
The risk management process
Employers should apply the risk management process to manage risks associated with bullying, so far as is reasonably practicable.
The risk management process involves the following steps:
- identifying psychosocial hazards
- assessing, where necessary, any associated risks to health or safety
- controlling risks to a person’s health or safety associated with psychosocial hazards
- monitoring, reviewing and, where necessary, revising risk controls.
There are certain circumstances where each step of the risk management process must occur.
This page explains how to identify bullying in the working environment. This is Step 1 in the risk management process.
Your duty
Employers must, so far as is reasonably practicable, identify psychosocial hazards such as bullying.
Employers must consult with employees and any health and safety representatives (HSRs) when identifying hazards.
The characteristics of the workplace will affect how consultation is done. Employers should choose methods and systems for consultation that are appropriate to the:
- size and needs of the organisation
- reasonable needs of affected employees.
The methods should be decided in consultation with employees and any HSRs.
Identifying bullying
Bullying is a psychosocial hazard that can exist in any workplace at any time.
You can use the following information to help identify:
- possible indicators or sources of bullying
- other psychosocial hazards that may increase the risk of bullying.
This list is not exhaustive.
In most circumstances, psychosocial hazards will not occur in isolation. Employees are likely to be exposed to a combination of hazards that may be present in the workplace some or all the time. These may not always be immediately obvious.
There is greater risk of harm when multiple hazards are present. Employers need to consider how psychosocial hazards combine and interact.
Review internal information
- Organisational or operational records
For example:
- Are there any themes emerging from employee feedback or concerns that indicate exposure to bullying?
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Do workforce survey results show exposure to bullying or disrespectful behaviour in any of the following groups?
- Certain teams.
- Certain roles.
- People who belong to at-risk groups. See What is bullying? for more information.
- The organisation as a whole.
This includes in any free-text responses. What areas of concern have employees raised?
- Do leaders understand the following?
- Bullying laws and their obligations.
- The nature, drivers and effects of bullying.
- Their role in creating a culture of respect and inclusion.
- Their duty to role-model respectful and appropriate workplace behaviour where bullying is not tolerated.
- Do leaders have the knowledge and skills to:
- identify bullying?
- control associated risks?
- Are all positions filled?
- Is there a workforce planning system or employee replacement process in place?
- Are staffing and resources reviewed in line with workload and available skills?
- Is there a plan in place to manage workload during peak or seasonal demands?
- Is workload shared fairly between employees?
- Have customers provided feedback about issues such as wait times or service levels?
- Is employee feedback encouraged and considered?
- Do employees feel comfortable providing feedback about bullying?
- Has there been a recent change in employee engagement or morale?
- Are leaders trained in how to recognise and respond to early signs of psychological harm in the workplace?
- Have work tasks, content and scheduling been clearly defined and communicated to all employees? This includes contractors and labour hire workers.
- Are employees given reasonable adjustments and adequate time, resources and support to complete tasks?
- Does a review of workflows, tasks and schedules show any inefficiencies that may increase workload?
- Is the physical working environment appropriate and set up to reduce the risk of bullying?
- Are employees regularly working in remote or isolated locations, or working alone?
- Are leaders trained in how to carry out reasonable management action or performance processes in a reasonable, lawful and safe manner? For more information, see the Fair Work Ombudsman’s Managing underperformance best practice guide.
- Human resources information
For example:
- Are there any issues identified that indicate exposure to bullying or disrespectful behaviour?
- What reasons do employees give in exit interviews for leaving the organisation? Are there themes emerging from exit interviews relating to bullying?
- Are there any complaints of bullying or disrespectful behaviour raised to human resources reporting pathways?
- Are any employees working excessive or unusual hours?
- Are employees working late or night shifts?
- Are rates of sick leave and unplanned leave higher than usual or higher than average?
- Do rates of sick leave or other unplanned leave show any trends? For example:
- There are higher levels of absenteeism in some work areas compared to others.
- More leave is being taken at certain times.
- Has employee turnover increased?
- Is employee turnover higher than average?
- Is employee turnover higher in some working areas than others?
- What reasons do employees give in exit interviews for leaving the organisation? Are there themes emerging from exit interviews?
- Are there any issues identified that indicate exposure to bullying or disrespectful behaviour?
- OHS information
For example:
- What hazards have incident, hazard, injury or near-miss reports identified? Do they include reports of bullying?
- Did workplace inspections include consideration of psychosocial hazards, including bullying? Were they completed by appropriately skilled people and any employee representatives, such as HSRs?
- What areas of concern have employees raised in the psychosocial hazard identification survey? Are there procedures in place to consider, consult on and address these concerns?
- What psychosocial hazards or risks have previous risk assessments identified? Has bullying been identified? Are risk controls adequately controlling the identified risks of bullying?
- Is there a hazard and incident reporting system or risk register for reporting psychosocial hazards or incidents, including bullying, that affect employee health and safety?
- Are employees aware of, and using, the reporting system to report bullying?
- Does the reporting system or risk register include psychosocial risks, such as those associated with exposure to bullying?
- Are there reports of bullying or disrespectful behaviour in the incident reporting system?
- Are there trends or patterns in the data that show psychosocial hazards, including bullying, are present?
- Is there a clearly defined process for how the organisation, supervisors and managers will respond to reports of psychosocial hazards and incidents, including bullying?
- Is hazard and incident reporting data used to inform proactive employee intervention?
- What is the source of the bullying being reported?
- How often is bullying being reported?
- Have bullying and associated risk controls been identified in health and safety committee meetings? Has any action been taken to control risks associated with this bullying?
- Are there trends or patterns in the Employee Assistance Program (EAP) data that show potential exposure to bullying or other associated hazards? Have any steps been taken to address previously identified bullying or risks?
- Has claims data (including rejected claims) been analysed to identify trends or patterns of psychosocial hazards, including bullying?
- Has the information from these claims been used to review current risk controls and revise them if necessary?
- Is claims data analysed by areas like work location and role?
- What is being done to support employees who have lodged claims?
For more information on how to identify hazards, see:
- WorkSafe’s Psychosocial hazard identification tool
- Appendix B of the Psychological health compliance code.
Observe the workplace and assess job-specific requirements
Bullying can also be identified by:
- observing how employees work and interact with each other
- assessing job-specific requirements.
Where possible, more than one person should do these observations. Any HSRs should also be invited to participate. Below are some suggested questions to consider when observing the workplace and assessing job-specific requirements.
- Workplace observation
- Is there a rigid hierarchical structure?
- Is the workplace environment one where:
- Leaders’ authority is rarely challenged?
- Employees feel unsafe to raise their concerns or speak up?
- Are work-related social activities or events inclusive?
- Is there a strong culture of group initiation, such as hazing, into the work environment or specific work groups?
- Do initiation activities emphasise the power imbalance between existing employees and newcomers, or aim to ‘harden’ employees up?
- Are there initiation rituals or activities that employees could experience as unreasonable, inappropriate, intimidatory or a risk to health and safety?
- Are there negative consequences for not taking part in initiation rituals or activities? For example, being excluded from social gatherings or getting the most time-consuming work tasks.
- Are employees working in remote or isolated conditions where they may be excluded from meetings or activities? Consider the following points.
- Employees working in geographically isolated locations.
- Employees working alone.
- Employees working out of scheduled hours.
- Employees working unsupervised.
- Employees working from home.
- Employees working from locations other than their usual place of work.
- Employees living in employer-provided accommodation.
- Employer-provided accommodation has inadequate facilities or cannot be secured.
- Are employees appropriately supported? Consider employees who are most at risk of bullying. See What is bullying? for more information.
- Are employees exposed to poor-quality environments? For example:
- poor lighting
- crowded conditions
- excessive noise
- uncomfortable temperatures
- poorly designed layout.
- Are employees repeatedly disrespectful to each other? This includes in online working environments like private chat functions. For example:
- using inappropriate language
- talking over each other
- playing ‘pranks’ on each other
- posting rumours or embarrassing photos or videos of other employees.
- Are customers and clients disrespectful towards employees? This includes in online working environments like chat functions. For example:
- Customers or clients repeatedly verbally abuse employees.
- Customers or clients send repeated offensive emails to employees.
- Customers or clients make repeated offensive, humiliating or derogatory comments about employees in public online forums.
- Does management tolerate or engage in potentially harmful behaviour? For example, consider the following workplace characteristics:
- Crude jokes are common and generally tolerated.
- There are no incident reporting systems in place.
- There are no protected or confidential reporting options.
- Incident reports are not taken seriously or are not appropriately responded to.
- Employees are unwilling to use incident reporting systems because of possible retribution.
- Supervisors and managers are not addressing inappropriate behaviour.
- Bystanders are not calling out harmful behaviour.
- Are there any images on display or lying around that may be offensive? This includes posters, calendars, magazines or screensavers.
- Assessment of job-specific requirements
- Do employees work with customers, clients, patients or members of the public?
- Do employees work in unpredictable environments with individuals who:
- have a known history of bullying?
- are highly distressed or emotionally dysregulated?
- do not get along with one another at a personal, professional or team level?
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Do tasks carry a heavy emotional load? For example:
- Responding to distressing situations or aggressive clients.
- Having difficult conversations or delivering unwelcome information.
- Helping people who are upset or unhappy.
Exposure to repeated harmful behaviours from external stakeholders could be considered bullying.
- Do employees work under time pressure or tight deadlines that may affect how they complete tasks? Consider whether employees:
- have inadequate time to finish their work
- have low levels of autonomy and flexibility
- take shortcuts to do a task rather than using standard procedures.
- Are tasks delayed due to inefficiencies in work systems? For example:
- technology issues
- slow decision-making
- burdensome administrative processes
- lack of leadership.
- Are there conflicting job roles, responsibilities or expectations that may lead to confusion or frequent mistakes? Consider the following:
- Multiple roles are doing the same task.
- Employees receive inconsistent instructions from management.
- Responsibilities between roles are unclear or overlap.
- Other employees, supervisors, clients or customers have an unclear understanding of an employee’s role.
- Do employees have the tools, equipment, training and support required to complete their tasks, including reasonable adjustments where required?