Psychosocial risk in aged care: What the new obligations actually require

Dr Anna Kiaos.
Dr Anna Kiaos.

Since 1 July, the Managing Psychosocial Hazards at Work Code of Practice has been an enforceable benchmark in NSW under section 26A of the Work Health and Safety Act 2011. Providers must either comply with the code or demonstrate a standard of health and safety equivalent to or higher than it. The underlying duty to manage psychosocial risk applies nationally.

On 2 October, the People at Work survey closes permanently. Around 5,000 organisations and more than 160,000 workers have used the free, government-backed platform since 2020, aged care providers among them. The bar has risen at precisely the moment the most widely used tool for clearing it disappears.

That timing matters more in aged care than in most sectors, because the hazards here are not incidental to the work. They are the work. High emotional demands. Exposure to death and grief. Occupational violence and aggression, including from residents living with dementia and from distressed families. Shift work and fatigue. And the persistent gap between the care staff want to give, and the time they have to give it. Layer on 24/7 registered nurse coverage, care minutes and a new Act, and the pressure carried by the workforce delivering all of it is considerable.


In my experience, the risk for providers is rarely indifference. It is misreading.

My latest peer-reviewed study, published this year in the Journal of Organizational Ethnography, examined organisational culture inside Service NSW over eight months through 74 interviews across six organisational levels. It found that organisations can be genuinely well-intentioned and still misread the psychosocial hazards in front of them, responding to exhaustion, rising errors and declining morale with engagement and culture initiatives rather than addressing workload and working conditions.

For aged care, that is the trap. Exhaustion is read as a morale problem and answered with wellbeing programs, recognition and resilience training, while the actual hazard — workload, staffing levels, emotional demand, exposure to aggression — goes untouched. A regulator asking how you identified and controlled a psychosocial hazard will not accept a wellbeing calendar as the answer.

The second finding matters just as much for multi-site providers. Cultural pressure does not sit evenly across an organisation. It accumulates in particular homes, on particular shifts, in particular teams, under particular leaders, and in the gap between what an organisation says it values and what it actually rewards. An organisation-wide engagement score averages away the very variation you need to see. The night shift in one home is not the day shift in another.

Four things worth doing now

  • Extract your People at Work data before 2 October. After that, the platform is gone, and with it your baseline and your evidence of what you have already done.
  • Stop treating a survey as the system. The obligation is to identify, assess, control and review psychosocial hazards on an ongoing basis, and to keep evidence of the actions taken.
  • Look below the organisation level. Hazards concentrate; averages conceal. Understanding where pressure is accumulating is what makes control measures targeted rather than generic.
  • Take it to the board. Psychosocial risk is increasingly treated as enterprise risk. Boards are expected to know where it sits, what is being done about it, and how that would be demonstrated to a regulator if asked.

Aged care already knows how to do this. Every provider runs a clinical governance system that identifies risks to residents, controls them and documents the reasoning. The task now is to apply the same discipline to the people delivering the care — because the evidence a regulator will ask for looks very much like the evidence you already produce.