What is involved in managing psychosocial hazards at work?

3.1 Essential elements of an effective systematic risk management process

Leadership and management commitment

Ensuring a genuine commitment to managing psychosocial hazards and risks by leaders and managers is essential for effective systematic work health and safety risk management. To achieve this, they must understand:

1. The WHS obligations of the PCBU, officer(s) and workers
2. the role of leaders and managers (including human resources and WHS managers) to assist the PCBU and officer(s) meet their WHS duties
3. systematic WHS management, including on psychosocial matters, and
4. the business case for WHS, including why managing psychosocial risks is a concern to your organisation.

Consulting workers

Consultation involves sharing information, giving affected workers and others reasonable opportunities to express views, taking those views into account before making decisions on WHS matters, and advising workers of the consultation’s outcomes in a timely and appropriate manner.

A PCBU must consult, at each step of the risk management process, workers who carry out work for them and who are or likely to be affected by a matter and their HSR(s). Consultation should occur as early as possible on:

• new policies, procedures and systems of work
• organisational restructures, new reporting arrangements and work locations
• changes to tasks, duties, and working arrangements, including rosters
• new technology, plant, equipment and production processes, or
• the redesign of existing workplaces.

The consultation processes should suit the organisation’s needs and the reasonable needs and expectations of affected workers and take reasonable steps where required to respect an individual’s privacy and confidentiality. It should provide workers with:

• clear, timely information on how psychosocial hazards and risks will be proactively identified, managed and monitored, and
• how work can be safely carried out.

Consulting those in your supply chains

A supply chain is a contractual network between an organisation and its suppliers or between agencies to produce and distribute a specific product or provide a service. WHS risks may result from supply chain arrangements, practices, or shared systems. Each PCBU in the supply chain must ensure, so far as is reasonably practicable, the health and safety of all workers that they engage, cause to engage, influence or direct; and must consult all workers that carry out work for them on WHS issues.

PCBUs must talk with suppliers, those commissioning their services, or sharing systems to understand each other’s needs and identify common psychosocial hazards, risks and controls, and opportunities to improve the health and safety of all workers and other persons affected by the activities in the supply chain. For further advice, see the Code of Practice Work health and safety consultation, cooperation and coordination (PDF, 635.62 KB).

Adequate planning

Before starting the risk management process, it is important to decide on the goals and processes to be used, for example:

• psychosocial hazard identification and risk assessment methods
• who will be involved (e.g. managers, workers, HSR(s) and, where required, subject-matter experts), and their roles in the process
• how appropriate confidentiality around personal information will be maintained
• what human, technical or financial resources will be provided to establish and implement effective psychosocial risk management processes e.g.
  • organisational policies and procedures to support the risk management process
  • information and training to ensure those participating in the process are competent, or
  • arranging in-house or external expert help, if required
• how controls will be selected and implemented
• who will be responsible for communicating the outcomes, and how and when will this be done, and
• how and who will review and document the effectiveness of the controls.

3.2  Step One: Identify the psychosocial hazards

The first step in the risk management process is to identify the psychosocial hazards which may arise from the work context or work content. This involves identifying the aspects of work and situations that could potentially harm people and why these may be occurring. It should also find where hazards and risks are, why they are not effectively managed, and opportunities to improve the quality of the existing controls.

To inform your risk assessment, you should always consider the underlying sources of psychosocial hazards and risks; these are likely to be both external and internal to your organisation. For example:

• the work environment, nature and type of work undertaken by your organisation
• your operating environment and economic pressures
• interactions and behaviours between people at work and within your supply chain (outsourcing, contractors, partner agencies, suppliers or customers) that impact workers’ and others’ health and safety
• the design and management of your organisation as a whole – structure, and governance, procurement and resourcing decisions
• resourcing decisions affecting work demands, training, instruction and supervision
• design and management of the work tasks and jobs
• design and maintenance of buildings, technology and plant
• hazardous working environments and locations, arrangements with those in your supply chains (e.g. contract requirements such as labour-hire, delivery schedules and penalties, overlapping policies and procedures), and
• significant changes such as downsizing, organisational restructuring, new work arrangements or technologies.

Psychosocial hazards can arise from organisational-wide systems, work practices and cultural issues. Where this occurs, information about psychosocial hazards may need to be collected across the organisation. This can help to confirm if there are widespread risks that need to be controlled. Other psychosocial hazards will relate to specific tasks and jobs, in this case you will only need to collect information from the affected workers.

There is commonly more than one psychosocial hazard present, however they can occur as an isolated event.

Some psychosocial hazards will be quite apparent, and others will require a more comprehensive process to identify them and their underlying causes. For example, arising from the business pressures, the way the organisation or work group is structured, how work is designed and managed, or from the actions of others such as contractors, partners, or suppliers.

The hazard identification process should consider if the psychosocial hazards differ between workgroups or teams, functions or workplaces.

Systematically collecting and reviewing available information and data

The PCBU should consider how the organisation’s work systems, including operating procedures and governance arrangements influence:

• the nature of the work
• how work is managed and undertaken, and
• impact on workers’, supervisors’ and managers’ attitudes and behaviours.

Relevant information and records should be reviewed; these may include, for example:

• psychosocial hazard and workforce or culture surveys
• outcomes from WHS focus group discussions
• work-related psychosocial hazard and incidents reports
• complaints and investigations into alleged harmful workplace behaviours
• issues raised at health and safety committee (HSC) meetings
• absenteeism, turnover, exit interviews, sick leave data and workers’ compensation claims
• business strategy resourcing decisions (e.g. staffing levels, achievements of key performance indicators)
• outsourcing, contracting, partner and procurement arrangements
• advice from WHS professionals, employer organisations and unions
• advice provided by the WHS regulator
• staff skills and experience profiles
• analysis of work tasks, schedules and locations
• duty statements and performance agreements
• WHS and human resources systems, policies and procedures, and
• WHS key performance indicators, including those specific to psychosocial hazards.

Useful insights into potential psychosocial hazards and risks may also be found in project risk management or procurement documents and through your supply chains and networks.

Workers generally know which aspects of the work are creating or likely to create hazards or risks and may have practical suggestions on how to manage these. The PCBU must consult affected workers and their HSR(s) when identifying psychosocial hazards and risks and throughout the risk management process. For example, this can be done through consultative forums, workplace surveys, health and safety committee meetings, and routine or dedicated project meetings between worker(s) and their supervisor.

By talking to your workers and asking about their experience of psychosocial hazards, you can also decide if they may need some additional support so they can do their work safely and effectively.

Observe and talk to workers about work activities

Hazards and risks can also be identified by looking and talking (walk-through/talk-through) with workers about how work is done under:

• normal operating conditions
• during peak workloads, and
• under unexpected circumstances, including emergencies (e.g. injury of a colleague or serious workplace incident).

You should also compare this to the work methods described in policies and procedures and check they are appropriate for the different circumstances. It is useful to talk with both experienced and inexperienced workers.

Examples of things to look out for and ask about may include:

• tasks or situations that are generally considered mentally, emotionally or physically very difficult or stressful
• frequent rushing, delays, work backlogs, increased rates of errors or wastage, unexpected incidents, or process failures
• workers improvising how work is done due to time pressures, or inappropriately delaying or avoiding tasks
• concerns about understaffing or inappropriate staff skills mix, inadequate or inappropriate tools or amenities
• significant differences between duty statements and required activities
• complaints that organisational policies, procedures and systems of work that are unsafe or too difficult to follow, or conflicts between patient or customer needs and WHS standards
• significant changes in the behaviours of workers (e.g. incivility, openly criticising others or the organisation, refusing offers of help when it is needed or others requests for help, lack of engagement, low-quality performance or failure to complete tasks/assignments on time, or increased absence from work)
• the behaviour of others at the worksite, including visitors (e.g. suppliers, clients, parents etc.), and
• new technology and equipment changes.

Many psychosocial hazards are quite common, and the risks well known. In these situations, if, after identifying the hazards, you already know the risks and how best to control them, you do not need to assess the risks. You must still consult with the affected workers and HSR(s) when considering proposed controls, on how these will be implemented and when checking if these are effective and working as intended.

For better psychosocial hazard identification, the PCBU should use a combination of information sources such as organisational data, observing work activities and consulting workers.

If you choose to conduct workplace surveys, giving your workers the option to respond anonymously may improve the response rate and quality of the information you receive. Ideally this information should be collected from a representative cross section of workers or through existing structures such as WHS Committees.

The free online and validated Australian Psychosocial Risk Assessment survey and resources which may suit your purposes are at the People at Work website.

3.3 Step Two: Assess and prioritise the psychosocial hazards and risks

The psychosocial risk assessment process will assist the PCBU in determining:

• the seriousness of the risk (considering both the consequences for affected workers and others and the likelihood of harm occurring)
• which workers are most at risk and affected
• if risks are organisational-wide or apply to specific groups of workers or work tasks
• what controls are currently used (if any), how effective they are
• what controls could reduce the risk(s) to the lowest practical level, and
• the priority for action.

You should do a risk assessment when:

• it is unclear if the psychosocial hazards may result in harm or how they may interact with each other to produce a new or more significant risk(s) of harm, or
• changes are planned, or underway that may impact the effectiveness of controls.

For small businesses, it may be as simple as regular toolbox discussions with affected workers. A more comprehensive process may be required if serious WHS risks have been identified or are suspected.

A risk assessment is not something that only happens once but should be part of a continuous improvement process.

Some hazards and risks may be widespread, and others only under certain circumstances. Like all risk assessments, you must make sure you consider both the usual work conditions and reasonably foreseeable unusual operating conditions.

Determine the psychosocial risk

When assessing risk, it is crucial to focus the most effort on psychosocial hazards that are severe or can impact large numbers of workers or groups of workers or things that have very high risk of harm for smaller numbers of people. For new or high-risk activities, a structured task analysis should be completed, including:

• a detailed description of the activities and which workers are undertaking these
• locations, duration and frequency of activities
• necessary information, plant and equipment
• environmental conditions
• mental and physical requirements to do the tasks
• identified psychosocial and physical hazards and risks, and
• any other relevant factors.

Working through the following questions will help determine which aspects of the tasks or jobs pose a risk of harm from exposure to psychosocial hazards and help prioritise controls.

First, make sure you sufficiently understand:

• the main tasks and duties that make up your workers’ tasks and jobs
• the number and locations of affected workers
• if psychosocial hazards listed in Table 1 of this code or others identified through your consultation processes are present
• how psychosocial hazard(s) might interact and increase or decrease the risk, and
• the effectiveness of existing controls implemented.

Then consider the following:

• the seriousness of the consequences for workers if exposed including:
  • the severity of possible harm and/or
  • the duration of exposure to harm
• the reasonably foreseeable likelihood that workers may experience harm doing the task or jobs, for example, has harm occurred previously or in similar workplaces?
• next determine consequences and likelihood in combination.

The outcomes and decisions from considering these three factors can help you prioritise action. Consider whether the consequences and likelihood of harm suggest controls are required, and how urgently action is needed to implement these.

Affected workers and their HSR(s) must be consulted as part of the risk assessment process.

To improve the accuracy of this process it is suggested you separately consider and rate risks to health and safety that are:

• unlikely but where the consequences may be very serious to catastrophic, and
• likely or very likely but where the consequences may be less serious.

Combining both groups together means psychosocial risk which is less likely, but may have very serious or catastrophic consequences, may not be given appropriate weight.

3.4 Step Three: control psychosocial hazards and risks

Every workplace is different. So, the best combination of control measures to eliminate hazards or minimise risks will be tailored to your organisation’s business size, type and work activities to manage risks during both everyday operations and emergencies.

Most effort should be on implementing control measures which target the psychosocial hazards identified and assessed in steps one and two. The risk controls can involve good work design across the organisation and/or be targeted to affected work groups and tasks with the highest risks. Targeting controls in this way will provide the highest level of protection for the largest number of workers. These controls will usually also benefit individuals identified to be at risk of harm.

This next section provides information about the considerations and processes you should use to select appropriate controls for your organisation.

Eliminate or minimise risk through good work design

Good work design is concerned with specifying and organising existing and new jobs and tasks of a workgroup (and if needed for individual workers) to be less hazardous. This will help meet organisational requirements to efficiently deliver services or products and assist in minimising harm from psychosocial hazards and risks. Groups of workers may be exposed to several different kinds of psychosocial hazards and risks. The best and most effective way to control these is at the source, that is, by substituting the current work methods with less hazardous alternatives.

It may not always be reasonably practicable to eliminate the hazard or risk for example, where jobs have some inherent hazards such as shift work, or police dealing with violent or abusive members of the public. Or if by doing so you cannot make your product or deliver your service, or where the cost of implementing the control(s) is grossly disproportionate to the risk.

If a hazard or risk cannot be eliminated, then the PCBU must minimise it so far as is reasonably practicable.

When redesigning work, you can consider the psychosocial hazards identified and look for opportunities to turn these into controls to mitigate risk. For example, where there is role overload such as excessive time pressure, role conflict, and poor practical support you could improve scheduling to minimise overload, clarify roles and responsibilities and provide additional practical support. For more information, see Safe Work Australia Principles of Good Work Design: a WHS Handbook.

Physical hazards contributing to psychosocial risks should be controlled through relevant isolation and engineering controls for example, the use of physical barriers to help control the risk of violence in the workplace.

Where hazards and risks remain even after the work has been redesigned, then administrative controls, including safe systems of work, and appropriate information, training, instruction and supervision, will also be required. Relying on administrative controls should never be the main risk management approach.

Safe systems of work

Safe systems of work are organisational rules, policies, procedures and work practices that must be developed and followed to ensure workers and others are not harmed by any remaining (residual) psychosocial risks. Systems of work may include rostering, working hours, task rotation and breaks to allow opportunities for rest and recovery, standards and procedures to manage hazardous tasks, and policies and procedures to manage workplace behaviour (such as bullying and harrassment) or organisational codes of conduct.

Safe systems of work must be developed in consultation with workers and reviewed whenever there are changes to the work activities to ensure they remain appropriate.

Information, training, instruction or supervision

The PCBU must provide adequate and suitable information, training, instruction or supervision to workers (including supervisors and managers) which has regard to and includes:

• the nature of the work and tasks to be carried out by workers
• the psychosocial hazards and risks associated with the work
• the required control measures including safe systems of work and how to comply with these
• how workers should report and respond if a problem or risk arises, and
• ensure information, training and instruction is readily understood by any person it is provided to.

A competent person (someone who has acquired through training, qualification or experience, the necessary knowledge and skills to safely carry out the task) should provide the information, training, instruction and supervision.

Uncertainty about how to safely and efficiently do new tasks including using new technology, or that may not have been undertaken for some time, or tasks undertaken during an emergency, and when working on unfamiliar worksites, are relatively common psychosocial hazards. Providing adequate and timely information, training, instruction and supervision are particularly important where the work has inherent risks (e.g. risk of violence for first responders).

In most cases, psychosocial risk management can use a mix of good work design, safe systems of work, and suitable and adequate information, training, instruction, and supervision. While PPE is not a common control for psychosocial risks, in some cases, where the absence of or inadequacy of PPE to control physical risks is causing workers’ concern, this will also need to be addressed. Some examples of common psychosocial risk controls can be seen in Appendix A.

Reasonable adjustments for individual workers

Duty holders may also need, so far as is reasonably practicable, to make reasonable adjustments to the design and management of the work to accommodate the needs of an individual worker to prevent harm (for example, a worker with a disability or returning to work after an injury). There may also be duties under anti-discrimination, privacy and other relevant laws that need to be considered.

Controlling residual risks

Before authorising the implementation of controls, the relevant duty holder should do a final check for residual risks that may remain and check the quality of the controls in place to reduce the risk as low as reasonably practicable.

Risk control quality could be rated as follows:

1. Controls are adequate, i.e., hazard/risk is eliminated, or residual risk is insignificant.
2. Controls are in place to the full extent that is reasonably practicable. The controls are not ideal, but there is no better control currently available, or the cost would be grossly disproportionate to the risk. Ongoing monitoring of this risk is needed.
3. Controls are satisfactory and appear to be working adequately. However, more effective controls are known and available and could be implemented.
4. Controls are inadequate. There are known limitations with existing controls, and further action to manage the risk is urgently needed.
5. The risk is uncontrolled. Controls either have not been implemented, or they are grossly inadequate. Immediate action is required.

If, after considering the residual risks and the adequacy of controls, the risk is uncontrolled, inadequately controlled, or controls are considered only satisfactory, further action is required. When making a judgement, about what additional controls are ‘reasonably practicable’, the PCBU should weigh up the elements of what is ‘reasonably practicable’ as set out in section 18 of the WHS Act.

Implementing controls

Because the controls you implement may require changes to the way work is carried out, it is necessary to support these with:

• safe work procedure(s) that describe the tasks, hazards, how tasks can be safely done, and the duties, roles and responsibilities of all parties to follow these
• information, training, instruction and supervision of workers on implemented controls including safe work procedures
• appropriate information and instruction for site visitors, and
• a schedule for maintaining, monitoring and reviewing controls to ensure they are effective and are not creating new unintended WHS or organisational risks.

When proposing changes to existing or new controls or workplace arrangements, it is essential you consult affected workers and their HSR(s) as early as possible. For example, on the:

• design and management of the work such as restructures, work locations, changes to tasks, duties, and working arrangements
• new technology, plant, equipment production processes, or the redesign of existing workplaces.

3.5 Step Four: Proactively implement, maintain, monitor and review the effectiveness of controls

Managers and supervisors should be provided with the authority and resources to implement and effectively maintain controls. Clear accountabilities for monitoring, reviewing and maintaining controls should be allocated.

The information and processes you used to identify hazards and risks will also help you monitor and review the effectiveness of control measures. Do not assume risks will not change or that controls will remain suitable, sufficient, and effective over time.

Reviews can be used to check whether:

• the approach to systematic work health and safety management is effective
• hazards and risks are being effectively controlled
• the organisation is meeting its WHS obligations, including for due diligence, and
• there are opportunities for improvement.

Reviews should occur:

• before significant organisational or workplace changes occur, for example, changes to the organisational structure, work location, environment, equipment and resources, employment conditions or systems of work
• where a new hazard or risk is identified
• if a serious incident, injury or illness occurs arising from the psychosocial risk, or a psychological injury occurs
• if a physical injury occurs where psychosocial risks were likely to be a contributing factor
• if the hazard changes and you are now uncertain of the risk
• if a control measure is not adequately minimising the risk
• where consultation indicates a review is necessary
• if requested by a HSR
• at agreed review dates, such as annually, or
• where audit results indicate, a review is necessary.

The results of a review of controls should trigger discussions between the PCBU and the duty holders to check they are taking all reasonable steps to manage psychosocial risks.

The PCBU should also have strategies to intervene early (to make necessary changes to the work design) if workers report stress, psychological or physical problems and to provide appropriate workers’ compensation arrangements and/or support for return to work if workers have been harmed.

The hazard and risk reporting system should be appropriate for the organisation and proportional to the seriousness and likelihood of potential harm. For example, where there is a reasonably foreseeable risk of occupational violence, the reporting system should include reviewing the effectiveness of controls for this risk.

Appendix A shows some example scenarios with related hazards, possible controls and approaches to monitor, review and continuously improve systematic work health and safety systems.

Common failures in the risk management process are:

• to focus on poor workplace behaviours by an individual and not identify and or sufficiently control the psychosocial hazards which may be contributing or giving rise to these behaviours, or
• not following the hierarchy of control principles and relying on mainly administrative controls.