With most Australian states now having specific regulations for managing psychosocial risks in place, regulators will be responsible for inspecting duty holders to ensure they have safe systems of work in place to prevent psychological injury. So what is required? Join Australian hosts Jason and Joelle as they share what to expect when a psychosocial inspector visits your workplace, and how to be prepared with information to demonstrate you are compliant with WHS regulations. Download the cheat sheet here: https://psychosocialriskassessment.com/download-the-psychological-health-safety-cheat-sheet/
Inspector Webinar
Jason van Schie: Hi listeners, Jason here. Today for you, we’ve got an Expert Series podcast with a twist. Joelle and I have been delivering a series of webinars on what Australian companies need to have in place to meet their legal obligations under new psychological health regulations.
As all three of the webinars were sold out, there were many disappointed to miss out, so we recorded the last of these webinars and are now pleased to share it via the Psych Health and Safety Podcast.
In this webinar, we refer to a downloadable cheat sheet, a link to that is provided in the show notes. We have to bring in more exclusive content like this in the near future. Now onto this episode.
Introduction: From FlourishDX. This is the Psych Health and Safety Podcast. With workplace mental health becoming a safety prerogative, this is the source of information on psychological injury prevention and health promotion.
Jason van Schie: Welcome along everyone today to this latest webinar from FlourishDX, I’m glad that you could all join us today and give us some of your valuable time.
Before we get underway with introductions, I just want to do a quick welcome to country.
So, I’d like to acknowledge the traditional custodians of the land that we’re on today, the Kvichak people. Joelle and I calling in from Perth today and pay my respects to their elders’ past, present, and emerging.
In terms of today, I’m going to just introduce myself quickly and then I’ll get Joelle to introduce herself. And then we will just take you through a bit of a synopsis before getting into it.
So, for those I haven’t met before, my name’s Jason van Schie. I’m the managing Director of a FlourishDX. I’m a psychologist and I’ve been working in the human factors space for about 15 years now, with a specific focus on psychosocial risk management for about six or seven years now too.
With me though we have our internal subject matter expert on regulations which is perfect for the topic that we have today, Joelle Mitchell. So, Joelle, welcome.
Joelle Mitchell: Thank you.
Jason van Schie: So, if you could just maybe give a quick introduction.
Joelle Mitchell: Sure. So, I’m the Global Head of Psychological Health and Safety here at FlourishDX. The reason that I’m on this call is before I joined FlourishDX I was working with NOPSEMA, which is the regulator for the offshore petroleum industry here in Australia. I was employed with them for nine years as a human factors specialist in their safety and integrity division, so that’s why I’m speaking about what you can expect if a psychosocial inspector comes to visit.
Jason van Schie: Yeah, and you’ve definitely done your first share of inspection, so I think it will be very relevant. And hopefully, there’s a few people from the different inspectorates around Australia getting some notes from you today as well about some of the questions I should be asking.
Joelle Mitchell: I’m sure they don’t need that. I just hope they don’t tell me off afterwards for giving incorrect information.
Jason van Schie: Well, they haven’t so far from the first two runs of this webinar, so I think we’re good. So, look, just for those people who are jumping on essentially, we’ve got one hour with you today, we’ll be finishing up at the hour.
Joelle and I will be talking for about 50 minutes taking you through a number of practical things you should be considering to have in place and to be able to evidence, should you have a psychosocial inspector visit, and then we’ll be opening it up for formal Q&A.
Now, just because we’ve got a formal Q&A section at the end, don’t feel that you can’t ask questions during, so if you have any pertinent questions as we go through, Joelle and I are pretty good at keeping an eye on the chat, so just drop your questions in the chat and we’ll try and pick them up as we go if we can. What you’ll notice on a number of the PowerPoints today is that there is a QR code.
The QR code is to our cheat sheet, which is a one-page downloadable resource, which has 10 questions that you should be asking yourself as an organization whether you have these things in place and whether you can evidence them.
But what we’re going to be doing today is actually going through each of those in turn, talking about why they’re important and giving you some examples of how you can provide evidence that you are doing those activities. Cool.
So, in terms of just before we get into it, for those of you who aren’t familiar with FlourishDX, essentially, we’re an end-to-end provider of psychological health and safety services.
What we do is that we blend consulting with people like Joelle and Alicia, who’s not on the call today, and myself and others with education and technology to help our clients to achieve a psychologically healthy and safe workplace that prevents harm to employees and promotes the opportunities for them to flourish at work.
We also do a lot of education beyond these webinars. If you’re not familiar through our podcast channel– the Psych Health and Safety Podcast– Joelle and I have been phoning it in lately because we’ve got ourselves a couple of UK co-hosts who will do alternate fortnights with us.
But what you’ll find is we’ve been doing that podcast for over two years, we’ve had over a 100 amazing guests on that podcast, so if you are new to the area of psych health and safety, and you’re seeking to educate yourself, then this is a really great resource with a very large back catalogue of our episodes to get into.
Joelle Mitchell: I don’t agree that we’ve been phoning it in, Jason. We just don’t have to do them as frequently.
Jason van Schie: Yeah, we never phone it in.
Joelle Mitchell: No. Well, sometimes we do, but that’s got nothing to do with our UK hosts.
Jason van Schie: You know me, I never use terms inappropriately or incorrectly, Joelle, so apologies for the mistake.
And apologies to listeners for my co-host and her shenanigans, but look, in terms of setting the context, as many of you’re aware, we have been going through a period of regulatory reform here in Australia to bring psych health and safety up to the same level of as how we manage physical health and safety.
This goes all the way back to the review done by Marie Boland of the Workplace Health and Safety Act in 2018, we’re out of 34 recommendations.
The second one was, “Hey, we need regulations dealing specifically with psychological health.” To be very clear, the new regulations do not actually bring about a new obligation for employers. These obligations were always contained in the existing Workplace Health and Safety Act from 2011.
However, a lot of organizations didn’t feel or didn’t interpret the definition of health to encompass both psychological health as well as physical health, even though that was definitely the intent.
And so now what we’ve seen is that we’ve got very specific regulations that are in place in many states in Australia, as you can see from this diagram where now it’s very explicit. These are the obligations you have if you employ people to keep them safe from harm– psychological harm in particular.
So, most states in Australia now have adopted the model regs. Northern Territory will adopt on the 1st of July. We’re still waiting on timeframes from South Australia, Victoria, and other ACTs for when they’ll have either the model regs or equivalent regulations if we’re talking about Victoria, which is not part of the harmonized legislation framework in place.
But we have heard that, it is likely within the next three to six months that every state in Australia will have psychological health regulations in place. So, with that in mind, we know that the regulators are arming up, and it might just be the echo chamber and who I follow on LinkedIn that I’m seeing a lot of advertising from the various regulators looking for either psychologist to join their team as subject matter experts or psychosocial inspectors specifically to help enforce some new regulations.
So, we thought with that in mind given that we’re going to be seeing a lot more activity and a lot of people just being unaware of what they need to have in place and what sort of questions the regulators are going to be asking that this session would actually be really relevant and pertinent to what’s going on in Australia in particular at this point.
So, before we start going through the 10 questions that we’ve got within the psych health and safety cheat sheet, I thought we might just do a quick poll question of the room to see how prepared people are for a visit from a psychosocial inspector.
So, if you have a look at the poll we’ve got here today, the question is, how prepared is your organization for a visit? And that might range from we would fail miserably all the way through to that you are actually doing all the activities that you’re required, and you can evidence that.
So, just have a think about how your organization would respond to that at this point in time. Okay, so from 68 people who have responded to that poll, it looks like the majority of people, the vast majority of 57% are doing some required activities and can provide evidence.
So, missing out on some, there are two people who look like they’re very well covered who are doing all required activities and can provide evidence. So, as always, we’d be very interested to find out who those people are at some point, and we’d love to invite them on the podcast to talk about their experience.
Then an evenly split between doing some relevant activities but don’t have the evidence, so definitely then today’s session talking about “What does the evidence actually look like?” is going to be relevant to you, and then many that are unaware of what they would need to see.
So, again, the cheat sheet’s going to be very valuable and going through this webinar as well. Any commentary on that, Joelle?
Joelle Mitchell: Yeah, again, probably a similar pattern to the last couple of these that we’ve run.
And yeah, I think just every time I mentioned the selection bias where we’re likely to see people coming along to these sessions who are already engaging with this topic and understanding that they’re needing to do something.
So, I think we’ve probably got a bit of a skewed response here than if we were looking sort of across all businesses in Australia.
Jason van Schie: Yeah, I would hope if we’ve got regular attendees of our webinars and listening to other podcasts that they would have a fair bit of knowledge and hopefully had done some actions internally already. We know that Mel definitely has from Barasa, Flora, yeah.
Well, we know that shouldn’t be email though. You’re close, you’ve got a lot in place which is great. All right, so let’s think then about this cheat sheet.
So, first of all, what we did was, we’ve been looking obviously regularly at the different information that the regulators have been sharing regarding what they’re expecting of PCBUs, so Persons Conducting Business or Undertakings.
We obviously have some great relationships with many of the regulators having actually been on our podcast as well. And then just reviewing the regulations themselves as well as the broader Workplace Health and Safety Act to consider what are the things that you need to have in place from a psych health and safety perspective and how would you go about evidencing that?
We’re also able to draw on Joelle’s experience, obviously being an ex-regulator herself with nine years experience in the human factors area. So, what I’ve got here on this page is the 10 activities that are listed in the cheat sheet.
So, what we’re going to do is go through these in turn, talk about why they’re important, and Joelle is going to give us some context around that, and then also give us some context around what would evidence look like in this space.
So, you can see the very first one that we’ve got here is a documented process for consulting with workers to identify psychosocial hazards, understand exposure and develop control measures.
So, first of all, if we talk about not just ticking the box, but why would that be important in order to achieve the aims of the regulations?
Joelle Mitchell: Yeah, so there is a primary duty under the Work Health and Safety Act to consult with workers who are impacted by, or likely to be impacted by hazards.
So, that’s a requirement under the act, which is a stronger instrument than the regulations, and that’s not just about psychosocial hazards, that’s relating to all hazards. When we’re talking about psych hazards, the consultation process is really critical because there’s an interaction between, I guess the presence of a work factor that may or may not be a hazard, and whether or not it’s a hazard largely depends on interpersonal factors for an individual as well as the presence or absence of other psychosocial factors in the workplace.
So, they’re a little bit different to physical hazards where we know if we fall from a particular height this is going to be the likely impact on the human body. And our preference for working at height isn’t going to have any effect on the impact that that fall is going to have on our body. Whereas we know that some people will have a preference for a higher workload than others.
Some people prefer to have a good amount of, or a high amount of autonomy in their role, and some people prefer to have very explicit rules and steps and processes to follow. So, there’s a lot of room for individual difference when we come to talking about psychosocial hazards.
So, we really do need to have broad consultation across the workforce to actually understand where we have these psychosocial factors present in the workplace, but are they actually hazards in that? Are they causing distress? Do they have the potential to cause harm to our workforce?
Jason van Schie: Yeah, so in terms of the different approaches you can do top-down right versus bottom up, so maybe if you could just explain the difference, I mean, I think you talked about.
Well, they’re explained, why we need to consult an individual level. But would a top-down risk assessment be enough for a regulator to look at and go, “Yeah, you’ve done your bit?”
Joelle Mitchell: So, I mean, a top-down risk assessment is generally where we would look at the activities that are going to be conducted, identify the hazards associated with those activities, and then decide what are the control measures that we need to reduce risk associated with those hazards.
So, workforce consultation in that type of a scenario would typically involve having the health and safety representatives from the relevant designated work groups participating in that risk assessment and contributing to that.
So again, that approach when we’re talking about psychosocial hazards probably isn’t as effective because again, the individual level factors, your health and safety representatives aren’t necessarily going to have good insight into how the members of their designated work groups are feeling about different hazards, they may, but they may not.
And they’re not likely to have as good an understanding of the risks associated with psychosocial hazards for the members of their work group. So yeah, that typical top-down approach is probably going to be less useful, less accurate, less robust when we’re talking about psychosocial hazards.
Jason van Schie: Okay. So, what would a good consultation process look like, Joelle?
Joelle Mitchell: So, a good consultation process would really look like engaging with as large a portion of the workforce as you can and making sure that you are getting insights from different segments of the organization because we do often see that different roles, different functions, and I guess different employee demographic groups, we’ll have different hazard profiles within an organization.
And so, I guess the more employees we can get involved in that consultation process, the better off it’s going to be. And in terms of the types of processes you can use, we’ve got, I guess, quantitative approaches where we can use surveys and those types of tools, or we’ve also got qualitative methods where we can do focus groups and interviews and combinations of those as well.
Jason van Schie: Yeah. And so then how would an organization evidence that they’ve done sufficient consultation?
Joelle Mitchell: Yeah, so you would essentially have if you’re doing surveys, you would be able to have sort of the number of responses and map the employee demographics so that you can show that you’ve got representation across the different sectors of your organization.
If you’re doing focus groups, you would take sort of attendance lists and again, you would then be able to show the representation across the organization. You would also take or make records of the communications involved in trying to engage employees in that consultation so that you can show that all employees or a representative group of employees have been invited to engage in consultation.
Jason van Schie: Yeah, I think that’s pretty straightforward. So, if we move to number two, then it’s fairly similar to number one. So, a documented process for consulting, coordinating and cooperating with other duty holders with whom the PCBU.
So again, Person Conducting a Business or Undertaking has a shared duty in relation to psychosocial hazards. But I guess to unpack that one, who are the other duty holders within an organization in relation to psychological health?
Joelle Mitchell: Yeah, so other duty holders are people who aren’t part of your organization, but who you will need to interact with as, as the PCBU. So, they might be sort of third-party contractors that you bring onto your job site suppliers, it could be clients, it could be your building management, it could be other tenants that you’re sharing a workspace with.
So yeah, just essentially any other entity that your workforce is going to be required to interact with or is going to have the potential to interact with during the course of their work.
Jason van Schie: Yeah. And beyond what we’ve talked about in terms of survey, records, focus group, attendance sheets, that sort of thing, is there any other documentation that might be required for this process?
Joelle Mitchell: So, this is quite a different process because we’re not. What we’re doing here is saying we have a shared duty because we are all PCBUs, and so in this particular location, we all share these particular duties.
And so, we need to have plans in place between us to be really clear about who’s going to do what, how each of us are going to discharge our duties, and making sure that nothing’s falling between the cracks and making sure that there is alignment where there needs to be alignment where there’s interactions.
So, for example, if we’ve got suppliers making a delivery to a warehouse, for example, it’s around the introduction of psychosocial hazards. There may be around behaviours and sort of different acceptable standards of behaviour between the two organizations, and so coming to agreements about how those workers are going to interact with each other in those scenarios, it might be related to workload, so looking at balancing workload for when those deliveries are scheduled versus sort of the competing demands on the warehouse employees, for example.
So, look, looking at those types of things, so where are the interfaces where we do both have that duty and how are we going to make sure that the approaches or the controls that we have in place to manage that duty don’t conflict?
Jason van Schie: Yeah, okay. So, what sort of evidence would the inspector be asking for if they were to come in and say, can you demonstrate that you’ve done this?
Joelle Mitchell: Yeah, so you would want to see essentially evidence that you’ve met with so, you’ve identified all of those shared duty holders that you’ve had some sort of a meeting with them that could be an agenda with attendees and then sort of action items and sort of what’s been agreed by who and then an action plan and sort of showing progress against completion of that action plan.
Jason van Schie: All right, terrific. Again, moving on to number three, documented key psychosocial hazards for the whole organization and specific teams. So, if we unpack that one, what is a psychosocial hazard to start with, Joelle?
Joelle Mitchell: Yeah. Probably should have started with that. So, a psychosocial hazard is anything in the design management or social constructs of work that have the potential to cause stress or psychological harm.
Jason van Schie: Okay. So, some examples of that would be things like workload, job control, or lack of autonomy, poor supervisor support, lack of role clarity things like that, right?
So, anything that can cause either significant levels of stress or distress or things that are ongoing kind of levels of distress that have the potential to cause harm over time.
Joelle Mitchell: Yeah, so I guess we’ve got sort of the big ones that we know are likely to cause significant distress on a single exposure if we like, so bullying, harassment, violence those types of things. And then we’ve got others that will tend to have more of a cumulative impact over time.
So, yeah, I guess being aware that there are kind of those different severities of hazards as well.
Jason van Schie: Yeah. So, we have here documented psychosocial hazards for the whole organization and specific teams. Why would it be important when it comes to psychosocial hazards to document them separately rather than just have at a company level? These are our main hazards.
Joelle Mitchell: So, I mean, depending on your organization if you are reasonably large and have any level of complexity, the likelihood is that different teams are going to have different hazards that they’re exposed to.
And whether that’s, you’ve got sort of some teams who have interactions with customers or clients for example, that exposes them to the risk of things like occupational violence and that kind of thing. Whereas we could look at again– sort of from the global perspective– bullying, harassment, those things are kind of constant hazards.
But yeah, different occupations or roles will have different hazard exposures. So, it’s important that we understand what those are for different teams so that we can have appropriate controls in place to address those hazards for those groups who may be at a greater risk of hazard exposure.
Jason van Schie: And in our chat, Sue’s actually shared a similar example where it’s customer aggression that is one of their key psychosocial hazards that they’re concerned about for their digital mental health service. We’ll come back to what sufficient controls might look like for something like that later when we get up to that point in the cheat sheet.
But it’s important to understand that even when things are very obvious, so if you’re like in first response or if you are in things like content moderation or anything with direct customer or community interaction, like Joelle was saying, we’ll be aware of some significant hazards, but often it’s the bureaucratic hazards, if you like, the run of the mill stuff like workload or unsupported boss that can also have the potential to cause harm.
So, we shouldn’t just look at those big-ticket items that Joelle was talking about, but we also need to consider some of those other things that can have the potential to cause harm. And so how would we document the psychosocial hazards for different parts of the organization?
Joelle Mitchell: So, it should really come through the consultation. So, basically as you’re doing that consultation, you’ll identify what the hazards are and it’s just a matter of recording those, whether that’s in minutes or if you’re having it sort of through a survey, then you’ll have your survey report that captures that. So, I think just your usual methods of recording that type of information.
Jason van Schie: Yeah, for sure. Okay, so number four is demonstrate consideration of the severity, frequency, and duration of psychosocial hazard exposures and how various psychosocial hazards combined to increase risk in determining control measures. So, there’s a couple of things there.
So, first of all, why is it important to consider severity, frequency, duration of psychosocial hazard exposure?
Joelle Mitchell: So, again, this comes back to the nature of psychosocial hazards, and I guess how they’re different to a lot of physical safety hazards. So, as we’ve been talking about, we do know that a lot of hazards have cumulative impact over time.
So, it’s a little bit like understanding the risk of industrial hearing loss, for example. It’s not just exposure to noise. We need to know, “Well, yeah, how loud is the noise that someone’s going to be exposed to potentially.”
But we also need to know how frequently they’re going to be exposed to it and how long the noise is going to last before we can come up with an indicator of whether that person is at risk of hearing loss or not.
And so, the same then can be said for psychosocial hazards that a one-off experience of your boss having a bad day and being a bit abrupt is probably fine, but if you’ve got a boss that’s just consistently rude and dismissive and doesn’t listen and doesn’t have time to give you the support you need that’s going to gradually erode away and have a greater impact on your mental health than just a one-off instance.
So, we do need to look at those three data points to get a good understanding of where there is actually risk to somebody.
Jason van Schie: Yeah, another good example we like to use there is you could work 60 to 80 hours in a week and you could be quite exhausted by the end of the week, but not have a psychological injury.
But do that for weeks or months on end, and that greatly increases the chances that that will turn into burnout or a more significant psychological injury. What about then why is it important to consider how various psychosocial hazards combine?
Joelle Mitchell: Yeah. well, again, because they’re tricky things– psychosocial hazards or the factors I guess rather than hazards– sometimes they can actually be protective or promoting of mental health, and sometimes they can be harmful depending on how they combine.
So, if we take work overload as an example when work overload or high workload rather is combined with high autonomy and good supervisor support a lot of the time when people have that type of a working environment, they are able to experience what we would call flourishing, which is a state of positive mental health where they’re sort of inflow and they’re really enjoying their work and they’re doing very well.
If we took work overload and combined that with workplace incivility and low autonomy, that’s sort of the ingredients for burnout. So, really we can see there one work factor high workload that can actually be a positive or a negative depending on how it’s interacting with those other hazards, as well as how it’s interacting with individual preferences.
Jason van Schie: Yeah. So, we know with psychosocial hazards, they can combine to create greater risk more so than a lot of physical hazards. So, if you think about things like working at heights, working in confined spaces, trip hazards that can all be mutually exclusive.
Whereas with psychosocial hazards, they tend to, like you say, interacting combined and to cause the risk, the potential of harm, yeah. So, how then do we go about documenting that we’ve considered these things, Joelle?
Joelle Mitchell: So, I think that’s probably where things like your existing risk management documents come into it. And so, populating those your hazards into your risk register, for example.
But again, I guess the evidence that you’ve considered that you would need to do that generally through focus groups would be the main way that people could currently do it outside of using the tool that we’ve developed in FlourishDX.
Jason van Schie: Yeah. So, we’re pretty excited about that new tool. In fact, the next webinar series that keeps off from next week, we’ll discuss I guess our multi-year process that we’ve been going through to develop a tool that looks at severity, consideration of psychosocial hazard exposure, and then using machine learning to look at the various interactions of different hazards a
nd how that can combine to cause risks.
So, very exciting because I would argue that that is actually the first true objective psychosocial risk assessment in market, so please join us for that webinar if you haven’t already registered.
Okay, number five though, do consideration of the aspects of work and worker demographics that influence risk of psychological harm. Okay, so what sort of worker demographics should we be mindful of here?
Joelle Mitchell: Yeah, so what we’re thinking about there are groups of workers who are known to be more vulnerable to psychological ill health or more vulnerable to particular types of psychosocial hazards.
So, if we’re thinking about young workers women, LGBTQI+ disabled workers, so those sorts of cohorts who we know are likely to, I guess have particular presentations of hazards, experience hazards with greater frequency and severity and just have additional challenges sometimes in addition to managing those hazards.
Jason van Schie: Yeah, and how do we document that?
Joelle Mitchell: So, I think that that’s sort of identifying who those workers are and making sure that if we’ve got either qualitative or quantitative data that we’re collecting around risk exposure or hazard exposure making sure that we’re able to capture the hazard exposure experience of those different workers.
Jason van Schie: All right, terrific. Okay, number six– we’re just past the halfway point– documented controls at the organization level and team level to reduce risk to ALARP. So, first of all, what’s ALARP?
Joelle Mitchell: ALARP is As Low As Reasonably Practicable, and that basically means that whether or not something is reasonably practicable is basically looking at what would be the cost of introducing this control and compare that to the risk reduction that that control would offer.
And if there is gross disproportion between the cost versus the risk. So, if the cost is grossly disproportionate to the risk reduction, then you would say that the risk is already reduced to ALARP.
Jason van Schie: Yeah. Okay, terrific. So, when we consider controls, this is something I guess that the regulators have been very vocal about.
You can think about the hierarchy of controls, and when we talk about the hierarchy, we’re talking about the most effective controls being most effective way to deal with a hazard is through elimination. If we get rid of the hazard altogether, there is no potential for harm.
And if not, then we need to think about introducing controls ranging from things like job redesign through to administrative controls, through to PPE. So, in relation to I guess, psychosocial risk controls, what would they generally look like and where would they be documented for an organization?
Joelle Mitchell: Yeah, so I think just to clarify, the model regs say that you don’t need to use a hierarchy of control. Queensland and the Commonwealth regulations have excluded that particular clause, so you do need to apply a hierarchy of controls for your psychosocial hazards. And the regulator in Queensland in their code of practice have explained that work redesign is equivalent to a substitution control.
So, essentially what we’re talking about there in work redesign is we’ve identified that there’s a system of work in the organization that that’s contributing to distress.
So, let’s say that it’s our annual performance appraisal process, maybe it’s really opaque, people aren’t clear on what their performance objectives are. And the process by which people are evaluated isn’t clear, isn’t transparent and people don’t feel like they have the ability to influence that in any way.
And so, to reduce the levels of distress associated with that, we would look at redesigning that process to improve transparency, to improve sort of opportunities for employees to have input into it, et cetera.
And so, what we’re doing there is we are taking a system of work that we know is creating harm and we’re substituting it with a system of work that is less likely to create harm.
Jason van Schie: Yeah. And I guess, so that’s a really great example of work redesign or actually addressing the psychosocial hazard at that substitution level like you say.
And the regulators have been quite vocal in most states about saying things like training and policies aren’t going to cut it, and they shouldn’t be seen as supportive controls alongside work redesign or elimination strategies.
Joelle Mitchell: Yeah. And in the draft Victorian regs, we’ve actually seen them explicitly say that work redesign must be your primary control and you can then augment or support with training and administrative controls, but that you need to be looking at work redesign as your primary control.
Jason van Schie: So, we typically would see those documented controls within the company risk register. And most risk registers I’ve seen particularly over the last few years, you’ll have your key hazards and it might just be psychosocial hazards is like dehazard and that’s it for the organization. And then they’ll have things like EAP and bullying harassment policy.
So, we see some very low level in terms of effectiveness controls and more administrative or PPE-type controls I would argue. So, that’s something that looks like it needs to be improved for many organizations in this new era.
Joelle Mitchell: Yeah. And look, EAP is typically a mitigation control, not a prevention control as well so it’s important to not only look at the hierarchy in terms of effectiveness but also whether it’s designed to prevent harm or whether it’s designed to limit the severity of harm escalation once that harm has occurred.
And so usually the EAP is something that people will contact once they’re already in some level of distress.
Jason van Schie: Yeah. If you think about a physical health analogy, it’s like giving people three to six sessions of free physio because they work in a job that requires manual labour. It doesn’t prevent the harm from occurring, it helps people get quick treatment if they start to see some symptoms.
Joelle Mitchell: Yes.
Jason van Schie: Yeah. All right, so that’s number six.
Number seven demonstrated controls applying work redesign, not simply admin policy controls. I guess we’ve talked through that one in number six, so we talked about the importance of that, and again, that might appear in your risk register.
Also thinking about though, Joelle, one thing that we picked up earlier is that you might have company-level controls, but you might also have team-specific controls.
So, again, it might be role-specific hazards, like we talked about customer-facing roles versus office space roles where there is no customer-facing responsibilities might be things like first responders. So, we need to think about not just organization risks, but team-specific risks potentially.
Joelle Mitchell: Yeah. And again, that comes back to that initial process of hazard identification and risk assessment that you’ve conducted, where you do have that information about different team exposure so that you can actually target your actions or understand what are the actions that are required by exploring those results with the team and understanding actually what are the drivers and enablers of this hazard manifesting, and then really target your interventions at those particular things.
So, it might be like a team-level intervention, it might be an organizational-level intervention, it really depends on the outcome of that exploration.
Jason van Schie: Yeah, did you want to pick up that question from Carolyn? Should just be a quick response.
Joelle Mitchell: Yeah. So, far as, is reasonably practicable, as low as is reasonably practicable, they just appear in different forms depending on the act that you’re looking at.
Jason van Schie: Yeah, but I guess they can be used interchangeably for the purpose of today. All right. Number eight, documented assessment, evaluation of controls to determine their effectiveness. So, first of all, why is it important to evaluate controls?
Joelle Mitchell: Well, because we need to know whether or not they’re doing what they’re designed to do. That’s how we demonstrate that we’re reducing risk if you’re putting that in.
Jason van Schie: You’re looking at me like I’m an idiot, Joelle. I’m just doing it to make the listeners aware.
Joelle Mitchell: How you’re interpreting my facial expression is on you, Jason, not on me. Yeah, so look, if we’re not able to show that our controls are effective, then we’re not able to really show that we are reducing risk. I mean, we can reassess, and that can be a way of showing that our controls are effective.
So, by sort of redoing our consultation after we’ve implemented those controls and, and given them sufficient time to take hold, we can actually evaluate them by reassessing and saying, “Yeah you know, based on these results, that indicates that the controls that we’ve put in place have been effective.”
And we can also do other types of evaluation as well, like we would for a training program, hopefully. You know, if you’re sending somebody for a particular competence uplift then typically there is an assessment of competence at the end of that. So, you’re able to evaluate whether that was actually effective or not.
Jason van Schie: Yeah. And if you have regular or periodic risk assessments or hazard identification processes in place or building them then yeah, you can definitely compare how you’ve gone in one assessment versus the previous one to see if the controls are been effective or not.
And then you have the documentation there as well. So, it’s a fairly easy one if you are going through this process of continuous improvement. Psychosocial risk assessment is not a one-off activity we’re supposed to put controls in and then continue to evaluate those controls and whether in fact, any other hazards have emerged in the interim. Cool! Documented timeframe and process for reassessing psychosocial hazard exposure.
So, first of all, what is the sort of timeframe that companies need to consider or is there more to think about than just a specific timeframe?
Joelle Mitchell: Yeah, so this sort of comes back to the duty to have a safe system of work, and that comes under the act, not the regs. So, this is around saying it’s not enough just to do a single consultation at a single point in time and put some things in place and leave it at that, this needs to be consistent with your risk management cycle of iterative improvement.
So, we do need to have timeframes in place for when we are planning to reassess our psychosocial hazard exposure. But there are also triggers in the legislation that sort of require you to redo your risk assessment, for example in relation to significant organizational change when new hazards or risks are identified when it becomes apparent that your existing controls aren’t effective when a health and safety representative requests it.
There’s probably a couple of others that I can’t remember at this point in time but they’re the same triggers that exist for, I guess your general physical health and safety hazards and when those risk assessments need to be redone.
But it’s also a good idea to have sort of, I guess, a regular periodic reassessment. How frequently you want to do that, really depends on your organization sort of how volatile is the broader environment around your organization, how volatile is the internal aspects of your organization.
So, there’s just a lot of individual or organization-specific elements there to consider when you’re determining how frequently you should be doing that.
Jason van Schie: Yeah. And how would a company go about documenting that?
Joelle Mitchell: That would be in probably your suite of documents that detail your risk management processes. You would have sort of detailed in there, what are the triggers for needing to redo this risk assessment and otherwise, what is the periodicity that we’re going to do this?
Jason van Schie: Did you just make up a word?
Joelle Mitchell: No.
Jason van Schie: That is okay. I’m going to Google it later.
Joelle Mitchell: No, it’s a word that I’ve heard other regulators use in my nine years of previous work experience, so I didn’t make it up, but somebody else maybe did.
Jason van Schie: Yeah.
Joelle Mitchell: But all words are made up if you really think about it.
Jason van Schie: This is true. All right. Number 10, records of information, training, instruction and supervision provided to workers that is relevant to their role in relation to psychosocial hazards, hazard identification and control measures.
Now, I haven’t seen this in the model regs, so where does this come from, Joelle?
Joelle Mitchell: That comes from the act.
Jason van Schie: Okay.
Joelle Mitchell: So, again, it’s not specific to psychosocial hazards. We have a duty to make sure that we’re providing workers with information, training, instruction and supervision to enable them to be able to do their role and to enable them to do their work in a way that’s safe and without risk to health.
So, having records of how we’ve done that is just an easy way to, again, show that we are compliant with that. It’s also a good way for us to recognize whether there are any gaps so we can actually look across our workforce and say, “Okay, well these people actually haven’t received this particular training or instruction and so we need to fill that gap.”
So, it’s just a good way of maintaining your own line of sight across that particular requirement.
Jason van Schie: Okay. It looks like Megan’s got your back as well. Periodicity is a noun and she’s given a definition, so well done.
Joelle Mitchell: So, there?
Jason van Schie: So, there, yeah.
Joelle Mitchell: No.
Jason van Schie: This is why you’re the subject matter expert. I’m not just regs, but also English language, yeah.
Joelle Mitchell: It’s true actually, I am the go-to person in the office whenever there’s a challenge about word usage.
Jason van Schie: Like greenage. Okay, so hopefully that for our listeners here has provided a bit more context in terms of the sorts of things that they need to have in place.
And obviously, if they’ve downloaded the cheat sheet then it gives them the context beyond why each of these things are included and some broader explanation of what they need to think about with each of these activities. Before I put up the next poll question, Joelle, anything else to add?
Joelle Mitchell: I don’t think so.
Jason van Schie: Okay, no worries. So, now that everyone’s aware, I guess, of what I guess needs to be in place from ACT and regulations perspective in relation to how you’re managing psychosocial hazards and their risks. It’d be useful for you to reflect on then what you feel your largest gap is. So, this goes through the key one so it could be consultation with workers, it might be psychosocial hazard identification at an organization level, it might be the team level.
You might still be struggling with how you’re going to consider hazard exposure so that’s severity, frequency, and duration. Those documented controls that are required following that risk assessment process, monitoring plan or training and education for relevant personnel, which is everyone, I guess, so let’s have a look.
Joelle Mitchell: That’s pretty even.
Jason van Schie: Yeah, I have not seen a poll like that before, that might be one to share on LinkedIn later. So, everyone has identified all of them as largest gaps. So, take from that what you will. Joelle, how would you comment on that one?
Joelle Mitchell: I guess we could say that different organizations are focusing on different things and everyone’s got different challenge areas.
Jason van Schie: Yeah, thanks Mel, shows the diversity.
Jason van Schie: And Estelle said that there was definitely more than one there that she could have chosen from. Yeah, so look, we do know, and that’s obviously why we’re doing these education programs, the webinars and the podcasts and all the rest to try and provide a broad range of education because there’s obviously lots of gaps. This is new territory for a lot of organizations as they seek to apply their psych health and safety processes to psychosocial, so interesting.
All right, so just quickly before we open it up to some other Q&A, if you do have any questions to drop them into the chat now, just briefly, obviously we’ve been working in this space for a number of years now, Joelle and myself, even before starting the FlourishDX journey, and we have been busy in over the last five years in particular building out a suite of resources, both consulting, education and technology to help companies at scale to address all of the things that we talked about today. So, if you do have a challenge, then obviously reach out, you’ll find us on LinkedIn.
And also, like I mentioned, we do have another webinar commencing Thursday next week and we’ll be running it two more times after that over the subsequent weeks on using new technologies to predict risk through hazard identification and consultation with the workforce, so there’s a QR code to access that.
All right, so let’s see, was there any questions that you saw, Joelle, that came up in the chat that we could answer in the last five minutes that we’ve got today with the group?
Joelle Mitchell: Yeah. So, Natalie has asked if we’ve got a comparison of different regs for each state or territory. So, I’ve done a review of the regs that are currently in force across the different states and as it’s literally, the only difference is the one that I mentioned earlier around whether or not you need to use the hierarchy of controls when you’re addressing psychosocial hazards.
And so, Queensland and Commonwealth are requiring the use of the hierarchy of controls, the other states who have the regs in force do not require the hierarchy of controls, so that’s the only.
I think there’s one other regulation that has some slightly different wording as well, but that’s sort of as a consequence of the hierarchy of controls regulations. So, that’s literally the only difference across the states in terms of the regs
Jason van Schie: The draft ranks and Vic have also got the reporting requirements.
Joelle Mitchell: Yeah.
Jason van Schie: Requirements in drafts.
Joelle Mitchell: Yeah, they’re not in enforce so we don’t know what they’re going to look like. The Victorian regs do look significantly different to the model regs. But yeah, until we actually see the final version of those, we don’t really know what that’s going to end up looking like.
Jason van Schie: Yeah. And we do know that WorkSafe Victoria have done their bit and really it’s just a ministerial decision now about when they get put into force, like you say. All right, was there any other questions?
So, we got one from James. Was that a question or a comment? Oh no, here we go. Yeah, so James says we have found that we have a lot of intersecting risks in risk ridges which are both physical and psychosocial aspects.
So, musculoskeletal would be a good example of that. Thoughts on having these listed as discreet psychosocial risk versus incorporating into the same risk?
Joelle Mitchell: Look, I think that if we’re looking at targeting our control measures to work redesign then it’s, I think, useful to combine them when you’re looking at, “This is the outcome that we’re seeing and this is sort of the cluster of hazards that are contributing to this outcome or this risk of this particular outcome. What is it that’s causing this cluster of hazards to present in the way that they are and cluster in the way that they are?”
So, it does actually make sense I think, to group those together and actually target your interventions at that. Again, whatever are the organizational drivers that are actually leading to that cluster of hazards presenting, so I think that that’s a really targeted approach to take. And I think that that’s useful but then you still do.
Also, I think need to take that wider view especially when we are looking at those bullying, harassment, violence-type hazards and also addressing those as individual hazards.
Jason van Schie: Yeah, terrific. Mel has confirmed that because she’s based in South Australia, she’s heard the regulator there say that they will have something in by the end of the year.
So, good to get that confirmation from someone local. Roomi has asked, “Could we get a list of the different types of evidence we can use?” Sounds like work, Joelle.
Joelle Mitchell: Yeah.
Jason van Schie: Maybe we can do another webinar on that.
Joelle Mitchell: Different types of evidence
Joelle Mitchell: Might need more clarity on that.
Jason van Schie: Yeah, I mean we have talked about and tried to give some examples of the different types of evidence for the 10 different activities that are on the cheat sheet. We will be releasing this for our normal EDM on Tuesday as a special podcast episode. So, you’re welcome to re-listen back and write that down or might need a transcription of this one, Joelle, so people can find it easy in the text. We’ll see what we can do.
But we haven’t got them all documented down though but definitely within our platform– the FlourishDX platform– that if you use it as intended, then it does document a lot of those things that you do require.
Okay, one last question from Kate, “How can we focus on work groups during risk assessment in a small site where data is hard to make anonymous?”
Joelle Mitchell: So, I suppose in that situation where you can’t collect anonymous data, it can be useful to use a third party to do that if you’re doing, I guess qualitative work. Yeah, if you’re using a third party as sort of intermediary there, then they’re kind of collecting that data and reporting it up so they’re still able to report it up in a de-identified format.
So, I think that that’s probably the best approach to take in that situation. If you don’t have enough people to be able to anonymize quantitative results then yeah, having a third party come in and run a focus group would be the best way to do that if you feel that the workforce want that anonymity to be able to feel that they can speak freely.
Jason van Schie: All right, do we have time for one more question, Joe?
Joelle Mitchell: Well, we’ve got one minute.
Jason van Schie: All right, so the last question then, that was the last question, this is now the last question. “When assessing where psychosocial hazards may combine, is it best to identify this combination from assessing the activities or roles through a risk assessment or is there a more effective approach to assess this?”
Joelle Mitchell: Yeah, so this I think is really comes through your qualitative consultation. So, our recommended approach after you’ve done a quantitative data collection is to then follow up at exploring particular at-risk groups.
And so that’s really where you’re going to get that better understanding of what are the combinations or how are these hazards combining and, and impacting our workforce.
Jason van Schie: Okay. Hopefully, that was a suitable response. Yeah, thank you. Okay, I think we’re done.
Joelle Mitchell: Thanks for your confidence in me, Jason.
Jason van Schie: All right. Well, everyone, thank you again for joining this webinar. We are on a cadence of doing this pretty much weekly, we’re just trying to fit them in around other client work that we do and we do promote them through our EDM. If you’re not part on the EDM, if you just go to the flourishdx.com website, put a forward slash join in there and you’ll be able to sign up so that you can hear about these webinars in the weeks leading up to when we run them.
But thanks again everyone for coming along today and we’ll catch you on the next one.
Joelle Mitchell: Thanks, everyone.
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