 One of the philosophical problems raised by the housework debate is how to draw the line between work and play or leisure activity when the activity is not paid: is a mother playing with her baby working or engaged in play? If the former, then her hours in such activity may be compared with those of her husband or partner to see if there is an exploitation relation present, for example, if his total hours of productive and reproductive work for the family are less than hers (cf. Delphy 1984). But to the extent that childrearing counts as leisure activity, as play, as activity held to be intrinsically valuable (Ferguson 2004), no exploitation is involved. Perhaps childrearing and other caring activity is both work and play, but only that portion which is necessary for the psychological growth of the child and the worker(s) counts as work. If so, who determines when that line is crossed? Since non-market activity does not have a clear criterion to distinguish work from non-work, nor necessary from non-necessary social labor, an arbitrary element seems to creep in that makes standards of fairness difficult to apply to gendered household bargains between men and women dividing up waged and non-waged work. (Barrett 1980).