the legal culture in specific countries. For professional associations, links with external confederations of trade unions are not normal, although they do exist, e.g., in Sweden and the Netherlands. In other cases, military associations have joined umbrella associations representing professionals or public servants. In addition, many military associations or unions are members of international associations promoting the interests of servicemen and -women. The largest by far is the European Organisation of Military Associations (EUROMIL), with more than 30 associations (both professional associations and trade unions) from over 20 countries, but a number of others exist on a regional basis. Most OSCE participating States prohibit industrial action by members of the armed forces. It is common in many countries for the freedom of association of public servants, including members of the armed forces, to be limited. This difference in treatment in comparison with other workers may be justified because of the public interest in ensuring that essential public services are not disrupted. It can be argued that members of the armed forces are not workers in a conventional sense in that, when enlisting, they subject themselves to a comprehensive system of restrictions under a system of military discipline that is far more extensive than the usual control of an employer over an employee. Nevertheless, it is notable that some legal bodies have treated members of the armed services as “workers”.83 Membership by servicemen and -women of trade unions or other collective representative bodies poses two distinct problems. The first is the question of military discipline and possible interference with the esprit de corps. The raising of collective grievances on the part of members of the armed forces has traditionally been seen as equivalent to insubordination or even the serious military offence of mutiny. It is argued that the disciplined nature of the armed forces requires that orders should not be questioned. Moreover, industrial action could disrupt vital operations in a way that threatens national security. Whether this interest also forbids any discussion of the conditions of service in general is more debatable, however. There is also cause for scepticism about the general argument, based on surveys of countries that have permitted military associations (see surveys by the French Senate and prepared for the Joint Services Command and Staff College in the UK).84 The second issue is related to allegiance and outside influence. Membership of trade unions is seen as undesirable because members of a union may act collectively on the instruction of union officials (for example, in taking industrial action), and this can be seen as a rival source of authority and allegiance to the chain of command within the armed forces. The objection is all the greater if the union in question is a civilian one. In order to address these problems to some extent, collective representative bodies — in countries where they are permitted — commonly work under two constraints. The first is that the representative body may be limited to members of the armed forces (so countering the objection of outside influence) and not linked to other trade unions. Second, legal barriers may be imposed that forbid strikes or other forms of industrial action that could disrupt operations or threaten security. The changing context in which military forces now operate prompts a re-evaluation of restrictions on association, for two distinct reasons. The first is that the nature of the tasks 83  In 1999, the South African Constitutional Court found that members of the South African Defence Force fell within the scope of a right in Section 23.2 of the Constitution of South Africa for “workers” to be members of a trade union, to participate in its activities, and to strike. 84  And see G. Caforio, “Unionization of the Military: Representation of the Interests of Military Personnel”, in G. Caforio (ed.), Handbook of the Sociology of the Military (New York: Kluwer Academic/Plenum Publishers, 2003), pp. 311-322, suggesting (from the experience in Austria) no discernible effect on operational performance. Also see the unpublished study for the UK Joint Services Command and Staff College by H. Akiwumi, “Would an Armed Forces Federation Undermine the Chain of Command?”. 66 Handbook on Human Rights and Fundamental Freedoms of Armed Forces Personnel