Advice & Strategy
Every Australian jurisdiction now requires PCBUs to identify, assess and control psychosocial hazards with the same rigour as physical risks. Regulators are issuing improvement notices, prosecuting failures, and expecting documented systems — not goodwill.
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Risk-based. Code-aligned. Built for due diligence.
A regulatory step-change
Amendments to model WHS Regulations and the release of Safe Work Australia's Code of Practice on Managing Psychosocial Hazards at Work have set a clear national expectation. NSW, Victoria, Queensland, WA, the ACT, Tasmania, the NT and the Commonwealth (Comcare) have each adopted or paralleled the framework — with regulators actively inspecting and enforcing.
PCBUs and officers must now demonstrate a systematic approach to identifying psychosocial hazards, assessing risk, implementing controls in line with the hierarchy of controls, and reviewing effectiveness. Reliance on EAPs, resilience training and one-off surveys no longer meets the standard.
"Psychosocial hazards must be managed with the same rigour as physical hazards — identified, assessed, controlled at the source, and reviewed."
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NSW Parliament
Culture Plus Consulting was engaged by NSW Parliament to design and deliver Respect at Work and Trauma Informed Response training across its workforce — a flagship reform initiative responding to the Broderick Review of bullying, sexual harassment and sexual misconduct in NSW parliamentary workplaces. This engagement represents a proud achievement in delivering reform-grade Respect at Work training in high-scrutiny environments.
NSW Premier's Department
In an ongoing engagement, Culture Plus Consulting delivers Respect at Work training to the Premier, Ministers and Ministerial staff — a key recommendation of the Goward Review aimed at building respectful, safe and accountable workplaces at the heart of government.
Programme snapshot
Managing psychosocial risk is now a sustained operational discipline — not a project, a survey, or a training module. Regulators expect evidence that the system is designed, used, and improved over time.
Boards and officers, executives, WHS and HR leaders, risk and compliance teams, and people leaders accountable for psychosocial safety under WHS law.
Trusted partners
I thank Felicity Menzies for the initial training sessions and commend her on the job that she has done.
Who we support
Discharging officer due diligence obligations on psychosocial risk under model WHS law — knowledge, resources, processes, information and verification.
Embedding psychosocial risk into enterprise risk, accountability and reporting — visible leadership across operations and culture.
Building a psychosocial risk management system integrated with existing WHS frameworks, incident processes and HSR consultation.
Connecting job design, change, performance and complaint handling to the psychosocial risk register and controls.
Assessing regulatory exposure across jurisdictions and aligning controls with Code of Practice and AHRC expectations.
Identifying psychosocial hazards in their teams, consulting workers, and escalating risks through the right WHS pathways.
What WHS psychosocial law covers
Model WHS Regulations and Safe Work Australia's Code of Practice on Managing Psychosocial Hazards at Work require employers to identify, assess and control any aspect of work that may cause psychological harm — not only physical injury. The duty extends to work-related interactions with third parties.
High and low job demands, low job control, poor support, lack of role clarity, inadequate reward and recognition — controlled at source through job and work design.
Bullying, harassment (including sexual harassment), conflict, poor workplace relationships and exposure to violence or aggression from clients, patients, students or the public.
Poor organisational change management, poor organisational justice, and weak governance over decision-making, complaint handling and performance processes.
Traumatic events or material, remote or isolated work, and poor physical environment — assessed for both psychological and physical impact.
Sexual harassment, sex-based harassment and hostile work environments — psychosocial hazards under WHS and unlawful conduct under the Sex Discrimination Act 1984 (Cth).
The 14 Common Psychosocial Hazards
Safe Work Australia's Model Code of Practice identifies common psychosocial hazards organisations must assess and control. Our advisory helps you build a register, prioritise risk, and design controls grounded in the hierarchy of controls.
Hierarchy of Controls
Safe Work Australia's Code of Practice adapts the hierarchy of controls for psychosocial risk. PPE has no meaningful application to psychological hazards — regulators expect PCBUs to eliminate risk at source through job and work design first, and treat training and individual supports as the lowest-order controls, not the starting point.
Remove the hazard at source — redesign roles, workloads, rosters, reporting lines and decision rights to remove exposure to harmful job demands, role conflict or poor support.
Substitute high-risk work practices, isolate workers from harmful interactions (e.g. third-party aggression), and engineer systems — staffing models, scheduling, technology and physical environment — to reduce exposure.
Policies, procedures, governance, consultation mechanisms, complaint and escalation pathways, leader behaviours and culture standards that reduce the likelihood and severity of harm.
Training, supervision, debriefing and EAP. The lowest level of the hierarchy — necessary, but never a substitute for upstream design and administrative controls.
Where organisations fall short
Most Australian employers have wellbeing programs and policies. Far fewer have the documented psychosocial risk management system regulators now expect — integrated with WHS, evidenced at the board, and used in daily decisions.
No systematic methodology for identifying and assessing psychosocial hazards across the organisation; risk is managed reactively, not proactively.
Reliance on individual-level supports at the bottom of the hierarchy of controls — without addressing upstream job and work design risks.
Workload, role clarity, change management and decision rights are not treated as WHS controls — leaving the most common psychosocial drivers unaddressed.
Treated as HR or culture issues rather than WHS hazards — disconnected from risk registers, incident systems and officer reporting.
Boards and officers cannot demonstrate the reasonable steps required under WHS law to acquire knowledge, ensure resources, and verify the system is operating.
Workers and Health and Safety Representatives are not consulted on psychosocial hazards, controls or reviews — failing a core requirement of WHS law.
What regulators weigh
Under WHS law, PCBUs must do what is reasonably practicable to eliminate or minimise psychosocial risk. Regulators apply these factors when reviewing whether your controls meet the standard.
Regulators weigh the type of psychosocial hazard, the potential severity of harm, and how it interacts with other hazards in your workplace.
Sustained or repeated exposure to high job demands, traumatic material, bullying or harassment carries greater risk and requires stronger controls.
How many workers, contractors, and third parties are exposed — and whether particular groups face elevated or compounded risk.
What is reasonably knowable about the hazard and effective controls — including the Code of Practice, ISO 45003, regulator guidance and industry evidence.
Whether higher-order controls (elimination, substitution, engineering) are reasonably practicable — not just whether training or EAPs exist.
Cost is considered only after the other factors. It does not excuse failing to implement reasonably practicable controls where the risk is significant.
Four guiding principles
Drawn from model WHS Regulations, Safe Work Australia's Code of Practice and ISO 45003, these four principles shape how prevention should be designed, delivered and reviewed.
01
Psychosocial hazards are identified, assessed and controlled using the same systematic risk management cycle as physical hazards.
02
Eliminate hazards at source through job and work design first; rely on training, EAPs and individual supports only as lower-order controls.
03
Genuine consultation with workers, HSRs and health and safety committees on hazards, controls, incidents and reviews — a legal requirement, not a survey.
04
Controls are reviewed after incidents, complaints, changes or new information — and on a scheduled cycle — with evidence reported to officers and the board.
Advisory Services
Defensible psychosocial risk assessments combining survey data, focus groups, incident and complaint trend analysis, and review of job and work design — delivered as a prioritised risk register with regulator-ready documentation aligned to the Code of Practice and ISO 45003.
Our methodology
Every Culture Plus engagement is built on the same evidence-based methodology. Hover any step for detail:
Your consultant
CEO, Author and Principal Consultant
Every Culture Plus engagement is delivered with behavioural rigour and practical relevance by Felicity Menzies — organisational psychologist, author, and specialist consultant.
Endorsed capability partner
Culture Plus Consulting is proud to design and deliver flagship DEI programmes for the Australian Human Resources Institute (AHRI) — Australia's peak HR professional body — supporting HR leaders and practitioners to build capability for inclusive leadership and organisational change.
Connect with us to explore how evidence-based DEI training can help your organisation build capability, strengthen culture, and deliver meaningful, measurable change.
Key questions for boards & officers
Do you have a documented psychosocial risk register and an assessment methodology that covers all 14 hazards?
Are psychosocial controls applied through the hierarchy — eliminating hazards at source, not just adding training and EAPs?
Are psychosocial hazards integrated into incident reporting, investigations and your WHS management system?
Have you assessed risks from work-related interactions with third parties — clients, patients, students, the public?
Have workers and HSRs been genuinely consulted on psychosocial hazards, controls, incidents and reviews?
Have you assessed how psychosocial risks fall differently on workers by role, gender, cultural background, disability and employment type?
Do managers have the capability to identify psychosocial hazards in their teams and respond in a trauma-informed way?
Can workers access confidential, trauma-informed support and trusted reporting pathways — without fear of retaliation?
Does the board receive regular, meaningful reporting on psychosocial risk, controls and leading indicators?
Can officers evidence the reasonable steps taken to acquire knowledge, ensure resources, and verify the system is operating?
Are psychosocial risk obligations managed in an integrated system with positive duty and respect at work — not parallel programs?
Is the psychosocial risk management system reviewed after incidents, change events, and on a documented cycle?
From the book
“Culture is the sum of behaviours leaders permit, model, and reward.”
Frequently asked questions
For boards, officers and WHS leaders, the practical question is no longer whether psychosocial risk applies — but how to build a system regulators will accept. If you have a specific question, please reach out.
Model WHS Regulations now expressly require PCBUs to manage psychosocial risk, supported by Safe Work Australia's Model Code of Practice. NSW, Victoria, Queensland, WA, the ACT, Tasmania, the NT and the Commonwealth have each adopted or paralleled the framework, with regulators issuing inspector guidance and enforcement priorities.
While you're here
Equip leaders to manage psychosocial hazards under WHS Regulations, ISO 45003 and Positive Duty.
Psychosocial Hazards & Safety Training for Leaders →Meet the Sex Discrimination Act positive duty with evidence, controls and assurance.
Positive Duty Advisory →Independent, evidence-based reviews of workplace culture, conduct and risk.
Culture Reviews →Further reading
Strengthen WHS — protect your people
We help organisations build defensible psychosocial risk management systems — integrated with positive duty obligations, respect at work, and existing WHS frameworks — so officers can evidence due diligence and workers are genuinely safer.
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