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Hand car washes need licensing to prevent ‘modern slavery'

15 November 2018

Hand Car Washes should require licences to operate to prevent exploitation of workers and water pollution, MPs on the Environmental Audit Committee are demanding.

Chair's comments

EAC Chair Mary Creagh MP said:

“Hand car washes are a common sight in our towns and cities. Yet they hide the widespread exploitation of workers through illegally low pay, poor working conditions and in some cases, forced labour. This is unacceptable.

“We were astonished and dismayed to discover that there have only been 14 minimum wage prosecutions since 1999. The Government must target the sector and prosecute exploitative employers. This would send a strong signal that worker exploitation has no place in the UK.

“Regulators seem to turn a blind eye to breaches of planning and environmental regulations at hand car washes. Being labelled as ‘low risk' must not mean hand car washes are given a permit to pollute. Councils, police and central government must work together to tackle labour and environmental abuses at hand car washes.”

The Report reveals risks to water quality through waste water being allowed to flow into drains that discharge directly into water courses. On combatting labour exploitation, the Committee found a failure of authorities to enforce the law.

Key Recommendations

  • Government should trial a licensing scheme for hand car washes that brings together all of the major compliance requirements, including on environmental pollution, into a single, more easily enforceable, legal requirement
  • Government should review whether the Modern Slavery Act 2015 could be updated to cover businesses as small as hand car washes
  • The Environment Agency should work with immigration, tax recovery and GLAA enforcement to ensure that unannounced inspection of hand car washes are comprehensively investigated for a full range of potential regulatory breaches


In the last 15 years, the rapid growth of cheap hand car washes has led to a drop number of automatic car washes on petrol forecourts of more than 1,100 in the decade up to 2016. Hand car washes now make up 80% of UK car wash sector, competing on costs and convenience of access.

Estimated that 10,000 to 20,000 hand car washes operating on our streets, but there is no accurate figure.

Evidence suggests that as a result of better enforcement of regulations far fewer hand car washes are operating in other northern European countries.

Hand car washes compete predominantly on costs and convenience of access and this has led to widespread practices of undercutting labour standards and other regulation.

However not all hand car washes operate in breach of labour, employment, health and safety and environmental regulations. A commercial “Wash Mark” scheme run by The Car Wash Advisory Service indicates whether a company is meeting best practice standards.


Labour exploitation:

Health and Safety Executive (HSE) found health and safety violations resulting in: one death in unsafe accommodation; cases of trench foot and chemical burns for workers from prolonged exposure to water and 20 cleaning agents.

In the last 3 years the HSE has taken enforcement action against 103 hand car washes with 45 businesses served with notices requiring an immediate stop to work activity, and 27 businesses served notices stating improvements to be made within a specified time period. However, the HSE has not prosecuted any car wash through the courts.

Car washes are one of the most commonly reported sites of labour exploitation according to the Modern Slavery Helpline, which recorded 194 cases concerning the treatment of workers in car washes in 2017, representing 27% of the total cases of labour exploitation.

Further evidence suggested a clear link to human trafficking. In one study out of 450 people who had been trafficked into the UK, 40 were working in hand car washes and had come from Eastern European countries. Examples of poor living conditions for exploited workers included; overcrowded and unsanitary accommodation; shared mattresses on the floor; lack of food with little money to buy more; low or no wages; verbal abuse and humiliation; working in wet clothing and shoes without protective equipment; long hours with few breaks.

Other evidence concerned extreme forms of labour exploitation in hand car washes including reports of worker control exercised through passports or identification documents being withheld, threats of denouncement to the immigration authorities, the threat of or infliction of physical abuse, and debt bondage.

Of the more serious cases of organised labour exploitation, such as modern slavery, the Gangmasters and Labour Abuse Authority (GLAA) said investigations had led to 25 investigations over a one-year period, with three cases being referred to the Crown Prosecution Service. In another case, 5 people are awaiting court hearings. The Committee noted the work by the GLAA and Director of Labour Market Enforcement to step up their efforts to tackle labour exploitation at hand car washes.

There is evidence that the Modern Slavery Act 2015 neglected the role of smaller businesses, such as hand car washes, in the regulation of slavery and lacks attention to local implementation and enforcement of anti-slavery policy. The Report is calling on the Government to consider updating the law to include small businesses such as hand car washes.

Hand car washes with gangs of workers that charge less than £5 per wash maybe an indication that the national minimum wage (NMW) is not being paid.  There was further evidence in a study in Nottingham that found evidence of “wage theft”, defined as non-payment of the national minimum wage or the living wage, holiday pay, and other employment protections.

Under National Minimum Wage law, there have been only 14 minimum wage prosecutions since 1999, a fact the Committee found to be “astonishing.” The Report is calling for more prosecutions for offences such as non-payment of minimum wage. An annual list published by Government that names and shames employers that have been found to be not paying the minimum wage this year included 18 car washes, some of which operate on a major supermarket chain's car parks.

The Committee is calling for major supermarkets and landowners to ensure that hand car washes operating on their sites are compliant with employment and environmental regulations.

Further information

Image: Creative Commons