism from its beginnings.

The Society of Friends, learned opinion would have it, disowned culpable bankrupts. Thereby, it created an incentive for Friends to be honest in their conduct of business. The empirical basis for these claims however is curiously thin. The literature cites few actual instances of disownments for business-related offences from the seventeenth and eighteenth centuries. Most known cases stem from the nineteenth century, when this was indeed common practice. The story of Quaker business honesty is thus based on a strong assumption of institutional and cultural continuity.

The Library of the Society of Friends holds records of London Quaker meetings dating back to the 1660s, when Friends first appeared in the capital. Consulting Quaker meetings’ minutes, disciplinary records, as well as journals and letters of London Quaker businessmen, I conducted the first large scale empirical study of London Quaker meeting’s attitudes towards debt and bankruptcy, c.1660 – 1800.

Surprisingly, these meetings rarely sanctioned business offenders prior to the 1750s. For about 100 years after its conception, the Society of Friends showed no particular interest in its members’ conduct of business. What is more, the letters and diaries of Quaker businessmen in this period contain no evidence that that they feared repercussions from the Society. Quaker businessmen in financial difficulties discussed their impending bankruptcy procedures, or fear of being incarcerated for debt. The possibility of disownment from the Society however, did not figure among their concerns. This indicates that the punishment of offenders was not common enough to work as a deterrence.

From the 1750s onwards, however, this changed. Numbers of disownments for business-related offences skyrocketed. The last decades of the eighteenth century saw far more disownments for business-related offences than the 100 years before.

What caused this change? The new emphasis on honesty in business was part of the Quaker reformation, a movement within Quakerism which refocused the sect’s ideals. Reform movements within religious denominations are not uncommon, what set the Quaker reformation apart was its stated emphasis on protecting the Society’s reputation, and focus on business conduct.

These priorities were a response to a political crisis of the 1750s, which took place in the Quaker-founded colony of Pennsylvania. Erupting over internal disagreements about who was to cover the expenses for the colony’s defense during the Seven Years War, it led to a public scandal which shook Quakerism across the Atlantic World. Contemporary media accused the Quakers of failing to protect the colony’s population from French soldiers and native American raiders. Quaker politicians supposed motivation, their pacifist doctrine was merely a mask for selfish greed. Pamphlets published in London attacked individual Quaker businessmen as war profiteers, who were accumulating fortunes at the expense of the lives of innocent civilians.

In other words, just like Barclay’s Bank in the 21st century, the mid-eighteenth century Quakerism suffered severe reputational damage. The sect’s new focus on honesty in business was a response to this. The Society of Friends conducted an exercise of corporate responsibility, which was a tremendous success – so successful that 250 years later, Quakerism and honesty remain inseparable in the minds of lay people and Historians alike.

Friends went on to become leaders in important ethical concerns, such as the abolition of the slave trade. Today, the Society of Friends indeed stands for an exceptional ethical approach to many areas of public life. What this story tells us is that taking action against reputational damage can lead to institutional change. And institutions shape culture. In other words, corporate social responsibility can indeed lead to a better conduct of business, to the benefit of society as a whole.

 

Retail revolution and the village shop (1660–1860)

By Jon Stobart (Manchester Metropolitan University)

Today, village shops are often seen as central to village life and their closure is greeted with alarm because, like pubs, they act as a litmus for the health and vitality of our rural communities.

Yet we know little about the long-term history of village shops: how widespread they were, what they sold, how they traded, who their customers were and how they related to the wider community. This is partly because they have been overlooked by historians of retailing, who are dazzled by the bright lights of the city and the seemingly revolutionary changes wrought by department stores and chain stores, who are seen as ushering in “modern” practise like display, fixed prices and leisure shopping. Rural historians have long focused on the production of the countryside; marketing is of interest only when it comes to selling the produce of farms.

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This article rescues village shops from both the neglect of historians and the rose-tinted perspective of nostalgia. It reveals how shopkeepers like Ralph Edge, an ironmonger in late seventeenth-century Cheshire, stocked goods from around the world, including calicos from India, tobacco from across the Atlantic, raisins from the Mediterranean; how Rebecca Course managed the credit of her customers to her shop in early-Victorian Buckinghamshire; and how Hardy Woolley mixed retailing in rural Lincolnshire with writing books of trade hints for his fellow shopkeepers.

We know about these people through their entries in trade directories, often with people listing several trades alongside their shop; their inventories, which tell us about their stock held, shop fittings, and sometimes their by-employments; their account books, which reveal prices, identify their customers and their shopping habits and uncover often complex credit arrangements; their diaries and memoirs, which let us into the lifeworld of a small number of shopkeepers and give us some understanding of their motivations and concerns.

Not every village had its own shop, of course, but most of England’s rural population was within easy walking distance of a shop. Whilst the image of the general store is perhaps misleading, they supplied a wide range of items, bringing the expanding world of goods into rural society. We should not judge them against the contested and problematic standards of urban modernity, but rather as businesses and social spaces that served the needs of their customers. The entries in Charles Small’s mid nineteenth-century account book which record mending baskets and mangling clothes for some of his customers may seem quaint and old-fashioned at a time when department stores were emerging in major cities. And the agonising of Thomas Turner about whether to execute an order for distraining the goods of Mr Darby, who owed him about £18 in shop debts, could be seen as a sign of weak business practice. Yet these men – and thousands of other men and women like them – were running businesses that thrived on customer loyalty and their place within the socio-economic fabric of their village communities. They were in the swing of broader changes in retail practice, but deeply embedded in their localities.

 

The full article is published on the Economic History Review and is available here

To contact the author: @Jon_Stobart

 

 

 

Pieces of Eight: Sailors, Wages, and Trade

by Richard Blakemore (University of Reading) – research conducted at the University of Exeter thanks to a ERC project.

 

In April 1642, Michael Johnson sailed from London aboard the Fame. The voyage took him to northern France, southern Spain, and the Caribbean, and Johnson started it with a ‘venture’, a personal investment of cash or goods, worth £5. He spent the voyage ‘turneinge and winding’ (as one of his shipmates put it) his venture and his wages: hiring out his cabin to passengers, buying and selling at each port. By the time the ship was heading for home, Johnson had accumulated 200 pieces of eight and some cargo, altogether worth roughly £50 – ten times his original ‘venture’.

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A white sailor seated and a black sailor standing; to left, the black sailor standing with the white sailor seated in profile facing right, and with a ship behind to right; a round composition. c.1660 Etching. From The British Museum, available at

 

This example invites us to reconsider the traditional image of mariners as wage workers, as poor and unskilled labourers, sitting at the bottom of a strictly ranked workforce. That is what this article is set to do.

This idea of mariners has endured among historians in part because it was popular among those mariners’ contemporaries, especially during the early modern period when global trade and shipping expanded enormously. A proverb from that period claims that ‘the sea and the gallows refuseth nobody’. Yet this interpretation has also been founded on a relatively limited analysis of sailors’ wages, which sought mainly to identify averages across the sector. This article presents a more detailed discussion of this topic, based on a dataset gathered from the papers of the High Court of Admiralty. It is possible to download the dataset here.

The data confirms the impression of a hierarchical labour market, with clear thresholds between ranks. Most mariners (sailors with no specific role) earned less than most specialists (men with a specific job, like boatswain, gunner, or carpenter); most specialists earned less than masters and master’s mates, who navigated and commanded ships. However, there was also remarkable variety – across the seventeenth century, mariners earned between 5 and 55 shillings a month, specialists between 13 and 100 shillings, though in both cases there was predictable lumping around a median point.

Such variation can be explained by the circumstances of a voyage, such as length, destination, and anticipated riskiness. In wartime, for instance, wages rose for most seafarers. This also reflects different levels of skill and social capital for individual sailors at all levels of the shipping industry. In other words, we must recognise that at least some mariners, as well as those at higher ranks, were experienced workers who could claim a skill premium in their wages.

As well as exploring this variety in wages, we also need to look beyond them to other forms of income – something which, like wages, scholars have often treated briefly, and with more attention to the activities of shipmasters. There were multiple available arrangements. Sailors might receive a share of the profits from a voyage, especially when working on a fishing vessel or a privateer, and they also expected a full ‘diet’ aboard ship, and protested loudly when the food did not meet their expectations.

Most crucially, it seems that Michael Johnson was not alone. Many sailors of all ranks carried goods aboard ship, sometimes in their own cabin or chest, sometimes in larger volumes with the ship’s other cargo. This is an area that historians have begun to investigate in more depth (as in this article by Beverly Lemire, and this roundtable edited by Maria Fusaro). Though there is not enough evidence on the value of these goods for a systematic analysis, we can at least establish that the practice was ubiquitous, and that it formed a significant portion of many seafarers’ incomes.

There are implications from this evidence for our wider understanding of the shipping industry and early modern economic developments. As well as the idea that they were unskilled, sailors have often been seen as an exploited group, essential to but not benefitting from European economic growth, to which shipping and trade were dynamic contributing sectors. There is some truth to this picture: sailors’ working lives were certainly hard and dangerous, and the period saw rising inequality, with wages falling behind inflation. Nevertheless, studying seafarers’ wages and trade shows us that they sought to make the best of, and some of them were able to successfully operate in, the venture economy of early modern shipping.

 

Full article: Blakemore, R. J. (2017), Pieces of eight, pieces of eight: seamen’s earnings and the venture economy of early modern seafaring. The Economic History Review, 70: 1153–1184. doi:10.1111/ehr.12428. Available here

To contact the author: r.blakemore@reading.ac.uk

 

 

On archives, macroeconomics and labour markets

Everything (well,… most things) you know about wages 1650 -1800 is wrong. That’s a great opportunity for historians

by Judy Stephenson (University of Oxford)

 

My forthcoming paper in the Economic History Review (abstract available here) makes some big claims about the level of nominal and real wages in urban England before industrialization. There is an early working paper version here

Specifically, I argue that the data used for the years between 1650 and 1800 are completely wrong because the people who compiled them (who go back in some cases to the 1930s and late nineteenth century) took figures from bills for construction services rather than actual wage books. As an actual wage book from the contractor who built the South West Tower of St Paul’s shows, men were not paid these charge out rates, they were paid considerably less.

This has some big ramifications for some influential economists and historians who have relied on long established data sets of ‘builders wages’, such as those of Phelps Brown and Hopkins (1955, 1956) to create macroeconomic models of the past to calculate real wages and infer GDP; to argue that Britain had ‘high wages’; or a comparative advantage in traded goods; or a narrower ‘skill premium’ and better institutions.

In truth, that these wages were ‘wrong’ is in no way surprising to anyone who has ever done work on early modern earning. Any historian of the eighteenth century sensed that these ‘average wages’ were unreasonably high and that their implied welfare ratios gave a falsely rosy picture. (As someone face palmed; ‘A labourer in London able to afford a respectable basket of goods for a family in the mid eighteenth century?? Have you read Dorothy George?’). Those who have ever worked with labour records and account books know that the homogenous figures found by Elizabeth Gilboy were questionable, and indeed in 2011, John Hatcher had successfully called into question the golden age of the fifteenth century. ‘Real’ day wages and wage accounts are always fascinatingly messy, unpredictable, and varied, yet econometricians clung to the old data sets because they believed it was too difficult to find anything else.

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Chart showing comparative real wages, in grams of silver, of European cities 1650 -1800, based on Allen, (2001), where the nominal wage has been reduced by 25%.

My findings make the idea that Britain was a ‘high wage’ economy in the long eighteenth century hard to sustain. If paid wages were 25% lower than we thought, the real wage for labourers through this period in London was not the highest by far. Rather, it seems, they were at the lower end of NW European advanced economies.

This is exciting for economists who think that explaining why the industrial revolution happened in Britain is the ‘Holy Grail’ (it’s back up for grabs). But, the debunking of these inaccurate wage series also makes it a really exciting time for people who want to understand the role of labour in the economy, and who think that the period before collective bargaining and factories has some strong parallels with our own. Lots has been written about the decline of ‘history’ in economic history, but the new opportunity is as wide and bright for historians as it is for economists and econometricians. This breakthrough in this long-run view on wages came not from new statistical techniques, but from the margins of dusty parchment, little iron pins, raggy old papers, smudged watered down ink, and the tentative ‘x’s’ and proud flourishes of the archives.

It’s time to stop recycling tired old data sets and expecting new technology to tell us something different about them. There is a wealth of sources and data in London archives, which have never been used before because they didn’t look comparable to Elizabeth Gilboy’s ‘day rates’, but which offer historians and economists the potential to look at earning, bargaining and the capital labour relationship in new ways. There is exciting work in progress from established and new scholars in the field. No one data set will ever be able to replace the supposed reliability of Phelps Brown and Hopkins, but even they were very tentative about their sources.

To contact the author: judy.stephenson@wadham.ox.ac.uk

References list available here

Constructing Equality? Women’s wages, physical labor, and demand factors in Sweden 1550-1759

by Kathryn E. Gary, PhD candidate, Lund University

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Women were important workers in the past, but they are still under-studied and their contributions largely absent from big-picture discussions of historical living standards. This is largely because women’s work remains to some extent a black box, but recent research has both challenged assumptions about how women participated in the paid labor market (c.f. Humphries and Sarasua 2012) and provided data about women’s payment for different kinds of labor (c.f. Humphries and Weisdorf 2015). The current work contributes to both these areas, by creating series of men’s and women’s wages in early modern Sweden, and by exploring both the mechanisms behind the gender gap in pay as well as the conditions under which women enter paid labor, with the goal of better understanding work in the past in general.

Primary data come from unskilled workers in the construction industry in Southern Sweden, predominantly from the towns Malmö and Kalmar; these are combined with published data from Stockholm, also from construction workers (Jansson, Andersson Palm, and Söderberg 1991). All data are for individuals paid by the day; relative wages are simply the percentage of men’s wages that women earn.

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Figure 1 shows women’s relative wages from 1550 to 1759. Relative wages are high at the beginning of the period, around 80 percent, and increase to levels of parity in the early 17th century, after which they decline substantially, reaching as low as 40 percent during the end of the seventeenth century and into the eighteenth. This is a substantial decline over the period of not much more than a generation.
Some relative wage peaks are related to events that change both the demand for and supply of labor. Kalmar was a border town between Sweden and Denmark; from 1611 to 1613 the two countries fought the Kalmar War. Following these years women’s wages peaked, likely due to necessary rebuilding and a shortage in the supply of men. There is a wage spike in the same city following a fire in 1647 – while the national average weighs down the peak values, the deviations are still clear in the series, and when Kalmar is examined individually women’s relative wages peak as high as 1.33.

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Table 1: Women’s work days as a percentage of all workdays in Kalmar, 1614-1710

 

Women’s ability to earn high wages goes against many of our theories about women’s earning potential – women are expected to earn less than men in physical tasks, because women are not as strong as men, and so are less productive physical laborers (Burnette 2008). Other theories suggest that women face constant wage discrimination (c.f. Bardsley 1999) – but this, too, is confounded by women’s ability to out-earn men, and by the large changes in the relative wage series. Something else is happening.

To understand we must look more closely at the data. In Kalmar workers are almost universally identifiable, allowing for deeper examination of the workforce. Table 1 shows the percentage of paid workdays that were worked by women, compared with the total number of paid work days in five year periods. Comparing the proportional feminization of the workforce with the amount of work, we see that the periods with the greatest amount of work are those in which the workforce is the most feminized – these periods are also those during which women’s relative wages are highest (see figure 1).

In combination with the relationship between total paid workdays and women’s relative wages across the whole country (figure 2), we are faced with a pattern that is familiar from the first and second world wars – when labor demand is high, women enter the labor force in higher numbers and are able to command higher wages. There is less evidence that women were systematically paid less either due to discrimination or because of their lower productivity – instead, women are responsive to economic forces, and especially to demand forces.

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Figure 2: women’s relative wages and total paid workdays in Sweden, 1550-1759

 

It is simple to to extend our sense of what is ‘traditional’ deep into the past, and to apply broad categories of ‘men’s’ and ‘women’s’ work. However, when we are able to suspend our assumptions and dig deeper into the evidence, the data tell a less expected story; women in Sweden worked in physical occupations, alongside men, often for similar wages. They worked especially hard when the need was highest, and women’s wages only fell away from men’s when work became less regular and men and women weren’t employed together.

Accounting for women’s work shifts our understanding of household living standards in the long run, and provides strong evidence for what is intuitively clear: we cannot truly understand the past if we continue to discount the experiences or contribution of half the population.

The full working paper can be read here, and a shorter version from the EHS annual conference is available here.

How (much) were British workers paid ? Evidence beyond wage rates

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J. Cobden (1953) The White Slaves of England

Since Phelps Brown Hopkins published ‘Seven centuries’ in the mid 1950s economic historians and cliometricians have used ‘day wages’ – day rates for masons, carpenters and bricklayers taken from building accounts – to estimate the earnings of workers of the past. Whilst recent work has shown that these rates were not what the masons, carpenters and bricklayers actually received [1] many historians have been working on the means of earnings of other groups. A wage formation conference at the Institute of Historical Research on 16 September aimed to bring the notion that wages are more multifarious than day rates to the fore. The programme brought research on lead and coal miners, hostmen, keelmen, laundresses, sailors, bankers, spinners, agricultural labourers and clergy to debate, and the features that all these groups had in common in their pay before 1900 was an observation that all who attended shared.

Kicking off the day in opening remarks, Leigh Shaw-Taylor put the conclusions that authors such as Greg Clark, and Robert Allen and others have drawn from long run compilations of builder’s day rates within a theoretical context of structural change, pointing out that the role of real wages and average wages has been confused by cliometricians, and reminding us that Malthus predicted shifts in the wages of the poor, not of the average worker.

In the first presented case of the day Jane Humphries and Ben Schneider (Oxford) overturned the notion, common in recent historiography, that spinners were well paid and part of a high wage economy in England in the 18th century; rather they showed only the most productive spinners in England earned what Arthur Young described, moreover many spinners were employed by parishes at low piece rates under the poor laws. Amy Ridgway (Exeter) presented the only data from agriculture at the conference. Using the records of Kingston Lacy in Dorset she showed that the number of day labourers hired on a casual basis increased throughout the late 18th century and early 19th century, contrary to the established literature. Kathryn Gary (Lund) presented a new wage series for unskilled men in Sweden in the long run. She showed definitively that the wages unskilled men were not enough to support a family.

Four papers presented at the workshop dealt with the earnings of miners or those engaged in the coal industry. Andy Burn (Durham) showed that the keelmen of Newcastle-on-Tyne in the late 17th and early 18th century had pay that consisted of variable elements. Part was for hauling, another part for loading, and the rates varied according to location and season. Although the men were relatively well-paid when they were at work, the seasonality of the trade challenged living standards, and created a public order problem for the authorities. Tim Barmby (Newcastle) has been researching the Allendale lead miners. There men and mine owners bargained a price per fathom to be mined. To bargain effectively they needed to be able to predict, or have better information about the seams and geology that they were mining. Barmby shows that wage bargains were a means by which the mine owners extracted information from the more knowledgable miners. Unsurprisingly, the system produced unequal gains, with the best teams repeatedly winning the bargains. Guy Solomon (Exeter), who has fully quantitatively analysed Peter Kirby’s 2010 data shows that piece rates in coal mining in Northumberland brought about large variations in wage amongst workers doing the same job. Matthew Pawelski (Lancaster) showed how a Derbyshire free miner of the mid 18th century, John Naylor, used his own rights to common mining land to earn a large amount to take him out of a period of significant indebtedness. The case shows that as well as having his own resources, Naylor took local work with other employers when he could, and highlights the multifarious nature of earning for men of this class, and the role of book credit in such small enterprise.

Richard Blakemore (Reading) has spent the last three years looking at how sailors were paid. He debunked the common myth that sailors were an early modern global proletariat paid poorly wages. Instead he shows that Sailors earnings were, again, highly variable – many mariners made money from trading goods between ports. The form in which sailors were paid varied according to risk. Blakemore showed that the bargaining systems between shipowners and mariners benefited both parties at different times. Laundresses – a vital group never properly examined before – are the subject of Kathryne Crossley’s (Oxford) research. Drawing on the records of Oxford Colleges she shows that their status, and the means by which they were paid shifted over the 17th and 18th centuries. In the earlier period they operated as enterprising sole traders, in the 19th century they were integrated into the discipline of college staff. Anne Murphy (Hertfordshire) brought some badly needed research into white collar workers. Bank of England clerks had much in common with sailors – and laundresses – it turns out. The basic salary that the clerks received was at the very lowest end of white-collar earnings in in London. Variation and extra income were earned by the clerks through gratuities, frequently for favours for clients, and trading illegitimately as brokers. Judy Stephenson (Oxford) gave a review approach, centred around the question of trying to work out how representative day wages used in macroeconomics series really are of earners in London across the long eighteenth century. Early research, funded by Cambridge Humanities Grant, indicates that few London workers were paid by the day before 1800. Wouter Marchand (Utrecht) demonstrated that the pay of clergy in early modern Friesland was dependent on the quality of land that church lands produced income from. The clergy are one of those groups that economists love to refer to as sacrificing wages for status. Marchand shows that their wages were not determined by custom. The best paid clergy were in merged or combined parishes on fertile soil.

The commonalities between the cases presented at the workshop was remarkable. These kept coffee breaks and lunch and dinner abuzz with debate, conversation and connections. The most marked was the observation of varying levels of income due to the effects of piece rates, bargaining and variable pay structures. Variation in earnings of people doing the same jobs was a consistent theme throughout the cases presented. Moreover, nearly all the cases showed only small part of income came from basic pay, and auxiliary rates, gratuities, alternate employment and bargains, were used to meet the problems of information asymmetry, seasonality or uncertainty. This was directly related to the materiality of some of the occupations. It was also noted that the agency or bargaining power of workers in a number of sectors was a determinant of their income. A final comment was that that ‘custom’, which dominates a great deal of historical literature, was not mentioned all day as as a determining variable in any of the cases presented.

The conference reinforced the idea held by many participants that wages in the early modern period and nineteenth century were a more complex issue than the use of real wages in long run studies have suggested, but it also showed that the topic of wage formation is ripe for further research. The full proceedings and papers will be published at a later date.

Judy Stephenson. Judy.Stephenson@wadh.ox.ac.uk

[1] Stephenson, EcHR, forthcoming.