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Impact case study

Reducing Exploitation of Vulnerable Workers at Informalised Exploitative Workplaces: Evidence from Hand Car Washes in England

Unit(s) of assessment: Business and Management Studies

Research theme: Safety and Security of Citizens and Society

School: Nottingham Business School


Unregulated labour at hand car washes (HCWs) creates problematic workplaces that sustain wage theft, modern slavery, and environmental and health hazards. NTU’s multi-disciplinary research is the first to develop robust methodologies that identify the number, location and risk posed by HCWs across England. The research directly informed the Environmental Audit Committee report (2018), and Director of Labour Market Enforcement (DLME) enforcement strategy documents (2018, 2020 and 2021) on policy for HCW licensing. The predictive modelling and HCW risk classification tool directly inform enforcement operations at the Gangmaster’s Labour Abuse Authority (GLAA), Regional Organized Crime Units (ROCUs) and Her Majesty’s Revenue and Customs (HMRC).

Research background

NTU’s research revealed the problematic nature of HCW workplaces and develops innovative employment relations methodologies to determine the scale of these and the factors that shape the presence of HCWs within specific neighbourhoods across local authority areas in England.

Phase One developed new theoretical insights on unregulated informal practice; ‘permissive visibility’, theorises abandoned spaces and economic restructuring and ‘mimicry’ theorises how these businesses avoid the attention of regulators where wage theft from workers is endemic. Lastly, we distinguish between labour market exploitation, modern slavery and labour trafficking at HCW sites. A range of business models (lawful and unlawful businesses, ‘pop-ups’, and trolley washes at supermarkets) were identified, and common practices of concern on worker welfare, recruitment, remuneration, conditions of work and coercion were highlighted. Phase Two developed these insights empirically and:

a) estimated the number of HCWs operating across England,

b) risk classified sites in relation to physical/environmental hazards and worker welfare; and

c) identified ‘opportunity structures’ that explain the spatial distribution of HCWs within and across English local authority areas.

Unsubstantiated estimates by regulated business stakeholders suggested that 20,000 HCWs were in operation across England. The research suggested that whilst still problematic, the scale of the unregulated sector was between 4,000-5,000 sites. It was identified that the presence of potential sites (petrol stations), demand from other businesses (second-hand car salesrooms), and declining, predominantly low skilled local economies created the opportunity structures for HCWs to emerge. In contrast to this greater neighbourhood belonging, localities with greater young and retired populations acted as protective factors.

The research identified the number of HCWs advertising online across 30% of neighbourhoods in England outside of London. Virtual neighbourhood tours using Google Street View in conjunction with physical ‘drive-throughs’ identified significant numbers of other HCWs. All sites were risk classified in terms of physical structure, environmental hazards and worker well-being drawing upon the interviews undertaken in Phase One plus information from Google Street View imagery and various forms of social media. Binary logistic regression was then used to identify the risk and protective factors that explained the presence or otherwise of HCWs within neighbourhoods at the LSOA (Lower Super Output Area) level. Using ONS Area Classification to identify different neighbourhood types within each local authority area, the evidence from the predictive spatial modelling was then used to arrive at a revised estimate of the number of HCWs across England.


Parliamentary process

Written evidence was submitted to the Environmental Audit Committee evidence call, and Professor Ian Clark was invited to give detailed oral evidence at the Parliamentary sessions in June 2018. The committee’s subsequent report centres on the NTU evidence submission and quotes the express call for licensing throughout the report to government. Most significantly, NTU research was extensively covered in the national news media and had a direct impact in raising public, parliamentary and regulatory awareness, and the public profile of labour and environment abuse at HCWs. As the following quote demonstrates, these impacts would not have occurred without NTU research:

"There is no data to indicate what proportion of the UK’s hand car washes may be evading tax or in breach of environmental, employment, and health and safety laws. However, we heard it claimed that it could be as high as 90%. Researchers at NTU said that ‘in terms of owner, landlord and regulator responsibilities our research found a confused and permissive picture where many blind eyes were being turned’. ‘We (EAC) were told that a “spectrum of exploitation” is going on at hand car washes on Britain’s streets from non-payment of the minimum wage or holiday pay to more serious cases of debt bondage and labour trafficking’."

National strategies

NTU’s published research made a direct impact on the 2018 DLME National Enforcement Strategy document that cites the work. This includes a policy recommendation that HCWs become an area of licensed work, a policy position developed after a formal consultation meeting with Clark at the Department of Business, Energy and Industrial Strategy September 20th , 2017. This policy would not have occurred without NTU’s work.

This impact was realised in December 2018 when the government accepted the recommendation for a pilot licensing study. NTU research rapidly accelerated (from a pilot) to a pathfinder where its iterative processes directly shaped policy actor objectives, design and policy delivery. The research will inform and be cited in the next DLME annual report/strategy document when it is published.

Regulatory activities

A third series of direct impacts were on regulatory strategy and practice. These followed an April 2019 invitation to make a second presentation to the DLME at BEIS, where we reported on NTU’s digital and predictive modelling. The impact of this meeting was realised as the DLME wrote to the CEO of the GLAA directing him to our research and requesting he use it. An associated impact is that the models will be of use to regulators beyond the introduction of any licensing regime for HCWs.

Each of these steers has had a direct impact on GLAA policy. Clark and Fearnall-Williams are now members of the GLAA user policy group and attend these monthly sessions at the GLAA HQ. In June 2019, they met the GLAA’s Head of Prevention and Head of Strategy – who now works with NTU, and in partnership with the GLAA and consequently within months mapped was carried out for the North-East of England.

The GLAA used these data to inform their operations following a series of training sessions with operations staff attended by two members of the team. These operations commenced in February 2020 before Covid-19 related cessation and will now to take place in Spring 2021 when one of the team will accompany the operations team. In February 2020, the work was presented at a DLME strategy workshop at BEIS and in June 2020, the DLME was updated via a Teams meeting on the research findings. This presentation and meeting led to the DLME and the GLAA formally endorsing NTU’s research, citing its impact on strategy and policy and collaborating with us in a successful funding application to the AHRC.

NTU research has improved the GLAA’s knowledge base and enables them to improve enforcement operations following on from the risk index produced by the research.

A final direct impact saw the research shape and influence the operational delivery of ROCUs nationally, for example, enforcement operations in Berkshire Operation Flinch, which Pickford attended. Furthermore, Greater Manchester Combined Authority modern slavery and organised crime team Programme Challenger used the research to understand the risk of HCW locations by mapping the NTU research insights with theirs. One impact of the research here is that Programme Challenger investigated the top ten problematic HCW sites for the region and found that three were problematic but not of immediate interest to them, four were no longer operational, and three sites are now under investigation that will lead to enforcement action (closure). These sites were not known to Programme Challenger until NTU’s research findings revealed this to them.


  • Clark, I. And Colling, T., 2016, online first (2019). New insights into informal migrant employment: hand car washes in a mid-sized English city. Economic and Industrial Democracy. 40 (3) pp.755-775. ISSN 0143-831X
  • Clark, I. And Colling, T. (2018). Work in Britain’s informal economy: learning from road-side hand car washes. British Journal of Industrial Relations: an International Journal of Employment Relations.56:2, 320-341. ISSN 0007-1080
  • Clark, I., 2018. Abandoned spaces and technology displacement by labour: the case of hand car washes. New Technology, Work and Employment. ISSN 0268-1072
  • Clark, I., Hunter, J., Pickford, R., Fearnall-Williams, H. (2020) How Licensing regimes can displace trade unions? Evidence from informal employment in Britain Economic and Industrial Democracy, Online first