Officers: Time to Sharpen WHS Due Diligence on Psychosocial Risks

Australian safety regulators are sounding the alarm—not on traditional hazards, but on the growing threat of psychosocial risks. Recently, AIHS urged company officers (directors, senior executives, board members) to reinforce their WHS due diligence as work-related mental health hazards escalate. With new and emerging governance standards, inattention is no longer an option.

Why Psychosocial Risk Matters for Officers

Under model WHS laws, “health” includes psychological well-being. Since April 2023, duty-bearers must actively manage psychosocial hazards alongside physical ones. Officers must demonstrate due diligence—actively identifying, assessing, controlling, and reviewing psychosocial hazards.

Directors are legally accountable: “It’s a personal duty”—failure can lead to prosecution.

The Strategic Importance of Governance and Reporting

Psychosocial risks—like job strain, conflicts, harassment, or poorly managed change—are emerging board-level concerns.

Effective governance includes:

• Board oversight: Directors setting tone, resourcing WHS initiatives, and expecting transparent metrics on workload, mental health incident rates, and workplace culture indicators.

• Robust reporting systems: Regularly updating the board on psychosocial risk controls—highlighting both leading (e.g., survey results, hours worked) and lagging (e.g., mental health claims) indicators

• Accountability channels: Clear governance roles integrating HR, WHS, and operations teams to embed psychosocial risk into enterprise risk management

What “Due Diligence” Really Looks Like

The model WHS Act outlines specific steps officers must take—summarised below.

Due Diligence Step	What It Means for Psychosocial Risk
Acquire Knowledge	Ensure familiarity with job design, operational pressures, and mental health incident data
.Understand Hazards	Identify psychosocial stressors: workload, unclear roles, conflict, restructures
Verify Controls	Confirm evidence-based job redesign, supportive policies, consultation, and training in place.
Report Effectively	Guarantee board receives clear, actionable info on risk control effectiveness.
Engage and Consult	Ensure workers have confiPlease make surel ways to report issues early.
Ensure Resources	Allocate people, systems, and budget to manage psychosocial risks.

Emerging Trends & Regulatory Pressures

• Positive Duty under Sex Discrimination Act now overlaps with WHS kinship—officers must ensure workplaces are free from harassment.

• Some jurisdictions (e.g. Queensland, Victoria) require written psychosocial prevention plans and stronger enforcement strategies.

• Regulators are shifting beyond physical hazards to monitor psychological ones actively. Safe Work Australia emphasises integrated hazard management.

Steps for Officers to Act Now

1. Board Education

   Brief boards on psychosocial hazards, current protections, and their oversight role.
   

2. Embed in Governance

   Establish regular WHS dashboard items on psychosocial metrics—for example, mental-health-related absenteeism, EAP usage, and staff engagement trends.
   

3. Integration Across Functions

   Ensure HR, WHS, and executive leadership share responsibility—clear roles and collaboration reduce gaps.
   

4. Implement Risk Controls

   Use the hierarchy of control: redesign roles, strengthen supervision, formalise support systems, and train managers to handle psychosocial risks.
   

5. Monitor and Verify

   Embed psychosocial risks in internal audits, engage assurance providers, and review after incidents.
   

6. Document Diligence Activities

   Keep minutes, board briefs, risk assessments, and review outcomes—all as evidence of compliance.

Final Word: Being a Proactive Officer

Psychosocial hazards aren’t “soft” risks—they carry real, financial, reputational, and legal consequences. As AIHS and Safe Work just reinforced, officers must step up.

It’s no longer enough to hope HR or EAP teams will handle it—governance leaders must drive integration, oversight, and evidence-based approaches.

Lead the change—protect minds like you protect hands and feet.