ON MONDAY, Commerce and Employment released a consultation paper as part of its review of employment law and workplace protections available in the island.

It was a comprehensive document which could lead to the introduction of significant pieces of new legislation covering the employment of children, ending discrimination, introducing the concept of equal pay for work of equal value and implementing statutory redundancy pay and insolvency cover.

None of these are small matters. The implications in terms of States time and resources are considerable and the impact on local businesses so regulated is potentially burdensome and expensive.

So it is disturbing that C&E hasn’t provided any evidence in its paper to suggest that any of this is necessary or that there are substantial problems that need to be resolved.

Instead, the report comes across as work for the sake of creating more work and more layers of bureaucracy and cost.

Such figures as it provides indicate that there really isn’t an issue: just three disability discrimination inquiries last year and two relating to race relations. The total number of approaches to the department over the last four years range from 1,608 to a peak in 2006 of 1,912 but, using last year as an example, only 300, or 16%, related to the areas being considered by C&E.

That is not evidence of a large-scale problem that has to be tackled.

The fear, of course, is that since the departmental juggernaut has started to roll, there will be no stopping it. Irrespective of employer or employee feedback – and how many staff groups will say ‘no’ to more protection that costs them nothing? – the department has done so much work that there’s no going back.

However, while things can always be improved, it is by no means clear from C&E’s own paper that legislation is needed.

Until any unsatisfactory businesses have been told what’s expected of them and been given a chance to improve, the need for a raft of new regulations is far from justified.