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Otis, Cindy L by wfq74180

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									                                     Otis, Cindy
   Disabled and Unemployed: Employment Variations in Europe
                         Faculty Mentor: Wade Jacoby, Political Science

        According to the 1996 European Community Household Panel (ECHP) survey, disabled
people account for an estimated 14.5 percent of the total working-age population of the European
Union, of which 42.6 percent are employed (Van Lin et al. 2001). This means that of a
population of 65 million people, roughly 30 million are employed. The European Union’s (EU)
core disability strategy has a four-fold emphasis aimed at increasing the civil rights of people
with disabilities. These emphasis include improving co-operation between the Member States,
encouraging exchange and development of information and good practice in the EU, raising
awareness of disability issues, and ensuring that disability issues are taken into account in all EU
legislation and policies (EU Charter on Fundamental Rights of the European Union). Through
documents and declarations such as, the Communication on “equality of opportunity for people
with disabilities,” the Communication “towards a barrier free Europe for people with
disabilities,” and the Council Resolution “on promoting the employment and social integration of
people with disabilities,” the EU has shown its commitment to a civil rights approach to
disability employment issues (EU Supplement 2003). However, because Member States have
control over national employment policy, the employment situation for people with disabilities is
diverse across the EU. The employment rate in many EU countries is more than half that of the
EU average (see Appendix I). This paper endeavors to explain why employment levels vary
across the EU by arguing the importance of two things—policy choice and national disability
organizations.,2

        In order to understand what factors most affect employment levels for people with
disabilities, it is necessary to consider the three main schools of thought on the issue. First, the
Organization for Economic Co-operation and Development (OECD) published a report arguing
the significance of active versus passive labor market policies on disability employment levels
(2001). According to the study, active labor policies (such as vocational training) encourage the
integration of disabled people into the labor market and therefore increase employment levels.
On the other hand, passive labor policies (like pension benefits) only increase economic
incentives to remain out of the workforce. The report is helpful in that it gives an effective and
detailed explanation of how certain kinds of legislation effect employment levels. Additionally, it
lays out the various policies and categorizes them as active or passive. However, it neglects to
consider why governments choose one type of policy over another. The OECD study also does
not consider the effect institutions have on employment levels. Without these considerations, the
OECD fails to produce a comprehensive analysis.

          The second key study on employment levels by Mariana Preda hypothesized on the roots
of attitudes towards people with disabilities. The study described how the development of
attitudes towards people with disabilities affects their ability to access the labor market (2000).
In her theory, Preda describes a situation where cultural attitudes suppress people with
disabilities so that they do not have the resources to become politically active. Because there is
little to no representation of people with disabilities in society, people with disabilities are not
considered in the development of legislation. Therefore, nothing encourages the changes to
cultural perceptions necessary to increase the integration of people with disabilities into society.
While Preda’s study addresses the very real issue of attitude, she fails to make the necessary
connection between cultural barriers and institutional barriers. Furthermore, basing the argument
entirely on cultural attitudes neglects the influence of legislation and policy choice on
employment levels.

        The third approach to disability employment levels is much more pertinent to the
question of why employment levels vary for people with disabilities. According to Lisa
Waddington and Matthew Diller, disability policies are “rooted in core assumptions [within the
nation state] about the nature of disabilities and the obligations of both individuals and society”
(2002, 1). These core assumptions can be grouped into two specific models: the social welfare
model and the civil rights model. Each country in the world can be classified as following either
the social welfare model or the civil rights model, following a mixture of both, or transitioning
from one to the other. Looking at the kinds of legislation a government pursues indicates which
model they follow, Waddington and Diller argue (22). Each policy has a well-known effect
(either exclusion or integration). If a country relies on socially excluding policies, they are
categorized as following the social welfare model. On the other hand, if a country relies on
integration policies, they are following the civil rights model.i The social welfare and civil rights
models help us to understand the reasons why governments choose certain disability policies.
However, the models are not complete enough to be the only indicator of employment levels.
Waddington and Diller’s theory does not consider the impact of political active, national
disability organizations on employment levels.

        In order to understand why national disability organizations are such an important
variable, I will submit four ways (if politically active) they can effect employment levels. First,
national disability organizations are extremely influential in determining which social model
(and thus policy choices) the government follows. Through political lobbying, disability
organizations have historically played a major role in civil rights movements. Second, national
disability organizations can gain a comparative advantage in knowledge about the needs of
disabled people within their country (Symes 1995, 262). As a result, national disability
organizations have the ability to provide useful information and make recommendations
regarding potential legislation. Regional and international disability organizations, on the other
hand, often make recommendations without considering unique national circumstances.
Governments can consult the organizations in potential changes or creation of legislation (Mont
2004, 16) . Third, generally speaking, disability organizations focus on one particular kind of
disability (organizations for the blind, deaf, physically disabled, etc.). If used in policy
consultation, they have the ability to work together, ensuring that all types of disabilities are
represented and taken into account in legislation. In regards to employment policy, this would
mean that governments ensure access to the labor market for all types of disabilities. Fourth,
many national disability organizations are involved in vocational rehabilitation and employment
services in addition to or in place of the services the government provides. This includes
organizations that provide job training, assistance in placement, or that organize international
exchanges to help develop skills and experience. Due to their roles as lobbyists, legislative
consulters, service providers, and campaigners, the existence or non-existence of national
disability organizations make a difference in employment levels.
         After a brief overview of the existing theories, their gaps, and a discussion of the
importance of national disability organizations, the complexity of employment variation is
obvious. The tendency would be to begin the analysis by making some connections. For
example, countries with low employment levels have many common attributes.4 Generally they
do not have specific legislation for people with disabilities; anti-discrimination rights are granted
generally through the nation’s constitution; there is little to no oversight or assessment of how
effective employment initiatives are. The exact opposite is generally true in countries with higher
employment levels for people with disabilities. However, this is over-simplifying the problem. In
this paper I will argue that the factors mentioned above are themselves, effects of a previously
unnoticed combination of factors. I will show that the mixture of the social welfare and civil
rights models and the existence of politically active, national disability organizations have the
greatest effect on the employment levels of people with disabilities. To do this I analyzed the
current employment situation of people with disabilities in two European countries—Poland and
the United Kingdom. Both countries at first glance appear to be following a general trend in
Europe—the governments pursue policies from both the social welfare and the civil rights
models (Bermeo 2001, 16). Yet the United Kingdom enjoys an employment level of roughly 50
percent, while Poland fluctuates around 20 percent.5 With a detailed overview of legislation and
institutions, I will show that these two countries represent the generally more complex situation
of people with disabilities in Europe, where the combination of social models and politically
active, national disability organizations are the greatest indicators of employment levels.

Social Models
         At this point it is important to understand the nature of the social models and how
disability employment policies fit under each model. The social welfare model sees disability as
a medical deficiency in an individual that makes them unable to work or function in society in
conventional ways. Disability is both an excuse from the obligation to work and a ground for
denying employment. The exclusion of people with disabilities is an inevitable natural
consequence of medical realities (Franchet 2001, 56-58). As a result, the government designs
social institutions such as employment and public services to meet the needs of the majority of
the population—the non-disabled. Rather than adapting these institutions to accommodate
disabilities, people with disabilities are removed from the mainstream. They are moved to a
separate, but parallel track that provides income and services completely apart from the
institutions that serve the non-disabled majority (Waddington and Diller 2001, 3). The state,
under the social welfare model, passes employment legislation for people with disabilities that
either provides generous pension benefits or creates segregated jobs specifically for the disabled
(see Appendix II). At the same time, people with disabilities are not completely ignored under
the social welfare model. Instead, policies and programs are developed to address what the
government perceives as basic needs. There are two main kinds of legislation or programs
typically created under the social welfare model—cash/pension benefits and sheltered
employment (Hviden 2002, 33).

        The civil rights model, on the other hand, views disability as a reason to reform
mainstream institutions. It rejects the premise that social exclusion is an inevitable consequence
of disability. Under this view, people with disabilities have historically been excluded from
social institutions because those institutions have failed to adapt to the needs of the disabled,
even as they routinely adapt to the needs of others (Shapiro 1993, 5-16). Seen in this light, the
problem is one of discrimination, rather than the need to address the inherent medical limitations
imposed by disability. Under the civil rights model, the goal of disability policy is to reform
mainstream social institutions to include people with disabilities, rather than exclude them.
Moreover, as the non-disabled majority gain increasing contact with people with disabilities,
prejudice decreases (Waddington and Diller 2001, 5). In regards to employment policy, the civil
rights model creates an expectation that people with disabilities continue in the workforce and a
requirement that employers accept them. Therefore, governments pursue three major policies
including quotas, anti-discrimination laws, vocational and rehabilitation services.

        In order to discover which aspects have the greatest effect on employment levels, I
analyzed the intended goals of each policy and categorized each area as following either the
social welfare or civil rights model based upon the above articulated definitions. The results can
be seen in Appendix II. In the following section, I will do two things: (1) give a general lay out
of the main policies in Poland and the United Kingdom’s governments pursue and how they fit
under the social models; and, (2) discuss how employment levels are affected.

        Poland
        According to the Ministry of the Economy, Labour and Social Policy, in 2002 611,000
people with disabilities were employed (European Industrial Relations Observatory On-line
2003). The low level of employment for people with disabilities in Poland is largely due to the
government consistently pursuing two major forms of disability policy classified as the social
welfare model—pension benefits and sheltered employment—to address disability concerns.
Disability employment policy gained importance after the fall of communism and the transition
to a market-based economy. Rather than increase unemployment rolls, people were funneled into
the disability pension system. Additionally, many employed people with minor disabilities
applied for a disability certificate because of the relative ease of being defined legally disabled.
Consistent with the social welfare model, disability was defined based on a medical
characterization. However, no precise regulations were established to define disability or
measure how each disability would impair one’s working ability (International Disability Rights
Monitor). By 1995 the government was spending 4.3 percent of its GDP on pension benefits for
people with disabilities, and the ratio of beneficiaries to labor participants ranked among the
highest in Europe (see Appendix III). About 5.5 percent of the total population received
disability pension benefits (Hoopengardner 2001, 12).

        The rising number of people receiving benefits lead to a series of reforms in 1995 and
1997 to encourage those capable to return to the workforce. First, eligibility for the program was
tightened to only include people with a demonstrated loss in functional capacity that would
preclude work. Second, a new training pension was established that paid higher benefits but that
could only be received for a limited period of time. As a result, disability pension expenditures as
a percentage of GDP began to fall. From 1995 to 2000, the percentage dropped from 4.3 percent
to 3.8 percent. Newly awarded pensions in 1990 numbered 241,400. By 1996 that number fell to
151,600 and reached 102,400 by 2000 (Bergeskog 2001, 226). These reforms may be seen as a
transition from the social welfare model to the civil rights model. Indeed, many viewed the
reforms as a positive change because they led to a decrease in the number of people receiving
pension benefits. However, disability was still viewed as a medical issue justifying exclusion
under these reforms—one of the main tenants of the social welfare model. According to the
Center for International Rehabilitation in 2001, the reforms excluded a significant portion of the
disabled population that should have received benefits. As a result, reductions in benefits
lowered the standard of living for people incapable of working. Additionally, a 2001 OECD
study showed that despite reforms, Poland did not made progress in addressing standard of living
issues or significantly reduced the extent of cash benefits since 1985 (see Appendix IV).

         The second major policy Poland pursues consistent with the social welfare model is
sheltered employment. This means that the government provides employment in segregated
facilities, either in a separate sheltered business or in a segregated section of a standard enterprise
for people with disabilities. In Poland there are 10.1 sheltered workers per 1000 of the
population—the highest in the EU (Klemmer and Wink 2000, 67). As of late September 2003,
there were 2,988 sheltered entities operating across the country, employing 208,000 people with
disabilities. The State Fund for Rehabilitation of Disabled People (Państwowy Fundusz
Rehabilitacji Osób Niepełnosprawnych or PFRON) is a state-operated fund created to support
activity geared to the social and professional rehabilitation of disabled people. At least 65
percent of the Fund’s revenues (paid by employers not meeting quota requirements) are
channeled into employment. 96.2 percent of the employment budget goes to subsidizing
employers of people with disabilities. However, almost 75 percent of that amount goes to
continuing sheltered work programs (Godfrey and Richards, eds 1997). In keeping with the
social welfare model, sheltered employment creates a separate but parallel track of employment.

         While Poland relies heavily on policies from the social welfare model, it also pursues
policies typically categorized under the civil rights model. However, the policies are often un-
enforced and do not include any anti-discrimination policies. Even if the policies are enforced,
they often further the separation of disabled people from mainstream society. First, the Polish
government employs quotas, requiring employers with at least 25 employees to hire a certain
percentage of disabled people (6 percent). Disability quotas are a regulatory approach for
promoting the employment of people with disabilities by directly influencing labor demand
(Thornton 1998, 72-74). The implicit assumption is that without quotas employers are turning
away disabled workers, either because of discrimination, a perception that they are not as
productive as disabled workers, or the unwillingness to bear the costs needed to accommodate
disabled workers. However, there is a quota-levy system in place in Poland, allowing employers
to opt out of hiring disabled persons by contributing money to PFRON. Yet, most employers
neither employ the minimum number of people with disabilities required nor pay the fee for
failing to satisfying the requirement. In fact, article 67 of the tax ordinance allows the
forgiveness of tax obligations (Barr 1994, 76-80). Therefore, most employers prefer to fight for
forgiveness rather than fulfill their obligations to the Fund, rendering the quota system virtually
useless.

        The second civil rights-based program that the government provides is vocational
rehabilitation and training. Vocational rehabilitation includes programs on training or retraining,
on vocational guidance and on selective placement. These enable people with disabilities to
secure, retain, and advance in suitable employment and thereby assist their integration or
reintegration into society. Polish labor law puts a cap on the number of hours people with
disabilities can work (approximately two to five hours per week less than non-disabled
depending on the region). During that time people with disabilities are expected to go to
vocational rehabilitation or receive treatment. However legally, employers are still required to
pay them for those hours. This not only decreases incentives to hire the disabled, but also further
separates people with disabilities from society.

        As shown through this brief policy layout, Poland relies heavily on policies that both
exclude and separate people with disabilities from mainstream society. While employment policy
appears to have aspects of the civil rights models, such as quota requirements and vocational
rehabilitation, these policies are inefficient and not enforced. Furthermore, Poland has not taken
any steps to creating anti-discrimination legislation. Policy choice for Poland, then, has a major
impact on employment levels.

       The United Kingdom
       The history of employment policy choice in the UK corresponds significantly with
employment levels. Initially disability employment policy in the United Kingdom (comparable to
the current conditions in Poland) consisted of an ineffective quota system, a reliance on pension
benefits, and separate employment institutions. The Employment Act of 1944 provided a basic
framework for the employment of people with disabilities. The Act established a register of
people with disabilities, aided them in obtaining jobs through rehabilitation and training, and
imposed the requirement that employers of twenty or more people employ a minimum of three
percent of people with disabilities (Neil and Thornton 1993, 201). To help secure jobs for people
listed in the register, a specialized, separate employment placement service was created to
monitor employment vacancies that could be filled by people from the register. However, the
resources of the employment placement services were limited and unable to adequately monitor
vacancies and propose candidates for employment. By the 1970s, it was proposed to eliminate
the quota mandate as unworkable, but there was no agreement on an alternative policy. The
quota system was the biggest failure of the employment act because of the extensive use of
exemptions. The quota requirements were also poorly publicized; businesses were generally
unaware of their obligations under the act. At the end of the 1970s, employment levels fluctuated
around 35 percent (Zagler 2004, 67-74).

       During the 1990s, the government made a major shift towards the civil rights model
regarding employment policy. First, and most significantly, starting in the early 1990s, disability
rights issues and anti-discrimination gained support and prominence in the UK. In general terms,
anti-discrimination laws made it illegal to base employment decisions on a person’s disability. In
the UK, the Disability Discrimination Act of 1995 (DDA) addressed such rights as equal
opportunities and equal participation in working life for people with disabilities. The DDA made
it unlawful for employers to treat people with disabilities less favorably than someone else due to
their disability (Mont 2001, 16). This applied to all areas of employment including recruitment,
training, promotion, and dismissal. Under the DDA, employers were required to make reasonable
changes in the workplace for disabled employees. The DDA is in the nature of the civil rights
model. It recognizes people with disabilities as equal members of society, entitled to full
integration into society. Two years after the creation of the DDA, Employment levels reached 43
percent (Disability Rights Commission 2004).

     Second, the UK began to reform mainstream institutions to meet the needs of the disabled
(even though people with disabilities still have special, independent programs based on need). A
number of mainstream institutions became responsible for implementing disability employment
policy. For example, the Department for Education and Employment (DfEE) became responsible
for implementing most aspects of the national disability employment policy (Muntigle, Weiss
and Wodak 2000, 46). It oversees the employment provisions of the Disability Discrimination
Act through the National Council for the Employment of People with Disabilities. Another
mainstream institution used to implement disability employment policy is the Employment
Services (ES) agency. ES operates Access to Work (a coordinated program of financial
assistance and practical aids to help overcome obstacles in the workplace) and oversees
vocational rehabilitation programs like Placement, Assessment and Counselling Teams (PACTS)
(International Disability Rights Monitor).

      Third, the government (under New Labor) began to focus on policies designed to integrate
people with disabilities into the labor market by reforming the pension benefit system. One of the
main developments included the “Welfare to Work” strategy, helping people move from benefits
to work by “providing work for those who can, and security for those who cannot” (Bergeskog
2001, 254). Under this strategy, the government launched the New Deal for Disabled People in
1998 aimed at rectifying economic disincentives that discourage people with disabilities from
entering the labor market. The deal addresses work disincentives by allowing people with
disabilities entering the workforce to keep their benefits for their first year of employment. The
New Deal also includes strong coordination between government agencies, employers, and local
disability groups. In 2001 the government established the Working Age Agency combining the
Employment Service and the Benefits Agency departments serving people of working age
(Overbeek 2003, 171). The new agency focuses specifically on accelerating the shift from a
welfare system that primarily provides passive support to one that provides active support to help
people with disabilities become more independent. According to the OECD, the UK has had the
second highest outflow of people with disabilities exiting the benefit system with a rate of 3
percent. By 2002, employment levels reached 50 percent, the highest in the EU (Disability
Rights Brief 2004, 6).

      Fourth, the government reformed its work based learning programs for youth and adults
(typically termed vocational rehabilitation). In 1998 the government established Work Based
Learning for Adults (Bergeskog 2001, 267). This program for long-term unemployed adults was
created to help unemployed people with disabilities gain occupational skills needed to fill locally
identified skill shortages or to move into self-employment. In the same vein, a program
specifically for young people with disabilities was created to equip them with the qualifications
and practical skills needed to gain sustainable employment.

      While it appears that the UK has made a complete shift from the social welfare to the civil
rights model, it is important to note that the UK relies heavily on sheltered employment
programs. Second only to Poland, there are 5.6 sheltered workers per 1000 of the population in
the UK (Mont 2004, 20). However, UK sheltered employment programs are unique in that it
generally does not create a separate track from mainstream employment. Introduced in the mid-
1940s, sheltered employment programs were meant to ensure the appropriate level of job
opportunities for people with disabilities. While sheltered employment in the UK involves
working in supported factories and businesses, it also involves placement in a company where
the employee works on the same terms and with the same day-to-day support/supervision as
other employees (Bergeskog 2001, 262).

       Some reforms have taken place recently to try to make sheltered workshops more of a
stepping-stone. First, employers must consider open employment options before selection into
supported employment, and must show why open employment is not feasible. Second, there
must be a goal for transition to open employment (Philpott 1997, 124). This has already proven
markedly successful in companies like Remploy (a nationwide non-departmental public body
that is a non-profit organization that operates commercially) that have increased the number of
people with disabilities transferring to open employment by 4 percent (Bergeskog 2001, 266).
The government also began to provide incentives (such as back to work grants) in 2001 for
people to transition from sheltered employment to regular employment. Thus, despite sheltered
employment, the UK has made an almost complete transfer to the civil rights model.
       As shown, the UK follows policies aimed at the integration of people with disabilities into
mainstream society. Furthermore, increases in employment levels correspond significantly with
major government civil rights legislation and institution reform. Thus, the UK’s transition to the
civil rights model has positively affected employment levels.

National Disability Organizations
       As discussed, the adherence to one of the social models effects policy choice and thus,
employment levels. The variation in employment levels between Poland and the United
Kingdom can be largely attributed to the differences in the kinds of policies the countries pursue.
However, the social models are not complete enough to explain the variation by themselves. As
previously stated, the activity of disability organizations is the other part of the puzzle. In
discussing disability organizations it is important understand why disability organizations are
considered a separate independent variable instead of an effect of the social models.
Governments cannot regulate the existence of national disability organizations or groups.
Citizens with a common interest (in this case, disability issues) or goal create disability
organizations. No matter which social model a country pursues, national disability organizations
exist (even in the most remote countries).

         At this point, it may be helpful to recall the four previously stated roles of national
disability organizations regarding employment. First, national disability organizations have the
ability to effect which social model a government pursues through political lobbying. Second,
national organizations understand the specific needs and situation of people with disabilities
within their country. Third, disability organizations can work together in order to ensure that all
disabilities are considered in developing legislation. Fourth, national disability organizations can
provide much of the vocational rehabilitation and employment services for people with
disabilities in place of or in addition to the services provided by the government. With the roles
clearly laid out, it is imperative to recognize the difficulty in measuring the impact of disability
organizations on societal changes and policy choices. Even though it is relatively easy to chart
the goals and outline the programs each organization offers, assessing their influence is largely a
qualitative measurement. In the following section, I will show that the existence of politically
active national disability organizations significantly affect employment levels.

       Poland
         In Poland, the most influential disability organization is the government-run State Fund
for Rehabilitation of Disabled People (PFRON). While PFRON is the main actor in disability
organizations in many respects, disability NGOs have been given much of the responsibility to
assure and implement state-suggested programs. For example, regional NGOs are required to
implement vocational rehabilitation, counseling, and employment programs consistent with
regional development strategies.6 The Ministry of the Economy, Labour and Social Policy claims
that it consults national disability organizations regarding potential employment legislation.
However, the Center for International Rehabilitation, estimated that disability NGO’s are only
consulted fifty percent of the time (International Disability Rights Monitor). This means two
things. First, because the state channels the majority of its funding into PFRON, other disability
organizations are left to battle over the rest of the money. Because of scarce resources, disability
organizations in Poland generally encompass all types of disabilities instead of being disability-
specific. Second, disability organizations generally focus what resources they have on ensuring
basic needs (such as income security) instead of lobbying and campaigning for civil rights
changes. In this respect, organizations have played a more passive role in Poland.

         PFRON is the major player in most disability issues. As outlined in PFRON’s charter,
their main duties include: preparing and reviewing draft legislation concerning employment
policy and vocational and social rehabilitation, cooperating with NGOs, reviewing plans on
employment policy, funding jobs (i.e. sheltered employment) at risk of being cut, establishing
vocational counseling services, preparing regional programs to improve the quality of life for
people with disabilities, and establishing associations, unions, and employee organizations at the
national level for people with disabilities (European Industrial Relations Observatory On-line
2003). While PFRON is the main actor in disability organizations, because it is state-run
PFRON’s future and focuses are determined by the government. In 2003 there was a proposal to
dismantle PFRON completely. While the proposal did not pass, PFRON’s future is uncertain.
Because it is the main disability organization (and the main voice for disabled people in the
government) in Poland, if the government cut PFRON the situation would be chaotic for disabled
people. National disability organizations would have full responsibility for disability issues.
However, most national organizations are just now laying the foundation that will give them the
ability to become more proactive. With the current lack of resources for national disability
organizations, NGOs would find it almost impossible to take over PFRON’s responsibilities.

         One of the disability organizations working towards becoming more politically active
(independent from the government) is the Polish Association of Disabled People (PADP),
established in July 1988. PADP is by far the largest national disability organization (outside of
the government) in Poland with one thousand members including citizens, members of other
NGOs, and government officials. When PADP was established, its goal was income security for
people with disabilities. However, over the years that goal has changed. The passive approach
many disability organizations take can be seen in the hesitant language of PADP’s charter. It
states that the main objectives of the association include “inspiring and organizing” various
forms of disability prevention and rehabilitation development programs for people with all types
of disability, “organizing regional, national, and international recreation and sporting events for
people with disabilities”, removing transport and architectural obstacles, increasing “societal
awareness and respect” for disability, and “impacting” social policy and legal regulation in the
area of equal opportunities.7 At the same time, PADP is slowly becoming more involved in
issues beyond income security. As PADP’s website indicates, the organization is becoming
increasingly aware of the importance of anti-discrimination legislation and a more integration-
based approach. With a successful transition to a civil rights approach, the PADP and similar
NGOs have the possibility of greater influence in the government.

       Due to the historically passive role of national disability organizations in Poland, there
are few institutions pushing for a shift from the social welfare to the civil rights model. While
PFRON gives people with disabilities a voice in the government and influences policy
development, its future is unsure. National organizations are transitioning slowly, but they
generally play little to no role in policy development or review.

        The United Kingdom
      The role of disability organizations in the UK is very different. National disability
organizations serve as policy monitors and act as catalysts for change in the UK through
lobbying (Shapiro 1993, 33). In April 2000 an Act of Parliament established the Disability
Rights Commission (DRC), a public service organization aimed at stopping discrimination and
promoting equal opportunities for people with disabilities. While the DRC is funded by the
government, it is not accountable to the government. Its statutory duties are: “to work to
eliminate discrimination against disabled people, to promote equal opportunities for disabled
people, to encourage good practice in the treatment of disabled people, to advise the government
on the working of disability legislation” (primarily regarding the Disability Discrimination Act
(DDA) 1995 and the Disability Rights Commission Act 1999) (Scottish Executive 2005). The
DRC is not responsible to the government and therefore, it has the ability to lobby and campaign
against the government for change in the workforce. For example, the DRC publishes literature
detailing practical guidance to employers and service providers on how to meet obligations under
the DDA. The DRC also publishes materials on how to integrate and accommodate disabled
workers in businesses to change employer attitudes. The DRC has also led several successful
campaigns that have turned into legislation, like the 2004 “Access for All” campaign.

        In addition to the DRC, national disability organizations across the UK actively lobby the
government for the rights of the disabled. According to the International Labor Organization,
disability organizations played the biggest role in securing the creation of anti-discrimination
legislation (Scotch 1984, 5). There are many ways disability organization lobby for change in the
UK. First, they join Cross Party Groups that deal with specific disabilities or disability issues.
Second, there are many point of access to disability organizations due to the devolution of the
Scottish and Welsh Parliament. Because of the relatively accessible nature of the three
parliaments, disability organizations can arrange meetings with various Members of Parliament
and suggest putting forward questions and motions. Third, if an act is about to be put forward as
legislation, disability organizations can lobby for amendments or suggest changes. They can do
this through e-mail, leaflets, policy documents, or meetings.8

        The Royal Association for Disability and Rehabilitation (RADAR) is one of the most
politically active disability organizations in the UK. Formed in 1977, RADAR has approximately
700 members including individuals, organizations of and for disabled people, and corporate and
public-sector organizations. RADAR’s main activities include: devising upbeat and proactive
campaigns towards the social inclusion of people with disabilities, providing quality
campaigning tools and services to organizations of and for disabled people, and developing
networks to maximize the development of inclusive policy, legislation, and regulations. RADAR
also works to create relations with employers. According to RADAR, working relationships with
local employers enhance the success of employment for people with disabilities.9 For the United
Kingdom pro-active relations with employers was identified as a successful way to help people
with disabilities to move into or stay in employment.

        Disability organizations are in general, extremely politically active in the UK. As
explained, national organizations were instrumental in pushing the shift from the social welfare
to the civil rights model. Additionally, because organizations give people with disabilities a
greater voice in the government and society (through lobbying, campaigns, and the services they
provide), they automatically impact employment levels.

Conclusion
       The European Union encourages co-operation and information sharing through a civil
rights approach; however, because Member States have control over employment concerns the
situation for people with disabilities is extremely diverse. While factors such as specialized
legislation, active versus passive policies, and cultural attitudes affect employment levels, the
most significant factors include the social model a country follows and the existence of national
disability organizations. The social models show why governments choose certain policies and
what affect these policies have on access to the labor market (either integration or exclusion).
National disability organizations by comparison influence which model is pursued, lobby for
change, have a comparative advantage in information, and provide employment services.

      As outlined, Poland takes a very social welfare based policy approach. The government
consistently relies on pension benefits and sheltered work programs to address the needs of
people with disabilities. This has resulted in (in addition to exclusion from the labor market and
mainstream society, disincentives to entering the workforce, and a dependence on the
government to guarantee income) low employment levels in Poland. The United Kingdom, on
the other hand, has followed a civil rights based path since the early 1990s. This includes specific
anti-discrimination legislation, a serious reform of the benefit system, and a reliance on
vocational rehabilitation services. This transition to integration policies resulted in employment
levels above the EU average.

      Regarding national disability organizations, Poland relies heavily on the state-run PFRON
to handle disability issues. The majority of PFRON’s budget goes to continuing sheltered work
programs that separate people with disabilities from society. Additionally, national organizations
independent from the government play a very passive role. Due to the lack of resources,
disability organizations in Poland have been unable to successfully lobby the government or
pursue issues beyond income security. Employment levels suffer in Poland because there is no
one pushing for change. They UK’s disability organizations, by comparison, lobby, campaign,
disseminate information, publish materials, review legislation, and build relations with
employers to combat common misconceptions about disabled people. While the government
established the DRC, the DRC is not responsible to the government. The DRC and other national
organizations were instrumental in the civil rights movement. Employment levels are above the
EU average largely because disability organizations are politically active.
      Despite a thorough overview of the employment situation for people with disabilities, this
study is not without holes. As discussed, the statistics are not always reliable. Countries have
different ways of gathering numbers, questions they ask on surveys, ways of measuring
responses, and definitions of disability. Additionally, percentages and raw numbers are not
available for every year in all countries. The study would be much more complete if there were a
way to track employment levels every year. For example, Poland started compiling statistics only
within the last decade, and data is not available for the UK during the 1940s when employment
issues gained importance. With more complete data, a cross-country comparison would be more
attainable. Furthermore, this paper did not discuss all of the factors that may influence
employment levels. However, because of the scope of this paper, the most probable factors were
included. Even with these gaps, this analysis furthers the (necessary) study of disability issues by
asking important questions and drawing conclusions. However, further study on the matter is
necessary.

        With more attention to disability employment issues, several things will happen.
Primarily, it will facilitate the break down of social and political barriers surrounding people
with disabilities in the EU. In turn further study will initiate the integration necessary so that
people with disabilities will become a more active societal group. Second, it will allow for the
expansion of the labor market to include other disadvantaged groups in society. Furthermore,
further understanding of the root of policy choice will encourage the adoption of more effective
governmental policies and programs. Finally, analyzing the politics of disability employment
laws in the EU will encourage the same type of study on the other parts of the world.
1
  It is important to note before continuing that the study of disability policies has been a largely untouched topic over the years.
This is due to many factors that may hinder collecting clear and concrete data. Many countries do not take regular or ad hoc
national surveys in order to generate even a rough estimate of how many citizens are disabled. National surveys on employment
numbers for the disabled are even more rare. However, in cases where surveys have been taken, the methods of collection may
vary from country to country and may either be unreliable, incomplete, or contradictory. Despite the statistical barriers inherent
in studying disability policy, it is still a worthwhile topic because people with disabilities account for such a large portion of the
European population. This is the first attempt at making sense of the roots of disability policy and its effects on employment
levels for people with disabilities.
2
  Disability legislation is a complex topic. This paper does not begin to address all of the factors involved in the legislation
process. But there are a few key conflicting issues surrounding disability policy that should be recognized. Disability policy has
two goals, which are at times in conflict—income security and integration into social and economic life. Policies aimed at
generating full participation of people with disabilities often downgrade the safety net, creating more risks. People who are not
successful at achieving a certain level of integration can suffer. Yet, programs that guarantee benefits can serve as a disincentive
to participate in the labor market. The challenge is to provide supports and incentives that facilitate full participation, while
ensuring the means to live a decent life regardless of any disability. Further complicating disability policy is creating programs
for such a diverse population. Disabling conditions are quite varied, ranging from mild to significant and consisting of physical
disabilities, sensory disabilities, mental disabilities that are cognitive or developmental in nature, and mental health conditions.
Furthermore, some are congenital while others are the results of injuries or illnesses. They can affect the old or the very young,
meaning that policies must address people entering the workforce, those wishing to remain or re-enter it, and those nearing the
end of their working lives.

3
 While this main sound circular, the problem is that it is impossible to measure a government or society’s attitudes towards
people with disabilities. There are ways of predicting it, however—one of the biggest being pursued policies.

4
  From this point on, I will assume the reader will understand that when I discuss employment levels, I am referring to
employment levels of people with disabilities, unless specified otherwise.
5
  Additionally, both countries have a large population of people with disabilities as compared to the EU-average. In a 1996
Eurostat report, the UK reported that 18.9 percent of their population had some kind of disability; Poland reported 18.4 percent.
6
  Regional in this sense means in regions of Poland. This is opposed to regional in the sense that Europe as a whole is a region.
7
  This information is available on PADP’s website at http://www.pson.ipl.net/us/index_us.html.

8
 These three points came from an interview with Sandra White, Member of the Scottish Parliament. She is also a member of the
Equal Opportunities Committee.

9
    This information is available on RADAR’s website at www.radar.org.uk.

								
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