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Safeguard Magazine

Design work to be safe

Preventing psychosocial injuries requires a primary focus on the design of safe and healthy work, before wellness interventions focused on individuals, argues DR PETA MILLER.

No one running a business deliberately intends to injure their workers or customers. Few employees consciously and deliberately plan to cause psychological harm to their workmates. Yet the evidence in New Zealand and Australia, and indeed across the world, is that work-related psychological injuries remain a serious problem.

Given the emotional, health and financial costs to individuals and their families – and the economic costs to society and organisations – it is not surprising there is keen interest in improving workplace mental health. There is now a plethora of programmes and vast numbers of documents created by governments, NGOs, employer groups, unions, researchers, lobbyists and of course consultants.

And therein lies some of the problem: we are awash with information of variable quality and relevance; it is time consuming and challenging to sift through all this material to source authoritative, evidence-based advice.

Despite the good intentions of those buying workplace mental health programmes (and probably of those delivering them), many are of limited benefit. The Health and Safety Executive in the UK recently reported on a systematic review on one of the most popular programmes – mental health first aid. It noted while these probably raise employees’ awareness they do not appear to improve organisational management of mental health conditions in workplaces.

Some programmes seek to destigmatise mental illness and normalise conversations, so people feel safe to say they are struggling. These can have positive outcomes but there are also dangers. It is seemingly so much simpler just to focus on vulnerable individuals and to give them “coping strategies”. But there is a risk that employers will use their limited resources and invest in wellness programmes, thinking they are doing what is needed and meeting their duty of care.

It is deeply worrying to think that we might be sliding backwards, where proportionally more effort is invested in programmes that focus on tertiary and crisis interventions for at risk individuals while the need to first “design in” workplace safety is ignored.


Much is made in the literature, as it should be, of the health and productivity benefits of “good work”, including mentally healthy work. I am a little confused how in practice this really differs greatly from what is already required under existing health and safety laws. A PCBU must ensure its operations are psychologically and physically healthy and safe as far as reasonably practicable. Workloads must be manageable, workers consulted and have reasonable control over decisions about work matters, opportunities to use and build their skills, appropriate support, feedback and recognition of their efforts.

When psychological hazards and risk are appropriately managed not only are the risks of harm reduced, but work naturally becomes a source of satisfaction and becomes “good work”.

Under their due diligence obligations leaders already have clear duties to ensure they know the hazards and risks – including psychological risks – associated with their operations, provide and use suitable resources and processes, effectively monitor what is really going on and verify that controls remain effective. If they are meeting their existing due diligence obligations they should naturally be showing leadership and their organisation’s meaningful commitment to health and safety.

There are already clear duties on employers to make reasonable adjustments to accommodate individual differences, including if people are physically or mentally ill, be this work-related or pre-existing. Finally, workers are prohibited from acting in ways that cause harm to their colleagues, including psychological damage. So perhaps all that really differentiates legally required good health and safety practices from those advocated under initiatives to promote mentally healthy workplaces is to engage all of us to be more tolerant at work.


If we return to the question of legal duties it is fair to say that PCBUs and even some H&S professionals are still confused about how to practically achieve psychologically healthy and safe work. To provide authoritative guidance, in June 2018 Safe Work Australia released the national guide Work-related psychological health and safety: a systematic guide to meeting your duties.

Directed at PCBUs and employers, it outlines a holistic and systematic approach to controlling key psychological health and safety risks. It also includes employers’ obligations to intervene early and support recovery should individuals experience work-related injuries. It links to some useful resources like the Principles of Good Work Design Handbook.

Importantly, in addition to the most common psychosocial hazards present to varying degrees in all workplaces, of interest to New Zealand readers is that the new guide explicitly lists workplace bullying, harassment and exposure to occupational violence. This is appropriate as research clearly shows poorly designed work is a common antecedent not only to stress but also workplace conflict and bullying.

So, perhaps the difference between H&S people and mental health advocates is how they encourage leaders to be engaged. In H&S we traditionally use a mix of incentives like insurance premium reductions and arguments that H&S is good for business, backing this up with the risk of prosecutions for the intransigent. In contrast, mental health and wellness advocates go straight to winning hearts and minds by appealing to our humanity.

The Australian guide should demystify employer obligations, and while it is a good start, it is by necessity rather simplistic. It follows the traditional task or hazard-based sequential risk management approach. We must remember to extend the risk identification and assessment processes beyond the examination of tasks in isolation. There are many tasks that make up a person’s whole job and combinations of tasks which make up a team’s role, all with concurrent psychosocial, biomechanical and physical hazards. These will all interact to change risk profiles.

Therefore, to effectively eliminate or minimise psychological risks we will need to systematically identify the key risks for the whole job and the whole team and then consider the right combination of controls. Realistically, a mix of measures that fall across the full hierarchy of control will always be required.


We know too many workplaces start and sometimes finish with organisational policies, procedures or training. In fact, many of the alternative workplace mental health models place in my view an overly strong emphasis on organisational policies. We need to remind PCBUs that while policies are an essential part of the mix, they merely describe how the work should be theoretically be done.

Polices are like the technical manuals for a machine, describing how it should be safely used. They do not inherently make the work either safe or healthy. They frequently reflect the work as imagined or hoped for compared to the harsh reality of daily operations. They won’t be followed unless the work and work systems are designed to make this ideal an operational reality. Your alarm bells should clang loudly if the primary focus is not on the pursuit of safety through good work design.


The release of the Australian guide was timely given the summary of the 2018 public consultations on the model WHS Act published in August. Unsurprisingly, it revealed a common view that the model legislation does not adequately focus on psychological health and safety. This lack of clarity in the existing H&S legislation seems to have impeded regulators from successfully mounting prosecutions around the failure to provide a psychologically safe system of work, despite the large number of accepted claims in Australia.

Well before this summary report was released several jurisdictions had started to seriously examine their own regulations and operations. Several have identified the need for a code of practice on psychological health and safety risk management, and to include a notification trigger for psychological injury, including arising from exposure to occupational violence or a worker suicide.

If progress to develop model regulations and a national code is not timely, I suspect there is a will at least amongst some jurisdictions to go it alone. Underscoring their commitment, several Australian H&S regulators are investing heavily in workplace mental health; NSW $55 million and Victoria $50 million, for example, and most of the others have smaller dedicated programmes underway.

There are common grumbles in New Zealand and Australia about lack of inspector expertise and consistent compliance and enforcement activity, so it is reassuring that the Work Health and Safety Authorities group (which includes a representative from the NZ inspectorate) is developing specialised inspector training and guidelines to improve consistent applications of rules and expectations around psychological health and safety.

The revised ISO 45001 now includes specific references to psychological health and safety and ISO is planning to develop a psychological health and safety standard.

The probable future tightening of legislation and the very significant investments by the H&S regulators bodes well for the future, at least in the short term. But governments change and priorities shift, so community pressure and lobbying by H&S professionals and researchers will be required to keep the pressure on.

Dr Peta Miller is a researcher at the School of Business, University of NSW, Canberra, and before that was director of policy and research teams with Safe Work Australia. She led the development of national policies, most recently the 2018 national guidance on psychological health and safety.

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