Convergence in Industrial Relations Institutions: The Emerging Anglo-American Model?

At the outset of the Thatcher/Reagan era, the employment and labor law systems across six Anglo-American countries could be divided into three pairings: the Wagner Act model of the United States and Canada; the Voluntarist system of collective bargaining and strong unions in the United Kingdom and Ireland; and the highly centralized, legalistic Award systems of Australia and New Zealand. The authors argue that there has been growing convergence in two major areas: First, of labor law toward a private ordering of employment relations in which terms and conditions of work and employment are primarily determined at the level of the enterprise; and second, of individual employment rights, toward a basket of minimum standards that can then be improved upon by the parties. The greatest similarity is found in Canada, the United Kingdom, New Zealand, and Australia. Ireland retains a greater degree of public ordering, while the United States diverges in favoring the interests of employers over those of employees and organized labor. The authors explore reasons for the convergence.