This is the twelfth article in a series on psychosocial hazard management in Australia. The series moves from the commercial stakes through recent prosecutions to The Psychosocial Safety Blueprint™, a proprietary executive operating model developed by Culture Plus for governing the systems that determine psychosocial safety. Subscribe on cultureplusconsulting.com.
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The previous article in this series examined Pillar I, Governance: the accountability, oversight and decision rights that determine whether psychosocial safety is led from the executive table or delegated below it. This article turns to Pillar II, Organisational Design, and to the question governance exists to answer. If executives are accountable for psychosocial risk, which of their decisions create it?
A large share of the answer lies in the design of work. Safe Work Australia's latest national data ranks work pressure as the second most common cause of serious mental stress claims, at 26.5 per cent in 2024-25, behind harassment and bullying. Job demands also head the list of common psychosocial hazards in the national model Code of Practice. Workload, role clarity, role conflict, job control and the allocation of decision rights are not attributes of the people doing the work. They are structural properties, produced by decisions about resourcing, operating models, spans of control, reporting lines and, increasingly, the technology through which work is allocated.
That places organisational design among the largest determinants of psychosocial risk in most organisations, although it is rarely examined through a psychosocial lens.
When harm is a consequence of design
When job demands chronically exceed the resources available to meet them, psychological harm becomes a foreseeable outcome of the design. It follows from choices made earlier and elsewhere: a headcount freeze while volumes rise, a restructure that removes a layer of management without redistributing its work, a role assembled from three predecessors, a matrix structure in which two leaders hold competing claims on the same person's time.
Each of those is a reasonable commercial decision on its own terms. What makes them hazardous is that they are rarely assessed for what they will do to workload, clarity and control once implemented. The cost surfaces months later, in a different budget line and a different function: rising absence, a cluster of complaints, a workers' compensation claim, a team that has stopped raising concerns.
This is why so many organisations struggle to reduce psychosocial risk despite sustained investment. The response is directed at the people absorbing the gap between demand and resource, through resilience programs, EAP referrals and stress management training, while the design that created the gap stays in place. The Court Services Victoria prosecution shows where this pattern can lead. From at least 2015 to 2018, workers at the Coroners Court of Victoria were exposed to high workloads and role conflict, alongside traumatic material and poor workplace behaviour, and Court Services Victoria admitted it had failed to identify or assess those risks. A lawyer at the court took her own life. In 2023 the organisation was convicted and fined $379,157, the maximum the Magistrates' Court could impose.
The most revealing question I put to executive teams is often the simplest. When the last material resourcing decision was made, did anyone ask what it would do to the people expected to absorb it? The honest answer is usually no, and the reason is structural. Psychosocial risk assessment sits with WHS or People and Culture, resourcing decisions sit with finance and the executive, and the two processes rarely meet.
You cannot train your way out of a design problem
The model WHS framework applies the same hierarchy of controls to psychosocial risk as to physical hazards, with administrative measures such as training at its base, and the model Code of Practice states that policies alone should not be relied on.
Victoria has gone a step further, writing an explicit limit on relying on training into its regulations. Its Occupational Health and Safety (Psychological Health) Regulations 2025, in effect since 1 December 2025, direct employers to control psychosocial risk through changes to work design, systems of work and the workplace environment. Information, instruction and training may be relied on exclusively only where those higher-order measures are not reasonably practicable. Where controls are combined, training must not be the predominant measure.
An organisation that answers a workload or role-clarity hazard with a training module is treating a design problem as a capability problem. The training may be well intended and well delivered. It will not change the conditions generating the risk, and in Victoria it may not satisfy the law.
The emerging risk: algorithmic management
A new category of structural demand is entering organisational design, and most organisations have not begun to assess it. Systems that allocate tasks, set the pace of work, schedule shifts, monitor performance and inform employment decisions shape the demands, control and fairness people experience just as surely as a restructure does. They do so continuously and at scale, often without any single decision-maker seeing the cumulative effect.
NSW has moved first. The Work Health and Safety Amendment (Digital Work Systems) Act 2026 received assent in February. Once its core provisions commence, a PCBU's primary duty will expressly extend to ensuring workers are not put at risk by digital work systems, defined to include algorithms, artificial intelligence, automation and online platforms. A specific duty will also cover the allocation of work through those systems. Those provisions have not yet commenced. They take effect on a date set by proclamation, which SafeWork NSW has indicated will follow publication of its guidelines on the new entry permit powers. The existing primary duty already reaches the risks these systems create, so organisations have no reason to wait for the commencement date.
The governance point follows directly. Decisions about how AI and automation are deployed are design decisions, carrying the same psychosocial consequences as any other change to how work is resourced and controlled. Most AI governance frameworks assess privacy, data and model risk. Very few ask what a system will do to workload, autonomy and perceived fairness before it is switched on. I will return to this in more depth later in the series.
What good looks like
In more mature organisations, the design of work is treated as a primary psychosocial control. Four markers tend to be visible.
- Material decisions are assessed before approval. Changes to headcount, structure, workload allocation, operating model or the technology that allocates work are assessed for their effect on demands, role clarity and job control, and that assessment is in front of the people approving the decision.
- Decision rights are defined. People know what they are accountable for, what they have authority to decide, and who resolves competing demands. Matrix and shared roles carry explicit arbitration rules, so individuals are not left to negotiate between two leaders.
- Demand and resource are monitored together. Leading indicators such as sustained overtime, untaken leave, vacancy duration, span of control and backlog are reported alongside output, so the gap between what is asked and what is resourced becomes visible before harm does.
- Fatigue is managed structurally. Rostering, on-call arrangements, after-hours expectations and peak-period resourcing are designed to keep demand within sustainable limits.
Each of these can be evidenced. An officer exercising due diligence can ask to see the impact assessment that preceded the last restructure, the decision-rights framework for a matrix role, or the demand indicators for a function under strain. Where none of those exist, the organisation is relying on the goodwill of its people to absorb whatever the design produces.
The design test
Governance establishes who is accountable for psychosocial risk. Organisational design determines much of what they are accountable for.
A practical test for boards and executive teams is to take the three most significant resourcing or structural decisions of the past twelve months. For each one, could the organisation show that its effect on workload, role clarity and job control was assessed before approval, and that the people affected were consulted?
If the answer is no, the organisation has been making psychosocial risk decisions without recognising them as such.
Next week, the series moves to Pillar III: Work Systems, and the management processes (performance management, complaint handling, investigations and restructures) that operate as psychosocial hazards at scale when they are poorly designed.
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Sources
- The Psychosocial Safety Blueprint™, Culture Plus Executive Papers No. 01, Chapter 15.2 (Organisational Design) and Chapter 4 (Recent Regulatory Signals).
- Occupational Health and Safety (Psychological Health) Regulations 2025 (Vic), as summarised by MinterEllison and the Victorian Government Solicitor's Office.
- SafeWork NSW, Work Health and Safety Amendment (Digital Work Systems) Act 2026.
- WorkSafe Victoria, Court body fined almost $380,000 for deadly work culture, October 2023.
- Safe Work Australia, Key Work Health and Safety Statistics Australia 2026, October 2026.
- Safe Work Australia, Model Code of Practice: Managing psychosocial hazards at work, July 2022.
This article provides executive advisory commentary, not legal advice. Organisations should obtain advice on their specific legal obligations from appropriately qualified legal practitioners.
This article refers to suicide. If it raises concerns for you, support is available from Lifeline on 13 11 14.
Felicity Menzies is the CEO and Principal Consultant of Culture Plus Consulting, a specialist executive advisory practice in organisational culture, psychosocial safety and executive governance. For more than fifteen years, she has advised boards, chief executives and executive leadership teams across government, listed companies and regulated industries on the organisational systems that shape culture, leadership, workplace conduct and psychosocial risk.