Labour Exploitation in the UK’s Hand Car Wash Sector

14 August 2019
Research Innovation

Akilah Jardine  | Research Fellow at the Rights Lab, University of Nottingham

Hand car washes (HCWs) are a relatively new phenomenon in the United Kingdom. Prior to 2004, their presence in the UK was virtually non-existent. However, evidence suggests that up to 20,000 HCW operations currently exist in the UK, making up 70 per cent of the share of the car wash market and inhibiting the growth of the automated car wash industry. They often spring up on the side of the road, petrol stations, disused forecourts, supermarket car parks and former public car parks, offering a low cost and conveniently accessible car wash service. In an age of technological advances, such labour intensive operations are fuelled largely by an abundant, low-skilled workforce.

HCWs and other businesses that are labour-intensive and utilize cheap, low-skilled labour are often susceptible to exploitative labour and employment practices, in addition to violating a host of other regulations. HCWs have attracted a lot of attention over recent months as investigations have unearthed numerous labour, employment, health and safety, and environment violations. Reports suggest that HCW workers work excessive hours, are paid below the national minimum wage and operate in poor living and working conditions. A notable case is the death of Romanian national Sandu Laurentiu Sava who was electrocuted in August 2015 while showering in squalid accommodation adjacent to the car wash where he worked, as a result of his employer, who had provided the accommodation, bypassing the electricity meter.

HCWs are widespread across the UK, yet the number of operations in existence remains unknown. Despite being known as one of the main industries in which labour exploitation occurs, the fragmented nature of the sector makes it difficult to identify and address violations. Separately, public acceptance and normalization of exploitative labour and employment practices in favour of a cheap car wash service—reportedly as low as GBP 3—has allowed abuse to thrive in plain sight.

Hand car wash. Elly Johnson/Unsplash.

In 2018, the Rights Lab and the Office of the Independent Anti-Slavery Commissioner  carried out a collaborative study on the nature and prevalence of labour exploitation and modern slavery in HCWs. We brought together existing information, including press reports, parliamentary evidence submitted to the Environmental Audit Committee, and new information from interviews and surveys with police authorities and key stakeholders. The research recognizes that labour exploitation does not rigidly fit into a specific category, but rather there is a continuum of abuse from below national minimum wage payments and poor working conditions at one end and modern slavery at the other.

Though operating in plain sight, the lack of data on this sector is one of the main challenges to assessing the extent to which labour abuse within HCWs constitutes modern slavery, human trafficking or lower level forms of abuse. This is partly due to the National Referral Mechanism (NRM)—the UK’s system for identifying victims of modern slavery and human trafficking—aggregating all labour and criminal exploitation into one category, rather than breaking it down by sector. The research found that HCW workers have been referred into the NRM by law enforcement officers and positively identified as victims. However, the exact number of victims identified is undetermined.

One police force we interviewed described cases of individuals trafficked from Romania, made to work in car washes for two weeks and only paid GBP 10. The workers collected dropped coins from the cars they washed to survive. Another police force reported a car wash where workers had their entire routine dictated to them, including what they should eat, when to work and when they could go to sleep.  We also found that some workers may not self-identify as victims of labour abuse or victims of modern slavery given the lack of alternative options to improve their livelihood.

Because many of these workers don’t see themselves as victims, it could lead to law enforcement overlooking exploitative labour practices. We also found that the status of a worker in the UK may hinder the identification of victims because workers without employment rights may choose not to engage with law enforcement, fearing their irregular status be found out.

Law enforcement often turn a blind eye to HCWs, allowing them to flout regulations such as paying taxes, paying workers the national minimum wage and adhering to environmental, health and safety standards. But there has been evidence of efforts to improve compliance in this sector. While the government has rejected the Environmental Audit Committee’s proposal to trial a licensing scheme for the sector, it supports the Responsible Car Wash Scheme, an industry-led voluntary licensing scheme. The Scheme’s Code of Practice covers core issues such as environment protection, health and safety, labour and employment rights, financial transparency and corporate governance. Such a code not only ensures that car washes are compliant with legislation and regulation, but could also educate entrepreneurs, particularly those who are unaware of the necessary regulations they should abide by, and thus are inadvertently complicit in violations.

Separately, the Safe Car Wash app was launched by the Clewer Initiative—the Church of England’s modern slavery initiative—and the Santa Marta Group to provide a community intelligence-led approach to mapping car washes across the UK and gathering data in relation to modern slavery. The app enables users to anonymously provide information on the location and setting of the car wash, workers’ access to suitable clothing, living arrangements, the presence of minors working on site and the cost and method of payment. Users are prompted to call the Modern Slavery Helpline if their answers indicate that there is a likelihood of modern slavery at the car wash. Anonymous data collected from the app is shared with the National Crime Agency, the Gangmasters and Labour Abuse Authority, and the National Police Chiefs’ Council. These agencies are given real-time access to the data to help develop their intelligence on car washes. The Safe Car Wash app shows the potential value of using technology in raising public awareness and using the community to gather intelligence on the sector.

HCWs can be commercially viable while ensuring that their business operates in an ethical, legal and responsible manner. They are not illegitimate business activities, but unregulated operations that not only threaten workers’ rights but also undercut an entire legitimate sector. By better regulating them and raising public awareness, workers can be made safer and the risk of labour abuse and modern slavery can be reduced.

This article has been prepared by Akilah Jardine as a contributor to Delta 8.7. As provided for in the Terms and Conditions of Use of Delta 8.7, the opinions expressed in this article are those of the author and do not necessarily reflect those of UNU or its partners.

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