The hand car wash (HCW) industry has consistently been identified as one of a number of areas where workers are vulnerable to exploitation and poor working conditions. Violation of labour, employment, health and safety, and environmental regulations are well documented as are incidences of more sinister criminal activity such as human trafficking and modern slavery. The continued presence and use of non-compliant car washes normalises illegal labour practices, and damages the reputation of the industry and those associated with it.
It is easy to fall into the trap of thinking that all hand car washes are non-compliant; those that are should be held to account, but not all fall into that category. There are many legitimate, compliant, professional HCWs found within networks and independent operators that are defining a new standard. These sites need recognition if they are to be the driving force for raising standards across the whole industry. In 2015 the Modern Slavery Act came onto the UK’s legislative books, representing the first legislation of its kind in Europe with the aim of tackling modern slavery and human trafficking, crimes which are sadly prevalent in today’s society.
Every business in the UK with a total annual turnover of £36m is now legally required to produce a slavery and human trafficking statement. This must show measures that are in place to ensure that modern slavery is not part of their business or supply chains. Regardless of whether your business meets the threshold of having to produce this statement, your association with a HCW on your premises could be putting your reputation and brand at risk if that car wash is operating non-compliantly. Furthermore, your business could be prosecuted if your tenants are operating non-compliantly, and the site subject to police and multi-agency visits.
In October 2018, the Responsible Car Wash Scheme (RCWS) was launched to drive up standards in the HCW and valeting industry. It is designed and supported by a consortium of stakeholders including the Gangmasters and Labour Abuse Authority, the Modern Slavery Police Transformation Unit, the HSE, the Environment Agency, HMRC and the charity Unseen. Underpinned by an Industry Code of Practice, the RCWS provides a compliant framework for operators, a mechanism by which customers can identify an ethical car wash, and a tool for landlords to assess the compliance of their suppliers.
In 2019 several pilots were implemented to stress test the scheme’s evidence requirements, audit regime and reporting criteria. They also identified how it could be used as a tool for the police and other enforcement agencies to enforce compliance within the industry. The pilots included working with three major national networks located on supermarket sites in the East and West Midlands; working with a major fuel retailer and their independent supplier; and most recently working with Thames Valley Police and the South East Regional Organised Crime Unit under Operation Flinch, targeting independent sites in Slough.
Our first pilot saw the RCWS working with 44 network-operated sites located on supermarket car parks. All sites were required to complete an online application form, provide comprehensive evidence of how they met the Industry Code of Practice and were subject to a site audit undertaken by the GLAA and RCWS. Many examples of compliant practice and good customer service were found. Sites which complied fully with environmental regulations; where workers were paid a fair wage and had good working conditions; where the business traded legally and customers were given an excellent level of service. These sites will be among the first to gain RCWS accreditation in 2020.
Our second pilot, working with a major fuel retailer, allowed us to illustrate the value of the scheme to landlords who rent out space on their forecourt to an independent operator. The RCWS audit of the business gave the landlord an assessment of the whole business operation including labour and employment practices. In this particular case it resulted in the immediate closure of the site.
Operation Flinch, our most recent pilot, identified a quick and efficient way in which to reach independent car wash operators, who are by far the biggest segment of the industry. Using Police intelligence, each site was visited by officers from the Regional Organised Crime Unit and the RCWS, allowing for the operator to be identified and for an initial assessment of the site. Operators were then invited to attend a workshop to learn more about regulatory compliance and encouraged to apply for RCWS accreditation. The workshop was very well received with over 70% of the sites visited being represented, with both operators and landlords attending. As a result of the workshop, several sites ceased operation after realising that their location was wholly inappropriate for a car wash and would not achieve accreditation. Subsequent to the pilot, we are supporting sites as they work towards accreditation.
Following the success of Operation Flinch, the RCWS is planning to work with other police forces, replicating the campaign and supporting sites that wish to achieve accreditation. This will complement our engagement with supermarkets, national networks, petrol retailers and other major landlords.
If you have a car wash on your forecourt, make it a requirement that it gains RCWS accreditation. Doing so will minimise the risk that the car wash is violating labour, employment, health, safety and environmental regulations. Furthermore you will enhance your reputation and brand by giving your customer base confidence that your supplier is an ethical one.
If you’re in any doubt as to how engaged the consumer is in reporting suspected bad practice, look no further than the Clewer’s Safe Car Wash App, designed and operated by the Church of England. Since its launch in 2018, there have been more than 8,000 individual reports generated by the public visiting car washes, which is testament to the fact that the public are getting better at spotting the signs.
We recognise that educating the consumer is vital if we are to create an environment where running a compliant car wash is a sustainable option. We will be working with our many supporters to raise awareness of the scheme during 2020 so that consumers can make an informed decision when choosing who washes their car and to enable them to choose a site that looks after its workers, trades legally, and looks after the environment. And they are making those decisions thousands of times a day across the UK. This year looks set to be a busy one for the RCWS. Come and join us.
For more information get in touch at admin@RCWS.org.uk