Reflections and Methodological Proposals

Olivier Giraud ^[1] and Frédéric Rey^[2]

Abstract

This chapter considers the methodological issues raised by the international comparison of gray zones in work and employment. It shows how globalization and decentralization have undermined national structures and so unsettled the customary basic categories of comparison—wage labor, the firm, the State. As the objects of comparison are no longer stable systems but evolve dynamically, it argues for the combination of quantitative and qualitative approaches to capture shifting realities in all their complexity. This approach is illustrated by reference to a study of the health of trade union representatives that shows how activist fatigue is one consequence of the institutional changes in course. The chapter concludes with an appeal for the methodological renewal that will enable the mapping of new relationships of power and emergent, hybrid forms of work.

   

Keywords: International comparison; mixed methods; scales; categories; gray zones.

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This chapter offers a methodological reflection on the comparative analysis of gray zones in work and employment, bringing together three lines of thought on comparison and the methodological challenges it presents. Each yields its own insights into the analysis of gray zones. The first begins with a review of the basics of the comparative method—its forms, its rationales, and its principal contributions as a means to discovery—and looks at how, in the light of these, it might be usefully applied to the gray zone in work and employment. The second considers recent changes in scales or levels of regulation and their consequences for comparison. The social sciences of today, industrial relations systems, and the regulation of work and employment more generally all developed and were institutionalized in their own national contexts at more or less the same time, beginning in the last quarter of the nineteenth century. Since the 1980s and ‘90s, a profound change in the relative significance of the different scales or levels of regulation has put into question not only the methodological foundations of comparison but also the logics governing the regulation of work and employment. This change, then, calls for a reconsideration of the methodology of comparison. The last part of the chapter then looks at the specific problems posed by the gray zone as an object of study, notably its lability and its multiform character, and the methodological responses that have been developed to enable international comparison. The chapter as a whole, then, takes the comparative method, a cornerstone of the scientific approach in the social sciences, and examines how it can be used to identify, characterize, and analyze the gray zone in labor and employment, given the specific problems posed by this particular object of study.

According to its canonical definitions, comparison involves the identification of similarities and differences between two or more comparable entities—such as social groups, firms, localities, countries, or social dynamics (Haupt and Kocka 2009). This seemingly simple operation also requires the deployment of frames of reference that most often take the form of abstract and contextualized categories. In general, one does not compare two countries such as France and Germany, but rather, for example, their vocational training systems or their systems of industrial relations. There has been much theoretical discussion, notably in sociology and labor economics, regarding the relationship between such systems and the employment levels or the economic competitiveness of the industrial sectors or nations concerned. These abstract categories thus play a fundamental role in comparison, because they allow one to situate the objects of study in relation to specific issues, whether economic, political, social, or scientific.

These categories that serve as the backdrop to any exercise in comparison have thus been fertile in research questions and results. They are nonetheless marked by an ambivalence that stems from the inevitable tension between abstraction and contextuality. For if a category of comparison seeks to embrace a large number of distinct historical realities, as it tends toward the universal it will necessarily, for the very sake of the exercise, increase in abstraction. Yet any gain in abstraction is at the same time a loss of contextuality, and the comparison will have little of significance to say regarding the many concrete instances (Sartori 1991). A category such as “vocational training,” for example, refers to such diverse realities within a single national economy—ranging from “on-the-job” apprenticeships to long, formalized, school-based programs leading to certification, as well as in-house corporate training—that this overly general category has no relation to the specifics. It is, for example, too abstract to be useful in explaining why the degree of protection against the risk of unemployment provided by vocational training should vary by country. Conversely, if a category is too contextualized—tailored to a single case or a small number of cases—it loses its ability to take into account other situations, in different local, national, or otherwise variant contexts. It loses in abstraction what it gains in contextuality. If one were to limit the comparison of historical systems of initial training to the apprenticeship systems developed in Rhenish Europe since the Middle Ages, this would necessarily entail limiting the comparison to a few countries—or run the risk of applying the category to systems that are, in fact, quite foreign to it. This dilemma lies at the heart of the concept of the ladder of abstraction (Sartori 1991, 254), which aims to resolve the contradiction by situating categories of comparison between the tendency to universalization—and thus to generality and abstraction—and the tendency to individuality and contextuality, historical in particular.

The concept of the ladder of abstraction is both spatial and dynamic: it entails reference to both the level of comparison (local, regional, sectoral, etc.) and the dynamics of the categories being compared (circulation, competition, diffusion, resistance, etc.). It thus invites us to ask whether it is legitimate to transpose ideas developed within one historical context into others—and if so, how? What, for example, do wage labor, retirement, strikes, or sick leave mean in countries that have not experienced the long history of the institutionalisation of work, with its labor movement struggles and its construction of systems of social protection (Castel 2003)? Such questions of method are of enormous importance, as work and employment are subject to processes of categorization and classification linked to institutions and organizations, such as those governing industrial relations. On the one hand, categorization assigns places and roles to workers within the organized, hierarchical systems of the world of work. On the other, the social and political issues of that world are also informed by comparison, which has been increasingly deployed in recent years, whether in political argument or as an instrument in the formation of public policy. Used by governments, organizations, or international institutions, comparison is often intended to justify reforms to national systems of employment, social protection, and industrial relations, making the question of contextuality even more salient.

Comparison as a Method of Acquiring Knowledge

Human societies and social dynamics cannot be subjected to experiment. Comparison is therefore one of the few methods available to the humanities and the social sciences for the explanation of historical phenomena such as unemployment, strikes, or social inequalities, or for understanding how social mechanisms such as the market, solidarity, or political deliberation function.

Although comparison in the social sciences and humanities is empirical in vocation, its capacity for discovery, for yielding new knowledge, is closely tied to theory. The relationships between social phenomena that it reveals contribute directly to theoretical construction. It also allows the testing of theoretical hypotheses, and thus the amendment or even invalidation of established theoretical propositions. Comparison also offers a number of more concrete advantages. It helps combat insularity and self-referentiality (ethnocentrism) by drawing lessons from foreign social or cultural realities or from local experiments that are little known within their own national context or field. The shift in perspective that comparison entails also leads, in turn, as a result of this detour through the examination of exogenous realities, to a richer understanding of one’s own social reality. It should, however, be noted that the comparative perspective in the social sciences has long suffered from a focus on categories and norms developed in European and Western societies. Since the start of the twenty-first century, calls for the “provincialization of Europe” (Chakrabarty 2000) or a “decentering” of the categories of comparison (Giraud and Lallement 2021) have urged a broadening of the methods, reference points and geographical scope of international comparison.

In terms of method, comparison is beset by fundamental oppositions of paradigm, contrasts being commonly drawn between a historical tradition of comparison, on the one hand, and a sociological on the other (Passeron 1991), or between a more Weberian, interpretive, tradition, and another more Durkheimian and explanatory (Leca 1992).

The historical tradition of comparison is more individualizing, more “case-oriented” (Ragin 1987), and therefore more contextualized. It requires in-depth knowledge of the cases studied in order to understand their internal logic, in this according with the approach of interpretive sociology. In the context of such in-depth, qualitative research, comparison can only involve a small number of cases, most often two or three. The decisive contribution of this style of comparison is that it enables a thorough understanding of the social dynamics under analysis through the production of in-depth case studies. There is, for example, a tradition of research comparing labor market regulation in France and Germany, whether in terms of vocational training, industrial relations or employment policy (Maurice, Sellier, and Silvestre 1986; Didry, Wagner, and Zimmermann 1999). These studies have revealed the historical roots of two distinct national configurations, as well as the logics of institutional complementarity at play in both cases—logics that undergird—or once undergirded?—a certain coherence on either side of the Rhine, notably between the educational system, the industrial relations system, and the style of workplace relations.

The historical approach to social explanation—qualitative, in-depth, and case-oriented—stands in contrast to a more sociological and quantitative approach. The latter aims to uncover systematic links between variables, notably in order to derive laws governing social phenomena. This tradition of comparison has correspondingly been called “variable-oriented” (Ragin 1987). It allows for the analysis of relationships between a wide variety of variables—provided they are documented and the data are available—most often with the aid of statistical tools. For example, there is a wealth of literature on the links between unionization rates and unemployment rates, drawing on and analyzing international statistical data—though the results to date have been contradictory and inconsistent. On the other hand, there are studies based on statistical data that not only yield a complex description of a phenomenon but also lead to the development of robust comparative explanations. For example, analysis of the gender pay gap within a single national context can involve the comparison of practice across a wide range of occupations and economic sectors (Dupray and Moullet 2015). And from this one learns that women are disproportionately disadvantaged when in predominantly female occupations or when they start a family earlier.

However, statistical relationships between variables often do not make immediate sense. On the one hand, beyond the raw statistical relationship, particular attention has to be given to distinguishing between correlation and causality and to the identification of any hidden variables, and on the other hand, additional analysis may be necessary. So to understand why women are even more disadvantaged in terms of pay when in predominantly female-dominated occupations requires one to draw on previous studies, or even to undertake qualitative research. Setting aside the opposition, then, a good many comparative studies today combine both quantitative and qualitative methods (Giraud and Maggetti 2015). And finally, we must note that the interpretations that give meaning to statistical relationships may be influenced by biases specific to the analysts.

Comparative studies of the regulation of the labor market or employment have also made use of models. Informed by the empirical realities found in a number of countries, regions, or industries, and inspired by Weber’s concept of the “ideal type,” these models represent a stylization of the facts. They often spring from the comparison of contrasting cases and lead to the development of typologies. In the 1990s, for example, Neil Fligstein and Haldor Byrkjeflot (1996) compared national employment regulation regimes using the concept of the employment system, which links the mode of provision of occupational training, a key resource for securing employment, to the relative power of the key actors in employment systems and to ensuing career patterns. While models frequently remain abstract constructs inspired by theoretical analysis, comparison often relies on the kind of “regime” derived from real-world cases. These cases are most often historic configurations of the characteristic variables of the models. It is the coherence of these configurations, as represented in those models, that allows one to speak of systems. In this case, the American researchers identified three employment systems: a vocationalism fostered by industrial trade unions and characterized by vocational training and a career in the occupation; a professionalism promoted by expert groups and their associations, characterized by university education and specialist qualifications followed by a career within the profession; and finally, a managerialism sustained by firms, with firm-specific training provided to an intake without specialist qualifications leading to a career within the firm.

Once the structural variables of the different systems have been identified—such as the relative weight of different types of training within the vocational training of a country or industry—it is possible to use statistical analysis to determine which group different countries fall into—vocationalist, professionalist, or managerialist. Thus, abstract categories inspired by real-world cases—the notion of professionalism, for example, likely being inspired by Germany, managerialism by France or some other country sharing the same characteristics—can then be operationalized in statistical indicators, enabling new kinds of analysis of quantitative data that will be applied, albeit according to a distinctly different logic, to other empirical cases.

In the varied uses made of categories in the construction of the typologies or “models” so important in the field of work and employment, one again finds the ambivalence already mentioned between abstraction/generality on the one hand, contextuality/individuality on the other. This ambivalence is, of course, crucial when considering levels of comparison and gray zone dynamics. In this regard, one is again struck by proliferation of international comparisons, driven by a growing fascination with statistics and the search for models and best practices to be disseminated. Though statistical sources have never been more abundant, the increasing fragility of the categories and indicators to which the numbers are referred raises questions about the meaning and scope of comparisons, and of institutional comparisons more particularly. With gray zones in mind, then, there are three characteristics of modern comparison that bear thinking about.

On the one hand, there is an ever-increasing production of data, accompanied by corresponding increases in accessibility and in the capacity to process it, and this more especially in the North, which again raises the question of comparability with data sources from other countries. On the other hand, the data is being produced amid growing uncertainty regarding the definitions of the objects, populations, categories, and spaces to which they relate. Finally, the political uses of comparison raise questions: such practices as naming and shaming, benchmarking, and the publication of international rankings (e.g. Shanghai) that pit national systems against one another (e.g., education systems [PISA], welfare systems, etc.).

The Difficulties of Comparison and the Phenomenon of the Gray Zone

The question of levels of comparison has taken on new significance in the contemporary sociopolitical context, notably in the field of work and employment. Sociology, and, following in its wake, the other social sciences, emerged in the late nineteenth century, at a time deeply marked by the phenomenon of the nation. Institutions—government departments, schools and universities, and later, systems of social protection—all modernized in that same context. During this pivotal period, which—depending on the (European) country—might be said to extend from 1870 to the years immediately following the Second World War, national cultures were theorized, national languages were standardized and imposed at the expense of the regional, and public space became national, as did the spaces of the economy and of social regulation. That the emergence of the social sciences coincided with the institutional, sociopolitical, and cultural closure of national spaces was undoubtedly a factor in the rise of methodological nationalism, with the development of national corpuses of analytical and theoretical work within the social sciences, on the one hand, and the naturalization of the nation as a key context for the emergence—and thus the understanding—of social phenomena on the other. For social scientists—for sociologists, political scientists, and economists, at least—to speak of a “society” is to speak of a national society. Émile Durkheim, for example, strongly insisted in The Rules of Sociological Method (Durkheim 2013) on international comparison’s irreplaceable contribution to sociological analysis.

This naturalization is, however, today being put into question by a number of trends. Firstly, significant decentralization has occurred in the countries of Europe, even in the most centralized, like France and the United Kingdom. Secondly, supranational processes of regional integration—the most significant being European integration under the aegis of the European Union and its predecessors—have also set limits on the relevance of the national framework. Finally, the process of globalization, a multifaceted development affecting the most diverse power relations in society, likewise puts into question the historic preference for the nation as the key context for the understanding of social interaction. The factors driving globalization are many, but two are undoubtedly worth mentioning. In the first place, the continuing weakening of national power over the regulation of finance and trade and the retreat of national public authority more generally, in a variety of domains, are the direct consequence of the dominance of neoliberal discourse and policies in Western societies since the 1980s. On top of this, the new information and communication technologies have led to a denationalization of cultural space, of the space of political debate, and, to some degree, the space of socialization of social actors. Although social influences and affiliations used to develop within a variety of frames of reference—local, regional, religious, political, or other—these were always linked, in one way or another, to the national context. The wave of globalization and the progress and diffusion of technological advances are contributing to an ever-greater and more rapid opening-up of these frameworks beyond the national sphere. They are helping bring about an acceleration, expansion and multilateralization of the circulation of social and cultural norms unprecedented in scope and scale—among these the regulatory norms in the domain of work and employment. These norms, whose mutation is so closely tied to globalization, will be addressed in the following section.

How, in fact, does the transformation of the national hierarchy that structured the relations between spaces of regulation within a determinate, that is, nation-centered context, and which prevailed throughout much of the twentieth century, affect the regulation of work and employment? And how is this transformation linked to the phenomenon of the gray zone?

First, the dissolution or erosion of earlier hierarchies leads to the autonomization of widely varying spaces of regulation—from the firm to transnational sectoral spaces, for example—and weakens the legitimacy of national regulation. This autonomization of regulatory spaces by sector, issue or object of regulation results almost automatically in a proliferation of standards and benchmarks relating to the regulation of domains of public policy, work and employment foremost amongst these. The rationalization of power relations and regulatory roles that had historically been the strength of the national frame of reference is thus put into question, in these domains too, by the weakening of existing scalar hierarchies.

Secondly, as a direct consequence of the mechanisms described above, the diversification of reference norms, the reduction of the state’s capacity to bring order to this diversity and the state’s loss of legitimacy in general are leading social actors to break free of former affiliations and to create ad hoc normative configurations. Such reconfigurations are especially evident in the very particular context of the labor market, at the intersection of the economic, social, political, and indeed technical spheres. They sometimes lead to new forms of isolation, of withdrawal into oneself and reliance on norms of one’s own—most notably in the case of the self-employed—or to the adoption of norms that regulate work in other contexts, which become accepted norms of behavior in certain segments of the labor market. Large companies, for example, draw inspiration from new forms of work organization—with the creation of “labs” and community spaces—that have long existed in alternative, creative, and artistic communities. The acceptance of a certain degree of precarity, notably among younger generations, stems from the adoption of norms previously confined to certain sectors. In this, the discoherence (décoherence) that sees categories inherited from a historical context now in flux lose their purchase, and which is one of the key mechanisms in the emergence gray zones, plays a particularly important role (Bureau and Dieuaide 2018).

These major transformations pose a challenge to comparison at a time when it is becoming simultaneously more necessary (to understand the changes under way), more difficult to perform, and, paradoxically, more frequently invoked if not instrumentalized by political forces. The multiplication and permeability of levels of regulation together with their growing autonomy produce complex interconnections between them, characterized by interdependencies and cross-influences that are becoming increasingly difficult to decipher. Consequently, comparison increasingly represents a methodological challenge, and strategic choices—whether to orient to cases or variables, and whether to adopt an interpretive or explanatory approach—are becoming increasingly critical.

The Circulation of Ideas and Categories

The proliferation of regulatory spaces and levels is both cause and consequence of the wholesale restructuring taking place in many countries. On the one hand, it is the result of actors striving for recognition of the relevance of particular spaces or levels, either at the expense of or in addition to others. A well-documented example is the conflict of legitimacy between company-level and industry-wide negotiations. The proliferation of spaces relevant to any situation thus reflects the growing recognition of new spaces of regulation. On the other hand, this proliferation is a factor in the emergence and perpetuation of gray zones. Finally, and more particularly in the context of work and employment, it again raises the question of the circulation of ideas and categories across different spaces.

The question is not new. The circulation of a category central to the domain of work—such as that of waged employment—has been a concrete issue for decades. While waged employees are undoubtedly be found in every country in the world today, the ideas of wage and employment can refer to very different realities depending on the socio-economic context in question. What does employment signify in a society like Brazil’s, where the rate of dependent employment barely reached 50% at its peak, but many of the institutions typical of the Global North did emerge, among them a system of social protection almost entirely confined to employees, and a robust system of employment law with labor courts to enforce it? And what does this same category signify in African or Asian countries—India, for example—where rates of dependent employment are even lower, and where none of the ancillary institutions that are integral to employment in Europe have developed? This again raises the question of the “provincializing” of Europe (Chakrabarty 2000) or, at the very least, underlines the need to consider the multiple trajectories of institutionalization of the norms and categories of employment to be compared.

Work on the circulation of categories generally highlights two factors that are valuable in analyzing the emergence of gray zones. Firstly, categories are always appropriated by local actors on the basis of their cultures, their priorities, their ways of understanding, and the resources available to them. Categories are thus not inert elements disseminated by an international agency, a trades union confederation, or the head office of a multinational corporation. Their adaptation is their appropriation. Disseminated by the European Union as part of its European Employment Strategy, the term “activation,” for example, has given rise to particularly significant national variations (Betzelt and Bothfeld 2011). Secondly, the circulation and appropriation of categories in the domains we are concerned with here most often involves the addition of a regulatory framework rather than the replacement of one by another. This is an example of the “layering” identified as a mode of institutional change by Kathleen Thelen and Wolfgang Streeck (2010). These phenomena, then, contribute to the increase in regulatory uncertainty evoked in the earlier discussion of levels of regulation.

Comparing Gray Zone Dynamics?

The fragmentation of spaces and sites of regulation, the weakening of normative hierarchies—as exemplified by the French labor legislation of 2016 and 2017 that saw norm-setting power devolved from legislature to firms—and the diversification of cultures of work are all key drivers in the development of the gray zone in employment. There is today a growing volume of research that compares gray zones across national borders, such as, for example, the comparison of the status of the self-employed in France and in Brazil (Giraud et al. 2014). Extending beyond the comparison of national or sectoral frameworks, the focus of such work is now shifting toward analysis of the mechanisms generating the gray zone in employment. Firstly, the dynamics of these gray zones reflect the emergence or decline of categories and of modes of individual engagement in various types of work. This is particularly true of such emblematic forms as the work of platform workers (Srnicek 2017; Cingolani 2024) or precarious intellectuals (Tasset 2019). Secondly, the sites or entities responsible for norm-institution [fabriques institutives] are constituted of dynamic social relationships productively engaging with market logics. Involving innovation in both production and its organisation, they are shaped by institutional constraints and resources (Bureau and Corsani 2019). With this in mind, the comparison of gray zones focuses specifically on changes in the logics of categorization of work and employment. The comparison of gray zones calls for a major mapping exercise, as one finds a multiplicity of dynamics at work: self-identification or self-classification by individuals; the generation of categories by private-sector infrastructure or tools such as digital platforms; processes of institutionalization driven by the constitution and mobilization of worker collectives—as in producer co-ops, for example; and the reorganization of normative hierarchies on the basis of territorial, sectoral or occupational developments.

Industrial Relations: Emblematic Category of the Gray Zone

At the heart of these dynamics, industrial relations systems have a preeminent place.

The rules governing work and employment are discussed, defined, and updated within these spaces, where the rationalities and interests of state, capital, and labor come together and clash. Industrial relations systems, then, are central to the creation and diffusion of gray zones, and the study of these systems is thus essential to any research on the gray zone—especially any that compares regions, countries, sectors, or firms. In practical terms, this means that the analysis of gray zones has to include detailed examination of the legal and contractual frameworks governing work and employment at various levels of regulation, from the global to the local, as well as study of the actors, cultures, practices and relationships, both formal and informal, involved in them.

In fact, the comparative approach, already demanding when applied in a context stabilized and formalized by institutions, becomes even more so when it has to deal with the complex, shifting and much more opaque dynamics of gray zones. This represents both a challenge and an opportunity. On the one hand, in exacerbating the familiar difficulties of comparison, gray zones invite the renewal, rethinking, and updating of comparative methods. On the other, they present an even greater risk of misapprehension, misunderstanding or misinterpretation of the realities and categories being compared. Gray zone dynamics thus reinforce the need for comparatists to remain vigilant in the face of the already well-known risks of the exercise, thus compelling them to reconsider basic categories long taken for granted.

The comparison of industrial relations, for example, no longer involves clear-cut, unambiguous categories or well-established systems: it has become the comparison of structures whose components are undergoing radical redefinition, to unpredictable effect. Liberal policies, multiple crises, massive technological advances and cultural shifts are disrupting these systems at every level, even if the impacts vary with the level and the country under study. In industrialized countries in particular, the fundamental categories of comparison provided—for several decades—a solid foundation for the exercise, whether dealing with work or employment, the firm as site of production and decision-making, the relationship of subordination between employee and employer, worker autonomy, hours (of work and non-work), social dialogue, industrial disputes or collective bargaining. This stability was accompanied by the sense of a certain convergence, of the growing similarity of systems that were becoming increasingly interconnected and interdependent. The spread of the employment form from the Global North to many countries in the South was a key factor in this. Since the 1980s, however, industrialized countries have seen a weakening of these postwar categories, under the combined effects of many weighty changes that have had a direct and drastic impact on the actors and institutions involved in regulation. International comparative research has naturally been affected, especially since investigators also have to contend with local and national dynamics affecting their own contexts, making the comparison of gray zones even more challenging. It is no longer a matter of stable systems being compared with one another, or of even evolving systems being compared to stable systems, but rather of systems all in flux. Research currently aimed at renewing or replacing the categories inherited from the postwar decades—which used to serve as a relatively solid foundation for comparison, being sufficiently shared between contexts—seeks to address the gradual obsolescence of the categories, adapting them to the shifting realities of work and employment (Bureau et al. 2019; D’Amours et al. 2023).

But alongside research on the categories themselves, the comparison of industrial relations systems can draw on several proven strategies. First, there is a more “literary” and qualitative tradition of comparison that uses socio-historical narrative to capture the complexity of the systems under study while paying particular attention to certain structural aspects of industrial relations. This tradition is an instance of the contextual approach discussed earlier. Studies in this tradition often select a small number of cases—typically a few national systems, industrial or occupational sectors, firms or regions, which they analyze on the basis of a wealth of qualitative data, leading to detailed and dense but stylizing presentations: Richard Hyman’s work on the “geometry of trade unionism”, for example, which perfectly illustrates this approach. He selects three variables indicative of the self-conception and strategic orientation of trades unions in the various countries studied—Great Britain, Italy, and Germany—variables read off from the priorities set by national trade union organizations, in terms of the improvement of terms and conditions, the promotion of reform, or the prosecution of class struggle, described as orientations to market, state and class, respectively. With these dimensions in mind, Hyman describes the social histories of the three nations and locates their industrial relations systems in terms of the relative importance their trades unions attach to the market, society, and class. Lipset’s work on dominant trade union ideologies in eight countries—the United States, the Netherlands, Switzerland, Great Britain, Germany, France, Russia, and Finland—follows the same socio-historical approach. For him, the study of the historical conditions governing these different peoples’ access to political and economic citizenship requires a contextualized and in-depth presentation (Lipset 1983, 1–18). These two examples suggest how we may get to grips, in all its complexity, with the evolution of industrial relations systems caught up in the gray zone dynamic. The goal has to be to examine, for each case and in a comparative manner, the changes in course together with the tensions and uncertainties attending reforms and negotiations, their concrete effects on work situations and forms of employment, as well as the positions of the actors involved. This contextualization is indispensable, since it is the liberal reforms that have proliferated and accelerated in many countries and sectors that have led to the growth of gray zones. For this qualitative style of comparative analysis, quantitative indicators are only one element of the contextualization. Conversely, other studies rely primarily on quantification to document their expansion.

The quantitative approach relies primarily on statistical data. It offers another useful way of comparing industrial relations systems as they relate to the gray zone. Because of their reliance on indicators, studies of this kind are immediately confronted by fundamental questions, such as the relevance of the chosen indicators, the quality of the data collected, and their equivalence with regard to the systems to be compared. As discussed above, these classical problems of statistical comparison become more acute in the context of the gray zone, marked by the lability of the realities being compared. In the 2010s, the European Foundation for the Improvement of Living and Working Conditions (Eurofound) produced two research reports devoted exclusively to such methodological issues (Eurofound 2016, 2017). The Foundation notes that the work that led to the reports was initiated in the early 2000s, on request of the European Commission, and began with the search for key indicators of industrial relations. The reports provide a detailed account of the difficulties and the methodological issues involved in developing an appropriate comparative framework that would be accepted by the then 28 Member States of the EU. They were countries with different cultures of industrial relations, and while they shared some history, they differed in economic, demographic, and social profile. The quantitative approach thus inescapably requires preliminary work to develop the indicators, so as to ensure the quality of the results. As the Eurofound reports note, this can only be done by also considering, for each indicator, more qualitative elements that shed light on the specific characteristics of the various countries in the sample, so contextualising the data.

Eurofound’s reasoning takes the form, one might say, of an inverted pyramid, starting with the most general and on that basis proceeding to the particular: the idea of “industrial relations”, the most general, is thus broken down into four “key dimensions”, themselves broken down into “subdimensions”. Each of those subdimensions is then assigned a battery of numerical “indicators” that will allow comparison. For Eurofound, “industrial relations” has four key dimensions: “industrial democracy”, “industrial competetiveness”, “social justice” and “job and employment quality”. Industrial democracy has four subdimensions: “autonomy”, “representation”, “participation” and “influence”. Each subdimension is then linked to statistical data that can be collected for each of the Eurofound countries. Representation, for example, is measured in terms of four indicators: “trade union density”, “employer organisation density”, “collective wage agreements” and “collective bargaining coverage”. For each indicator, Eurofound identifies existing European databases, among them the European Company Survey, International Labour Organization, and Institutional Characteristics of Trade Unions, Wage Setting, State Intervention and Social Pacts (ICTWSS) databases.

Alongside the substantial effort devoted to the identification of indicators and tools for the measurement of social realities in flux, some fifteen “quality criteria” were also developed, to ensure the validity of the figures used. Such studies in the tradition of comparative statistics—more abstract than contextualized—equally need to be taken into consideration in discussing the comparison of gray zones, as they directly address the question of the pertinence of the categories of comparison as it relates to the choice of measurement indicators.

Both strategies of comparison, therefore, face a common challenge: that of capturing categories themselves undergoing profound change, whether by documenting them empirically through concrete examples and socio-historical insights, or by measuring them statistically using quantitative indicators. More and more studies are now combining the two approaches to take advantage of the virtues of each. One of these is SyndiCARE, a recent research project looking at the conditions under which union representatives carry out their duties in different countries, and their effects on the health of elected officials and employee representatives—a topic of growing interest to certain funders.

The Health of Employee Representatives: A Case Study

The SyndiCARE project is a response to a deterioriation in the conditions under which union representatives carry out their duties, a deterioration unprecedented in recent history noted by research teams in Belgium, France, Great Britain, and Quebec.^[3] This is a development that threatens the institutional foundations of social democracy. After decades of uninterrupted neoliberal reform that has both opened up markets and made them more flexible—the labor market among them—trade unions’ capacity for collective resistance and advocacy has been severely undermined. Their future is not guaranteed, and a continuing role as key actors in the industrial relations system is now just one possible scenario among others, with some suggesting their possible replacement by alternative organizations, others their relegation to the margins of industrial relations or even their outright disappearance (Visser 2019, 2023). The deterioration in the conditions under which union duties are carried out is now taking its toll on the health of elected officials and employee representatives. This is one of the most tangible symptoms of unions’ current fragility and of the weakening of social democracy as it developed in the postwar period. There are therefore numerous links between the SyndiCARE research project, which looked at the health and well-being of union representatives in Quebec, France, and Great Britain—and the study of gray zones. One hypothesis would relate the emergence of psychosocial risks among elected officers and employee representatives to the uninterrupted liberal reforms supported by the new technologies, the continuing expansion of gray zones and the weakening of trade unions.

In France, for example, the Macron government’s industrial relations legislation of 2017 has led to a concentration of union responsibilities, with a growing workload falling on the shoulders of fewer activists. The same wave of market-liberal reform also saw the abolition of the Comités d’Hygiène, de Sécurité et des Conditions de Travail, the specialist health and safety and working conditions committees that formerly had to exist in every establishment of more than 50 employees, and also of the statutory staff representatives, the shopfloor reps mandatory in every every establishment of 12 or more employees. The disappearance of these longstanding institutions (the statutory staff representatives dating back to 1936, the CHSCT to 1982) has relegated matters of health at work to the bottom of the list, and cut elected officers off from workplace realities while also depriving union organizations of a shopfloor role that had long served as a starting point for a career as a union activist, providing a grounding in workplace industrial relations (Béroud and Nizzoli 2023; Chabbert et al. 2023). In the United Kingdom, Cécile Guillaume and Heather Connolly remind us that the gradual fall in union density (Johnstone and Dobbins 2021) has been accompanied by unions’ growing difficulty in finding members willing to act as workplace representatives (Kirton and Guillaume 2017) and the weakening of the role of workplace health and safety representatives (Moore et al. 2023). In Québec, Mélanie Dufour-Poirier and Jean-Paul Dautel observe that the most recent reform of occupational health and safety legislation in 2021 tended to ignore not only the already well-known and documented shortcomings of the province’s system of inspection, but also the obstacles to union participation in joint committees and to the exercise of workers’ rights more generally, particularly for non-unionized workers, and more especially for those employed in small workplaces (Baril-Gingras and Cox 2023). In all three regions of study, however, the historic social movements of 2022–23 reinvigorated the activist base; yet these movements either failed to force the government to back down or were followed—in the United Kingdom—by further restrictions on the right to strike, particularly in the railway sector, the last major union stronghold (Connolly 2023). In Québec, the unprecedented wave of mobilization in the education and healthcare sectors in the fall of 2023 helped to legitimize union demands regarding access to and the sustainability of high-quality public services for all. However, these mobilizations also generated expectations later disappointed, leaving many militants with the sense of an opportunity missed, notably with regard to the organisation of work or any more ambitious transformation of society (Lavallée 2024).

To carry out a comparative study of the health of trade union representatives in three countries with growing gray zones, the team chose to combine different levels and methods of research. The institutionalist approach long favored in the study of industrial relations was appropriate to a period of relative stability of systems and categories. With the emergence of the gray zone, it needed to be supplemented, notably by increased attention to the experiences, lived realities, and testimony of the elected representatives concerned, at a more microsocial level. In fact, in France, as in Quebec and the United Kingdom, union representatives are ever more evidently suffering “activist fatigue” (Guillaume and Rey 2023). The collection of first-hand testimony and personal experiences should make it possible to set these actors on the same level in the analysis as the institutions to which they belong. These themselves are by no means inactive, and indeed play a significant role in the phenomenon: in the past, by downplaying or even refusing to recognise the existence of the psychosocial risks faced by trade union representatives; today, by taking these risks more seriously and legitimizing, with varying degrees of success, the expression of concerns about them. The combination of the study of national industrial relations systems, the trades unions operating within them, and, finally, the lived experiences of elected representatives necessitated a fruitful renewal of comparative methodology. The three levels are treated as equivalent in terms of their contribution to the understanding of the phenomenon, so avoiding the risks inherent to comparison in the gray zone.

Conclusion

The growth of the gray zone in work and employment reflects a weakening of categories, regulations, institutions and collective organizations in these fields. It also reflects a transformation in the ways individuals approach work. The affiliations, identities, and, above all, the power relations that form around work have broken down or are in the course of reconfiguration. The boundaries between subordination and independence, and training and employment, for example, are becoming unclear, and the very terms in which we understand the motivations for work—remuneration, personal motivation, creativity, volunteering, collective action, etc.—are losing their purchase. Comparative analysis is a particularly useful aid to grasping the dynamics at work, especially as they would appear to be playing out simultaneously across the globe. Different institutional, economic, and sociopolitical contexts afford insight into different aspects of the gray zone. We can also learn from different forms or strategies of resistance or resilience in the face of the phenomenon. It is not enough, however, to say that the gray zone takes many forms. It manifests itself at different levels of social life, and accounting for the relations between levels raises important methodological issues for any international, intersectoral or other comparison (Giraud and Lallement 2021), issues particularly salient in the analysis of gray zones.

The methodological challenges presented by the gray zone in work and employment require us to take a broader view of the methods and problems of observation. To understand the categorial frameworks used by employment professionals, for example, or the ways in which individuals describe or categorize their relationship to work or the dynamics of power relations in work and employment, we now often have to go beyond the written sources (regulations, laws, agreements, codes, pay scales etc.). It is today increasingly necessary to conduct in-depth interviews, group interviews, and participant observation, and also to expand the field of observation (notably to non-work life) if we are to understand the mechanisms governing work and employment. In this, the comparative approach certainly brings out the distinctive features of individual and collective experiences of work.

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