Comparison of the Convention on the Rights of Persons with Disabilities and Sheltered Workshop Policies in Sweden, Germany, and the United States

抄録

　Improving the living conditions and quality of life for persons with disabilities (PWDs) are crucial aspects guiding disability policies in several countries. From the Americans with Disabilities Act (ADA) (1990) to the United Nations Convention on the Rights for Persons with Disabilities (CRPD) (2006), the importance of a rights-based approach to disability policy may be regarded as the most frequently mentioned resolution of the last two decades. The nations participating in the CRPD are required to enforce the content of the convention. However, disability policies have long been seen as an important part of welfare state policies, the characteristics and construction of which are deeply influenced by the financial resources and payment structures of individual countries. Sheltered workshop policies for PWDs are no exception, although these policies do share some similar characteristics across countries, such as a facilities-based working plan and low wages. Thus, it is worth studying how the core values and policy practices identified by the CRPD－such as integration, nondiscrimination, and decision-making with the participation of PWDs－influence the sheltered workshop policies of individual welfare state countries. This article examines the impact of the CRPD on the sheltered workshop policies regarding PWDs in three welfare state nations. Notably, the welfare policy framework and resource allocation patterns of each country affect its sheltered workshop policies more than does their signing the CRPD.