Psychosocial hazard case studies

These case studies are based on Comcare regulatory activity in response to incidents involving psychosocial hazards and risks at workplaces in the Commonwealth jurisdiction.

They are intended as an education resource to provide the jurisdiction with examples of hazards and risks and how they can be managed.

CASE STUDY 1 – Poor organisational change management

Poor change management can lead to psychological injuries and other adverse health outcomes, as well as reduced productivity. It is identified as a common hazard in the Model Code of Practice: Managing psychosocial hazards at work.

Consulting workers is a critical element of implementing organisational change and is a legal requirement under work health and safety laws.

What happened?

An Australian Public Service agency introduced a new performance management system across part of its business. The new system included performance ratings which determined the number and frequency of work assessments.

The agency decided that only ongoing staff – not contractors – needed to be consulted ahead of implementation. Staff working on labour hire contracts complained the new system caused bullying and harassment, increased their stress and had negative effects on their mental health.

Action and outcomes

A Comcare inspection found it was foreseeable that all affected workers may feel pressure from the increased scrutiny and that it would impact their psychological health and safety. This was particularly the case for workers in more vulnerable labour hire employment arrangements.

The agency’s actions contravened the Work Health and Safety Act 2011 (WHS Act) in relation to:

failure to manage the risks to psychological health and safety in the rollout of the performance management system; and
failure to consult all workers on a change that may affect their psychological health and safety, and a failure to include Health and Safety Representatives (HSRs) in that consultation.

The organisation was directed to develop a corrective action plan to ensure:

there was a process/system in place to identify and manage psychological hazards associated with organisational change that could affect workers’ health and safety that change; and
all workers and their HSRs were included in consultation on the change.

WHS duties

WHS Act section 19: Duty to manage risks to psychological health and safety. Persons Conducting a Business or Undertaking (PCBUs) have a duty to manage risks to the psychological health and safety of workers by eliminating or minimising exposure to psychosocial hazards so far as reasonably practicable.
WHS Act section 47 – Duty to consult with workers. This provides that a PCBU has a duty to consult with workers who are likely to be affected by a matter relating to work health and safety.

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CASE STUDY 2 – Work demands

Work demands are one of the most common sources of workplace stress and psychological harm.

Poor health outcomes from work demands are far less likely in organisations with a supportive culture that rewards workers, promotes early reporting of issues and proactively manages risk.

Employers have a legal obligation under work health and safety laws to implement safe systems of work that identify hazards and effectively manage psychosocial risks to prevent harm to workers.

What happened?

An APS agency was experiencing high workloads and staff shortages in one of its key frontline business areas over a period of at least a year. Staff reported workloads that were excessive and unsafe, with obvious negative impacts on workers’ mental health.

The agency advised it planned to implement a number of controls over a period of several months to control psychosocial risks associated with workloads, including boosting staff numbers and streamlining workflows and roles.

However, a Comcare inspection found the organisation was contravening work health and safety laws by failing to adequately address immediate psychosocial risks across its workplaces.

Action and outcomes

A Comcare inspection found the organisation was not meeting its duties under the Work Health and Safety Act and Regulations 2011:

Failure to provide and maintain a safe system of work relating to psychosocial risks associated with workload management.

The agency developed and implemented a corrective action plan which detailed measures to manage and control immediate risks including:

Engaging with Health and Safety Representatives to discuss the agency’s approach to managing psychosocial risks from work demands
Closer monitoring of workloads, including structured and documented engagement by line managers with workers
A range of workplace wellbeing activities

The inspector also recommended improvements to communication with workers about psychosocial hazards and risks, and in the way Work Health and Safety Committee meetings were run.

WHS duties

WHS Act Section 19(3)(c): Provision and maintenance of safe system of work, so far as reasonably practicable, relating to psychosocial risks associated with workload management.

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CASE STUDY 3 – Bullying and harassment

Bullying is repeated, unreasonable behaviour directed towards a worker or group of workers, that creates a risk to health and safety. Harassment is harmful behaviour that creates a risk to health or safety when a person is treated poorly based on personal characteristics such as age, disability, race, nationality, religion, political affiliation, sex or gender identity.

Workplace bullying and harassment are often the result of poor workplace culture supported by an environment which allows this behaviour to occur. Identifying and addressing these conflicts early helps promote respectful behaviour and prevents bullying and harassment from becoming accepted behaviour.

What happened?

Comcare received complaints from workers at an Australian Government entity who raised concerns about a range of workplace issues including:

Alleged bullying and harassment by managers
Unrealistic timeframes for completing training
Insufficient resources to complete tasks
Excessive hours and fatigue

Action and outcomes

Comcare’s inspection did not identify a specific contravention of the Work Health and Safety Act and Regulations 2011.

However, the inspector did recommend a range of improvements to strengthen responses to identified psychosocial hazards and risks, including:

Consulting with all workers likely to be directly affected by a health and safety matter
Updating workplace risk assessments to refer to psychosocial hazards, including bullying and harassment
Retraining all workers on policies and procedures regarding bullying and harassment and grievance procedures
Improving executive managers’ understanding of workplace hazards and risks to assist in meeting Officer Due Diligence obligations and promote a positive safety culture

WHS duties

WHS Act section 19: Duty to manage risks to psychological health and safety. Persons Conducting a Business or Undertaking (PCBUs) have a duty to manage risks to the psychological health and safety of workers by eliminating or minimising exposure to psychosocial hazards so far as reasonably practicable.
WHS Act section 47: Duty to consult with workers. This provides that a PCBU has a duty to consult with workers who are likely to be affected by a matter relating to work health and safety.
WHS Act section 27: Duty of officers. Officers of corporations, the Crown or a public authority in the Commonwealth jurisdiction have a specific duty to exercise due diligence to ensure the organisation meets its work health and safety obligations.

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CASE STUDY 4 – Combined hazards

Psychosocial hazards often don’t occur in isolation, with workers likely to be exposed to a combination of hazards. Some hazards may always be present in the workplace, while others may be occasional.

What happened?

Health and Safety Representatives contacted Comcare to address complaints of unresolved psychosocial hazards resulting in multiple psychological and physical injuries to workers at an Australian Government agency.

The hazards were reported to relate to managerial administrative action for performance management, code of conduct action, a review of flexible working hours and a restructure.

The issues combined a range of common psychosocial hazards including:

Poor organisational change management
Bullying
Harassment
Poor organisational justice
Job demands
Lack of role clarity

Action and outcomes

Comcare carried out multiple inspections and issued an Improvement Notice in relation to these matters.

Inspectors formed a reasonable belief that the organisation had contravened several duties under the Commonwealth Work Health and Safety Act. Failures included:

Ineffective Work Health and Safety Management Systems to prevent or minimise psychological injury to workers
Lack of a change management plan and inadequate worker consultation
Inadequate rehabilitation management system that did not integrate with the hazard identification component of the WHS Management System
Failure to conduct incident investigations into the causal factors that contribute to psychosocial incidents

In response, the agency introduced and strengthened a range of existing controls across its business, including:

A mediation process to resolve staff grievances
Regular staff wellbeing checks
Establishing a unit to assist with integrating teams in future Machinery of Government changes
Developing a suite of tools to improve performance management

WHS duties

WHS Act section 19: Duty to manage risks to psychological health and safety. Persons Conducting a Business or Undertaking (PCBUs) have a duty to manage risks to the psychological health and safety of workers by eliminating or minimising exposure to psychosocial hazards so far as reasonably practicable.
WHS Act section 47: Duty to consult with workers. This provides that a PCBU has a duty to consult with workers who are likely to be affected by a matter relating to work health and safety.

More information

Page last reviewed: 07 July 2023