Working Time Directive

The current approaches to Employee Relations in relation to working time regulations between France and the UK.


The most controversial EU measure in the area of health and safety has been the Working time Directive 1993 .The effect of this directive lead to the Working Time Regulations in UK in 1998 .The regulations introduce a range of significant new rights and entitlements, such as minimum four weeks paid annual leave. There is significant scope in the regulations for employees and employers to enter into agreements ion how the working time rules will apply in their own particular circumstances Collective agreements can be made with workers who are not covered by the collective bargain etc and created a new chapter in the development of the employment conditions across Europe including France and UK and changes in the legislations controlling the Hours of Work has been one of the cornerstones in this process.


Hours of Work Policy & Regulations in UK
A summary of the main features of working-time practices in the UK
State policies, economic conditions and collective agreements influence actual and preferred working hours. These institutions are shaping the current re-organisation and intensification of working-time that can be observed to a greater or lesser degree across Europe (Bosch et al. 1994, European Foundation 1998a, 1998b, Rubery et al. 1995). These policies, and the workplace practices which develop within this context, shape the number of hours that people work, which parts of the day, week and year their employment is concentrated in, and the degrees of variability, unpredictability, and autonomy in their work schedules.


The relationship between actual and preferred working hours is two-way. Working-time preferences influence actual hours through their influence on job search and employment decisions and plans, through individual and collective negotiation of working-time at the workplace, and through their contribution to broader political debates about the organisation and use of time in society. Implicit in all of these processes is the fact that working-time preferences may not be realised due to the competing objectives and constraints that also shape the working-time practices that result. In turn constraints and context shape preferences. Preferences can change if economic conditions, workplace innovations or policy interventions alter the context men and women find themselves in, and their evaluations of their current experiences and the alternatives that they consider are open to them.

Working-time legislation and collective agreements
Until very recently a distinctive feature of UK labour law was that there was no general legislation regulating working time or guaranteeing minimum rest periods or annual leave entitlements. There were restrictions on working time in some occupations where there is a threat to safety, such as in transport. However, junior doctors work some of the longest hours in the UK but there was no limit until the early 1990s when a limited guideline (72 hours per week) was introduced into the National Health Service. The only general legal requirement was that all employees had the right to receive a written contract within two months of starting their employment which specifies the terms and conditions relating to hours of work and holiday entitlement, and the duration of the contract if it is fixed-term (1978 Employment Protection (consolidation) Act, replaced by the 1993 Trade Union Reform and Employment Rights Act) (Hepple and Hakim (1997).

Developments in working-time regulations in the 1980s and early 1990s
In the 1980s and early 1990s the statutory regulations that had offered protection to some groups of workers was dismantled (Hepple and Hakim 1997). Limited regulations fixed maximum hours and paid holidays for certain sectors (mainly retailing, catering, hairdressing and clothing manufacturing) were set by the 1979 Wage Councils Act (replacing earlier legislation dating back to 1909). The coverage and regulations were reduced in the 1986 Wages Act and the wage councils were abolished altogether (with the exception of agriculture) in the 1993 Trade Union Reform and Employment Rights Act. Legislation relating to women's working hours in manufacturing industry, including night work were removed in the 1986 Sex Discrimination Act and the 1989 Employment Act. The 1989 Employment Act also removed a number of restrictions on the hours worked by those between the minimum school-leaving age (16 years) and 18 years. Sunday working in retail had been limited by legislation which restricted the opening hours of shops, but this was repealed by the Sunday Trading Act (1993).

Regulations on the number of hours worked:
The 1998 Working Time Regulations Act implemented the EU Working Time Directive, introducing the first complete legislation in the UK on working time and annual leave entitlements. This introduced the following provisions established in the Directive:
" 3 weeks paid leave, which can not be cashed in (4 weeks since 1999)
" Daily and weekly rest periods (rest period after 6 hours, 11 hours rest in each 24 hour period, one day off in seven)
" Maximum 48 hour week
" Average of 8 hours on night work.
The Directive permitted various derogations and exemptions that have limited its coverage (transport workers, seafarers, junior doctors in training, and managers and professionals whose working time is 'not measured or predetermined' and are thus considered to determine their own hours). The Directive also permitted 'voluntary opt-out' agreements between employers' and employees. A new Directive extending the Working Time Directive to cover transport workers, sea farers and junior doctors was agreed in May 2000 (EIROnline 2000a), which the UK government will be obliged to implement in due course.
Despite the incomplete coverage and limited ceiling on working hours this piece of legislation has still been important for having introduced national working-time regulations into the UK. One important aspect has been the introduction of the statutory entitlement to annual leave. The normal entitlement to annual leave established in collective bargaining was four and a half weeks, but a large minority of the workforce did not have this entitlement, primarily part-timers and full-time manual employees (Fagan 1997:94). It is estimated that around 10% of the workforce have gained from the introduction of a statutory entitlement to annual leave (IDS 1996).
The introduction of the Working Time Directive was resisted by the then Conservative government and was also fiercely opposed by many employers, which is the usual response in the UK to the development of European level regulations. This piece of legislation is still a matter for debate between the current Labour government and the social partners. Those employees covered by collective agreements have always had their 'normal' hours regulated through bargaining, and some reductions in working-time have been negotiated in recent years. The engineering union has traditionally been the pace-setter in working time reductions in the UK and initiated industrial action in 1989 which culminated in a series of agreements which established a 37.5 hour week for many engineering workers by the early 1990s (Richardson and Rubin 1994). Another important example is the 1997 'single status' agreement which reduced the normal weekly hours for manual employees in the public sector from 39 to 37 to harmonise their normal hours with non-manual public sector employees, and which came into effect on April 1st 1999. The 37-hour week in the public sector is lower than the norm set in some parts of the private sector, but not all. For example, a 35-hour week is the collectively agreed norm in the banking sector, which is one of the private sectors that have a reasonably highly level of collective organisation (EIROnline 2000b).
By 1999, the average collectively agreed normal weekly working hours were 38.4 hours per week in the UK, which is close to the average set in most EU member states (EIROnline 2000b). However, few collective agreements set explicit limits on the amount of permitted overtime for the union movement in UK has traditionally focused upon using reductions in basic hours combined with negotiating better rewards for overtime as a means of raising wages (Rubery et al. 1994). Regular and extensive paid and unpaid overtime in the UK means that actual or usual working hours typically exceed contractual normal hours (see Marsh 1991, Harkness 1999). Very long basic or total hours will be curtailed somewhat with the 48 hour ceiling established by the Working Time Directive, although the enforcement of this regulation will be more difficult in the non-unionised parts of the economy.

Hours of Work Policy & Regulations in France

In view of other countries, France appears as a country where working time issues are regulated mainly by law.The successive presence of the socialist government has made things quite eay in France for the introduction of the Hours of Work and the flexibility along with it . It is also necessary to stress the fact that the main evolutions concerning the regulation of working time, particularly those concerning working time reduction, have occured during and after the survey undertook by the Euro foundation . The first Aubry law has been passed in the parliament on the 13 of june 1998. Moreover, this law wanted to indicate orientations, leaving to the social partners the task of giving life to them, while the regulation in itself has appeared with the second Aubry law (january 2 000,the 19th.)

The process of law and negociation in France

Between 1982 and 2 000, around seven laws dealing with working time issues have been introduced in France showing the effort and the policies of the french governments towards the work related environments and considering it as a health and safety issue . From the middle of the 80', the search for a greater productive efficiency has been prevalent in the working time policies either through legislation which gave more room for working time arrangements at the firm level as through the implementation of such arrangements in firms. The two Aubry laws (1998 and 2000) could be considered as the pinnacle of all these legal developments which have occurred during nearly 20 years : the new legislation try to combine the search for an impact on unemployment as well as on the firm's efficiency through combining working time reduction and working time reorganisation. The first Aubry law has associated evolution of the reduction of the legal working week from 39 hours a week to 35 hours a week and that should be implemented from the 1st of january 2000, and social and organisational innovation through incentives given to the social partners in order to negotiate agreements which may depart from the current legislation and consequently influence the future legislation (for instance concerning the way to account professionnal and managerial staff's working time or how to count up working time, e.g on a weekly, annual or, even, a pluri annual basis etc.)

The changing role of the law : From the work sharing issue to working time organization

Successive socialist governments added a series of arrangements aiming at the reduction of working hours at the company's level to the existing legislative frame in order to promote their policy of work sharing and reduction of the unemployment rates in this fashion ,some of these did not succeed as the rules were too many for the usefullness of the corporates in France . This was the case for the so called
"contracts of solidarity" in 1982 that were intended to encourage firms to reduce working hours and to hire additional staff or at least to maintain the level of employment by offering them exemptions from certain social contributions and premium. Others fared better, such as the contractual arrangements which encouraged early retirement of employees aged 55 and over, then taking on the young unemployed to compensate for these retirements, in order to avoid the prospect of several million unemployed. The overall results achieved were disappointing on the whole, and from 1984 the tone of the discourse altered. In a context of continuously increasing unemployment, any improvement in the employment situation was seen to depend on an improvement in the competitiveness of companies, to be acquired through greater flexibility.

The Delabarre law dated 28 February 1986 amended the edict of January 1982 in this direction, and specified that branch agreements should provide companies with the ability to modulate working hours in return for an overall reduction of working time5. Following a change in the parliamentary majority, the Seguin law dated 19 June 1987 added even greater flexibility into work-time legislation, representing a significant liberal swing. In particular, it gave companies and units the option to reach working time agreements without waiting for the prior branch agreements which would
formerly have given them this authority. The law also authorised
abandonment of the obligation to reduce working hours wherever work
schedules were submitted to variations. In summary, the Seguin law
sanctioned a break in the link between the reduction and the organization of working hours, the first now being no more than one of the possible counterparts of the second.
The final significant act in the area was of flexibility regulation was the Loi Quinquennale of 1993. Among others, this law looks at the development of part-time work and the annualisation of this type of employment pattern (part-time work is no longer calculated as previously on a weekly basis, but on a yearly basis). The law also provides a new scheme for short-time working and unprecedented options for departure from Sunday working principles, and so on. These original measures are aimed, not at sharing the available working hours, but at making their use more flexible.

A trend toward decentralised collective bargaining which has been increasingly focused on work-time flexibility and which now tend to match employment issues and productive efficiency.By promoting new forms of regulation of working hours over the last fiteen years, the French government seeks to delegate to the employer's organizations and to the unions the task to negociate and to define the new working time standards. What have been the results of such a strategy? In spite of an interprofessional agreement (29 March 1989) which was in line with the Seguin law (1987) and which stressed the role of the sectorial level as the favoured forum for working time bargaining, the results were very thin. Between 1983 and 1987, only three significant agreements were concluded (public works, the dairy industry and metal industry). Although the 1987 law and the 1989 agreement were looking at the development of the bargaining process, the theme of working hours has remained secondary, and has shown no sign of intensifying. In 1993, only 53 endorsements or agreements dealt with organization of working hours, 36 of which were of a national dimension. Negotiations, when they actually took place, were dealing mainly with arrangements of working hours such as time modulation or part-time working. The 31 october 1995 national agreement concluded in order to encourage the different sectors to conclude agreements linking working time reduction and working time reorganization has also failed insofar as only about 40 agreements (among 128 industries concerned) have been signed. Moreover, the scope of these agreeements was thin as far as the working time reduction is concerned. In companies on the other hand, the contractual dynamic was far more vigorous. In general, the last fifteen years have been marked in France by a large increase in the number of company agreements. Until 1995, an average of 2500 agreements related to working hours, and these were almost exclusively concluded in large companies and concerned mainly the working time organisation. In 1993 for example, agreements on the organization of working hours represented exactly 44.2% of all company agreements. If one leaves out a few compromises which were included with the aim of safeguarding jobs (negotiation of reduced working hours with no compensation in terms of wages), the agreements negotiated in 1993 are very representative of the trends during that period. Half of the agreements cover the organization of working hours in a wide range of diverse forms, such as modulation of hours, part-time working, flexitime, compensatory time off, operating time, shiftwork, week-end shifts, night work for women, etc. But it was practically impossible to find agreements about the reduction of working hours. Since 1996 onwards, important changes have occured as we have mentionned earlier : the number of agreements concerning working time reduction increased in a large proportion, firstly as a result of the Loi Robien and secondly in the frame of the Aubry laws process (200 in 1995 ; 2000 in 1997 as a result of the Robien law and 19000 in 1999: Eurofound.Eu.int : Working Papers on France ).
Comparison:
There are a lot of similarities & dissimilarities among the patterns in the 'Hours of Work' has changed in UK and in France .The main similarities come from the fact that the movements and the legislations in both the countries started at the same time for this cause .The difference is in the approach .In France successive socialist governments have been too proactive in introducing the laws about reduces and flexible working hours whereas the conservative governments in UK are initially opposed to the process of flexibility and reduced work hours .The best example of that came during the protest launched by the British government in 1993 against considering the Hours of Work to be a health and safety issue (Gennard et al 1999 Page 106 ). Introduction of the Employer's Associations has lead to a better environment of collective bargaining as found by Marchington et al 1996(as cited in Gennard et al page 112) and created an environment of collective nature in the issue of the Hours of Work in the countries. The legislations in France have been quite continuous towards the improvement of the Hours of Work issue with continuous amendments but in UK the process has faced several obstacles and making some progress since the introduction of the Hours of Work in the Maastricht treaty .the new governments in UK is following right path at this time, but more political agreement is required to make it a success.

BIBLIOGRAPHY

Gennard J and Judge G. Employee Relations (2nd ed) IPD publications 2000

Marchington M and Goodman J, New Developments in Employee involvement, Dept of employment, 1992

Bosch G., Dawkins, P., and Michon, F. (1994) Times are Changing: Working Time in 14 Industrialised Countries, Geneva: Institute for International Labour Studies (ILO).

EIRO (2000a) 'Extension of working time Directive agreed' EIROnline, May http://eiro.eurfound.ie/2000/05

EIRO (2000b) 'Working-time developments - annual update 1999' EIROnline February. http://eiro.eurfound.ie/2000/02

Ezard, J. (2000) 'UK's work burden grows fastest in Europe' The Guardian, June 21st, p 7. http://www.guardianunlimited.co.uk

Fagan, C. (1997) Absent men and juggling women: gender, households and working-time schedules in Britain. Unpiblished doctoral thesis. University of Manchester, UK.

Harkness, S. (1999)'Working 9 to 5?' in P. Gregg and J. Wadsworth, op cit.

Hepple, B., and Hakim, C. (1997) 'United Kingdom' in European Foundation (1997) Legal and Contractual Limitations to Working Time in the European Union. Luxembourg: Office for Official Publications of the European Communities.

IDS (1996) Employment Europe, issue 413, May.

Marsh, C. (1991) Hours of Work of Women and Men in Britain London: HMSO.

Martin, J. and Roberts, C. (1984) Women and Employment: a Lifetime Perspective, London: HMSO.

Rubery, J., Deakin, S., and Horrel, S. (1994) 'The United Kingdom' in Bosch et al. op cit.

Rubery, J., Fagan, C., and Smith, M. (1995) 'Changing Patterns of Work and Working-Time in the European Union and the impact of Gender Divisions', V/6203/95-EN Brussels: European Commission (DGV).
http://www.eurofound.eu.int/working/options.

Paul Bouffartigue1 and Jacques Bouteiller :Is the working time of managerial staff a clockable bargaining issue?
http://www.univ- aix.fr/lest/lespublications/contributionsadesouvrages/2001/bouff/bouffis.pdf


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