Psychosocial hazards belong in the WHS risk register — not the EAP folder
If your psychosocial “system” is a counselling brochure and an annual survey, you do not have a WHS control. You have a wellbeing initiative.
Under Australian model WHS framing, psychosocial hazards are health and safety risks. They sit beside plant, process, and people not in a separate HR drawer that never reaches the WHS risk register.
Safe Work Australia publishes a Model Code of Practice: Managing psychosocial hazards at work. That document is national model guidance. It only has legal effect in a jurisdiction if that jurisdiction has approved it as a code of practice. Check your state or territory WHS regulator before you treat the model CoP as enforceable law on your sites. (SWA Model CoP — Managing psychosocial hazards at work)
SWA itself is not a regulator. For workplace advice on what applies to you, contact your state or territory WHS authority.
What “in the register” actually means
A usable psychosocial row looks like any other risk row:
- Hazard named in plain language (e.g. high job demand, role conflict, remote/isolated work, aggression from customers, poor change consultation).
- Owner named — usually an ops or people lead who can change the work design, not only the EAP vendor.
- Controls that change the work, not only referrals after harm (roster design, escalation paths, consultation records, training where it is a control).
- Evidence you can open — meeting notes, roster rules, incident trends, review dates — so an inspector or auditor is not waiting on someone’s inbox.
EAP still matters. It is not a substitute for identifying and controlling psychosocial hazards at the source.
Why mid-market teams get this wrong
Ops owns plant. HR owns “culture.” Finance owns headcount. Psychosocial risk falls between them, so it never gets a register owner.
Treat psychosocial rows with the same permanence as plant rows — not a one-week awareness push. The register should still be current in February.
Practical first pass (one afternoon)
- List the top five psychosocial hazards that actually show up in your incidents, absenteeism, or exit themes.
- Put each on the WHS register with an owner and a next review date.
- Attach one piece of existing evidence per row (roster rule, consultation note, training record, customer-aggression procedure).
- Schedule a 90-day reopen — same cadence you use for plant risks.
If you already run a compliance register or risk register in Lahebo, psychosocial rows belong in the same system as your other WHS obligations linked to actions and incidents, not a parallel spreadsheet.
What this post is not
This is not certified advice, a psychosocial risk assessment, or a determination that your workplace is or is not compliant. It is a register-design pattern for Australian mid-market ops and people leads.
Primary: Safe Work Australia — Model Code of Practice: Managing psychosocial hazards at workhttps://www.safeworkaustralia.gov.au/doc/model-code-practice-managing-psychosocial-hazards-work
Related Lahebo reading: WHS risk register Australia · WHS risk management