By Dr Tom Nehmy
If your organisation relies on its wellbeing program and Employee Assistance Program (EAP) to manage psychosocial hazards, it's worth taking a second look. In my view, they don't meet the psychosocial duty on their own.
The duty is to identify the hazards in how work is designed and managed, and to control the risks they create. Wellbeing programs and EAPs support people, and that matters. But they don't change the work that is causing harm.
My passion is preventive psychology, so I'm a strong believer in good wellbeing programs. That's exactly why I want to be clear about what they can and can't do. In this article, I'll explain what the duty asks for, where wellbeing programs and EAPs fit, and some questions to ask about your own program.
What the psychosocial duty actually asks for
Safe Work Australia's model Code of Practice, Managing psychosocial hazards at work, describes psychosocial hazards as hazards that arise from, or in relation to, things like the design or management of work, the working environment, and workplace interactions or behaviours. They may cause psychological and physical harm, including anxiety and depression.
The Code states the core duty plainly: "A PCBU must eliminate psychosocial risks in the workplace, or if that is not reasonably practicable, minimise these risks so far as is reasonably practicable." PCBU stands for "person conducting a business or undertaking", a legal term that includes employers. The model Code only has legal effect where it has been approved as a code of practice, so check with your WHS regulator whether it applies to you.
To meet that duty, the Code sets out four steps: identify the hazards, assess the risks, control the risks, and review the controls to check they're working. You must also consult the workers who are affected, so far as is reasonably practicable. Our Code of Practice walkthrough explains each step in plain English.
Notice where the focus is. When the Code explains how to minimise risks, it talks about changing the design of work, the systems of work, the work environment, workplace interactions, and the tools and equipment used. The duty is about the work.
What wellbeing programs and EAPs do well
Let me be fair, because both wellbeing programs and EAPs play an important role in an organisation’s wellbeing and psychosocial hazard management approach.
In many organisations, the EAP is the usual route to employer-supported psychological help, and early help matters: one of the best predictors of a quick recovery from a mental health issue is early intervention. The Code itself mentions EAPs in its section on traumatic events. Among the measures aimed at the individual worker, it says: "Provide employee assistance programs and encourage workers to use them."
Good wellbeing programs can work even earlier. Working with clients in therapy, I became preoccupied with a question: what if they had been taught the skills I was teaching them before their problems arose? That question stayed with me, and eventually led me to develop and test the Healthy Minds program in my doctoral research. Preventive programs like ours aim to keep healthy people healthy by teaching psychological skills before problems start.
They also help with culture. When everyone in a workplace learns a shared language for wellbeing, it becomes easier to talk about it, and to ask for help.
Where they fall short on their own
So where's the problem? It comes when wellbeing programs and EAPs are the whole response to psychosocial hazards. On their own, they fall short in three ways.
An EAP mostly helps after harm has started. It's like a firefighter putting out a fire: essential, but it would be better to stop the fire from starting in the first place. It also only helps the people who use it. In our experience, many organisations have low uptake of their EAP. Our 2026 Australian Psychosocial Safety Benchmark Report, prepared with HumanListening, found that only 53% of the 994 employees surveyed would seek support at work if they needed it. Another 21% knew help existed but wouldn't feel comfortable using it, and 26% didn't know it was there at all.
Wellbeing programs work on the person, not the work. Even the best preventive program builds people's skills for managing pressure. It doesn't reduce the pressure when the pressure itself is the hazard. Most of us know to bend our knees when we lift something heavy, and it's a good skill to have. But if a box is too heavy for anyone to lift safely, better technique won't solve the problem. The box needs to be lighter. When wellbeing training becomes the main response to a problem in the work, it puts the fix on the individual. Individuals do have a part to play in looking after their own wellbeing, but that doesn't take away from the employer's obligations.
Neither an EAP nor a wellbeing program changes workloads, role clarity, or how change is managed. Yet that's where many of the risks sit. In our benchmark research, high job demand was the number one hazard, and how change is handled was the most widespread area of unhappiness we measured, with 31% unhappy with it. As the report put it, "The benchmark describes a work-design and management problem, not an employee resilience problem." No wellbeing program, however good, can make up for an unreasonable workload, a poorly designed job, or poorly managed change.
Where wellbeing fits in a psychosocial risk approach
Wellbeing programs and EAPs work best as a support layer. That layer sits on top of the controls that fix the work. It doesn't replace them. Here's a simple way to see the difference:
| Fixes the work | Supports the person |
|---|---|
| Reviewing workloads, staffing, and deadlines | An Employee Assistance Program (EAP) |
| Making roles and responsibilities clear | Psychological skills training |
| Consulting workers and planning change carefully | Wellbeing workshops and webinars |
| Giving people more say over how they do their work | Mental Health First Aid |
Both columns matter. But if everything in your plan sits in the right-hand column, the work itself hasn't changed.
Questions to ask about your current program
Here are five quick questions to ask about your own organisation:
Can we name the psychosocial hazards in our work, and show how we identified them?
Apart from wellbeing initiatives, what have we changed in the work itself over the past year, such as workloads, roles, or how change is handled?
Does our wellbeing program teach skills before problems start, or does it mostly help once people are already struggling?
Do our people know where to go for support, and would they feel comfortable using it?
How do we know whether any of it is working?
If the first two questions were hard to answer, that's the gap to close first.
How Healthy Minds brings the two together
At Healthy Minds, we work on both layers.
To manage the risks in the work, we use our 5-Step Compliance Program: Quick Start, Assess, Upskill, Embed, and Sustain. Our psychosocial risk assessments give you a clear picture of where your risks sit. Then our psychosocial hazards training, delivered by registered psychologists, equips leaders to identify emerging risks early and have effective, early conversations with their teams about risk. Leaders keep building their skills through our Forget Me Not® microlearning platform, in five minutes a day.
To support the person, our workplace mental health programs teach the specific skills associated with lower rates of anxiety and depression, and help people become effective self-managers of their wellbeing. They're designed and delivered by registered psychologists, and always supported by scientific evidence.
That way, you can fix the work and support your people at the same time.
Frequently asked questions
Is an EAP enough to meet psychosocial obligations?
Not on its own, in my view. An EAP is a valuable support for people who are struggling, but it doesn't change the hazards in how work is designed and managed. Meeting the duty means looking at the work itself.
Do we need to stop our wellbeing program?
No. A good wellbeing program teaches people skills that help protect their mental health. Keep it, and make sure it sits on top of controls that fix the work, rather than standing in for them.
What should we do first?
Find out where your risks are. Our free Psychosocial Hazard Audit Readiness Checklist takes minutes, and gives you a clear picture of where you stand. From there, a structured psychosocial risk assessment shows you where your risks sit, so you know what to fix first.
Where to from here?
Wellbeing programs and EAPs help your people. Meeting your psychosocial duty means fixing the work as well. You need both.
If you'd like to know where your organisation stands, start with our free Psychosocial Hazard Audit Readiness Checklist.
