Most NZ employers know they have health and safety obligations for physical hazards — slips, falls, machinery, manual handling. Fewer know that the Health and Safety at Work Act 2015 applies equally to psychological harm. WorkSafe NZ released its Good Practice Guidelines on Managing Psychosocial Hazards at Work in 2024, making the expectations significantly clearer.
If your business has not reviewed its approach to psychosocial risk, you are likely behind where WorkSafe expects you to be.
What Psychosocial Hazards Actually Are
Psychosocial hazards are aspects of work — how it is designed, organised, managed, or the social environment it occurs in — that can cause psychological or physical harm. WorkSafe's 2024 guidance lists the main categories:
Job demands. Excessive workload, time pressure, emotional demands, and exposure to traumatic or distressing content.
Job control. Low autonomy over how or when work is done, or limited ability to contribute to decisions that affect the role.
Support. Inadequate support from managers or colleagues, lack of recognition, or poor communication.
Relationships. Conflict, harassment, bullying, violence, or discrimination — from managers, colleagues, or customers.
Change. Poorly managed organisational change, restructures, or job insecurity.
Any of these can cause depression, anxiety, burnout, or physical health consequences including cardiovascular disease. WorkSafe treats them as workplace hazards in the same category as a wet floor or unguarded machine.
Your Legal Obligation
Section 36 of the Health and Safety at Work Act requires a PCBU (Person Conducting a Business or Undertaking) to ensure, so far as is reasonably practicable, that the work environment does not put workers' health — physical or psychological — at risk.
Section 22 defines health to include mental health. This is not ambiguous. WorkSafe has prosecuted businesses for harm caused by psychosocial hazards, including cases involving workplace bullying and excessive stress. Fines for failing to manage these risks carry the same maximum penalties as physical safety failures — up to $500,000 for a body corporate.
The 2024 guidance does not change the law. It clarifies what WorkSafe considers "reasonably practicable" in the context of psychosocial risk — and raises the bar for what constitutes an adequate response.
What WorkSafe's 2024 Guidance Expects
The guidance sets out a risk management approach that mirrors the physical hazard framework most employers are familiar with:
Identify. Know what psychosocial hazards exist in your workplace. This means going beyond anonymous surveys to understand specific roles, working conditions, and team dynamics. Customer-facing and care roles, shift work, and high-pressure target environments carry elevated risk.
Assess. Consider the likelihood and severity of harm. A role with high emotional demands and no peer support is higher risk than the same demands with strong management support. Context matters.
Control. Implement controls using the hierarchy of controls. Eliminate the hazard where possible — redesign the role, reduce workload, change shift patterns. Where elimination is not practicable, minimise: provide support, clear reporting pathways, regular check-ins, access to employee assistance programmes.
Monitor and review. Review controls after incidents, complaints, or significant changes. Track early warning indicators including sick leave rates, staff turnover, and the number of informal complaints.
Practical Controls for NZ Employers
WorkSafe does not require perfection. It requires a documented, genuine attempt to identify and manage the risks. Specific controls that appear in WorkSafe's guidance include:
- Workload review processes that give workers a way to flag unsustainable demands
- Clear anti-bullying and harassment policies with accessible reporting mechanisms
- Manager training in recognising signs of psychological distress and responding appropriately
- Regular one-on-one check-ins for high-demand roles
- Access to an Employee Assistance Programme (EAP)
- Return-to-work plans that consider psychological as well as physical recovery
The most common WorkSafe finding in psychosocial incidents is not that the business had no policy — it is that the policy existed but was not implemented, managers were not trained, and workers did not believe reporting would lead to any action.
Training Is a Key Control
Manager capability is central to psychosocial risk management. WorkSafe's guidance specifically identifies inadequate management behaviour as both a hazard and a control failure. Managers who cannot recognise early warning signs, who respond poorly to disclosures, or who themselves engage in high-demand or dismissive behaviour create measurable risk.
Mental health first aid training for team leaders and managers is one of the most practical starting points. It builds awareness of common presentations — anxiety, depression, burnout — and provides a framework for responding supportively and referring appropriately. See our guide to mental health first aid training for NZ workplaces for what this covers and who should complete it.
Broader H&S rep training also addresses psychosocial hazards as part of the core curriculum. If your workplace has or is required to have elected H&S reps, ensuring they are trained to handle psychosocial issues alongside physical ones strengthens your overall risk management position.
What to Do Before Your Next WorkSafe Interaction
Whether WorkSafe contacts you proactively or following an incident, the following documentation demonstrates a genuine response to psychosocial risk:
- A psychosocial hazard register covering your key roles and work environments
- Evidence of a workload review process — meeting notes, outcome records
- A bullying and harassment policy with a named reporting contact and documented complaint handling procedure
- Training records showing manager and H&S rep completion of relevant training
- EAP provider details included in your employee handbook or induction materials
- Records of any incidents, complaints, or near-misses and the actions taken
If you do not have these in place, start with the hazard identification step. WorkSafe's guidance and templates are available at worksafe.govt.nz. The expectation is not a perfect system on day one — it is a documented effort to understand and address the risks.
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