Many organisations can point to their psychosocial controls. Far fewer have checked whether those controls protect the workers most exposed to harm, who are often the same people inclusion work is trying to reach.
A customer service officer on a casual roster regularly deals with abuse at the counter. She came to Australia ten years ago and English is her second language. Her organisation has a policy, training, an EAP and a speak-up line, and all rely on her to come forward while her shifts are allocated week to week.
I meet versions of this person in almost every organisation I work with. In most of those organisations, psychosocial risk and inclusion are run separately, so no one asks whether the safety systems work for the people they are designed to protect.Â
When I look at any system with an inclusion lens, I ask who it was built for and who it misses. With psychosocial controls, what’s usually missing is any analysis of power, and how it shapes the people those controls actually protect.
Why this matters now
Every Australian jurisdiction now regulates psychosocial risk. The rules are also getting stricter. In Queensland and in NSW, employers must follow the approved codes of practice or show a higher or equal standard.Â
Other states and territories may follow. So, wherever you’re based, it makes sense to treat the code as the minimum.
NSW’s 2025 WHS Regulation also requires employers to use the hierarchy of controls. That means removing the risk first where they can, not relying on workers to report it or cope with it.Â
Victoria goes further, noting that training can’t be the main control. Psychosocial risk is also a SafeWork NSW regulatory priority for 2026-27.
Last year, in an article for AHRI, Anna Dawson and I argued that WHS and DEI need to work together on inclusive work design. Now that regulators are enforcing these duties, the stakes are higher.
If your controls weren’t designed with your whole workforce in mind, you’re only managing part of the risk, and compliance becomes a tick-box exercise.
Why the protection is uneven
The risk of harm isn’t spread evenly. The Australian Human Rights Commission’s 2022 survey found a third of workers had been sexually harassed at work in the past five years, rising to 46 per cent for LGBTIQA+ workers, 48 per cent for workers with disability and 56 per cent for First Nations workers.
ANROWS research with migrant and refugee women found that in a third of the incidents they described, women were threatened or warned not to report.
Part of the reason is power, meaning job security and a real say in how your work is done. Both are shaped by how you’re employed, and by discrimination and bias based on who you are. That’s why protection follows power, and why bias can end up built into safety systems without anyone intending or realising it.
Safety systems tend to be built for a full-time, permanent worker who is typically a male without heavy caring responsibilities and from the majority culture. They are usually confident that speaking up won’t cost them their reputation, their social capital or their job. This isn’t the case for others.Â
A casual worker can be told about the EAP. Whether they’ll ring it on a break to talk about their manager, with next week’s shifts not yet allocated, is another matter.
Rae Cooper, Elizabeth Hill and colleagues in the Working for Women Research Partnership distinguish “good flex” – which gives workers genuine choice and security – from “bad flex”, which limits control.
Men are more likely to have good flex. Women are more likely to have bad flex. Bad flex often means low job control, which is a recognised psychosocial hazard.
A part-time coordinator fitting a full-time job into three days has flexibility on paper but no say over their workload, and raising it could cost them the arrangement. So they absorb the extra load and risk burning out, while the organisation counts them as a flexibility success story.
Or take a First Nations employee who is asked to brief the executive after a racist incident involving other members of the team. They are asked to advise on top of their normal job load and usually without recognition or time back.
Gari Yala 2 found one in two First Nations employees does at least an hour a week of what the researchers call “unpaid workplace demands”, sometimes referred to as cultural load.Â
This can include being constantly asked to do Acknowledgement of Country and Welcome to Country sessions, or to educate/train employees on cultural biases.
This can add to the psychosocial load these workers carry, and most risk assessments don’t capture this.
Hear from a range of other DEI experts at AHRI’s DEI Week – a series of virtual webinars running from 17-19 November. Free for AHRI members.Signs your controls may be missing people
There are some important signs to look out for that could signal that your psychosocial risk measures aren’t capturing your full workforce:
- Casual, labour hire and part-time staff are under-represented in survey responses.
- Engagement or inclusion scores differ sharply by group.
- Complaints come mainly from permanent, more senior staff.
- Teams doing frontline, client-facing or shift work report very little.
Quiet teams deserve a second look. Few complaints can mean the people most at risk have learned that reporting costs more than it gets them.
“Administrative controls such as training and speak-up lines, and supports like EAPs, depend on workers being willing to use them. If they’re your main controls, you’re relying on the people with the least power to protect themselves.”
Testing your controls
The ‘hierarchy of controls’ puts changing the work ahead of training and individual reporting.Â
A better roster or fairer shift allocation can reduce exposure for everyone in the role, without anyone having to speak up first. This is a better way to reach workers least likely to speak up.
Administrative controls such as training and speak-up lines, and supports like EAPs, depend on workers being willing to use them. If they’re your main controls, you’re relying on the people with the least power to protect themselves.
For each control, ask whether the workers with the least power could and would realistically use it. A speak-up line assumes someone feels safe naming their manager. An EAP assumes time, privacy and trust that it’s confidential and culturally safe.
Then ask whether health and safety representatives, and staff who are First Nations, living with disability, LGBTIQA+ or culturally diverse, were consulted when it was designed. In my experience, they rarely are. An open call for feedback mostly brings in the people who already speak up.
Where to start
In most organisations I work with, diversity data sits with HR, claims and incident data with WHS, and the two are rarely put side by side. Bringing them together is a job for WHS and DEI, working with HR and the people affected. It’s deeper work than a compliance check.
Together they can:
- Check who uses your controls. Compare who uses each control, including the EAP where data allows, with your workforce by employment type, role and diversity group, avoiding groups small enough to identify people. If casual or frontline staff barely appear, find out why.
- Add a “who does this miss?” column to your risk register. For each psychosocial control, note who it may fail to protect and what change would close the gap.
- Involve the people most exposed in designing controls. Ask frontline staff: “If something happened on shift, who would you tell?” Test changes with them, health and safety representatives and staff networks, and check back afterwards that they’re working.
Report what you find to the executive alongside your usual compliance measures, so they can see who the controls are reaching and who they aren’t.
Back to the counter
For the employee at the counter, protection could mean a roster that doesn’t leave her alone with abusive customers, ensuring there’s a way to raise concerns that doesn’t go through the person setting her shifts, and being asked what would make her safer. Then someone checks whether it’s working.
Before your next psychosocial risk review, ask who each control was built for, and whether the people it’s meant to protect had any say in it.
🧰 HR’s career resource toolkit
- Virtual Event: Register now for AHRI DEI Week 17-19 November and learn from experts on what how inclusive practices can drive meaningful change in your workplace.
- Article: Responding to psychosocial safety concerns
- Course: Advanced DEI practices
Emilie Priday is the Principal Consultant at Emilie Priday Consulting. Drawing on senior executive experience in NSW Government and at the Australian Human Rights Commission, she helps organisations build safe, inclusive and high-performing workplaces, with a focus on psychosocial risk and culture.
