WHS Psychosocial Compliance · Australia

Your WHS obligations just got more specific about mental health

Safe Work Australia’s 2023 Code of Practice on Managing Psychosocial Hazards in the Workplace sets out clear employer duties. Here’s what it means for your business — and how an EAP helps you meet them.

Definitions

What are psychosocial hazards?

Under the Work Health and Safety Act 2011 (Cth) and equivalent state/territory legislation, a hazard is anything with the potential to cause harm. Psychosocial hazards are hazards that affect workers’ psychological (mental) health and safety.

High job demands

Excessive workload, cognitive demands, emotional labour

Low job control

Inability to influence how or when work is done

Poor support

Inadequate support from supervisors or colleagues

Poor role clarity

Unclear expectations or responsibilities

Workplace conflict

Interpersonal conflict, bullying, harassment, discrimination

Traumatic events

Exposure to distressing incidents, client trauma, vicarious trauma

Isolated or remote work

Working alone, away from others

Poor change management

Restructures, redundancies, poor communication

These hazards can lead to work-related stress, anxiety, depression, and burnout — all of which carry significant cost for employers (absenteeism, presenteeism, turnover, workers’ compensation claims).

The legal framework

What the law requires

Work Health and Safety Act 2011 (Cth)

Section 19 of the WHS Act imposes a primary duty of care on employers (referred to as “persons conducting a business or undertaking” or PCBUs). This duty extends explicitly to psychological health and safety, not only physical safety.

Safe Work Australia — Code of Practice: Managing Psychosocial Hazards at Work (2023)

This Code of Practice, updated in 2023, provides practical guidance on how to comply with the WHS Act. It establishes a clear 4-step framework:

1

2

3

4

An EAP is explicitly listed in the Code as a control measure for psychosocial hazards.

State & Territory Laws

All Australian states and territories have WHS legislation that mirrors or references the Model WHS Act. Safe Work NSW, WorkSafe Victoria, and equivalent bodies in each state have also published guidance reinforcing psychosocial risk obligations.

Where Resplora fits

How an EAP satisfies your obligations

An EAP alone does not eliminate psychosocial hazards — you still need to address root causes (workload, management practices, conflict). However, an EAP provides:

A documented control measure

In the event of a WHS audit or investigation, having an EAP demonstrates that you identified the risk of work-related psychological harm and implemented a control measure. This is a legally significant defence.

A confidential support pathway

Employees experiencing psychological harm have access to professional support without needing to disclose their struggles to their employer. This is specifically encouraged in the Code.

Evidence of ongoing commitment

Monthly utilisation reports show that the EAP is actively promoted and available — not just ticked as a box.
The cost of inaction

What happens if you don't comply

Failing to manage psychosocial hazards is not a minor administrative issue. Potential consequences include:

The risk is real. Beyond penalties, psychological injury claims are among the most costly and complex to manage.

Documenting your control measures

Resplora EAP as a control measure

When you implement Resplora EAP, you can document
Psychosocial hazard
Control measure implemented
High job demands / stress
EAP — confidential counselling and psychology available
Poor support
EAP — confidential sessions per employee, no referral needed
Traumatic events
EAP — registered psychologists with trauma expertise
Workplace conflict
EAP — professional mediation support
Low mental health literacy
EAP — proactive promotion of mental health support
Documentation: Resplora provides monthly utilisation reports. These can be retained as part of your WHS records — evidence that the control was implemented and actively used.
Good to know

Frequently asked questions — WHS

Does an EAP mean we’ve fully discharged our WHS psychosocial obligations?

No. An EAP is a control measure — one part of a broader approach. You still need to identify specific hazards in your workplace, assess their severity, and implement controls at the source (e.g. managing workloads, addressing conflict). However, an EAP meaningfully strengthens your overall compliance position.

Yes. The Code applies to all persons conducting a business or undertaking (PCBUs) regardless of size or sector.

Yes. We recommend retaining monthly reports as part of your WHS management records. They demonstrate that the EAP control measure was promoted and utilised.

Yes. The duty of care under the WHS Act applies to all employers. Small businesses often have fewer resources to manage psychosocial hazards, which is exactly why a simple, low-cost EAP like Resplora is valuable.

Meet your obligations

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This page provides general information only. It is not legal advice. For advice specific to your situation, consult a WHS consultant or employment lawyer.