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High work demands and poor change management = Psychosocial Hazards

Posted on August 10, 2023

Recent case studies published by Comcare (the national work health and safety authority) reveal that two unnamed Australian Public Service (APS) agencies failed in their duty to eliminate or minimise workplace psychosocial risks by introducing a new performance management system without proper consultation and by placing excessive work demands on staff[1].

In our previous article, we discussed significant amendments to the Model Work Health and Safety Act, Regulations and Codes of Practice (WHS Model Laws) which focused on psychosocial hazards. Specifically, the WHS Regulations were amended to define psychosocial hazards and risks and require a person conducting a business or undertaking (PCBU) to manage psychosocial risks in the workplace. A model code of practice called ‘Managing psychosocial hazards at work’ (Model Code) was released to provide practical guidance to PCBUs on how to manage psychosocial hazards at work.

The WHS Model Laws are designed to provide a harmonized approach to WHS laws across all states and territories, however amendments to the WHS Model Laws are not automatically implemented in each jurisdiction and states and territories are responsible for enacting the amendments.

Psychosocial risks are increasingly becoming a focus point for safe work regulators across Australia with many states and territories adopting the new Model Code. We expect that South Australia will also adopt the amendments and the new Model Code.

Case study: Poor organisational change management

Poor change management can lead to psychological injuries and other adverse health outcomes, as well as reduced productivity.

In this case study an APS agency had introduced a new performance management system across part of its business which included performance ratings which determined the number and frequency of work assessments.

The agency only consulted employees prior to implementation and not its contractors. The contractors who were working on labour hire contracts complained that the new system caused bullying and harassment, increased their stress levels and had negative effects on their mental health.

A Comcare inspection found that 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 were held to contravene the WHS Act in relation to failing to manage the risks to psychological health and safety in the rollout of the performance management system and failure to consult all workers likely to be affected by the change.

The agency was directed to develop a corrective action plan to ensure there was a system/ process in place for identifying and managing psychosocial hazards associated with organizational changes and all workers were included in consultation on these changes.

Case study: Work demands

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

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 were reporting that the workloads were excessive and unsafe, and having obvious negative impacts on workers’ mental health.

Despite the agency advising that it had planned to implement a number of controls over a period of several months to control these risks, a Comcare inspection found that the agency had contravened WHS laws by failing to adequately address immediate psychosocial risks across its workplace.

The agency had failed to provide and maintain and safe system of work relating to psychosocial risks associated with workload management and was required to develop and implement a corrective action plan to control immediate risks.

Please contact our workplace relations team if you require assistance in managing psychosocial risks in your workplace.


[1] https://www.comcare.gov.au/safe-healthy-work/prevent-harm/psychosocial-hazards/more-information-on-psychological-health-and-safety-in-the-workplace/whs-regulations-case-studies

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