Understanding the Managing Psychosocial Hazards at Work Code of Practice 2024

Understanding the Managing Psychosocial Hazards at Work Code of Practice 2024

Luke Giuseppin

Luke Giuseppin

Workplace health and safety in Australia has changed. Regulators, courts, and workers themselves are increasingly focused on psychological safety, not just physical safety. The Managing Psychosocial Hazards at Work Code of Practice 2024 ('the Code') is now a critical reference point for Australian employers navigating this shift.

Whether you're a WHS officer, an HR manager, or a senior leader responsible for governance, here's what this Code means and what it requires from you.

Why Psychosocial Safety Matters Now

Psychosocial hazards in the workplace are features of work design and management that can cause psychological or physical harm. Think bullying, excessive workloads, poor support, lack of role clarity, and inadequate change management.

For years, psychological health at work was treated as a secondary concern. That's no longer the case. Regulatory changes in almost every Australian jurisdiction now mandate that psychosocial risks be managed with the same rigour as physical hazards. Recent amendments to the model WHS Regulations in most Australian jurisdictions now require specific obligations for psychosocial hazards. Mental health claims have increased 161% over the past decade and now represent 12% of all serious workers' compensation claims, costing approximately four times more than physical injury claims. Average time lost to mental health claims is 35.7 weeks, compared to 7.4 weeks for other injuries.

What the Code Actually Is

The Code of Practice is an approved code under the model Work Health and Safety (WHS) Act. It provides practical guidance on how to meet the obligations set out in the WHS Regulations regarding psychosocial risks.

Safe Work Australia released the original model Code of Practice for Managing Psychosocial Hazards at Work in 2022. This was updated in 2024, with changes including a greater focus on the interaction between physical and psychosocial hazards, additional practical examples, and updated definitions to align with the latest research and regulatory expectations.

Legal Standing: Why You Can't Ignore It

Under the model WHS Act, an approved code of practice is admissible in legal proceedings as evidence of what is known about a hazard, risk, or control measure. If you don't follow the Code, you'll need to demonstrate an alternative means of achieving compliance that is at least equivalent. In practice, this makes the Code the de facto standard. Regulators use it as a benchmark for audits and investigations. Courts reference it when assessing whether duty holders have met their obligations. Insurance underwriters and legal advisors are increasingly treating it as the baseline for reasonable diligence.

SafeWork Australia publishes the model Code, but individual states and territories adopt it (sometimes with jurisdictional variations). Make sure you know which version applies in your jurisdiction.

Who Must Comply

The Code applies to all persons conducting a business or undertaking (PCBUs), which in practical terms means employers, but also extends to labour hire companies, principal contractors, and others in the supply chain with influence over work design and conditions.

Officers (directors, senior executives) have a personal due diligence obligation to ensure the PCBU complies with WHS duties, including those related to psychosocial hazards. Workers have a duty to take reasonable care for their own health and safety and to not adversely affect the health and safety of others.

The Psychosocial Hazards (14 in Model Code, 17 in Commonwealth Code)

The model Code identifies 14 psychosocial hazards. These are not exhaustive; they represent the most commonly recognised hazards based on current evidence:

1. Job demands 2. Low job control 3. Poor support 4. Lack of role clarity 5. Poor organisational change management 6. Inadequate reward and recognition 7. Poor organisational justice 8. Traumatic events or material 9. Remote or isolated work 10. Poor physical environment 11. Violence and aggression 12. Bullying 13. Harassment, including sexual harassment 14. Conflict or poor workplace relationships and interactions

The Commonwealth Code of Practice (2024) identifies three additional hazards, bringing the total to 17: 15. Exposure to discrimination 16. Exposure to poor leadership behaviours 17. Exposure to poor mental health literacy among managers

Importantly, these hazards often interact and compound. A worker dealing with high job demands, low job control, and poor support simultaneously faces a much greater risk than any single hazard would suggest. Your risk management approach needs to account for these interactions.

Key Obligations

Under the WHS Regulations (as amended) and the Code, PCBUs must:

Identify psychosocial hazards in the workplace. This includes consulting workers, reviewing data (incident reports, complaints, survey results), observing work practices, and considering the design of work. Assess the risks arising from those hazards where appropriate. Consider the duration, frequency, and severity of exposure, whether multiple hazards interact, and the effectiveness of existing controls. Control the risks so far as is reasonably practicable. Controls must follow the hierarchy of controls, which prioritises eliminating the hazard, then substituting, isolating, or using engineering controls, then administrative controls, and finally personal protective equipment. For psychosocial hazards, this hierarchy often translates to redesigning work systems rather than relying on individual training or awareness programs. Review control measures regularly and when triggered by specific events (such as a notifiable incident, a report of a hazard, or a change to the work environment).

The Four-Step Risk Management Process

Step 1: Identify hazards. Use multiple data sources: worker consultation, surveys, incident data, absenteeism and turnover patterns, workers' compensation claims, and direct observation of work practices. Don't rely on a single source. The Code explicitly states that workplace surveys alone are insufficient.

Step 2: Assess risks. Not all hazards require a formal risk assessment, but where the risk is not well understood or controls are unclear, assessment is required. Consider the nature of the hazard, the duration and frequency of exposure, how many workers are affected, the interaction with other hazards, and the characteristics of the workers involved.

Step 3: Control risks. Apply the hierarchy of controls. For psychosocial hazards, this often means: Eliminate or minimise the hazard through work design (e.g., adjust workloads, clarify roles, improve rostering). Reduce exposure through organisational controls (e.g., rotate workers through high-demand tasks). Provide training, information, and support as a supplementary control. The 2024 update emphasises that training and awareness programs should not be the primary control measure.

Step 4: Review controls. Schedule regular reviews and review whenever: a control is not working effectively, before a change to the workplace or work process, new hazard information becomes available, after a workplace incident or near miss, or after a worker raises a concern. Document your review process and outcomes.

Practical Steps to Get Compliant

Build a psychosocial hazard register. Document identified hazards, their sources, affected roles, existing controls, and review dates. This is the backbone of your compliance framework.

Consult workers. Consultation is not optional. The WHS Act requires meaningful consultation with workers who are, or are likely to be, directly affected by a health and safety matter. For psychosocial hazards, this means asking workers about the hazards they experience and involving them in developing controls.

Review your work design. Many psychosocial hazards are built into how work is structured. Job demands, role clarity, shift patterns, reporting lines, and change management processes are all design choices that can either create or mitigate psychosocial risk.

Train your leaders. Frontline managers and supervisors are often the first point of contact for workers experiencing psychosocial harm. They need the skills to recognise hazards, respond appropriately, and escalate effectively.

Report and record. Establish clear reporting channels for psychosocial hazards and incidents. Make sure workers know how to raise concerns and that reports are followed up systematically. Under certain circumstances, psychosocial incidents are notifiable under the WHS Act.

Use data. Monitor indicators such as absenteeism, turnover, incident reports, and workers' compensation claims for trends that may signal unmanaged psychosocial risk. Data-driven risk management is far more defensible than reactive responses.

Wrapping Up

The Managing Psychosocial Hazards at Work Code of Practice 2024 is not just a compliance document. It's a clear signal from regulators that psychosocial safety is now a core obligation for every Australian employer.

Meeting this obligation requires a structured, evidence-based approach: identifying hazards, assessing risks, implementing controls, and reviewing continuously. The organisations that get this right will not only avoid regulatory action but will build healthier, more resilient workplaces.

If your organisation hasn't yet mapped its psychosocial hazards and established a systematic risk management framework, the time to start is now.

This article provides general information about psychosocial WHS requirements in Australia. It does not constitute legal advice. Requirements may vary by jurisdiction and change over time. Consult relevant legislation, approved codes of practice in your jurisdiction, and qualified advisors for your specific circumstances.

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