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Part 3 – Step 3: Control risks

Part 3 of the Psychological health compliance code has 4 steps. Step 3 of the risk management process explains ways to eliminate or reduce risks, so far as is reasonably practicable.

This is page 6 in a series of 11 that comprise the Psychological health compliance code. You must read the whole Code so that you understand how to meet your deemed compliance obligations.

An employer must, so far as is reasonably practicable, eliminate any risk associated with a psychosocial hazard. <OHS (Psychological Health) Regulations r15(1)>
If it is not reasonably practicable to eliminate a risk associated with a psychosocial hazard, the employer must reduce the risk so far as is reasonably practicable, by:
1. altering the –
  1. management of work, or
  2. plant, or
  3. systems of work, or
  4. work design, or
  5. workplace environment, or
2. using information, instruction or training, or
3. using a combination of any of the controls listed in (a) and (b).
<OHS (Psychological Health) Regulations r15(2)>
Information, instruction or training may only exclusively be used as a risk control measure where none of the risk control measures listed under paragraph 86(a) are reasonably practicable. <OHS (Psychological Health) Regulations r15(3)>
Where a combination of risk control measures is used, information, instruction or training must not be the predominant control measure. <OHS (Psychological Health) Regulations r15(4)>

Diagram 4: Controlling exposure to psychosocial hazards and risks

What is reasonably practicable?

What is reasonably practicable can be decided objectively and is based on the standard of behaviour expected from a reasonable person. A reasonable person is taken to be:

committed to providing the highest level of protection for people against risks to their health and safety
proactively taking action to protect people’s health and safety.

Employers must do what a reasonable person who is committed to the highest level of protection against risks to health and safety would do in the circumstance. To do this, they must put in place reasonably practicable measures.

In working out what is reasonably practicable, they must have regard to:

the likelihood of a hazard or risk occurring (the chance of a person being exposed to harm)
the degree of harm that could be caused if the hazard or risk occurred (the possible seriousness of injury or harm)
what the person knows, or reasonably should know, about the hazard or risk, and ways to eliminate or reduce that hazard or risk
the availability and suitability of ways to eliminate or reduce the hazard or risk, and
the cost of eliminating or reducing the hazard or risk. <OHS Act s20(2)>

For more information about what reasonably practicable means when complying with duties under Part 3 of the OHS Act or the OHS (Psychological Health) Regulations, see the WorkSafe Position How WorkSafe applies the law in relation to Reasonably Practicable.

Eliminating the risk

Employers must first consider if it is reasonably practicable to eliminate the risk associated with a psychosocial hazard. This means employers must consider whether it is reasonably practicable to organise work or the working environment in a way that does not expose employees to the risk.
The best way to do this is to consider:
- which psychosocial hazards may arise in the working environment
- how factors such as work design, systems of work, plant, management of work and workplace environment can be designed or altered to avoid introducing hazards in the first place.
For example, removing solo shifts can eliminate the risk of working alone.
It may not always be reasonably practicable to eliminate a hazard. This may be the case where, for example:
- eliminating would mean the product cannot be produced or the service cannot be delivered
- a job has inherent exposure to psychosocial hazards; for example, work that requires exposure to traumatic scenes or supporting individuals in distress.

Reducing the risk

If it is not reasonably practicable to eliminate a risk associated with a psychosocial hazard, an employer must reduce the risk so far as is reasonably practicable by:
1. altering the –
  1. management of work, or
  2. plant, or
  3. systems of work, or
  4. work design, or
  5. workplace environment, or
2. using information, instruction or training, or
3. using a combination of any of the controls listed in (a) and (b).
<OHS (Psychological Health) Regulations r15(2)>
Information, instruction or training may only be exclusively used as a risk control measure where none of the risk control measures listed under paragraph 92(a) are reasonably practicable. <OHS (Psychological Health) Regulations r15(3)>
Where a combination of risk control measures is used, information, instruction or training must not be the predominant control measure. <OHS (Psychological Health) Regulations r15(4)>

For limitations on how information, instruction or training is to be used, see paragraphs 113–125.

To determine how to reduce the risk associated with psychosocial hazards so far as is reasonably practicable, employers need to:
- review any risk controls currently in place and assess their effectiveness at controlling the risk
- identify as many risk control measures as possible that may reduce the risk
- consider which of these risk control measures are most effective in reducing the risk
- consider which risk control measures are reasonably practicable in the circumstances
- determine which reasonably practicable risk control measure, or combination of risk control measures, reduces the risk so far as is reasonably practicable.
Reducing the risk might involve a:
- single risk control measure
- combination of different risk control measures that work together to provide the highest level of reasonably practicable protection.

Example of using a combination of risk controls

An employer identifies high job demands, aggression or violence and poor support as psychosocial hazards that pose a risk to the health or safety of their customer-facing employees.

To control the risks associated with these hazards, they use a combination of the following risk control measures:

reviewing and redesigning roles to remove unnecessary job demands; for example, streamlining administrative tasks
altering the workplace environment to physically separate employees and customers
reviewing staffing numbers so there are enough employees available to meet demand, which can reduce the risk of customers becoming aggressive
using technology to automate tasks to improve efficiency and reduce customer-facing interactions
rotating jobs to reduce exposure to aggressive customers
rostering employees to avoid anyone working alone
training employees on de-escalation strategies to manage aggressive customers
providing employees with personal duress alarms and establishing appropriate response systems
providing employees with adequate supervision and support, with clear escalation procedures to a supervisor or manager
managing customer expectations by clearly communicating processes such as wait times
communicating with customers on standards of behaviour and what will not be tolerated
adding appropriate security measures, including security officers, CCTV, alarm systems
implementing procedures for responding to aggression from customers
providing employees with appropriate post-incident support, including access to peer support and Employee Assistance Program (EAP) services.

For more examples of risk controls, see Appendix C.

Employers may also have duties under the Occupational Health and Safety Regulations 2017 to control certain physical hazards in accordance with specific hierarchies of control for:

noise
plant
hazardous substances
hazardous manual handling.

For more information on managing specific risks, see the relevant compliance code or guidance at worksafe.vic.gov.au.

Management of work
Management of work includes things such as:
governance, leadership, and decision-making and escalation structures
workforce planning
resource allocation and rostering.
Risk control measures related to management of work could include:
Reviewing current work processes to:
eliminate unnecessary administrative processes
arrange work rosters or processes so employees can vary tasks that require high concentration or are physically demanding
provide a clear management reporting structure
ensure employees have the necessary qualifications and experience for their roles, and are appropriately inducted and trained as part of recruitment and onboarding
support flexible working arrangements.
Upskilling leaders in:
health and safety, including how to identify hazards and engage employees in consultation processes
how to effectively manage complex staffing matters; for example, workload, poor workplace behaviours, bullying and sexual harassment.
Demonstrating leadership commitment to managing psychosocial hazards; for example:
responding appropriately to all reports of harmful behaviours such as bullying
modelling good work/life balance
creating a positive workplace culture where employees feel valued and feedback is welcome
building employee confidence and trust that safety is taken seriously.
Plant
Plant includes:
any machinery, equipment, appliance, implement and tool; and
any component of any of those things; and
anything fitted, connected or related to any of those things. <OHS Act s5(1)>
Well-designed and properly maintained plant can help prevent exposure to psychosocial hazards by:
reducing noise, vibration or dust
controlling temperature.
Risk control measures related to plant may include:
replacing plant with new plant that presents less risk
separating employees from the plant
making changes to existing plant.
For example:
repairing any plant that is regularly malfunctioning and causing frustration or increased work pressure for employees
replacing equipment with new models that create less noise or vibration
regularly servicing and maintaining all plant
upgrading frequently used appliances so that buttons, screens and software are easy to use and straightforward, reducing the need for prolonged concentration
choosing plant with adjustable light emission to reduce the risk of fatigue; for example, night mode lighting settings or increased brightness
optimising equipment with more automated functions to reduce workload and save time; for example, using automated visual inspection software rather than manual quality inspections to detect defects in real-time during production
applying a privacy screen filter on a computer screen if an employee needs to view traumatic or graphic material
using image recognition and classification software when reviewing distressing images or videos.
Systems of work
A system of work encompasses the way that work is planned, organised and done. This may include the interacting set of policies, procedures, practices, equipment, materials and environment. Policies and procedures on their own are not systems of work.
Employers should consider how altering systems of work can reduce the risks of exposure to specific psychosocial hazards; for example:
Reviewing systems in place to manage high job demands and the risk of fatigue to look for improvements. Areas to consider include:
staffing requirements
rostering practices
working hours
shift work arrangements
task rotation
breaks, including during and between shifts.
Developing a tailored system to reduce the risks of aggression or violence by customers towards employees. This could include:
designing the working environment to reduce unnecessary interactions between customers and employees
rostering employees so no one works alone
providing adequate resources to deliver the service
introducing an incident reporting and investigation system
providing appropriate training and supervision for employees
implementing response procedures, which may include the use of duress alarms and onsite security
providing appropriate post-incident support.
Putting in place systems to reduce risks of working in isolation or in unpredictable environments like a client’s home. This could include:
developing a communications plan
ensuring suitable communications equipment is available
reviewing supervision levels to ensure they are appropriate
determining the minimum number of employees that should be rostered to shifts in high-risk environments or during high-risk periods.
Implementing policies and procedures to reduce risks associated with the organisational response to psychosocial hazards. For example:
procedures that clearly explain what will happen when a report of a psychosocial hazard is made
a policy that outlines what information will remain confidential following a report of a psychosocial hazard and what needs to be shared
training for all employees on how to report a hazard
training and support for leaders who are expected to receive and respond to reports.
PPE can form part of the systems of work at an organisation. PPE refers to anything employees use or wear to minimise risks to their health and safety; for example:
gloves and gowns for jobs involving exposure to contagious diseases, or hazardous chemicals or substances
hearing protection for noisy environments
personal alarm devices.
Providing appropriate PPE can help reduce:
exposure to some physical hazards that contribute to psychosocial risks
risks associated with psychosocial hazards where exposure to the hazard causes concern or distress.
Policies and procedures can also form part of a system of work, but are not a system of work on their own. Policies and procedures should clearly set out the expectations and processes for managing psychosocial hazards in the working environment. These must be:
developed in consultation with employees and any HSRs
reviewed regularly
updated when necessary.
There may be separate policies and procedures for particular hazards, or a single policy or procedure that covers several hazards. These could cover things like:
working alone, remotely or in isolation
harmful workplace behaviours such as bullying, sexual harassment, or aggression or violence
reporting and resolving complaints or grievances
post-incident support
fatigue risk management
workload management
flexible work arrangements
critical incident management
how to manage exposure to trauma, including cumulative and vicarious trauma.
Employers must provide information, instruction and training about:
the systems of work for managing psychosocial hazards
expectations for employees and leaders to support and participate in the process. <OHS Act s21(2)(e)>
Work design
Work design means the equipment, content and organisation of an employee’s work tasks, activities, relationships and responsibilities within a job or role. <OHS (Psychological Health) Regulations r4>
Employers should consider how altering work design can reduce the risk of exposure to psychosocial hazards. For example, consider if:
Employees have an appropriate amount of responsibility for their skills and experience.
Employees have the right resources and equipment to do their work.
Tasks can be scheduled at more suitable times. For example, schedule high-risk tasks when employees are likely to be more alert or when more support is available. Alertness is usually lowest in the early morning (between 1am and 6am) and mid-afternoon (around 2pm).
Tools or equipment can be adjusted to reduce hazardous manual handling risks that may create a psychosocial hazard. For example, anti-fatigue matting or sit–stand desks.
Risks arising from personal interactions can be reduced by processes like:
using an automated ordering system to reduce the number of interactions with customers
refining complaints processes so complex or difficult complaints can be escalated to more senior employees empowered to resolve them
streamlining tasks to eliminate double-handling or unnecessary administrative tasks
using automated technology for reviewing traumatic content.
Workplace environment
The workplace environment includes environmental conditions that contribute to psychosocial risks, such as lighting, temperature, noise or vibration.
Making alterations to the workplace environment could include:
Considering the layout of the office when employees need to view graphic or potentially traumatic material. The layout should minimise unnecessary exposure to other employees; for example, facing computer screens away from the centre of the office.
Providing a secure lockable space for employees, good lighting and visibility in the workspace where there is a risk of harm from aggression or violence.
Installing physical access barriers, surveillance cameras or duress and alarm systems to reduce the risk of harm from aggression or violence.
Providing access to private spaces in the workplace to ensure the confidentiality of sensitive conversations.
Providing a sectioned-off part of the office away from customers for employees to have a break; for example, a staff room.

When considering the use of surveillance devices, employers must consult with employees and any HSRs before installation. <OHS Act s35>

To reduce the risk of these devices causing harm, employers also need to:

consider other laws, such as those relating to privacy and surveillance
place devices in appropriate locations
develop clear process for accessing, storing and using the information gathered
engage in ongoing communication with employees.

Using information, instruction or training

Employers must provide employees with any necessary information, instruction, training or supervision to enable them to perform their work in a way that is safe and without risks to health. This duty also extends to independent contractors (including any employees of the independent contractor) engaged by the employer in relation to matters over which the employer has control. <OHS Act s21(2)(e), s21(3)>
In addition to these duties under the OHS Act, there are specific requirements under the OHS (Psychological Health) Regulations for using information, instruction or training. This is because using information, instruction or training on its own is often a less effective way to reduce risks associated with psychosocial hazards.
Often it will be necessary to use a combination of risk control measures to effectively control the risks associated with psychosocial hazards. Where a combination of risk control measures is used, information, instruction or training must not be the predominant control measure. <OHS (Psychological Health) Regulations r15(4)>

Example of using information, instruction or training

An employer has identified aggression or violence as a hazard in their workplace.

Following a risk assessment, they identify gaps in their control measures. To reduce the risk, they install security features as the predominant, or main, control. The security features include duress alarms and protective screens.

They also provide employees with information, instruction and training about:

how and when to use the duress alarms
the response procedure for when the alarm is activated
de-escalation techniques.

Employers may only exclusively use information, instruction or training if it is not reasonably practicable to reduce the risk by altering any of the following:
- management of work
- plant
- systems of work
- work design
- workplace environment.
<OHS (Psychological Health) Regulations r15(3)>
Information, instruction or training for employees might include:
- what psychosocial hazards are and how to identify them in the working environment
- the psychosocial hazards and risks that have been identified in the workplace and current risk control measures in place
- the causes and drivers of psychosocial hazards
- how to identify early signs of harm or potential injury from exposure to psychosocial hazards
- how to report psychosocial hazards and incidents, and what will be done following a report
- fatigue identification, prevention and mitigation
- appropriate workplace behaviours, and related policies and procedures
- responsibilities under the OHS Act and OHS (Psychological Health) Regulations in relation to psychosocial hazards.
To encourage a wider understanding of their working environment, employees should be provided with necessary training on:
- health and safety
- performance management
- conflict resolution
- interpersonal skills
- emotional intelligence
- effective communication.
Employers need to provide information, instruction or training to employees in a variety of appropriate and accessible formats, such as:
- presentations
- procedure manuals
- demonstrations of work processes.
Employers must also, so far as is reasonably practicable, provide information about health and safety to employees in appropriate languages. <OHS Act s22(1)(c)>
Information, instruction or training needs to be provided by a suitably qualified person. Their knowledge or skills may have been acquired through training, qualifications or experience.
Training programs should be practical and engaging. The structure, content and delivery of the training needs to consider any special requirements of the employees being trained, such as their specific skills or experience, disability, literacy and age.
Employers need to provide information, instruction and training to employees:
- during their initial induction
- on an ongoing basis during their employment.
Ongoing training needs to be provided as appropriate for the workplace and relevant to the psychosocial hazards identified for the working environment. The frequency of training should be determined according to:
- the type of hazard
- content of the training
- recent advances in knowledge
- the size of the workplace
- changes in the way work is structured or performed
- how often employees are exposed to psychosocial hazards and how severe the risk of exposure is.
Employers should keep records of induction and training provided to, and completed by, employees and independent contractors. Employers also need to regularly review the effectiveness and frequency of the training in consultation with employees and any HSRs.

Training and support for supervisors and managers

Effective leadership is associated with better health outcomes and improved work performance. Employers should provide supervisors and managers with appropriate training and support so they are equipped to:
- recognise and proactively address psychosocial hazards and associated risks
- respond appropriately to reports of psychosocial hazards, in accordance with relevant policies and procedures
- support employees and intervene when they identify employees showing signs of a negative psychological response.

For examples of what a negative psychological response might look like, see Table 1 in Part 2.

Training for supervisors and managers should be determined by a training needs analysis and may focus on:
- leadership skills such as:
  - communication skills and active listening
  - interpersonal skills and emotional intelligence
  - performance reviews and performance management
  - difficult conversations and conflict resolution
- psychological health and safety at work, including:
  - understanding and identifying psychosocial hazards in the workplace and associated risks
  - effective risk control measures and how to implement them
  - how to support employees during implementation of risk controls
  - how to identify negative psychological responses and provide employees with assistance
- appropriate workplace behaviours and related policies and procedures
- how to encourage employees to raise health and safety issues and the procedure for responding to these.
Practical and ongoing leadership support for supervisors and managers can be provided through:
- formal training
- mentoring programs
- peer support
- supervision
- professional services such as suitably qualified consultants, or manager assist services through EAP.

Choosing the most effective risk controls

Which risk control measures will be most effective in any given working environment will depend on:
- the combination of psychosocial hazards identified and the associated risks
- the circumstances of that working environment; for example:
  - type, size and location
  - organisational structure and culture
  - environmental conditions
  - technology available
  - organisational activities, products and services
  - supply chains and contractual arrangements
  - employee skills and attributes
  - workplace relationships
  - economic conditions
  - employee roles, responsibilities and workload
  - availability and suitability of controls.
Employers should consider which type of risk controls will be most effective at reducing the risk of harm from psychosocial hazards in their workplace. The most effective risk controls should be used first. This means that the order in which controls that alter the management of work, plant, systems of work, work design or workplace environment are used may vary in different circumstances.
Often it will be necessary to use a combination of risk control measures to effectively control the risks associated with psychosocial hazards. The best combination of risk control measures will depend on what is reasonably practicable. This may be influenced by an organisation’s size, type and work activities.

For more information, see What is reasonably practicable?, above.

Used on its own, information, instruction or training is often a less effective way to reduce risks associated with psychosocial hazards. It may only be used:
- in combination with other risk controls, but not as the predominant control
- exclusively, when it is not reasonably practicable to reduce the risk using other controls.
<OHS (Psychological Health) Regulations r15(3) and (4)>
When determining risk control measures, employers should consider the hazards and the associated risks they have identified collectively, rather than in isolation. For example, in some circumstances, poor workplace relationships may develop as an inappropriate response to high job demands or poor support. Considering hazards and risks collectively will help to determine:
- the most effective risk control measures
- how a risk control measure implemented for one risk may introduce additional hazards and risks.
A risk associated with a psychosocial hazard may affect an employee or a group of employees. For example, an employee tells their employer that the job demands associated with their role are negatively affecting their health. The employer should:
- make adjustments to the employee’s job or role in the short term
- consider if other employees do the same, or similar, roles
- review the existing risk controls as required and consider if a broader review of the design of work may be needed to determine how to reduce the risk across the organisation.

For more on reviewing risk control measures, see paragraphs 149–161 in Part 3, Step 4.

Where an employer has multiple workplaces, there may be common hazards and risks. If hazards and risks are similar across workplaces, the employer may be able to use common risk controls.
If hazards and risks differ across multiple workplaces, the employer may need to use tailored risk controls for some or all the workplaces. This should be based on risk assessments that are specific to teams, locations or designated work groups.
When considering risk control options, employers must also consider whether a risk control will introduce additional risks. For example:
- An employer introduces a workload management system to control the high job demands of one group of employees without effective consultation or communication. This inadvertently increases the job demands of another group of employees.
- An employer reallocates a manager who is accused of bullying to a different part of the organisation without formally investigating the allegation or controlling any associated risks.
Where the implementation of a risk control measure is going to take time, employers should consider any interim measures available to reduce the risk. For example, if addressing high job demands will require a recruitment process, it may be weeks or months before new employees can reduce the workload for existing employees. Short-term measures that may help to quickly reduce the risk include:
- using contracted temporary employees or internal employee secondments to take on work
- reprioritising work
- renegotiating scheduled commitments.
Employers must, so far as is reasonably practicable, consult with their employees and any HSRs when making decisions about how to control risks. <OHS Act s35> Consulting with employees is likely to result in better risk control measures being implemented because it:
- gives employees the opportunity to contribute ideas and participate in trials for new risk control measures
- is likely to improve the uptake of risk control measures when they are implemented.
Employees will be able to recommend ways to control risks as they are the ones doing the work and will understand the implications. In some instances, discussions with relevant stakeholders may also help; for example, suppliers, customers, industry bodies and associations.

Implementing risk controls

Employers may need to trial or test risk control measures before relying on them.
Any decision-making about implementing proposed risk controls must be done, so far as is reasonably practicable, in consultation with employees and any HSRs. <OHS Act s35(1)(b)>
Risk controls should be supported by necessary information, instruction or training to ensure they are implemented effectively. For example, information about procedures and training on how to use risk controls.
Employers should allow enough time for employees to adjust to changes before assessing the effectiveness of risk control measures. Employers should frequently check with employees if they think the improvements are effective.
Employees must co-operate with their employer’s actions to implement risk controls to eliminate or control the risk of psychosocial hazards. <OHS Act s25(1)(c)> For example, it is important for employees to:
- Follow the information, instruction or training provided.
- Follow the organisation’s policies, procedures and processes.
- Behave fairly and reasonably when working with others. For example, being respectful and following the organisation’s policies and procedures, including those to manage the risk of bullying and sexual harassment.
- Ask supervisors or experienced employees for help if they are unsure about something or don’t know how to do the work safely.
- Promptly report to their supervisor or HSR if psychosocial hazards are present or existing control measures seem inadequate. This will enable the employer to review and, if necessary, revise risk control measures.

Monitoring and maintaining risk controls

Employers must ensure risk control measures are properly maintained. <OHS (Psychological Health) Regulations r8> A procedure should be put in place to monitor and maintain risk controls to ensure they:
- perform as originally intended
- continue to eliminate or adequately reduce the risk of harm from psychosocial hazards.
How this is done needs to be determined when the risk control measure is being decided on, in consultation with employees and any HSRs.
Maintaining risk control measures includes:
- ongoing consultation with HSRs and employees on the effectiveness of the measures
- allowing adequate time for HSRs to carry out regular workplace inspections
- conversations with employees about psychosocial hazards
- verifying that wellbeing checks, supervision and regular discussions with employees are occurring
- annual or biennial surveys for measuring psychosocial hazards and risks
- reviewing hazard reports
- reviewing complaints related to psychosocial hazards
- frequent inspections of the workplace
- visual checks to ensure risk controls are being properly applied by employees and contractors
- regular checks to ensure documented systems of work are implemented fully and appropriately
- preventative testing and maintenance of plant and physical risk controls, such as duress alarms
- any necessary remedial work to ensure physical risk controls continue to work effectively.

This is page 6 in a series of 11 that comprise the Psychological health compliance code. You must read the whole Code so that you understand how to meet your deemed compliance obligations.

Part 3 – Step 3: Control risks

Control risks

What is reasonably practicable?

Eliminating the risk

Reducing the risk

Example of using a combination of risk controls

Management of work

Plant

Systems of work

Work design

Workplace environment

Using information, instruction or training

Example of using information, instruction or training

Training and support for supervisors and managers

Choosing the most effective risk controls

Implementing risk controls

Monitoring and maintaining risk controls

Information

Services

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