In this section

• Apply the principles of effective work design
• Consider the hierarchy of control measures and psychosocial risks
• Work design approaches to psychosocial risk control
• Address organisational-wide design issues
• Improve project planning and management
  • Put in place workload planning and review systems
  • Make sure tasks are clearly defined and prioritised
  • Discuss with the workers how complex tasks can be best scheduled
• Design administrative controls to support safe and healthy work
  • Design safe systems of work
  • Organisational rules, policies, and procedures
  • Improve information, instruction, training, and supervision
  • Give suitable personal protective equipment
• Deciding what work designs are reasonably practicable
  • Pilot and monitor major work design changes

Psychosocial control measures are the wide range of measures that could be put in place to manage a psychosocial risk at work. PCBUs need to use a combination of control measures.

The goal of your work design process should be to eliminate psychosocial hazards by designing the work tasks, organisation, working environment and equipment so workers are never exposed to that hazard. Only if that is not reasonably practicable, then minimise psychosocial risks through improved design of the work, workplace, plant, structures, and the systems of work.

Following the steps recommended in the Code of Practice (illustrated in Figure 4: Psychosocial risk management cycle), once you have completed steps 1 and 2 to identify and assess the key underlying cause of the psychosocial risks and prioritised these, you can move to step 3 to consider work design options to control the risks. Part of this step will be to test and put in place appropriate design solutions. Step 4 involves reviewing these control measures and solutions.

Address organisation-wide design issues

Many psychosocial risks may impact multiple teams across organisations. For example, risks such as the design and maintenance of IT systems, new or existing technologies or infrastructure, tensions around office relocations or restructures, and hours of work and/or rosters.

Typically, you can address these through early effective communication and genuine consultation with workers about the issues. This can help to reduce uncertainty and make sure proposed changes are appropriately planned and done.

If a SafeWork NSW Inspector visits and the duty holder has identified these issues, we will expect you to be able to show how you have genuinely consulted with workers and taken their views into account.

Improve project planning and review systems

Planning to deliver services, produce goods, manage fit-outs, move offices, downsize or upsize, recruit staff and design organisational structures are all part of normal business operations.

It can be easy to overlook applying good work design when embarking on these ‘business as usual’ projects. However duty holders should think about work design at all stages of a project. Sometimes it can help to use project management tools to think about work from concept through to closure.

There are opportunities to proactively find and manage key psychosocial risks effectively from the start of the project. Doing this will often help you avoid costly redesign issues or workarounds that may lead to poorer results than you had originally pictured.

There are legal duties and obligations for PCBUs to make sure that psychosocial and physical risks to the health and safety of workers and others are effectively managed throughout the entire life cycle of a project. This includes duties to, as far as is reasonably practicable, consult, cooperate and coordinate with all other persons who have a duty in relation to the same matter (section 46, WHS Act 2011), and to have regard to the design of work, to eliminate or minimise psychosocial risks as is reasonably practicable (clause 55D, WHS Regulation).

Unfortunately, despite the legal requirement to consult with other duty holders and workers so far as is reasonably practicable, many organisations do not routinely include workers and WHS subject matter experts in project planning, especially during the concept and development phases.

Typically, WHS staff and workers are only consulted immediately before or during implementation (execution), when the opportunities to make significant design changes are usually low and the cost of any changes is higher. Organisations therefore miss important opportunities to improve work design.

Organisations must make sure they genuinely consult, coordinate and cooperate with other duty holders, relevant workers and local subject matter experts at the start and throughout the entire project lifecycle.

Put in place workload planning and review systems

PCBUs must make sure, so far as is reasonably practicable, they provide and maintain safe systems of work. This includes considering the design and management of workload in peaks and troughs. This duty rests with the PCBU and cannot be delegated or contracted out (sections 14 and 272 of the WHS Act).

Line managers are often responsible for the day-to-day decisions around workloads. PCBUs should give these managers reasonable flexibility and autonomy so they can effectively manage staff workloads and make adjustments to deal with day-to-day changes. In turn, managers should give information to the PCBU and senior leaders so they can take appropriate action to address workloads if needed.

Inappropriate workloads (i.e. those that are too high or too low, too frequently) is one of the most common psychosocial risks and good work design is essential for it to be effectively managed. It is important to remember workload is the amount of work to be achieved and the difficulty to do the work in the allowed time. Workloads are inappropriate if the amount and difficulty of work mean that staff regularly need to miss their lunch breaks or work beyond normal hours, at excessive speeds. When workers have too little to do in the time or where most of their tasks are boring and monotonous, this can also present a WHS risk that PCBUs must manage so far as is reasonably practicable.

Most organisations will have workload peaks and troughs across a month, week or even a day. Examples are when staff are on leave or end of month reconciliations are due for finance teams. Importantly, most of these are or should be reasonably foreseeable. Even when they can’t be, there should be controls in place to manage these if they arise. Effective planning for high workload periods or if there is an emergency will help with this.

Organisations should effectively design and monitor the workloads of individuals, teams and divisions. This is especially important when you make significant changes to the way work is organised or completed. Times when this may happen are:

• when introducing new services or products, or changing existing ones
• during organisational restructures and staff recruitment
• during changes to the way work is organised and managed
• during periods of staff shortages and absences due to sick leave or failure to recruit.

Signs workloads may be inappropriate:

• reports from staff, managers, HSRs and customers about poor service or product quality
• outcomes of workplace surveys such as the People at Work Psychosocial Risk Assessment, or other staff consultation processes
• failure of individuals or teams to achieve production goals or targets
• work backlogs and increased errors or product wastage
• failure to follow safety procedures because staff say it takes too long to do it that way
• high rates of overtime, unspent recreation leave, accrued days off or time off in lieu
• unacceptable workplace behaviours and poor organisational culture
• decreased worker engagement and interactions with other team members
• WHS incidents or workers’ compensation claims attributed to high workloads
• above average unplanned absences, such as sick leave and staff resignations

You should use this information to inform work design decisions.

When deciding the right mix of skills and staff needed to do a task, the duty holder should make sure that:

• you allocate work based on realistic, accurate and timely data and information, not best-case scenarios. Duty holders must take into account actual staff numbers and their skills, public holidays and leave. You must include reasonable allowances if there are unscheduled staff absences
• you comply with WHS and industrial legislation, awards, and agreements
• workers should not be required to do work that significantly and regularly exceeds ordinary working hours. This includes when there is urgent or unexpectedly high volumes of work that is short-term; when it is for a specified time; or where there are essential unplanned service needs, like emergency management
• your decisions and distribution of workload is fair
• you consider individual and team training, skill, knowledge, career development and work-life balance, including home responsibilities
• you consider current and future workforce initiatives such as flexible work arrangements, employee health, safety and wellbeing and the impacts of organisational change such as workforce renewal and redundancy
• you have clear, well understood, and fair workload management processes. Your organisational culture should encourage workers to promptly report workload issues and feel comfortable suggesting practical solutions to their supervisors so these can be promptly addressed.

Make sure tasks are clearly defined and prioritised

Simple approaches are often overlooked as part of work design. One such approach is making sure key tasks are clearly defined and described so everyone understands what needs to be done by whom and when.

Related to this is deciding and letting workers know what the priority tasks are and planning what order to do them in. Tools like a modified Eisenhower decision matrix (see Figure 5: Modified Eisenhower task matrix) can assist, by dividing tasks into four categories: the tasks that are important and urgent, so must be completed first; those that are important but not urgent, so you can schedule a time to complete; those that are not important but are urgent, so need to be delegated to someone else to complete; and those that are not important and not urgent, so they can be eliminated. These tools can help to prioritise tasks that are both urgent and important, so should be done first.

As well as identifying important and urgent tasks, it is helpful for a team to agree together which tasks need inputs or have dependencies on others, either within or outside the team; which tasks may be more complex and take longer to do; and what order they prefer to do them in. Where possible, managers should schedule tasks that are complex or that need help from others for times of the day (or times of a project) when workers are less likely to be fatigued and time pressured.

Discuss with the workers how complex tasks can be best scheduled

We all have our own working styles and preferences so, as far as possible, this needs to be balanced with giving workers reasonable job control so they can manage their own fatigue and stress.

Discuss the work person fit

The risk of psychological or physical harm will increase whenever there is a poor job to person fit or match. That is, the demands of the work don’t align with the worker’s knowledge, skill, ability, and work interests.

This is a reasonably foreseeable risk. Duty holders must design work, so far as reasonably practicable, to be free from risk to health and safety and then appropriately match available staff to the task. You must carefully consider the inherent requirements of the role. These are the essential duties, necessary knowledge, licenses, experience, and mental, emotional, and physical skills, a worker needs to perform the tasks safely and well. Reasonably accommodating peoples’ work interests and passions can be highly beneficial and increase motivation and engagement.

Remember some workers may be at higher risk from the same psychosocial and physical hazards due to:

• limited experience, such as in new or young workers, apprentices, and trainees
• barriers to understanding safety information, due to literacy or language challenges
• perceived barriers to raising safety issues by workers with job insecurity
• certain attributes – such as sex, race, religious beliefs, pregnancy, gender identity, sexuality, age, or a combination of these – that may put them at risk of behavioural psychosocial hazards like bullying or harassment
• an injury or illness preventing them from performing their full or normal duties, or
• a lack of interest in the task, so finding it boring and unmotivating work.

Consult your workers to help identify who may be at greater risk, and what further work designs (so far as is reasonably practicable) you can put in place to manage risk for them.

You should also check that you consider the inherent requirements of the work, and work-person fit, during recruitment processes. You must comply with anti-discrimination legislation when you do this. Information and resources on this can be found at Anti-Discrimination New South Wales.

Design administrative controls to support safe and healthy work

Design safe systems of work

Before outlining how to use safe systems of work or administrative control measures to control psychosocial risks, it’s important to note they do not control hazards at the source. They rely on human behaviour, needing people to be effective supervisors and monitors. So, while they can help PCBUs minimise psychosocial risks, they are not reliable or effective on their own. If you use these as your main psychosocial risk control measure, you will not meet the required WHS standards.

As noted earlier, many different people in organisations may be involved in designing and/or managing systems of work, such as human resources staff, WHS teams and line managers. These groups of people must work together to design the systems of work and consult with affected workers while keeping WHS as their overriding priority.

Task rotation

Task rotation is a work procedure that aims to minimise risk by limiting the amount of time and/or number of times a worker is exposed to a hazard. It can be used as part of job control to allow workers to choose (within reason) the order they do tasks, to help reduce boredom and fatigue.

Another way to do task rotation is to have team members take turns doing the task. Managers can do this to give workers increased task variety and chances to use their skills (reducing workers’ boredom, helping them grow new skills and increasing ways of coping).

However, task rotation does not eliminate the underlying hazard. Workers will be exposed to the hazard, just for shorter periods. So task rotation should not be your organisation’s main control measure and ideally you should only use it as a short- term intervention until you can put better design solutions in place.

Organisational rules, policies and procedures

WHS rules, policies, and safe work procedures include acceptable workplace behaviours, working arrangements and conditions. To be effective, workers must know about them, find them beneficial, and use them. To achieve this, PCBUs must consult affected workers or their representatives when designing rules, policies, and procedures. You should also consult workers after they have been introduced to find out if they are still effective.

The rules, policies and procedures should:

• clearly describe -
  • psychosocial risks and how these will be managed
  • management and workers’ WHS responsibilities
  • what to do if a workplace incident occurs
• be in languages and formats that suit affected workers
• make sure resources are put somewhere where workers can easily find them when they need them, such as by using QR codes or by clearly displaying them on your intranet or notice boards.

Improve information, instruction, training and supervision

If there are still risks to workers after a PCBU has put work design processes in place, you must tell your workers about them. You must also tell workers what control measures you have introduced and what they should do to make sure they and others are psychologically and physically healthy and safe. This includes giving them appropriately designed information, training (including required certificates to undertake the work), instruction and supervision as required by WHS Regulation (cl.55D(2)(i)).

The types of information, instruction, training, and supervision to give workers are noted below.

Work tasks

• Tell workers:
  • what needs to be done and by when
  • how to do tasks and operate equipment safely and well
  • what the psychosocial risks are and how these are controlled.
• Give them appropriate training to manage, supervise and support others.

Systems of work

• Set up clear, simple, and known organisational policies and procedures to manage and carry out the work.

Communication and interpersonal capabilities

• Tell workers what communication style to use, and when. For example, give instructions on how to use a two-way radio to communicate in noisy environments, or how to do a pre-start check before a shift.

Team management

• Manage staffing levels, allocating tasks, budgets, mentoring and supervision and so on.

Use of PPE

• Tell workers what PPE must be used when and how to use it.

SafeWork NSW does not consider interventions that do not eliminate or minimise the psychosocial risk to be a sufficient psychosocial risk control measure. These can include mental health awareness (Employee Assistance Programs, mental health de-stigmatisation programs) and physical well-being programs (yoga, weight loss, gym, exercise, or healthy eating programs).

Give suitable personal protective equipment

PCBUs must give personal protective equipment (PPE) to help control physical risks, where required. For example, workers may need to have personal duress or emergency alarms where there is a risk of assault or when working in remote locations, and adequate respiratory protective equipment when they are likely to be exposed to hazardous substances. Inadequate PPE may lead to an increase in stress and presents a risk to health and safety.

Deciding what work designs are reasonably practicable

The term “reasonably practicable” refers to a standard that a PCBU is (or was at a particular time) reasonably able to do to ensure the health and safety of workers and others, while taking into account and weighing up all relevant matters (section 18 of the WHS Act). You must consider:

• the likelihood of the psychosocial hazard or the risk occurring within your organisation
• the degree of harm it might cause
• all the suitable ways you could eliminate or minimise the psychosocial risk
• what you know or ought to know about these types of hazards or risks in your organisation and industry, and how to eliminate or minimise them
• the availability and suitability of ways to eliminate or minimise the risk.

SafeWork NSW Inspectors consider whether an employer has or has not done all that they reasonably can to protect their workers’ health and safety.

SafeWork NSW expects that duty holders will always put in place the highest reasonably practicable level of risk control for affected workers. When duty holders are deciding what work design changes to make, you need to decide what is reasonably practicable in your circumstances.

To help you decide what is reasonably practicable, consider:

• as many possible control measures as you can
• which are the most effective
• which are reasonably practicable in your circumstances.

Only after you have assessed the size of the risk and effective ways to eliminate or minimise it can you think about the cost of putting controls in place. If the cost of a work design strategy is very disproportionate to the risks, it may be that using that design strategy is not reasonably practicable and therefore you do not need to use it. This does not mean that you do not need to take action to control the risk. You must use a less expensive way of minimising the risks instead. If two control measures provide the same level of protection and are equally reliable, you can use the less expensive option.

To check you have done everything that is reasonable to do, PCBUs must make sure you have carefully considered everything that may be relevant to managing the risks within your organisation. Duty holders should be able to show, if asked, how you made decisions and that these were based on sound information.

Pilot and monitor major work design changes

Putting work design and control measures in place changes the way people work. Organisations should test designs and other solutions with a representative group (or groups) to make sure they do what you intended, or if you need to change them further before you roll them out more widely. This piloting stage is also when duty holders can collect useful information on the likely ‘real cost’ of rolling out the changes. This can help you demonstrate what is or is not reasonably practicable and proportionate to the risk.

Before you authorise any new work designs, and put control measures in place, duty holders must do a final check for residual or new risks. To help you do this check, there is a suggested rating scale and outcomes noted below. Use it to check the adequacy of your control measures. They must be to at least level 2 and ideally level 1.

Adequacy of work design and control measures

1. Work design and control measures are adequate and effective, i.e., hazard or risk is eliminated, or residual risk is managed so far as is reasonably practicable. There is a very low risk of harm. Outcome: monitor and review the risks and controls.
2. Work design and control measures have been considered and put in place, but no better alternatives are currently available, or the cost would be grossly disproportionate to the risk. There is a low risk of harm. Outcome: keep reviewing and progressively put more effective options in place.
3. Work design and control measures are inadequate. There is a moderate risk of harm. Outcome: take action as a matter of priority.
4. The psychosocial risk is uncontrolled because work design and control measures have not been put in place or are very inadequate. There is a high risk of harm. Outcome: take action immediately.

Remember that people-based controls, or administrative controls, are vulnerable. These are controls that rely on the skills, knowledge and experience of individuals and teams, including how they interpret your organisation’s rules. The reliability of these controls will depend on the degree to which they address the psychosocial risks, whether everyone acts on their new roles and responsibilities to manage these risks, and how skilled and trained the relevant workers are to apply the controls.

Work design, however, does not rely solely on people remembering and following policies and procedures. It is far more likely to be effective and sustainable.

For more information on tools to develop skills in designing work to improve psychosocial risk management see Work Design for Mental Health. The resources were commissioned by the NSW Centre for WHS research.