Psychosocial hazards: what Queensland employers must manage
Short answer: psychosocial hazards are aspects of work that can cause psychological harm, including bullying, harassment, excessive workload, poor support, role ambiguity and exposure to traumatic content. Under work health and safety legislation, employers must identify them, assess the risk and eliminate or minimise it so far as is reasonably practicable, and keep doing so. Managing them is not a wellbeing initiative. It is a safety duty, and it is enforceable.
Most employers I speak to understand physical safety. They have a hazard register, they run inductions, they know what a safe work method statement is. Ask the same business how it manages psychosocial risk and the answer is usually an employee assistance program and a wellbeing policy.
Neither of those is risk management. One is a support service and the other is a document.
What counts as a psychosocial hazard
A psychosocial hazard is anything in the design or management of work, or in the working environment, that can cause psychological harm. The common categories are these.
Hazard | What it looks like in practice |
Job demands | Sustained excessive workload, unreasonable time pressure, long hours as the norm rather than the exception |
Low job control | Employees with no say over how or when work is done |
Poor support | Inadequate supervision, training or resourcing for the work assigned |
Poor organisational change management | Restructures and role changes handled without consultation or clarity |
Inadequate reward and recognition | Effort and reward persistently out of balance |
Role ambiguity or conflict | Unclear responsibilities, or competing instructions from different managers |
Poor workplace relationships | Unresolved conflict, incivility, exclusion |
Bullying, harassment and sexual harassment | Repeated unreasonable behaviour, or unwelcome conduct of a sexual nature |
Violence and aggression | Exposure to aggressive customers, clients or members of the public |
Traumatic events or material | Work involving exposure to distressing incidents or content |
Remote or isolated work | Working alone without adequate communication or emergency support |
Two things matter about that list. Most of those hazards are features of how work is organised, not features of individual employees. And several of them, particularly organisational change and role ambiguity, are created by decisions management makes without ever considering them as safety decisions.
The hazard is the work, not the person
This is the shift employers find hardest.
When a complaint comes in about workload or a manager’s conduct, the instinct is to assess the employee. Are they coping? Are they resilient? Have they accessed support?
The duty runs the other way. The obligation is to examine the work and the environment, and to control the hazard at its source. Offering counselling to someone carrying an unmanageable workload addresses the symptom while leaving the hazard in place, and it will not answer a regulator asking what was done about the risk.
Why this is now a compliance issue, not a culture issue
Three developments have moved psychosocial risk from the soft end of HR into enforceable obligation.
Work health and safety regulations across Australian jurisdictions now expressly require psychosocial risks to be managed, with Queensland having its own Managing the risk of psychosocial hazards at work Code of Practice 2022, which commenced on 1 April 2023. A code of practice is admissible in proceedings as evidence of what is known about a hazard and of the reasonable means of controlling it.
Separately, employers carry a positive duty in relation to sexual harassment, sex discrimination and hostile work environments, which requires reasonable and proportionate measures to prevent the conduct rather than a response once it has occurred.
And the Fair Work Commission can make stop bullying and stop sexual harassment orders, which brings a second forum into play alongside the safety regulator.
The investigation overlap employers miss
When a bullying or harassment complaint lands, most employers correctly identify that they may need to investigate. Fewer recognise that the same facts also raise a safety question.
The investigation establishes what happened between the people involved. The safety duty asks something different: what in the work or the environment allowed that risk to exist, and what has been done to control it for everyone else exposed to it.
A substantiated bullying finding that produces a disciplinary outcome and no change to supervision, workload or reporting lines has answered one question and left the other open. Our guidance on when to run a workplace investigation covers the first. This is the second.
How to actually manage psychosocial risk
The method is the same risk management cycle used for physical hazards. Identify, assess, control, review.
Identify the hazards. Consult employees, because they hold the information. Use existing data as well: complaints, turnover, absenteeism patterns, exit interviews, workers' compensation claims and incident reports.
Assess the risk. Consider the duration, frequency and severity of exposure, and how hazards combine. High demands with low control and poor support is a materially different risk to any one of those alone.
Control the risk. Work down the hierarchy. Eliminate where you can, for example by removing an unnecessary task or correcting a workload distribution. Then substitute, isolate, apply engineering and administrative controls, and use training and support last rather than first.
Consult. Consultation is a standing requirement, not a step. Controls designed without the affected workers are routinely the wrong controls.
Document. Record the hazards identified, the assessment, the controls chosen and the reasoning. This is the record that answers a regulator, and it is the record most businesses do not have.
Review. After any incident, complaint, restructure or change to how work is done, and on a set cycle regardless.
The three things to do this quarter
If none of this exists in your business yet, start here rather than with a policy.
Add psychosocial hazards to your existing risk register, using the categories in the table above as prompts. Ask your managers, in writing, which of those categories currently apply in their teams. And check that your grievance process produces a safety review as well as an outcome for the individuals involved.
Frequently asked questions
Is an employee assistance program enough to meet the duty?
No. An EAP is a support measure sitting at the lowest level of the control hierarchy. It does not identify hazards, assess risk or control it at the source, and it cannot substitute for doing so.
Do these duties apply to small businesses?
Yes. Work health and safety duties apply regardless of size. What is reasonably practicable will differ for a small business, but the obligation to identify and manage psychosocial risk does not disappear with headcount.
What if the hazard is a manager’s behaviour?
Behaviour by a manager is within scope, and it is usually both a conduct matter and a safety matter. Those run through different processes, in parallel, rather than one substituting for the other.
Can an employee claim for psychological injury arising from these hazards?
Psychological injury claims are part of the workers' compensation scheme, and exposure to unmanaged psychosocial hazards is a recognised pathway to them. Claims handling and return to work obligations then apply on top of the safety duty.
Workplace relations support from the Gold Coast, Australia-wide
IndustrialHR is based on the Gold Coast, Queensland, and supports employers across Australia with investigations, psychosocial safety, wage and award compliance, performance and restructures, and workplace reviews. Our work covers small employers through to larger organisations, in any industry.
If a psychosocial complaint has already been raised, or you want the risk assessed before one is, see projects and high-risk work or IndustrialHR Alliance for ongoing written advice.
Contact Rhiannon on 0481 100 416, email [email protected], or schedule a consultation.
Employers dealing with this now can book a free 30 minute discovery call or a 60 minute case review with Rhiannon. Book a consultation. IndustrialHR does not provide legal advice.
