Regulatory guide - Managing psychosocial hazards

1. Identify psychosocial hazards

The first step in the process is to identify all reasonably foreseeable psychosocial hazards arising from work carried out by the business or undertaking. This involves PCBUs identifying the aspects of work and situations that could potentially harm workers or others at the workplace and why these may be occurring.

Below is a list of some common examples of psychosocial hazards PCBUs should consider when identifying psychosocial hazards in their organisation. The list is not exhaustive.

• Job demands
• Low job control
• Poor support
• Lack of role clarity
• Poor organisational change management
• Inadequate reward and recognition
• Poor organisational justice
• Traumatic events or material
• Remote or isolated work
• Poor physical environment
• Violence and aggression
• Bullying
• Harassment including sexual harassment
• Conflict or poor workplace relationships and interactions

Workers are likely to be exposed to a combination of psychosocial hazards; some risks may be constantly present, while others arise sporadically.

When identifying psychosocial hazards, PCBUs must consult, so far as is reasonably practicable, with workers who carry out work for the business or undertaking and who are (or are likely to be) directly affected by a psychosocial hazard or risk. Consultation must include any health and safety representatives (HSR) who represent the affected workers.

It may be reasonably practicable for a PCBU to accommodate the needs of an individual worker to prevent harm where the worker has disclosed those needs or the PCBU is aware. For example, a worker with an injury or disability may need a quiet work area or different equipment to do their work. As well as making changes for individual workers PCBUs must still eliminate or minimise psychosocial risks for all workers so far as is reasonably practicable.

These changes may include, but are not limited to, changing workload and work hours, the nature of work, the work environment, or support and supervision.

2. Assess the risks

Once the psychosocial hazards have been identified, PCBUs will need to assess the risks the hazards create. PCBUs should carry out a risk assessment in consultation with workers and their HSRs (if any) for any hazards that have been identified. However, if the risks and how to control them effectively are already known, PCBUs can implement the controls without undertaking a risk assessment and then check to confirm these have been effective.

To assess the risk of harm, PCBUs need to identify the workers affected and consider the duration, frequency, and severity of their exposure. PCBUs need to consider psychosocial hazards collectively rather than in isolation. Workers and others may be exposed to more than one psychosocial hazard at any time and hazards can interact or combine.

Psychosocial risks increase when exposure to hazards is more severe (e.g. exposure to a traumatic incident), more frequent (e.g. regularly performing tasks without adequate support), or is longer in duration (e.g. high job demands over weeks or months).

When assessing risk, PCBUs must consult with workers, other duty holders, and any HSRs (if any). Depending on the circumstance, it may also be appropriate to consult:

• Industry experts
• Hazard experts (for example, organisational psychologist where there are complex psychosocial risks present or security professionals where there is a risk of violence and/or aggression), and/or
• Experienced WHS professional who can assist with conducting a risk assessment and communicating the results to workers and their HSRs.

PCBUs must provide workers with a reasonable opportunity to raise psychosocial health and safety issues, express their views and contribute to decision-making. PCBUs must consider whether existing consultation arrangements are appropriate for psychosocial risks.

For more information about identifying and assessing psychosocial hazards and risks, refer to the following Codes of Practice approved under the WHS Act:

• Model Code of Practice: Managing psychosocial hazards at work
• How to Manage Work Health and Safety Risks Code of Practice 2015
• Work Health and Safety Consultation, Co-operation and Co-ordination Code of Practice 2015

3. Control the risks

In determining the control measures to implement, PCBUs must have regard to all relevant matters, including:

1. the duration, frequency and severity of the exposure of workers and other persons to the psychosocial hazards; and
2. how the psychosocial hazards may interact or combine; and
3. the design of work, including job demands and tasks; and
4. the systems of work, including how work is managed, organised and supported; and
5. the design and layout, and environmental conditions, of the workplace, including the provision of:
1. safe means of entering and exiting the workplace; and
2. facilities for the welfare of workers; and
6. the design and layout, and environmental conditions, of workers’ accommodation; and
7. the plant, substances and structures at the workplace; and
8. workplace interactions or behaviours; and
   1. the information, training, instruction and supervision provided to workers.^[6]

These relevant matters, which are listed in Regulation 55D, assist PCBUs to ensure they are identifying all appropriate controls and relevant conditions in the context of their individual workplace which in turn will put them in a position to effectively apply the requirements for managing psychosocial risk in accordance with the regulations/hierarchy of controls.

Eliminating risks

Eliminating risks is the most effective control measure and PCBUs must always consider elimination before anything else. Eliminating risks means completely removing the psychosocial hazard and associated risks.

It may not be reasonably practicable to eliminate the risk, for example, if doing so means a product cannot be made or a service cannot be delivered. Where a risk cannot be eliminated, PCBUs must minimise the risk so far as is reasonably practicable.

Minimising risk

Hierarchy of controls

The hierarchy of controls must be followed if it is not reasonably practicable to eliminate psychosocial risk.

The hierarchy of controls ranks control measures from the highest level if protection and reliability to the lowest and requires PCBUs to minimise psychosocial risks by one or more of the following methods:

• Substitution—minimise the risk by substituting (wholly or partly) or replacing a hazard or hazardous work practice with something that gives rise to a lesser risk.
• Isolation—minimise the risk by isolating or separating the hazard or hazardous work practice from any person exposed to it.
• Engineering controls—minimise the risk by implementing engineering controls as a physical control measure.

If a psychosocial risk remains, PCBUs must implement administrative controls, so far as is reasonably practicable. Any remaining risk must then be minimised by providing suitable personal protective equipment (PPE), so far as is reasonably practicable.

Administrative controls and PPE do not control the hazard at the source are less reliable at minimising psychosocial risk on their own. This is because they rely on human behaviour and supervision and should therefore be used in conjunction with higher order controls, so far as is reasonably practicable.

A combination of the controls set out in the hierarchy of control measures may be used to minimise psychosocial risks, so far as is reasonably practicable, if a single control is not sufficient for the purpose.

Consideration of which control measures to implement is not to be limited to matters as they currently exist and the PCBU must also have regard to what changes, if any, should be made. For example, PCBUs must consider existing plant, substances, and structures in the workplace, but also consider whether different or additional plant, substances or structures should be in use in the workplace to manage psychosocial risks.

PCBUs must ensure that control measures are maintained so that they remain effective, including by ensuring they are fit for purpose, suitable for the nature and duration of the work; and set up and used correctly. PCBUs should decide what maintenance a control measure will require when they implement the control and establish a schedule for routine checks and maintenance.

For more information about controlling psychosocial risks and maintaining controls refer to Regulations 36 and 37 and the following Codes of Practice approved under the WHS Act:

• Model Code of Practice: Managing psychosocial hazards at work
• How to Manage Work Health and Safety Risks Code of Practice 2015

4. Review control measures

The last step of the psychosocial risk management process is to review the effectiveness of the implemented control measures to ensure they are working as planned. If a control measure is not effectively controlling a psychosocial hazard or risk, it must be reviewed and modified or replaced. This includes reviewing control measures:

1. when the control measure is not eliminating or minimising the psychosocial risks so far as is reasonably practicable
2. before a change at the workplace that is likely to give rise to a new or different psychosocial risk that the control measure may not effectively control
3. if a new psychosocial hazard or risk is identified
4. if the results of consultation indicate a review is necessary, or
5. if an HSR requests a review because they reasonably believe one of the above has occurred and it has not been adequately reviewed already

For more information about reviewing control measures for psychosocial risks refer to Regulation 38 and the following Codes of Practice approved under the WHS Act:

• Model Code of Practice: Managing psychosocial hazards at work
• How to Manage Work Health and Safety Risks Code of Practice 2015