The HR manager plays an increasingly central role in WHS compliance as the regulatory focus expands beyond physical hazards to encompass psychosocial risks in the workplace. Under the WHS Regulation 2025, Regulation 55C imposes specific obligations on PCBUs to identify, assess, and control psychosocial hazards, and the HR manager is typically the person responsible for implementing these obligations. The role also encompasses training record management, fitness for work assessments, injury management and return to work coordination, and worker consultation on WHS matters. Regulators now routinely examine HR systems and records during workplace investigations, making the HR manager a key duty holder whose competence directly affects the PCBU's compliance posture under the Work Health and Safety Act 2011.
Reg 55C WHS Regulation 2025
Psychosocial Regulation
Schedule 14 WHS Regulation 2025
Health Surveillance
Part 4.5 WHS Regulation 2025
Licensing
1 July 2026
Section 26A Commencement
1 December 2026
WEL Transition Date
Part 5 WHS Act 2011
Worker Consultation
Regulation 55C of the WHS Regulation 2025 requires every PCBU to manage psychosocial risks in the workplace using the same hierarchy of controls applied to physical hazards. Psychosocial hazards include workplace bullying, harassment including sexual harassment, violence and aggression, excessive workload and work pressure, poor organisational change management, remote and isolated work, traumatic events, and role ambiguity or conflict. The HR manager must establish systems to identify these hazards through worker surveys, exit interview analysis, complaint records, and absenteeism data. Once identified, the hazards must be assessed for their risk level and controls must be implemented. Controls may include workload redistribution, roster changes, conflict resolution procedures, employee assistance programs, and organisational design changes. The HR manager must document the risk assessment process, the controls implemented, and the review schedule. Regulators assess psychosocial hazard management using the same evidentiary standards applied to physical hazard management, meaning undocumented or informal approaches will not satisfy the regulation.
The HR manager is typically responsible for maintaining the PCBU's training records system, which must demonstrate that every worker has received task-specific induction, competency verification, and refresher training within prescribed intervals. Under the WHS Regulation 2025, training records must include the date and content of training, the name and qualifications of the trainer, the assessment method used to verify competency, and the worker's acknowledgment of completion. For high-risk work requiring licences under Part 4.5 of the WHS Regulation 2025, the HR manager must maintain copies of current licences and certificates of competency, track expiry dates, and ensure workers do not perform licensed work after their licence has expired. The training records system must also capture toolbox talk attendance, SWMS sign-on records, and any specialist training required for work involving hazardous chemicals, confined spaces, or elevated work platforms. Regulators request training records as a standard part of any investigation, and the inability to produce records is treated as evidence that training did not occur, regardless of whether it actually did.
The HR manager coordinates fitness for work assessments that ensure workers are physically and psychologically capable of performing their assigned tasks safely. This includes pre-employment medical assessments, periodic health surveillance for workers exposed to specific hazards under Schedule 14 of the WHS Regulation 2025, drug and alcohol testing programs, and return to work fitness assessments following injury or illness. Health surveillance obligations are mandatory for workers exposed to certain hazardous chemicals, noise levels exceeding exposure standards, and other specific hazards identified in the WHS Regulation 2025. The HR manager must ensure that health surveillance is conducted by a registered medical practitioner with appropriate qualifications, that results are communicated to the worker, and that the PCBU takes appropriate action based on the findings. When workplace exposure limits transition to the new WEL values on 1 December 2026, the HR manager must coordinate with the safety manager to review health surveillance programs and ensure they align with the revised exposure standards.
The HR manager coordinates injury management and return to work programs that comply with workers compensation legislation and the WHS Regulation 2025. Effective injury management requires early intervention, genuine consultation with the injured worker, medical opinion from treating practitioners, development of a return to work plan with suitable duties, and progressive increase in work capacity towards pre-injury duties. The HR manager must maintain confidential records of all injury management activities and ensure that the return to work process does not expose the injured worker or other workers to additional health and safety risks. Common failures identified by regulators include failing to investigate the psychosocial factors contributing to mental health injury claims, maintaining training records in paper systems that cannot be searched or verified during an inspection, conducting fitness for work assessments using non-qualified practitioners, and failing to act on health surveillance results that indicate a worker should be removed from exposure. Prosecution for psychosocial hazard failures is increasing across all jurisdictions, with several PCBUs receiving penalties exceeding $500,000 for systemic failures to address workplace bullying and harassment.
EHS Atlas provides psychosocial risk assessment tools, training record management, health surveillance tracking, and injury management workflows that satisfy Regulation 55C.
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