The new approach to mental health at work may need a new profession

Managing psychologically healthy and safe workplaces makes me extremely nervous. I don’t think that anyone in Australia is suitably qualified to meet the new occupational health and safety (OHS) regulations and expectations imposed by OHS regulators in response to community demands and needs. Perhaps we need a new category of professional.

The significance of introducing psychologically healthy workplace regulations on employers has only just started to be recognised. It is a significant change to occupational health and safety. The OHS profession is probably underprepared, and the situation is one for which the Human Resources (HR) profession seems to be still in denial. These changes are the pointy end of the wedge in terms of health and safety for employers. If we take “as far as is reasonably practicable” out of the discussion, because who said we can’t, and return to the “first principles” of OHS where work is not to result in harm, Profit and Productivity should be of no more import than the safety of the people conducting the work.

From this perspective, employers are not permitted to have any work or production or services that could create mental illness or anguish in workers. That is an extremely high bar to reach. Because the psychological health of workers is not something that is wholly the responsibility of work of employers.


OHS has developed, partly, on anthropometric data. The physical dimensions of a worker have been relatively uniform and those calculations have structured how we work, the speed of production lines, seating dimensions, and a whole range of workplace designs. What we don’t have is a psychological/psychosocial anthropometry of workers (my Greek is not up to creating a new “sexy” intellectual term and “psychometry” is already taken). We cannot easily determine whether a worker is anxious, depressed, happy, or contented, without external assistance.

The lack of an easy psychological assessment illustrates the size of the challenge for an employer to provide psychologically healthy and safe workplaces? How do they assess their workers? How do they prevent ill health? How do they assess the degree that their business’ operations harm the mental health of their workers? The day of a massage at your desk should be well and truly over.

The New South Wales code of practice for managing psychosocial hazards at work (the best of the current bunch of OHS psych guidances, according to some. Others prefer ISO45003) recommends, amongst other suggestions:

“For better psychosocial hazard identification, the PCBU should use a combination of information sources such as organisational data, observing work activities and consulting workers.”

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But this should have already been part of business-as-usual for hazard identifications and assessments. Stating the obvious risks dampening the employers’ enthusiasm for improvement rather than convincing them that improving psychosocial health is acheivable.


The advice being given by some of the OHS jurisdictions on this issue is a little unhelpful because it is based on a traditional version of OHS management. It has been written from an assumption that employers know about wellbeing and workplace wellness. What we should understand is that employers have been ignoring the hazard of mental health for decades, just as society and other institutions have been ignoring this hazard for even longer. We should not assume that people have even a basic understanding of what is meant by psychologically healthy workplaces.

This flaw in official OHS advice is appearing partly because the writers assume the consultative structure that has been applied for years to physical OHS hazards and harm also applies to psychological harm. And it’s just not necessarily the case.

It also fails to acknowledge how decades of corporate wellbeing programs have skewed, some may say corrupted, the OHS principles and duty of care. Presenting a new application of OHS to workplace mental health without trying to address the misunderstanding of employers’ legislative psychological obligations creates ideological and professional conflict when cooperation is required.


The psychological assessments of workers’ health in the past have almost entirely occurred through the recruitment process and via the human resource profession. That has been okay because that was usually part of the recruitment purposes. Very, very rarely do workers ever have another psychological assessment; perhaps until they apply for their next job, and then maybe not. It may be time to consider annual/regular psychological assessments of workers, and psychological audits of the business or OHS management system as long as a suitable and independent model is available.

The psychological health and safety of workers outside of recruitment has not necessarily been the purview of HR. If it has, it has been in the context of well being and on a substantially false assumption that psychological harm is a result of, and managed through an individual intervention of, the worker. HR has rarely been involved with the prevention of harm through structural change or reorganising work tasks and job design. The HR profession is ill-equipped, currently, to deal with psychological assessment outside the recruiting process.


This is another part of the challenge for employers. The traditional structures and resources they’ve relied on to determine and manage psychological health are likely to be no longer deemed suitable or sufficient for OHS compliance. In fact, WorkSafe Victoria actively discourages the administrative level of control of these hazards, such as training and awareness sessions, and is looking specifically for systemic and organisational change. This is a radical change, and a radical challenge, for occupational health and safety and the psychological health of workers.

Employers need more than an idiot’s guide to psychological health at work. There are plenty of “idiot guides” out there, but almost all of them have originated in HR or the psychological sector. Very few of them originate in occupational health and safety. And so they remain focused on individual interventions as if individuals need to cope with the stresses and the pressures at work. Workers do not need to cope with high stress at work. It is the employer’s legislative obligation to reduce that stress to a level that almost all workers can cope with. Every time coping and resilience training is provided, it lets employers avoid their responsibility.

Psychological health at work should perhaps be considered as a new management stream or even one requiring a new management profession. Some workplaces during the COVID pandemic employed Occupational Physicians specifically to address the hazard of trying to explain mandatory vaccinations and provide medical treatment and advice to workers, individually and for the development of policy. Some employed Occupational Hygienists. Psychological health at work needs a similar level of attention, resources and focused targeting because it requires a combination of skills that employers don’t have. (In the past, I have considered Chaplains as a potential model)

But also HR doesn’t have it, OHS doesn’t have it, and neither does Psychology, currently. If those three were drawn up as a Venn diagram, there’d be minimal overlap as they all have different approaches to managing psychological health at work. Yet whoever inhabits that overlap is the professional required for today’s workplaces, to address the new hazard and management requirements being imposed on employers by OHS regulators and to meet the expectations of workers, particularly younger workers.

If you find that professional, let me know. If you become that professional, let me know.

Kevin Jones

3 thoughts on “The new approach to mental health at work may need a new profession”

  1. I personally like the article take on this emerging trend that all Victorian workplaces will be going through if the proposed Psych Regulations come into play – the uphill battle of knowledge, experience and implementation within workplaces will be an interesting time.

    1. The OHS regulators may have their acts together and be developing a strategy of information, education and explanation on workplace mental health. They may be conducting workshop meetings with the OHS, HR, IR and business associations seeking clarity on their multidisciplinary communication strategy. But I have yet to see or hear of any of this.

      A test for Victoria and other jurisdictions will be 2022’s Work Health and Safety Month. Local and national OHS psych regulations should be in or close to finalisation by October. If this is the case, the theme for the month should reflect the significance of the changes. (I would be planning for joint presentations on psychosocial hazards from OHS and HR associations, and marketing the month, or the special week, of events to reframe the understanding of workplace mental health away from wellness programs, especially as Victoria has said that administrative controls like mental health awareness and wellness programs are not to be relied on to comply with OHS duties. It is time for “co-opetition” between OHS and HR and for the various WorkSafe’s to co-ordinate this.

  2. Kevin,
    Do not get too fussed about professionals.

    Health and Safety Representatives can do the job.

    Workers subject to psychosocial hazards are the best source of advice.

    Peter Moylan

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