How should WA employers manage psychosocial hazards at work?

A Western Australian person conducting a business or undertaking (PCBU) should manage psychosocial hazards as a work health and safety risk: identify exposure arising from work, assess the likelihood and severity of harm, eliminate the risk where reasonably practicable, otherwise minimise it, consult workers, and test whether the controls work. The duty concerns the *design and management of work*, not simply whether workers can access counselling. WA's WorkSafe psychosocial hazards code of practice sets out this continuing process, while WorkSafe's psychosocial regulations announcement explains that specific requirements commenced on 24 December 2022. Check the current legislation and regulator guidance for the workplace and sector before applying a generic template.

This guide addresses the WA risk-management task. It is not a substitute for a confidential complaint process, fair employment investigation, medical care or advice about a particular incident. The existing Complys Australian WHS software page explains the broader record-management platform; this page addresses what a WA PCBU needs to decide and do about psychosocial risk. The same hazard may have employment-law or discrimination consequences, but those are separate from this WHS workflow.

What counts as a psychosocial hazard?

WorkSafe WA's code includes hazards and risk factors associated with stress, fatigue and burnout, bullying, harassment, violence and aggression, discrimination and misconduct. The exposure can arise from work design, the environment, relationships, management practices or repeated interactions with customers and the public. A busy period alone is not a complete risk assessment: the question is how the demand is designed and supported, how long and often people are exposed, and what other factors combine with it.

Examples include consistently excessive workloads; unclear or conflicting roles; little control over the order or method of work; inadequate training or supervision; isolated work; traumatic material; poorly managed change; and violence or aggression from clients. A hospital reception team receiving threats, a FIFO team working extended rosters, and an office team facing relentless deadlines may need different controls. Do not assume that only industries with visible physical danger have psychological risks.

Some issues overlap. A threat from a customer may combine with lone work, insufficient staffing and an ineffective escalation procedure. Repeated bullying reports may point to a supervisory or organisational problem rather than one interpersonal disagreement. WorkSafe WA's violence and aggression guidance explicitly directs PCBUs to consider how hazards interact. Record the work conditions producing the exposure, not just a label such as “stress”.

What do WA's rules require?

The Work Health and Safety Act 2020 establishes the PCBU's primary duty to ensure, so far as reasonably practicable, workers' health and safety; health includes psychological health. The Work Health and Safety (General) Regulations 2022 contain risk-management requirements, including provisions directed at psychosocial hazards. WorkSafe WA explains that a PCBU must eliminate psychosocial risks, or minimise them so far as reasonably practicable. Mines may be subject to the corresponding mines regulations, so verify which regulatory instrument applies to the operation.

The approved code of practice is practical guidance for meeting the duty, not a promise that ticking its steps guarantees legal compliance. It recommends a cycle of identification, assessment, control, monitoring and review, with communication and consultation throughout. A business should apply the current law, relevant code and the real facts of its work. Where uncertainty exists about a particular duty, obtain competent WA legal or WHS advice.

The duty is proactive. Waiting for a diagnosed illness or a formal complaint can miss a foreseeable exposure. Equally, an isolated complaint does not prove a particular legal breach. Treat reports as information to assess, act on and investigate fairly, while protecting privacy and avoiding retaliation.

Step 1: identify hazards in the work itself

Map each work group, role, location, shift and customer interaction. Look at the normal work and predictable peak periods. Ask what can cause psychological harm, who may be exposed, how frequently, and what organisational factors may make the exposure worse. Workers and health and safety representatives often know where a written procedure diverges from actual practice. Consult them in a way that permits candid participation.

Use more than one information source. Review incident and near-miss reports, complaints, exit feedback, absenteeism patterns, overtime, turnover, workload measures, customer aggression reports, consultation notes and changes to the work. WorkSafe WA's workplace assessment guidance identifies records such as incidents, complaints and sick leave as possible hazard signals. A high absence rate is not a diagnosis, and personal health records require careful handling; the value lies in recognising patterns that suggest work-related exposure.

For example, a maintenance team may report that fault-call targets cannot be met without skipping rest breaks. The hazard is not simply “people feel stressed”. The assessment should examine workload, staffing, response targets, travel time, on-call arrangements and the ability to escalate. A different team with apparently similar targets may have enough staff and control over the sequence of tasks. Assess the actual system.

Document hazards in terms that support action: “two workers regularly close the premises alone after customer disputes, with no reliable assistance route” is more useful than “violence risk”. Keep identifying hazards after a change in service, roster, contractor model or customer mix; a one-off survey is not the whole process.

Step 2: assess the risk and prioritise action

Consider duration, frequency and severity of exposure, the likelihood of harm, and what could happen if current measures fail. Think about cumulative exposure and combinations: high work demands can be more harmful when control, support and role clarity are low. A single severe incident may require immediate action even if it is uncommon. WorkSafe WA's violence and aggression page describes these factors for that particular hazard.

Identify existing controls, then test whether they are real. A policy that says workers may call for help is weak if the phone cannot be reached or nobody answers overnight. A workload limit that is routinely exceeded is not an effective control. Ask workers how the measure works in practice. Separate immediate protection from longer-term design changes; both may be needed.

A simple risk matrix may help prioritise, but it is not the legal test. A precise-looking score cannot replace evidence about exposure or the obligation to eliminate or minimise risk so far as reasonably practicable. Record the assumptions behind the assessment and who was consulted. For complex or sensitive issues, involve a competent WHS practitioner and other specialists as appropriate.

Step 3: choose controls that change exposure

Start with the source of the hazard. Can the business remove a harmful work practice, redesign a task, change unrealistic targets, add staffing or supervision, alter a roster, improve physical security, or create a reliable escalation path? If elimination is not reasonably practicable, combine measures that minimise exposure. WorkSafe WA's code puts changing the work and organisational factors at the centre of the control process.

For excessive job demands, useful controls might include redistributing work, changing performance measures, setting realistic service levels, providing task autonomy, and making adequate recovery time possible. For customer violence, consider service design, safe layouts, staffing, communication arrangements and a clear response to threats. For poorly managed change, explain the change early, consult affected workers, clarify roles and provide training. These examples are not universal prescriptions; choose controls after assessing the particular work.

Policies, awareness training and employee assistance programmes can support the system, but they rarely remove the source on their own. “Be resilient” is not a control for an impossible workload. A complaint policy is important for reports of bullying, but also ask why the behaviour could continue and whether supervision or incentives need changing. WorkSafe WA has separate bullying-risk guidance and a workplace behaviour code for those narrower issues.

Assign each measure to an owner, implementation date and follow-up check. Tell affected workers what will change and how to report if the control fails. Where the hazard is urgent, put interim protection in place while designing a lasting solution. If a worker has suffered harm, the business may also need incident response, support and appropriate reporting, but do not treat individual support as a substitute for risk control across the group.

Step 4: consult, communicate and protect confidentiality

Consultation is not a survey followed by silence. Explain what hazards were identified, what controls are proposed, what was changed after worker feedback, and when effectiveness will be reviewed. Include workers who are remote, casual, on night shifts or supplied through contractors where they are affected. Multiple PCBUs sharing a workplace should coordinate about risks and controls within their influence.

At the same time, protect sensitive information. An assessment can record a systemic hazard without repeating a named person's medical history or a confidential allegation in a general-access register. Restrict access to complaint and health records, distinguish verified facts from reports, and follow the organisation's privacy and employment processes. A risk assessment supports action; it does not determine whether a named person committed misconduct.

Step 5: monitor and review effectiveness

Select indicators that reflect the hazard and control. If the intervention was a new staffing pattern, examine actual queue times, overtime, missed breaks and worker feedback. If the intervention was a violence response process, check whether calls for help are answered, incidents are reported, and staff feel safe using the procedure. Trends may take time, but obvious control failures should be addressed promptly.

Review after a serious incident, repeated reports, a changed roster or service, an ineffective control, or a major organisational change. WorkSafe WA's code presents monitoring and review as part of a continuous cycle. Record the finding: keep, adjust or replace the control, and explain why. An annual diary reminder is useful, but a known failed measure should not wait for the next scheduled review.

Example: reducing a call-centre's aggression exposure

A WA service team receives repeated abusive calls. The first assessment identifies long waiting times, lone overnight shifts, no clear permission to end threatening calls, and a reporting system workers avoid because nothing happens. Management initially proposes resilience training. That may help staff respond, but it leaves the main exposure unchanged.

A better control package could change staffing at peak times, give workers clear authority to terminate abusive calls, route repeat threats to a trained escalation team, provide immediate support after serious incidents, and review the service process that drives customer frustration. The PCBU would consult workers, document the control owners and test whether incident frequency, severity and worker confidence improve. The exact measures depend on the business and available options; the example illustrates why system design matters.

What records should the business keep?

A usable record should show the workplace or work group, hazards identified, evidence considered, who was consulted, risk reasoning, controls chosen, owner and due date, communication, and review result. Link the assessment to incident investigations and corrective actions where relevant. Keep document versions so a reviewer can see what was in place when the work changed. The law and sector may impose specific retention duties for particular records; do not invent a universal psychosocial assessment retention period.

The record should be proportionate. A small business may have a concise assessment and action log, provided it accurately reflects the real work. A large multi-site employer may need group-specific assessments and a central control register. The test is whether the business can explain and demonstrate how it manages the exposure, not how many pages the document contains.

Complys risk assessment software is presented as a way to record hazards, risk ratings, controls and reviews in one place. Use it to maintain an accountable register and review prompts where the current product supports them. Do not assume the software diagnoses psychological illness, conducts confidential investigations, produces a legally sufficient WA psychosocial assessment automatically, or certifies compliance. The PCBU remains responsible for consultation, the choice and implementation of controls, and verifying current law.

Common mistakes to avoid

• Treating psychosocial risk as an HR-only matter. Complaints and employee relations processes matter, but WHS requires prevention of work-related harm.
• Using generic labels without identifying the source. “Stress” does not tell a manager what work to redesign.
• Offering counselling as the only control. Individual support may help someone affected; it does not remove unsafe work design.
• Ignoring combined hazards. Workload, low support, isolation and customer aggression can interact.
• Assessing only permanent office staff. Consider shifts, remote work, contractors and public-facing roles as applicable.
• Collecting sensitive stories in an unrestricted register. Separate system-level risk information from confidential personal files.
• Never testing controls. A policy that nobody can use or a target routinely exceeded is not effective protection.
• Assuming software provides legal sign-off. Records support a process; they do not replace judgment or regulator assessment.

The practical next step

Choose one work group with a plausible exposure, consult the people doing the work, identify the conditions creating it, and agree a control owner and review date. Use the WorkSafe WA psychosocial code as the local process guide. If you need a consistent place for the resulting assessments and actions, examine Complys risk assessment software against your current workflow and product requirements. Confirm current WA requirements and the live Complys feature set before implementation or publication.

For the related Complys product, see Risk Assessment Software. This guide is general information, not legal advice; verify current requirements against the official sources linked above.