Bullying and excessive workload usually make it into a psychosocial risk register. Lack of role clarity often does not. That omission matters because uncertainty about responsibilities, decision-making authority and accountability can be a persistent source of work-related stress, even where no single incident appears serious enough to trigger attention.
Under Part 3.5 of the Model WHS Regulations 2022, a person conducting a business or undertaking, or PCBU, must identify psychosocial hazards and manage the risks they create. The Safe Work Australia Code of Practice: Managing Psychosocial Hazards at Work provides the practical framework.
The difficulty is not always a lack of care. Psychosocial hazards are often embedded in ordinary management practices, team relationships and work design. They can fluctuate by team, season or manager. Workers may also be reluctant to describe them openly, particularly where they believe the information will be traced back to them.
A defensible assessment therefore needs more than a survey score or a general statement that "stress is managed". It should record the hazard, the likelihood and severity of harm, the proposed controls, the nature of the exposure, its duration and frequency, and who may be harmed.
1. Poorly designed jobs
Poor job design commonly appears through high job demands, low job control, or both. Examples include unrealistic deadlines, constant interruptions, insufficient staffing, monotonous work, poorly designed systems and a lack of authority to make decisions needed to complete the job.
This hazard is often recorded only as "workload". That is too broad to guide a useful response. Two employees may have the same volume of work, but very different risks. One may control the order and timing of tasks. The other may be expected to respond immediately to competing requests from several managers, with no ability to negotiate priorities.
A proper assessment asks:
- What demands are placed on workers, and when do they peak?
- How often are workers required to work excessive hours, skip breaks or switch rapidly between tasks?
- What control do they have over methods, sequencing, deadlines and escalation?
- Are systems, staffing levels, equipment and training adequate for the work?
Controls might include reviewing staffing and deadlines, setting escalation rules for competing priorities, removing unnecessary approvals, redesigning workflow and giving workers genuine input into how work is performed. Telling people to "manage their time better" is not a control where the job itself is structurally unmanageable.
2. Lack of role clarity
Role clarity is more than having a position description on file. Workers need to understand their responsibilities, authority, reporting lines and performance expectations. Problems arise when two managers give conflicting instructions, accountabilities overlap, or important tasks fall between teams.
This hazard is frequently missed because ambiguity can look like an individual performance issue. A worker who hesitates, makes repeated approvals requests or is criticised for failing to act may not be underperforming. They may be trying to operate within unclear boundaries.
Assessment should examine how work is actually allocated, not just how the organisation chart is drawn. Useful questions include:
- Who makes the final decision when priorities conflict?
- Can workers identify the person responsible for approving, reviewing and delivering key tasks?
- Do temporary staff, new starters and workers returning from leave receive the same clarity?
- How are changes to responsibilities communicated and documented?
Controls can include clear decision rights, updated position descriptions, team-level responsibility maps, consistent induction and a documented process for resolving conflicting directions. Managers should also check whether workers understand the arrangements, rather than assuming that a circulated document has solved the problem.
3. Low support from management
Support is sometimes reduced to whether a manager is approachable. The risk is broader. It includes inadequate guidance, poor feedback, a lack of resources, inconsistent supervision and failure to respond when a worker raises a concern.
Low support is difficult to assess because workers may give socially acceptable answers, particularly when a survey is issued by their direct manager. It can also be mistaken for a personality mismatch. A manager does not need to be well liked to provide appropriate support, but workers do need access to reasonable instruction, feedback and assistance.
A sound assessment considers the systems around management, including:
- Whether managers have the time and training to supervise effectively
- How often workers receive meaningful feedback and check-ins
- Whether new or vulnerable workers receive additional support
- What happens after a worker raises a workload, conduct or safety concern
- Whether managers are held accountable for following up agreed actions
Controls may include manager training, defined response timeframes, regular one-to-one conversations, accessible escalation channels and additional supervision during restructures or periods of high demand. A wellbeing hotline may be useful, but it does not replace fixing a management process that leaves workers without practical support.
4. Workplace conflict
Workplace conflict can involve disputes between colleagues, conflict with a manager, perceived unfairness in decisions, incompatible working styles or unresolved complaints. It can relate to poor organisational justice and interpersonal conflict, and it may exist without meeting the legal threshold for bullying.
That distinction is important. An employer should not wait for a bullying finding before assessing the risk created by repeated hostility, exclusion, inconsistent treatment or a breakdown in working relationships. Nor should every disagreement be treated as a psychosocial hazard. Ordinary differences of opinion can be managed appropriately. The risk increases when conflict is persistent, unmanaged, targeted or connected to unequal power.
Assessment should look for patterns, not only formal complaints. Relevant information can include grievance themes, staff turnover, repeated team escalations, absenteeism, exit feedback and reports that people avoid particular meetings or colleagues. Confidentiality and procedural fairness still apply. Information should be collected and handled carefully, without turning a risk assessment into an informal investigation.
Controls may include clear conduct expectations, fair complaint handling, facilitated resolution where appropriate, independent escalation options and documented follow-up. Managers should record what action was taken and whether the working conditions improved. Closing a complaint administratively is not the same as controlling the underlying risk.
5. Remote or isolated work
Remote work is not automatically unsafe, and working from home is not automatically isolated work. The hazard arises when a worker cannot readily access assistance, supervision or emergency support, or when physical separation contributes to poor communication and disconnection from the team.
Risk can be higher for workers who work alone at a site, travel between locations, work outside normal hours, perform high-risk tasks without nearby assistance, or are geographically separated from their manager and colleagues. It may also affect remote workers who are excluded from informal information flows or expected to remain constantly available.
Assessment should consider the worker's actual arrangements:
- Where and when is the work performed?
- What assistance is needed if the worker becomes distressed, unwell or faces a threatening situation?
- How frequently does the worker have meaningful contact with a manager and colleagues?
- Are communication channels reliable, and are after-hours expectations clear?
- Do disability, language, caring responsibilities or other circumstances change the risk?
Controls may include scheduled check-ins, buddy arrangements, reliable escalation procedures, limits on isolated high-risk tasks, planned team contact and clear availability expectations. For home-based work, the assessment should address the work design and support arrangements rather than assuming that the employee's home environment is the employer's responsibility in every respect.
Making the assessment useful to a regulator and to workers
SafeWork NSW has conducted enforcement activity and issued improvement notices concerning psychosocial hazards since 2023. In practice, regulators are interested in whether the PCBU has taken a systematic approach: identifying the hazard, consulting workers, considering exposure and potential harm, implementing controls and reviewing whether those controls work.
For example, a synthetic scenario from the type of workplace ReFresh supports might involve a 120-person professional services organisation introducing a new case-management system. Its register identifies "change-related stress" but does not record that analysts are receiving instructions from three separate team leads, working late to reconcile duplicate records and receiving little feedback during the transition.
A more useful assessment would separate the risks. It might identify poorly designed work caused by competing demands, lack of role clarity caused by overlapping approval responsibilities, and low management support caused by limited supervision during the implementation. The proposed controls could then include a single priority owner, revised approval rules, realistic implementation milestones, additional supervision and a review after four weeks.
Software can help organise this evidence, track changes in regulation and support drafting. It cannot replace consultation, professional judgement or decisions by the people who control the work. This article is general information, not legal advice, and the application of WHS duties depends on the circumstances and the jurisdiction.
The most revealing risk register is often not the one with the longest list of hazards. It is the one that shows what workers said, what the business changed, who owns the control and whether the problem actually reduced.
