

Managing psychosocial hazards is no longer optional. Under Australian WHS laws, PCBUs must identify, assess, and control psychosocial risks with the same rigour applied to physical hazards. For HR managers, this means building compliance into everyday people practices.
This checklist provides a practical framework for assessing your organisation's psychosocial compliance against the requirements of the Work Health and Safety Act 2011, the WHS Regulations, and the Model Code of Practice: Managing Psychosocial Hazards at Work.
Understanding Your Obligations
Under the WHS Act, health includes both physical and psychological health. PCBUs must eliminate psychosocial risks so far as is reasonably practicable. Where elimination is not reasonably practicable, risks must be minimised so far as is reasonably practicable by applying the hierarchy of controls. Officers (including directors and senior executives) have due diligence obligations to ensure the PCBU complies with its duties.
The Model Code of Practice identifies 14 common psychosocial hazards: job demands, low job control, poor support, lack of role clarity, poor organisational change management, low recognition and reward, poor organisational justice, traumatic events, remote or isolated work, poor physical environment, violence and aggression, bullying, harassment (including sexual harassment), and conflict or poor workplace relationships.
Section 1: Governance and Leadership
Policy and Framework
We have a documented policy on psychosocial hazard management that is approved by senior leadership
The policy defines psychosocial hazards and sets expectations for acceptable workplace behaviour
The policy outlines reporting mechanisms for workers to raise concerns
The policy is communicated to all workers during induction and is readily accessible
The policy is reviewed at least annually or following significant incidents or changes
Officer Due Diligence
Officers have received training on their due diligence obligations for psychosocial hazards
Officers receive regular reports on psychosocial risks, incidents, and control effectiveness
Psychosocial risk is a standing item on WHS committee or board agendas
Officers have verified that appropriate resources are allocated to manage psychosocial risks
Officers have ensured that appropriate processes exist to receive and respond to psychosocial hazard information
Section 2: Hazard Identification
Data Sources Reviewed
Workers' compensation claims data (psychological injury claims, trends over time)
Incident and hazard reports (including near misses related to behaviour or stress)
Absenteeism and sick leave patterns (by team, role, or location)
Staff turnover data and exit interview themes
Grievances and complaints (formal and informal)
Employee Assistance Program (EAP) utilisation data (aggregated)
Overtime and working hours data
Performance management patterns
Worker Consultation
Workers have been consulted about psychosocial hazards in their work area
Health and Safety Representatives (HSRs) have been involved in hazard identification
Anonymous surveys or other mechanisms allow workers to raise concerns confidentially
Consultation has occurred across different work groups, shifts, and locations
Managers and supervisors have been consulted about hazards they observe
Hazard Register
Psychosocial hazards are recorded in the hazard register alongside physical hazards
Each identified hazard is linked to specific work areas, roles, or tasks
The hazard register is reviewed and updated regularly
New hazards are added when identified through consultation, incidents, or data review
Section 3: Risk Assessment
Assessment Process
Identified hazards have been assessed for likelihood and severity of harm
Assessment considers the duration, frequency, and severity of worker exposure
Assessment considers whether multiple hazards interact or combine to increase risk
Assessment considers the needs of specific worker groups (young workers, new starters, workers with disability, culturally diverse workers)
Assessment is documented and includes rationale for risk ratings
Priority Areas
High-risk hazards have been identified for immediate action
Work areas, roles, or teams with elevated risk have been prioritised
Assessment outcomes have been communicated to relevant managers and workers
Section 4: Risk Control
Hierarchy of Controls Applied
The WHS Regulations require PCBUs to apply the hierarchy of controls when managing psychosocial risks. Higher-order controls (elimination, substitution, isolation, engineering) should be prioritised over lower-order controls (administrative controls, training).
We have considered whether hazards can be eliminated (e.g., removing unnecessary tasks that cause stress)
We have considered substitution (e.g., replacing high-demand work systems with better-designed processes)
We have considered isolation (e.g., separating workers from sources of aggression)
We have considered engineering controls (e.g., redesigning workspaces, adjusting workflows)
Administrative controls are used to support higher-order controls, not replace them
Training and individual coping strategies are not the primary control measure
Control Measures in Place
Job Demands
Workloads are reviewed regularly and adjusted where necessary
Deadlines and performance targets are achievable
Workers have adequate time and resources to complete their work
Work is distributed fairly across teams
Job Control
Workers have input into how they perform their work where possible
Flexible work arrangements are available and supported
Workers can take breaks as needed
Support
Managers are trained to provide day-to-day support to their teams
Workers have access to EAP services
Peer support or mentoring arrangements are in place
Return-to-work support is provided following psychological injury
Role Clarity
Position descriptions are current and clearly define responsibilities
Reporting lines are clear
Workers understand what is expected of them
Organisational Change
Change processes include consultation with affected workers
Workers are given adequate notice and information about changes
Support is provided during and after change processes
Recognition and Reward
Workers receive feedback on their performance
Achievements are acknowledged appropriately
Pay and conditions are fair and transparent
Organisational Justice
Decisions affecting workers are made transparently and consistently
Workers can raise concerns without fear of reprisal
Complaints and grievances are handled fairly
Harmful Behaviours
There is a clear process for reporting and responding to bullying, harassment, and discrimination
Workers know how to report harmful behaviour
Reported incidents are investigated promptly and fairly
Perpetrators are held accountable
Victimisation of complainants is prohibited and monitored
Remote or Isolated Work
Workers in remote or isolated settings have access to support and communication
Check-in procedures are in place for lone workers
Emergency response arrangements are documented
Traumatic Events
Workers in roles with exposure to trauma have access to appropriate support
Critical incident response procedures are documented
Debriefing and follow-up support is provided after traumatic events
Violence and Aggression
Risks of violence from clients, customers, or the public have been assessed
Control measures are in place (e.g., security, de-escalation training, physical barriers)
Workers can remove themselves from dangerous situations without penalty
Section 5: Monitoring and Review
Ongoing Monitoring
Control measures are checked regularly to ensure they remain effective
Workers are consulted about whether controls are working
Leading indicators (e.g., survey results, absenteeism trends) are tracked
Lagging indicators (e.g., claims, incidents) are tracked
Managers report on psychosocial risks in their areas
Review Triggers
Control measures must be reviewed when there is evidence they are not effective, before a change that may create new risks, when a new hazard is identified, after an incident, or when directed by the regulator. Additionally:
We have a schedule for routine review of psychosocial risk controls
Reviews are conducted following significant incidents
Reviews are conducted following organisational change
Review findings are documented and actioned
Section 6: Documentation and Records
Records Maintained
Psychosocial hazard register
Risk assessments
Control measures implemented
Worker consultation records
Training records (managers and workers)
Incident reports and investigation outcomes
Review and audit findings
Policy documents and version history
Record Retention
Records are retained for the required period (check jurisdictional requirements)
Records are stored securely and confidentially
Records are accessible for regulatory inspection if required
Section 7: Training and Capability
Manager Training
Managers understand their role in managing psychosocial hazards
Managers can identify signs of psychological distress in their teams
Managers know how to respond to complaints and concerns
Managers understand what constitutes reasonable management action
Training is refreshed periodically
Worker Training
Workers understand what psychosocial hazards are
Workers know how to report hazards and concerns
Workers understand the organisation's policies on acceptable behaviour
Workers know how to access support services
Section 8: Incident Response
Response Procedures
There is a documented process for responding to psychosocial incidents
The process includes immediate risk assessment and interim measures
The process includes investigation requirements
The process includes support for affected workers (complainants and respondents)
The process includes escalation pathways for serious incidents
The process addresses confidentiality and natural justice
Regulatory Notification
We understand when psychosocial incidents must be notified to the regulator
Notification procedures are documented
Responsible persons are trained on notification requirements
Jurisdictional Variations
This checklist is based on the model WHS laws. Requirements vary by jurisdiction. Victoria operates under the Occupational Health and Safety Act 2004, not the model WHS laws. Check with your state or territory regulator for specific requirements:
Comcare (Commonwealth)
Resources
This checklist provides general guidance on psychosocial hazard management under Australian WHS laws and should not be relied upon as legal advice. Requirements vary by jurisdiction and may have changed since publication. Consult relevant codes of practice, regulatory guidance, and qualified advisors for specific circumstances.
For more information on how to identify, assess, and control psychosocial hazards in your workplace, visit refresh.tech to see how we can help you meet your duty of care obligations


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