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Comparing England, Scotland,Wales and Northern Ireland: Thecase for 'home internationals' incomparative researchDAVID RAFFE , KAREN BRANNEN , LINDA CROXFORD &CHRIS MARTINPublished online: 28 Jun 2010.

To cite this article: DAVID RAFFE , KAREN BRANNEN , LINDA CROXFORD & CHRIS MARTIN(1999) Comparing England, Scotland, Wales and Northern Ireland: The case for 'homeinternationals' in comparative research, Comparative Education, 35:1, 9-25, DOI:10.1080/03050069928044

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Comparative Education Volume 35 No. 1 1999 pp. 9± 25

Comparing England, Scotland,Wales and Northern Ireland: thecase for `home internationals’ incomparative researchDAVID RAFFE, KAREN BRANNEN, LINDA CROXFORD& CHRIS MARTIN

ABSTRACT The differences among the four education systems of the UK are often perceived as a

nuisance by comparative researchers. This paper argues that they are also an opportunity. It describes

the four systems and summarises their similarities and differences. It then presents ® ve reasons for

giving `home international’ comparisons a more prominent role in comparative research. These are,

respectively: their potential contribution to theoretical debates; speci® c differences among the four

systems, which touch on core problems of educational research; the practical value of home

international comparisons; their potential for policy learning; and the relative ease of conducting

them.

1. Introduction

The UK is represented by four `national’ football teams, those of England, Scotland, Walesand Northern Ireland. Matches between these teams were once called `home internationals’ .Each home country of the UK also has its own education and training system; this paperpresents the case for `home international’ comparisons of these systems.

For many comparative researchers, the differences among the four systems may seem anuisance. The differences tend to be small, and often less important than the similarities, butthey are compounded by a scarcity of data covering the whole UK on a comparable basis.They are further compounded by the shortage of accessible and reliable accounts whichdescribe and compare the four systems. Most descriptions of UK education and training forinternational audiences focus on England. Texts which describe Scottish education (e.g.Clark & Munn, 1997) tend to be written for English rather than overseas audiences. Thereare fewer descriptions of Wales or Northern Ireland, and very few which compare all foursystems (e.g. Mackinnon et al., 1996; Bell & Grant, 1977). Most international indicators,such as those of the Organisation for Economic Cooperation and Development (OECD)(1997), present aggregate data for the whole UK, even if their concept validity is restrictedto England. Intra-UK differences may also appear as a nuisance in European Union

Correspondence to: D. Raffe, Centre for Educational Sociology, University of Edinburgh, 7 Buccleuch Place, Edinburgh

EH8 9LW, UK. E-mail: d.raffe@ed.ac.uk

0305-0068/99/010009-17 $7.00 Ó 1999 Taylor & Francis Ltd

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10 D. Raffe et al.

(EU)-funded studies which are organised around nation states, thus substituting administra-tive and political criteria for empirical and theoretical criteria in the design of comparativeresearch.

It is not surprising that researchers, both within the UK and overseas, ® nd it hard tocope with the differences among the UK systems. Many researchers shift their focus betweenEngland, Great Britain and the UK depending on the institutional context or the availabilityof data; others purport to cover the UK but in fact describe England, typically dismissing Scot-land, Wales and Northern Ireland in the ritual footnote; others simply ignore the differencesand treat England, Great Britain and the UK as synonymous. More acceptable responses tothe problem are to focus explicitly on one country of the UK (usually England) as the unitof study (e.g. Green, 1990), to maintain a focus on the whole UK where this is possible withthe data and appropriate for the problem (e.g. Be duwe & Espinasse, 1997), or to include thecountries of the UK as separate cases in cross-national studies (e.g. MuÈ ller & Karle, 1993).

However, the differences among the UK systems are not just a nuisance and a problemto be coped with. They are also an opportunity for research (Bell & Grant, 1977; Smith,1983), a source of empirical and theoretical challenges and of lessons for policy and practice.The ® rst aim of this paper is to increase awareness of the UK systems by analysing some oftheir key differences and similarities. We do this in Section 2. Our analysis is highlycondensed but it still contains substantial descriptive detail; readers mainly interested in themore general argument of the paper may turn to the concluding section of Section 2 whichsummarises the similarities and differences of the four systems. The second aim of the paper,which we pursue in Section 3, is to draw on this analysis of the four systems to present a casefor giving `home international’ comparisons a more prominent role in comparative research.

2. The Four Systems of the UK

Origins and Development

The development of the four systems up to the 1970s is outlined by Bell & Grant (1977), ifnot in detail at least more fully than we have space for in this article. Here we identify a fewcritical phases or events which have shaped the differences and similarities of the foursystems. Two critical events are the emergence of national education systems and theformation of nation states (Archer, 1979; Green, 1990). Wales was politically incorporatedwith England throughout the period when its education system developed, and as a result thedifferences between Welsh and English education have been historically small. When thesystems have diverged this has, until recently, re¯ ected contingent circumstances such asrelative poverty and sparsity of population more than political differences (Jones, 1997). InScotland, compulsory education was ® rst promoted by an Act of 1494 or 1496 (allegedly the® rst such legislation in the world), but the origins of Scottish education are more convention-ally traced to the 16th century reformation which established the principle (and, more slowlyand unevenly, the reality) of a school in every parish (Scotland, 1969). Scottish education hadthus begun to develop as a national system before the union with England in 1707, and it hasremained more distinct ever since. Ireland developed a national system of elementaryeducation in the 1830s, earlier than such a system became effective elsewhere, but itseducation was already affected by religious divisions (Bell & Grant, 1977). These divisionsinhibited the development of a distinctive system in Northern Ireland after the partition ofIreland in 1920. The education systems of the two parts of Ireland have diverged, and despiteits formal autonomy for much of the period the system of Northern Ireland has moved closerto England and Wales than to the Republic.

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The Case for `Home Internationals’ in Comparative Research 11

Another critical event was the establishment of a `territorial’ department of the UKgovernment responsible for certain policy areas within each territory. Once again, thisoccurred at different times in the three territories. The Scottish Of® ce was established in1885 with responsibilities including school education, although several other aspects ofeducation and training remained under the control of `British’ departments until recently. Bycontrast the Welsh Of® ce was established as recently as 1964 and assumed responsibility forschool and college education in 1970. In Northern Ireland, education was a devolvedresponsibility of the province’s administration under the Stormont Parliament which wasestablished after the partition of Ireland. When Stormont was suspended in 1972 educationcontinued to be administered by the Department of Education Northern Ireland (DENI),although in contrast to its Scottish and Welsh counterparts, DENI is formally separate fromthe Northern Ireland Of® ce which was established in 1972.

Other critical events concern the establishment of quali® cations, which have played animportant role as instruments of control and levers for change in all four UK systems. Oneof the main educational functions of the Scottish Of® ce, in its early years, was the adminis-tration of school examinations; it developed and maintained a separate system ofquali® cations which have been an important source of distinctiveness ever since (Philip,1992). A separate Welsh body was established in 1896 to oversee the processes of examina-tions and inspection (Evans, 1997), but Wales has shared a common quali® cations systemwith England since 1917 (Jones, 1997). Over time Northern Ireland has abandoned the`Irish’ features of its quali® cations and increasingly adhered to the English system.

Two further critical events, or phases, are currently in progress. The ® rst is there-structuring of post-compulsory education and training to increase their coherence andeffectiveness as a system. This process, which is common to many other countries, respondsto problems raised by the growth of participation, by the wider range of demands onpost-compulsory education and training systems, and by their growing functional complexityand the increased interdependence of their component parts. The process has been occurringover the last 20 or so years and is re¯ ected in policy measures which promote coherence andlinkages between different parts of the system, and more uni® ed arrangements for curricula,quali® cations, funding, quality assurance and so on. It may be understood as a process of`uni® cation’ of post-compulsory education. However, the different systems of the UK havedeveloped different strategies for uni® cation, and this may lead to future divergence(Howieson et al., 1997; Raffe et al., 1998).

The other critical event which is still ongoing is devolution, ® rst administrative and thenpolitical. In the 1970s, government responsibilities for education and training were divided ina complicated way between the t̀erritorial’ departments and the education and employmentdepartments of the UK government (the predecessors of the present Department forEducation and Employment (DfEE)). Depending on the ® eld of policy, the responsibilitiesof the DfEE’s predecessors covered the whole UK, Great Britain (e.g. universities andtraining), England and Wales and Northern Ireland (e.g. vocational quali® cations), Englandand Wales (e.g. teacher education) or just England. The territorial departments ® lled thegaps in this complex matrix of responsibilities. During the 1980s and early 1990s responsibil-ities were devolved to the territorial departments; by 1994 most ® elds of education were theresponsibility of the DfEE in respect of England and of the territorial departments in respectof Scotland, Wales and Northern Ireland. Over the same period separate agencies wereestablished within each territory for such matters as the curriculum, regulation, inspection,quality assurance, funding and teacher training.

Administrative devolution will be matched by greater political autonomy from 1999when the Scottish Parliament, the National Assembly for Wales and the Northern Ireland

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Assembly assume executive and (in the case of Scotland and Northern Ireland) legislativeresponsibility for education and training within their territories.

Some commentators have speculated that these developments may be part of a processof `disuni® cation’ of the UK (Delamont & Rees, 1997). However, greater autonomy withineach territory will not necessarily encourage the systems to diverge. It may even encourageconvergence: for example, a directly elected Scottish Parliament or Welsh Assembly may feelless need to pursue separate policies in order to assert its legitimacy. Nevertheless, it is clearthat the relations among the four territories are developing rapidly, even if the long-termdirection of change is uncertain. In the rest of Section 2 we compare the four systems as theywere in 1998. We focus on four key aspects: governance, institutions, courses andquali® cations, and the social relations and societal context of education and training.

Governance

As described above, most aspects of education and training are the responsibility in Englandof the DfEE and elsewhere of the relevant territorial department: the Scottish Of® ce, WelshOf® ce and DENI (except for training in Northern Ireland which is the responsibility of theTraining and Employment Agency (T&EA)). Each department controls a governmentmachine with similar functions and mode of operation. However, the systems of governanceof education are not independent, equal and parallel across the four home countries.

First, they are not independent. As at 1998, before the devolution plans are fullyimplemented within each territory, all four departments belong to the central UK govern-ment, are accountable to the UK Parliament and implement UK policy, although this policymay vary to re¯ ect the needs and circumstances of each territory. The Parliament in Scotlandand the Assemblies in Wales and Northern Ireland will be able to make their own policy buttheir freedom of manoeuvre will be restricted. Each territory will have only limited power tovary the level of public spending on education; its policies must mesh with those (such asemployment and social security policies) that remain determined at UK level; and it mustrespect the practical constraints arising from the interdependence of the systems, for example,from the cross-border ¯ ows of students and of quali® ed workers.

Second, the four departments are not equal. The DfEE is the l̀ead department’ and hastended to set the tone of the policy across the UK; it also retains UK-wide responsibility forsome areas, such as the bodies responsible for training standards. It is much larger and hasconsiderably more resources for policy-making. The Welsh Of® ce and DENI are small, havea limited capacity to develop policy, and are more likely to adapt DfEE policy to thecircumstances of their territories (Raffe, 1998). The Assemblies will not themselves removethis constraint on their autonomy. The Scottish Of® ce is larger and has somewhat morecapacity to develop policy.

Finally, in their detail the four systems are not parallel. In each territory a network ofinstitutions is responsible for such functions as funding, quality assurance, curriculum advice,regulation, teacher training, certi® cation and accreditation; but the structure and roles ofthese institutions vary across the four territories. For example, the inspection function isentrusted in Northern Ireland to the Education and Training Inspectorate, in Scotland toHer Majesty’s Inspectorate, in England to the Of® ce for Standards in Education (Ofsted) andin Wales to the Of® ce of Her Majesty’ s Chief Inspector. These bodies differ in the way theyare constituted, in their spheres of responsibility (variously for schools, colleges, trainingand/or careers guidance services), and in their functions (for example, they have varyinginputs to policy-making).

The local administration of schools also varies. In Northern Ireland schools are admin-

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The Case for `Home Internationals’ in Comparative Research 13

istered by government-appointed Education and Library Boards. In England, Scotland andWales most state schools are administered by elected Local Education Authorities whoseorganisation, powers and responsibilities vary across the territories. In recent years localauthorities have lost powers both to schools and to central government, but the nature andextent of these changes have also varied across the territories (Raab et al., 1997). The controlof colleges of further education (described below) moved from local authorities to centralgovernment and its agencies in 1993.

The local delivery of public training programmes is the responsibility of the T&EA inNorthern Ireland, local Training and Enterprise Councils (TECs) in England and Wales, andthe Local Enterprise Companies (LECs) in Scotland. In Scotland, two regional developmentbodies, Scottish Enterprise and Highlands and Islands Enterprise, mediate LECs’ relationswith central government. The T&EA and LECs have broader responsibilities, includingeconomic development, than TECs (Bennett et al., 1994). TECs have broader responsibili-ties in England than in Wales.

Finally, the organisation of the teaching profession has varied across the territories,especially between Scotland, whose General Teaching Council has provided a measure ofprofessional self-regulation for school teachers, and the rest of the UK where the governmenthas had more direct control. In 1998 the government legislated to establish General TeachingCouncils for England and Wales.

Institutions

Throughout the UK full-time education is compulsory from 5 to 16 years. Students rarelyrepeat school years so the systems are tightly de® ned in terms of age. Most pupils attendprimary school to the age of 11 years (12 in Scotland) and then continue at secondary schooluntil the age of 16, 17 or 18. Parents have a choice of school, subject to the availability ofplaces. Sixteen year olds who continue in education do so either in school or in colleges offurther education. Further education colleges also recruit school leavers at 17 or 18 years, aswell as adults, and offer a wide variety of general and vocational courses, including part-timecourses. Well-quali® ed students may progress from school or further education to university.The higher education system has been uni® ed since 1992 when polytechnics were givenuniversity status, but some higher education is provided in further education colleges. Youngpeople leaving full-time education before 18 years have guaranteed access to places onwork-based youth training programmes, which may include part-time further educationcourses.

The description in the previous paragraph covers the whole of the UK. The four systemsvary in numerous details such as the age regulations for starting and leaving school, fundingmechanisms, and the arrangements for parental choice (Adler, 1997). Some major differ-ences are summarised below.

Selection for secondary education. The secondary school system in Northern Ireland isselective, and pupils go to grammar schools or secondary intermediate schools according toacademic ability. In Scotland and Wales almost all state schools are comprehensive. InEngland the pattern is more diverse. Most schools in England are nominally comprehensivebut some areas retain selective grammar schools. England has the most pupils (7%) inindependent schools; Wales and Northern Ireland have the fewest. When the Conservativegovernment encouraged schools to `opt out’ of local authority control, more English schoolsdid so, sometimes gaining the right to select a proportion of their students. In each systemsome schools have religious af® liations. In Scotland these schools are fully integrated into the

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14 D. Raffe et al.

state system; in England, Wales and Northern Ireland they are `voluntary’ schools withgreater autonomy than other state schools (but their precise status and powers, needless tosay, vary across the territories).

Structure of post-16 institutions. In Scotland there is a relatively clear division of functionsbetween schools and further education colleges. Most 16± 18 year olds in full-time educationare in schools; further education colleges cater mainly for adults and older school leavers, andfor the small minority who enter vocational courses at 16 or 17. In England and Wales more16± 18 year olds study in further education colleges than in schools; the further educationsector is more diverse, and includes sixth form colleges (which offer the typical schoolcurriculum for 16± 18 year olds in a separate institution) and tertiary colleges (which combinethe post-16 functions of schools and further education colleges). The organisation andfunctions of post-16 institutions vary locally, and in many areas schools and colleges competedirectly by offering the same courses. In Northern Ireland the further education collegesmirror the selective school system: most selective school students stay on at school and manynon-selective school students progress to further education at 16. The further educationsector in Northern Ireland recruits fewer adults.

Organisation of youth training. England and Wales are developing a three-tier structure ofModern Apprenticeships, National Traineeships, and other youth training (known in Walesas `Training Below Level 2’ ), corresponding to three levels of vocational quali® cations.Scotland has a uni® ed programme, Skillseekers. Northern Ireland’ s Jobskills programmecaters for older entrants to the labour market and for unemployed adults as well as for 16± 17year olds. The different programmes are broadly similar in content and mode of learning.

Higher education. Further education colleges play a larger role in the provision of highereducation in Scotland than elsewhere in the UK. There are substantial cross-border ¯ ows ofstudents between the different countries; Northern Ireland is a net exporter of students (it hasfewer places than its share of UK students) and Scotland is a net importer (Cormack et al.,1997).

Courses and Quali® cations

Once again we can identify several features common to the UK as a whole. In each territorythere is a nationally prescribed or recommended curriculum up to 16 years, broadly generalin character (Croxford, forthcoming). The ® nal stage of compulsory schooling, from 14 to 16years, leads to subject-based examinations designed to cater for (almost) the full ability range.Each subject is separately certi® cated and there is no group award. There is no concept ofsecondary school graduation or completion; there is a range of possible exit points, each ofwhich has equal legitimacy but not equal status. After 16 some students take academiccourses, also subject-based and ungrouped; the main function of these courses is to preparestudents for university but they do not confer an entitlement. Other students enrol onfull-time vocational courses, many of which offer a `broad vocational’ programme covering a® eld of employment rather than an occupation. Others enter youth training programmes,where they pursue competence-based, unitised quali® cations for a speci® c occupation.Despite recent increases in participation, many young people still leave education andtraining at 16 or 17. University admission is competitive and based on the number and gradesof passes achieved. Rates of graduation from university ® rst degrees are high by Europeanstandards.

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The Case for `Home Internationals’ in Comparative Research 15

Within this general pattern, there are signi® cant differences.

Compulsory school curriculum. Except in Scotland there is a statutory National Curriculum,although its content varies across England, Wales (where it includes the Welsh language, andsubjects such as history and geography have more `Welsh’ content) and Northern Ireland(where Irish is a separate subject, and where subjects are grouped into areas of study). EachNational Curriculum allows a limited degree of vocational specialisation for 14± 16 year olds,especially in Wales, although in both England and Wales the government proposes to allowsome 14± 16 year olds (especially the disaffected) to increase the vocational content of theircurriculum. Scotland has no statutory National Curriculum, but all local authority schoolsfollow agreed guidelines. The Scottish curriculum re¯ ects a different philosophy, based onbroad curricular areas rather than subjects up to 14 years, and on modes of study from 14to 16 years (Harrison, 1997), although the secondary school curriculum remains subject-based.

Language. The Welsh language has enjoyed a recent upsurge in education in Wales whereit is the main or only medium of instruction in more than one ® fth of Welsh schools.Assessments leading to national certi® cation may be conducted in Welsh. Some schools inNorthern Ireland teach in Irish and some Scottish schools carry out some teaching in Gaelic.Gaelic has also enjoyed a recent upsurge (Clark, 1997), but neither Gaelic nor the Scotslanguage playes a role in maintaining the distinctiveness and identity of Scottish educationcomparable to that of the Welsh language in Welsh education (Harrison, 1997). In most partsof the UK, English is the medium of instruction and of assessment for national certi® cation,although schools may provide varying forms of support for children whose home language isnot English.

Quali® cations at 16 years of age. The last 2 years of compulsory schooling (14± 16 years) leadto the General Certi® cate of Secondary Education (GCSE) in England, Wales and NorthernIreland and to Standard grade in Scotland. GCSE and Standard grade are both ungroupedsubject-based quali® cations, graded on a seven-point scale. Each student takes up to eight ornine GCSEs or seven or eight Standard grades. GCSEs and Standard grades perform similarroles as the main predictor of post-16 destinations, and are valued in the labour market aswell as in education. However, they differ in their curricula, in the way that students aredifferentiated on the courses, and in assessment.

Post-compulsory courses and quali® cations. In England, Wales and Northern Ireland post-16education and training tend to be organised in three quali® cations pathways, leading,respectively, to `academic’ A levels, to `broad vocational’ quali® cations such as GeneralNational Vocational Quali® cations (GNVQs), and to occupational quali® cations such asNational Vocational Quali® cations (NVQs) which are mainly taken by employees or youngpeople in training programmes. In Scotland it is harder to distinguish equivalent pathways asthere is more mixing of academic and vocational courses, and the pathways overlap more.From 1999 a uni® ed curriculum and quali® cations system will cover all academic andvocational courses based in schools and colleges in Scotland. Work-based provision willremain outside this system, in the form of Scottish Vocational Quali® cations (SVQs) which,despite their Scottish title, are much the same as NVQs in their structure and content.

Higher education. Participation has grown throughout the UK, but tends to be higher inNorthern Ireland and Scotland among young people, and higher in England among adults

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16 D. Raffe et al.

(Parry, 1997). Most ® rst degree courses are of 3 years’ duration, except in Scotland wherea majority of students take 4 year degrees (Paterson, 1993). The Scottish curriculum tendsto be broader than elsewhere for the ® rst 2 years, but institutions and courses vary widelywithin each territory.

The Social Relations and Societal Context of Education

An earlier comparison of 16± 18 transitions in Scotland and England suggested that Scotlandmore closely approximated Turner’ s (1961) model of `contest’ mobility through education,and that its post-compulsory sector had a more substantial `cooling-out’ function. However,these differences re¯ ected different institutions, courses and quali® cations, rather than anyobvious differences in the culture or societies of the two countries. The analysis concludedthat

the institutional differences [including differences in courses and quali® cations]between the two countries’ education systems may be theoretically, and practically,signi® cant. On the other hand these differences occur within contexts, re¯ ected inthe two countries’ labour markets and in patterns of differentiation among youngpeople, which appear to be very similar. (Raffe & Courtenay, 1988, p. 36)

While there are differences in the educational systemsÐ in the sense of governance, institutionsand courses, as described aboveÐ these map on to social relations and contexts of educationthat are in many respects similar. For example, young people in England and Scotland givesimilar reasons for their educational and labour market decisions after 16 years of age(Bynner, 1991); when they make different decisions this re¯ ects the different institutionalarrangements and opportunities and incentives that they provide, rather than different valuesor orientations to education (Gray et al., 1992). England, Scotland and Northern Irelandhave similar levels of social mobility and of class inequality in education (Erikson &Goldthorpe, 1993; MuÈ ller & Karle, 1993). Gender differences across the four countries arealso similar in comparison with those elsewhere. The four education systems interact with aneconomy which is integrated and organised at a UK level. The labour market is organised onthe same basis throughout the UK, with distinctively `British’ features, including high-statusand well-paid youth jobs (at least until recently), a f̀ront-end-loaded’ training system and atradition of training and socialisation on the job (Ashton, 1988). This labour market hashelped to sustain a distinctively British pattern of participation in education and training,characterised by relatively high proportions leaving full-time education at 16 or 17 years ofage, high participation in work-based training, high participation in higher educationmatched by very low participation beyond 18 years of age in intermediate level education,and a tradition of second-chance education through part-time study (Bynner & Roberts,1991; Banks et al., 1992; Kerckhoff, 1993). All of these features are common to the wholeof the UK.

One could summarise the differences among the four territories by suggesting that theeducation systems are (in some respects) different but their social relations and contexts aresimilar. Indeed the social relations and contexts of education may vary more within territo-ries, for example, between inner-city and suburban or rural environments, than betweenterritories (Ball, 1997; Delamont & Rees, 1997). However, the case should not be exagger-ated. Education systems interact with their contexts; differences in systems re¯ ect and sustaindifferences in social relations.

There are three more speci® c respects in which the social relations and contexts ofeducation vary across the territories. First, while individuals’ participation and behaviour in

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The Case for `Home Internationals’ in Comparative Research 17

education re¯ ect similar values and priorities, their political values and attitudes to theorganisation and governance of education vary more sharply across the four territories. Forexample, the Scottish public shows more commitment to comprehensive education, morerespect for teachers, more deference to the professionalism of teachers and headteachers andmore con® dence in local authorities (Scottish Of® ce Education Department, 1995; Curtice,1996; Raab et al., 1997). Scottish debates about post-16 education have been dominated bystrong opposition to selection or tracking in secondary education, while those in Englandhave been dominated by a concern with `standards’ (Howieson et al., 1997). Differentattitudes to the governance of education are re¯ ected in the varying proportions of schoolswhich `opted out’ of local authority control when this was made possible by Conservativelegislation; many English schools did so, compared with only 17 in Wales and three inScotland. Attitude surveys in Northern Ireland reveal different attitudes to the school system,and more con® dence in it, than in the rest of the UK (Gallagher, 1997).

Second, national identity has been an increasingly important theme in education policydebates in Scotland and Wales. In both countries criticisms of `anglicisation’ carry strongforce (Bellin et al., 1994).

Third, the social context of Northern Ireland, with its distinctive religious and politicaldivisions, may differ more than that of Wales or Scotland from the rest of the UK. A recentstudy in Northern Ireland found greater stability in the activities of early school leavers, anda lower proportion in `status zero’ (without education, training or employment), than anearlier study in a Welsh county. While methodological differences make it hard to comparethe two studies, differences in the family and social environment, as well as in education,training and guidance services, may help to explain their different ® ndings (Istance et al.,1994; Armstrong, 1996). Nevertheless interviews with young people in `status zero’ in thetwo territories revealed very similar attitudes and responses to social exclusion (Loudon et al.

1996; Rees et al., 1996).

An Overview of the Four Systems

As at 1998, the similarities and differences among the four systems can be summarised asfollows.

First, the systems are interdependent to a greater extent than in the case of separate nationstates. The interdependencies are complex: Bell & Grant’s (1977, p. 13) observation that `notwo systems enjoy the same relationship’ still holds. The administrative devolution of the past20 years has reduced this interdependence, and political devolution will reduce it further, butneither will end it. The territories will still belong to the same political system and each willbe constrained by such factors as UK ® scal policy, UK-wide economic and labour marketinstitutions, and cross-border ¯ ows of students and graduates (Rees & Istance, 1997).

Second, the similarities are more important than the differences. All the UK systems havedistinctively `British’ features: the broad institutional structure of schools and colleges; thestructure, function and timing of certi® cation; the scale, structure and functions of highereducation; the role of school- and work-based provision within a `mixed model’ of post-compulsory provision (OECD, 1985); a general emphasis on ¯ exibility and institutionalresponsiveness; a competence-based model of vocational education; a `medium-participation’system with a tradition of early transition to adulthood; and so on.

Third, the differences vary according to the territories concerned (England and Wales arethe most similar and Scotland the most different) and according to the sector of the system(there is more variation in respect of `education’ than t̀raining’ ).

Fourth, in a few respects the systems of the UK represent different types of systems, and would

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be categorised differently in cross-national typologies. One such difference concerns second-ary schooling, where Northern Ireland represents a selective system and Scotland and Walesrepresent comprehensive systems. Another difference concerns upper secondary education,where Scotland is moving towards a uni® ed system, whereas the rest of the UK is consolidat-ing a `linked’ form of a tracked system (Howieson et al., 1997; Spours et al., 1998). A thirddifference may be in respect of curriculum: the philosophy which underpins the 5± 14 yearscurriculum in Scotland differs from that of the National Curricula elsewhere in the UK(Harrison, 1997).

Fifth, in a much larger number of respects the differences among the systems represent

`variations upon common themes’. Similar functions are performed in slightly different ways,and similar institutions and structures perform slightly different functions. For example,schools and further education colleges have broadly similar functions across the four territo-ries, at least when compared with their nearest overseas equivalents, but the differences arestill signi® cant. Other `variations upon common themes’ include the different versions of theNational Curriculum in England, Wales and Northern Ireland, and the institutions andagencies for regulation, standard setting, funding, quality assurance, and so on. It is particu-larly in these areas that most published descriptions of the `British’ or `UK’ education systemare inaccurate.

Sixth, although most of these `variations upon common themes’ may be relativelyunimportant individually, their cumulative impact may be much more signi® cant. To the extentthat this type of variation has increased with the devolution of powers to the territorialdepartments, they may create a subtle and diffuse pressure for divergence between thesystems.

Seventh, and most tentatively, the social relations and societal context of education and

training vary less across the four home countries than they typically do across nation states;the most signi® cant cultural differences concern the politics of education and nationalidentity, rather than individual behaviour.

Finally, the relations among the four systems are changing rapidly. There is the potential forthe four systems to diverge, although it is uncertain whether or to what extent this potentialwill be realised. Especially in respect of post-compulsory education, this could be a criticalperiod in which future system characteristics are determined.

All these conclusions are provisional. There is a need for more systematic research on theUK systems and analysis of their similarities, differences and interrelationships.

3. The Case For Home International Comparisons

In reviewing the literature on intra-UK differences in education and training we have beenstruck by the paucity of research in this ® eld. There is a growing literature on the history,institutions and performance of each individual system. Some of this is indirectly comparativein the sense that the distinctiveness of the Scottish, Welsh or Northern Irish system isestablished through implicit comparison with England. There is much less research which isexplicitly comparative, and very little research which systematically compares all four UKsystems. There is little analysis of the consequences of system differences, and few attemptsto theorise about the similarities and differences and to place them in a broader conceptualframework.

There are at least ® ve arguments for giving home international comparisons higherpriority than they currently receive. The ® rst three of these suggest that they may be of asmuch value to researchers, policy-makers and users of research outside the UK as to those

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within it. Similar arguments may apply to the study of other states, such as Canada, Spainand Belgium, with distinctive `national regions’ .

Theoretical Contribution

The ® rst argument concerns the potential theoretical contribution of home internationalcomparisons. Since the mid-1980s, many comparative researchers have been in¯ uenced bythe `societal’ approach of Maurice et al. (1986). This approach emphasises the need toanalyse education and training systems in their societal context, for example in relation to thelabour market and the production system (Ashton & Lowe, 1991; Soskice, 1993; Marsden &Ryan, 1995). However, the societal approach is open to criticism. In focusing upon theuniqueness of national education and training systems and their societal contexts, it divertsattention from the structural similarities of systems, from their internal variation, from theirinterdependence and from the diffusion of educational practices between them. In particular,societal analysis tends to assume that each society has clear and unambiguous boundaries andthat the boundaries of education and training systems coincide with the boundaries of theeconomic, social and political institutions which provide their societal context.

Many studies within the societal tradition have focused on larger and more self-contained systems such as France and Germany. Home international comparisons reverse theassumptions on which much research in this tradition is implicitly based. They thereforeprovide a critical test of the approach and of its theoretical underpinnings.

In the ® rst place, home international comparisons exemplify the ambiguity of societalboundaries. In varying degrees, the nations of the UK have distinctive education and trainingsystems, but all belong to the same state and share its homogenising in¯ uence. The economyand the labour market, their regulatory frameworks and their ways of working, are alsorelatively uniform across the UK. The boundaries of education/training systems, in otherwords, do not coincide with the boundaries of such important aspects of the societal contextas the state, the economy and the labour market. As a result, home international comparisonsmay provide more opportunities for theory development than the study of homogenoussystems with unique boundaries. For example, if we postulate that `training’ varies more withthe economic context, and that `education’ varies more with the social and political context,then the relative homogeneity of the economy and the labour market across the UK,compared with somewhat greater variation in the social and political contexts of education,may explain why `training’ varies less than `education’ across the UK systems. The apparentexceptionÐ Northern Ireland’ s distinctive training arrangementsÐ could be explained by thestronger `social’ functions of training in Northern Ireland and by its weaker integration intothe UK economy and labour market.

A closely related opportunity for theoretical development is in relation to the role of thestate in the development of education systems (Green, 1990). The history (past and future)of education in the `stateless nations’ of Scotland and Wales would provide considerablematerial for this (McCrone, 1992). So would a study of the separate development ofeducation in the north and south of Ireland after the latter ceased to be part of the UK.

Another potential theoretical contribution arises from the fact that the similarities amongthe UK systems are often more important than their differences. Home internationalcomparisons thus draw attention to the need for conceptual frameworks which take accountof types and degrees of similarity among systems as well as their differences.

Finally, home international comparisons may help us to conceptualise the interdepen-dence of systems. Many education and training systems share common histories and presentday systems increasingly in¯ uence each other. They compare each others’ performance and

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processes; they learn lessons from each others’ institutions and policies; they harmonisearrangements in such ® elds as quali® cations and student mobility; and they submit to theauthority of supra-national bodies such as the European Commission and the World Bank.These processes of interdependence and mutual in¯ uence have been largely neglected byresearchers in the societal tradition. The interrelationships of the home countries of the UKare a fertile ® eld for research because they are so varied. As Bell & Grant (1977, p. 13) note:f̀or anyone concerned with the interplay of national systems, and the problems of single

systems in a multinational complex, Europe’s offshore islands offer unique opportunities fortheir study in microcosm’.

The Nature of the Differences

The second argument arises from the particular ways in which the UK systems differ.Comparisons among them can address some of the core problems of educational research.

One example is the study of equality and inequality in education. Each of the four UKterritories has a distinctive tradition of educational equality, in the sense that differentconcepts and `myths’ of equality have played a role in the development of the educationsystem and of its national identity (e.g. Gray et al., 1983; Gorand, 1997). Comparativestudies of educational inequality are stronger for including separate measures of the differentUK systems (e.g. MuÈ ller & Karle, 1993).

A second example concerns the organisation of education systems, and, in particular,how they handle the differentiation of students with varying needs, abilities or aspirations. Atsecondary level, Northern Ireland’ s selective system contrasts with the comprehensive sys-tems of Wales, Scotland and (more ambiguously) England. Not only is this contrast ofinterest in its own right, but it may interact with other issues of theoretical or practicalinterest. For example, the developing literature on `quasi-markets’ in education is enriched bycomparing the effect of open enrolment in the selective system of Northern Ireland and thecomprehensive systems elsewhere in the UK (McKeown & Byrne, 1997). At post-16 level,England, Wales and Northern Ireland are developing a three-track system, while Scotland ispreparing to introduce a uni® ed system in 1999. A comparison of these developments hasbeen used to develop a conceptual framework of the `uni® cation’ of post-compulsoryeducation and training; this framework subsequently proved relevant to the comparativeanalysis of non-UK countries, in a parallel study of reforms across eight European countries(Raffe et al., 1998, 1999).

Practical Need for Knowledge about Differences and Similarities

A third argument for home international comparisons is that policy-makers, students,teachers, employers and the public at large share a practical need for information on the foursystems and an understanding of their differences and similarities. While such comparativeknowledge is most obviously relevant to people within the UK itself, it is increasingly valuablefor those elsewhere. For example, policy-makers in the European Commission and othersupra-national organisations cannot assume that all member states are homogeneous; theymust allow for the diversity within the UK as well as the differences between the UK andother countries. EU policy is increasingly based on a recognition of such `regional’ differ-ences. The global economy and the international mobility of capital and labour make a basicknowledge of the UK systems, especially vocational training and quali® cations, useful forworkers and employers overseas. Much of the UK’s inward investment is attracted toScotland, Wales and Northern Ireland; those who manage this investment need to under-

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The Case for `Home Internationals’ in Comparative Research 21

stand the systems of the territories where they locate. The UK has been a popular destinationfor students participating in European exchange schemes, who will be spread across thedifferent territories. Comparative researchers and statisticians have a practical need forknowledge of the UK systems and of their similarities and differences.

Potential for Policy Learning

The fourth argument is more speci® cally relevant to UK policy-makers: this is that homeinternational comparisons are more likely to generate conclusions that have direct implica-tions for policy or practice.

It is usually dif® cult to draw direct conclusions for policy by examining equivalentinstitutions, arrangements and policies in different countries and comparing their effective-ness. It is often impossible to identify `equivalent’ institutions or policies in the ® rst place;even if they can be identi® ed, an institution or policy which is effective in one country maynot be effective in another, because the education and training system and/or its social,economic and cultural context are too different. However, when we compare the four homecountries of the UK, the systems and their contexts are more similar.

Rose (1993) identi® es seven contingencies which may affect the transferability of aprogramme from one time or place to another. These are the `uniqueness’ of the programme,the substitutability of the institutions which deliver it, the equivalence of resources, thecomplexity of cause-and-effect models underlying the programme, the scale of the change,the interdependence of the jurisdictions concerned and the congruity of their values. With thepossible exception of the complexity of cause-and-effect models, all of these contingenciessuggest that policies or institutions are more likely to be transferable across the territories ofthe UK, than from other nation states.

There are many differences between the UK systems which might yield practical policylessons if studied systematically. They include differences in:

· mechanisms for funding further and higher education;· school management and organisation, and policies for parental choice (Adler, 1997; Raab

et al., 1997);· curricular and vocational guidance (Burdin & Semple, 1995);· the professional organisation and registration of teachers (Maclure, 1993): the General

Teaching Councils being introduced in England and Wales draw on the Scottish experi-ence;

· the local control and funding of public training (TECs and LECs) (Bennett et al., 1994);· the organisation of youth training: Northern Ireland’ s Jobskills programme anticipated

many of Dearing’ s (1996) recommendations for England and Wales;· post-16 policy: the development of a uni® ed system in Scotland, and initiatives such as the

Welsh Credit Framework (Fforwm, 1997), have been seen as models for other parts of theUK; and

· the organisation and content of higher education (National Committee of Inquiry intoHigher Education, 1997).

At present, UK policy-makingÐ whether at UK or territorial levelÐ makes less effective useof home international comparisons than it might, partly because of the nature of thepolicy-making process, and partly because of the political constraints within which it operates(Raffe, 1998). Academic research, separate from the policy-making process and free of itsconstraints, could play a larger role.

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Feasibility of Comparison

Our ® nal argument for home international comparisons is that they may be easier or cheaperto conduct. They are facilitated by a common language, cultural af® nities, a commonadministrative environment and geographical proximity. Costs of travel and communicationare lower. Collaboration among UK universities or research institutes, where research isorganised and funded along similar lines, is likely to be easier than among institutions indifferent nation states where these things are organised differently. Funding is more likely tobe available from a single source. More statistics and datasets for secondary analysis areavailable on a comparable basis across the UK than across nation states (although many keydatasets only cover Great Britain or England and Wales).

We should not exaggerate this argument. We have found that reconciling thedifferences in design and de® nition across the youth cohort surveys of England and Wales,Scotland and Northern Ireland, respectively, is just as dif® cult and challenging as theconstruction of a cross-national dataset for Ireland, The Netherlands and Scotland (Hannanet al., 1994).

4. Conclusion

In this paper we have compared the education and training systems of England,Scotland, Wales and Northern Ireland, and argued that there is a case for increasingthe attention to home international comparisons. Such comparisons can serve a rangeof scienti® c and policy-related goals, and are of interest outside the UK as well aswithin it.

What should a programme of home international comparisons look like? In the ® rstplace, they should not address only domestic UK agendas; they are of potential value toresearchers and to users of research elsewhere. Indeed, they should not be seen as sui generis,as a qualitatively distinct style of research, but rather as part of a spectrum of comparativestudies, which embraces varying con® gurations of system and societal boundaries, varyingdegrees and types of difference between systems, and varying levels and modes of interactionbetween systems.

Second, they should address a broad range of issues. They should encompass thehistory and development of systems, their economic and social contexts and the policy-making process, as well as the analysis of speci® c institutions and processes and theevaluation of their effectiveness. They should contribute to theoretical development andcomparative methodology as well as generate applied knowledge to solve problems of policyand practice.

Finally, the potential of home international comparisons is increasing as theirsubject matter is changing. There is already a trend towards divergence among the fourUK systems, and this trend may accelerate under the Scottish Parliament and Welshand Northern Ireland Assemblies. A programme of home international research needs ahistorical perspective and a capacity for analysing social change if it is to understand thesedevelopments; and it must be able to respond to the new questions and challenges that theypresent.

Acknowledgements

We gratefully acknowledge the support of the UK Economic and Social Research Councilwhich funded the Home Internationals Project (R000236840) of which this paper is a product.

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The Case for `Home Internationals’ in Comparative Research 23

Presentations based on an earlier version of the paper were made at a symposium at the Yorkconference of the British Educational Research Association, and at the Dublin workshop ofthe European Research Network on Transitions in Youth, in September 1997; we aregrateful to participants for their comments.

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