Control Plan Development
Most psychosocial assessments end at a report. The duty does not.
Regulation 15 requires employers to control the risks associated with identified psychosocial hazards, working down a hierarchy that puts elimination and work redesign ahead of administrative measures. It also states that information, instruction and training cannot be the exclusive control measure unless nothing else is reasonably practicable, and where controls are combined, training cannot be the predominant one.
That single provision invalidates most of what organisations currently do about psychosocial risk.
The problem with most control plans
An organisation identifies workload pressure. It responds with resilience training, an EAP reminder and a wellbeing webinar.
Every one of those is either an administrative measure or an individual support measure. None of them changes the workload. The hazard is unchanged, the exposure is unchanged, and the organisation now has a documented record showing it knew and responded with the lowest-order controls available.
That is a worse position than not having identified the hazard at all.
What we do
1. Review the hazards and the evidence behind them. We work from your risk register. Where hazards were identified by a process that could not have surfaced them properly, we say so before building controls on top.
2. Work the hierarchy from the top. For each hazard: can this be eliminated? If not, can the work be redesigned? Can the exposure be reduced at source? Only then do administrative and individual measures enter the plan, and only as support.
3. Test what is reasonably practicable. Where a higher-order control is not adopted, the reason is recorded. That record is what makes a decision defensible later.
4. Assign ownership and timing. Every control has a named owner, a date and a measure. Controls with neither are intentions.
5. Build the review triggers. Regulation 16 requires review when work changes, when new information emerges, when an incident or complaint occurs, or when a health and safety representative asks. Those triggers go into the plan, not into someone's memory.
What you receive
- A control plan mapping every identified hazard to controls ranked against the hierarchy
- A documented reasonable practicability assessment for each hazard where higher-order controls were not adopted
- Named ownership, timing and measures for every control
- Review triggers aligned to regulation 16
- Implementation support, scoped to what your team needs
Who this is for
Organisations that have completed an assessment, by us or by anyone else, and now have a register they do not know what to do with. Organisations whose current controls are mostly training and support. Organisations that need to show a regulator, a board or an insurer what they did about what they found.
Common questions
We already have an assessment. Can you work from it?
Yes. We review the register and the method behind it first. If hazards were identified by a process incapable of surfacing them properly, we will tell you, because controls built on an incomplete register inherit its gaps. Where the assessment is sound, we build directly from it.
What counts as a higher-order control for a psychosocial hazard?
Anything that changes the work rather than the worker. Redesigning a role, adjusting workload allocation, changing rostering, resourcing a function properly, altering a reporting line, removing a task from a person who should never have carried it, changing how decisions are made. Training, awareness and support are legitimate parts of a control system, but regulation 15 prevents them from being the predominant part.
How do we prove a control worked?
By measuring the exposure rather than the activity. Attendance at a session is evidence the session happened. A reduction in the exposure that created the hazard is evidence the control worked. We build the measure into the plan when the control is written, because retrofitting one later rarely produces anything a regulator will accept.
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