C/HR/52. Dissertation. Employment and Disabled People: A Comparative Critical Review of the Literature and Laws in the UK and US

Disabled people remain one of the most discriminated against and unprotected social groups. This has in part resulted from their treatment as second class citizens, protected under social welfare and charity law. However, major pieces of legislation, including the US Americans With Disabilities Act of 1990, EU Framework Employment Directive and UK Disability Discrimination Act of 1995 have helped to herald a way forward. Measures have been put in place to enforce countries and businesses to comply with legislation aimed at preventing employment-related discrimination and equality for disabled people. Using the medical (personal tragedy) model and social (or rights-based) model of disability as a framework, this dissertation investigated the issues of disability and employment in the UK and US, providing a critical review of the literature and law.