The hand car wash sector has long been identified as an area of high risk for labour market abuses, as well as a multitude of other non-compliances. Mathew Taylor used his first speech as Interim Director of Labour Market Enforcement in February 2020 to call for the mandatory licensing of hand car washes, having reached the conclusion that “a range of forms of non-compliance are endemic in the hand car wash sector”. The government’s recent decision to create a single enforcement body responsible for employment rights provides the opportunity to consider both the extension and implementation of licensing regimes to new sectors.
The Responsible Car Wash Scheme (RCWS), launched late 2018 to drive up standards in the car wash and valeting industry, supports the licensing of hand car washes. Its Code of Practice and audit regime provides independent third-party assessment, confirming compliance across the different facets of regulation that cover hand car washes. Despite having proved its effectiveness, we find that many operators are reluctant to sign up to the RCWS scrutiny because they feel that many of their competitors continue to operate with apparent impunity.
The number of car washes across the country is now believed to be in the region of 7,000, a significant reduction from figures previously quoted, following extensive mapping undertaken by Nottingham Trent University. Of these, independent operators have a substantial market share being located at petrol stations, garages, retail car parks as well as at standalone premises. Data collected from The Clewer Initiative’s Safe Car Wash App contributes to our understanding of both the location of these sites as well as concerns over noncompliance.
In a new pilot, the RCWS is working with the Gangmasters and Labour Abuse Authority and Slough Council to evaluate the effectiveness of the scheme when implemented with the support of local council enforcement. Each operator is being asked to demonstrate compliance in planning consent, trading standards, payment of business rates, site health and safety, environmental disposal of waste and compliant employment practices. Operators are encouraged to apply for RCWS Accreditation with successful sites being able to display the RCWS logo evidencing to consumers and enforcement agencies that they have demonstrated compliant practices. As an incentive, operators in Slough have had their accreditation fees waived.