The purpose of this article is to compare the new British trade union recognition procedures with those of Canada and the United States. The article considers how the new legal framework in Britain affects the collective bargaining process and contrasts this with North American arrangements. It is argued that the British legal position involves a much lower level of interference with the administration of collective agreements and a much higher level of autonomy and independence given to workers to negotiate their own terms and conditions of employment than is the case in Canada or the United States. The article also examines the level of statutory and judicial support given to union security arrangements in Canada and the United States and compares this with the British position where no change has been made to the extensive range of statutory protections given to the non-union worker.
International Journal of Comparative Labour Law and Industrial Relations