Psychosocial Compliance Checklist for WHS and HR Managers

Psychosocial Compliance Checklist for WHS and HR Managers

Luke Giuseppin

Luke Giuseppin

Feb 1, 2026

Feb 1, 2026

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

  1. We have a documented policy on psychosocial hazard management that is approved by senior leadership

  2. The policy defines psychosocial hazards and sets expectations for acceptable workplace behaviour

  3. The policy outlines reporting mechanisms for workers to raise concerns

  4. The policy is communicated to all workers during induction and is readily accessible

  5. The policy is reviewed at least annually or following significant incidents or changes

Officer Due Diligence

  1. Officers have received training on their due diligence obligations for psychosocial hazards

  2. Officers receive regular reports on psychosocial risks, incidents, and control effectiveness

  3. Psychosocial risk is a standing item on WHS committee or board agendas

  4. Officers have verified that appropriate resources are allocated to manage psychosocial risks

  5. Officers have ensured that appropriate processes exist to receive and respond to psychosocial hazard information

Section 2: Hazard Identification

Data Sources Reviewed

  1. Workers' compensation claims data (psychological injury claims, trends over time)

  2. Incident and hazard reports (including near misses related to behaviour or stress)

  3. Absenteeism and sick leave patterns (by team, role, or location)

  4. Staff turnover data and exit interview themes

  5. Grievances and complaints (formal and informal)

  6. Employee Assistance Program (EAP) utilisation data (aggregated)

  7. Overtime and working hours data

  8. Performance management patterns

Worker Consultation

  1. Workers have been consulted about psychosocial hazards in their work area

  2. Health and Safety Representatives (HSRs) have been involved in hazard identification

  3. Anonymous surveys or other mechanisms allow workers to raise concerns confidentially

  4. Consultation has occurred across different work groups, shifts, and locations

  5. 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

  1. Identified hazards have been assessed for likelihood and severity of harm

  2. Assessment considers the duration, frequency, and severity of worker exposure

  3. Assessment considers whether multiple hazards interact or combine to increase risk

  4. Assessment considers the needs of specific worker groups (young workers, new starters, workers with disability, culturally diverse workers)

  5. Assessment is documented and includes rationale for risk ratings

Priority Areas

  1. High-risk hazards have been identified for immediate action

  2. Work areas, roles, or teams with elevated risk have been prioritised

  3. 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).

  1. We have considered whether hazards can be eliminated (e.g., removing unnecessary tasks that cause stress)

  2. We have considered substitution (e.g., replacing high-demand work systems with better-designed processes)

  3. We have considered isolation (e.g., separating workers from sources of aggression)

  4. We have considered engineering controls (e.g., redesigning workspaces, adjusting workflows)

  5. Administrative controls are used to support higher-order controls, not replace them

  6. Training and individual coping strategies are not the primary control measure

Control Measures in Place

Job Demands

  1. Workloads are reviewed regularly and adjusted where necessary

  2. Deadlines and performance targets are achievable

  3. Workers have adequate time and resources to complete their work

  4. Work is distributed fairly across teams

Job Control

  1. Workers have input into how they perform their work where possible

  2. Flexible work arrangements are available and supported

  3. Workers can take breaks as needed

Support

  1. Managers are trained to provide day-to-day support to their teams

  2. Workers have access to EAP services

  3. Peer support or mentoring arrangements are in place

  4. Return-to-work support is provided following psychological injury

Role Clarity

  1. Position descriptions are current and clearly define responsibilities

  2. Reporting lines are clear

  3. Workers understand what is expected of them

Organisational Change

  1. Change processes include consultation with affected workers

  2. Workers are given adequate notice and information about changes

  3. Support is provided during and after change processes

Recognition and Reward

  1. Workers receive feedback on their performance

  2. Achievements are acknowledged appropriately

  3. Pay and conditions are fair and transparent

Organisational Justice

  1. Decisions affecting workers are made transparently and consistently

  2. Workers can raise concerns without fear of reprisal

  3. Complaints and grievances are handled fairly

Harmful Behaviours

  1. There is a clear process for reporting and responding to bullying, harassment, and discrimination

  2. Workers know how to report harmful behaviour

  3. Reported incidents are investigated promptly and fairly

  4. Perpetrators are held accountable

  5. Victimisation of complainants is prohibited and monitored

Remote or Isolated Work

  1. Workers in remote or isolated settings have access to support and communication

  2. Check-in procedures are in place for lone workers

  3. Emergency response arrangements are documented

Traumatic Events

  1. Workers in roles with exposure to trauma have access to appropriate support

  2. Critical incident response procedures are documented

  3. Debriefing and follow-up support is provided after traumatic events

Violence and Aggression

  1. Risks of violence from clients, customers, or the public have been assessed

  2. Control measures are in place (e.g., security, de-escalation training, physical barriers)

  3. Workers can remove themselves from dangerous situations without penalty

Section 5: Monitoring and Review

Ongoing Monitoring

  1. Control measures are checked regularly to ensure they remain effective

  2. Workers are consulted about whether controls are working

  3. Leading indicators (e.g., survey results, absenteeism trends) are tracked

  4. Lagging indicators (e.g., claims, incidents) are tracked

  5. 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:

  1. We have a schedule for routine review of psychosocial risk controls

  2. Reviews are conducted following significant incidents

  3. Reviews are conducted following organisational change

  4. Review findings are documented and actioned

Section 6: Documentation and Records

Records Maintained

  1. Psychosocial hazard register

  2. Risk assessments

  3. Control measures implemented

  4. Worker consultation records

  5. Training records (managers and workers)

  6. Incident reports and investigation outcomes

  7. Review and audit findings

  8. Policy documents and version history

Record Retention

  1. Records are retained for the required period (check jurisdictional requirements)

  2. Records are stored securely and confidentially

  3. Records are accessible for regulatory inspection if required

Section 7: Training and Capability

Manager Training

  1. Managers understand their role in managing psychosocial hazards

  2. Managers can identify signs of psychological distress in their teams

  3. Managers know how to respond to complaints and concerns

  4. Managers understand what constitutes reasonable management action

  5. Training is refreshed periodically

Worker Training

  1. Workers understand what psychosocial hazards are

  2. Workers know how to report hazards and concerns

  3. Workers understand the organisation's policies on acceptable behaviour

  4. Workers know how to access support services

Section 8: Incident Response

Response Procedures

  1. There is a documented process for responding to psychosocial incidents

  2. The process includes immediate risk assessment and interim measures

  3. The process includes investigation requirements

  4. The process includes support for affected workers (complainants and respondents)

  5. The process includes escalation pathways for serious incidents

  6. The process addresses confidentiality and natural justice

Regulatory Notification

  1. We understand when psychosocial incidents must be notified to the regulator

  2. Notification procedures are documented

  3. 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:

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