Psychosocial Hazards on Victorian Farms: What Labour Hire Providers and Hosts Must Do in 2026

Featured image: illustrative discussion, not a specific Orchard Tech workplace or named worker.

Reviewed 8 September 2026 | Victoria. The Occupational Health and Safety (Psychological Health) Regulations 2025 have applied since 1 December 2025. This article explains current duties and practical action.

Two supervisors give a packing crew different priorities. One wants speed; the other rejects work that does not meet the quality standard. The workers cannot tell which instruction takes precedence, and asking for clarification earns an irritated response.

This hypothetical situation shows how psychosocial hazards on Victorian farms can develop through ordinary work decisions. The problem to examine is the conflicting direction, pressure and lack of support. A talk about coping with stress would leave those conditions in place.

What are the current legal duties?

Victoria’s Psychological Health Regulations sit under the Occupational Health and Safety Act 2004. Psychological health was already part of employers’ OHS responsibilities before these regulations commenced.

Regulations 14–16 require employers to identify psychosocial hazards so far as is reasonably practicable, eliminate associated risks so far as is reasonably practicable, or reduce them so far as is reasonably practicable where elimination is not reasonably practicable. Employers must also review controls and revise them where necessary in the circumstances specified by regulation 16.

These duties concern factors in the work and working environment that can create risks to health or safety. They are not a request for supervisors to diagnose workers. See the authorised regulations, particularly regulations 4 and 14–16.

Both the provider and the host have responsibilities

In a labour hire placement, the host and provider both have duties to the worker. Section 35A of the OHS Act requires them to consult, cooperate and coordinate with each other, so far as is reasonably practicable, where they share duties.

Employers must also consult affected employees so far as is reasonably practicable. Where employees have a health and safety representative (HSR), that representative must be involved. WorkSafe’s compliance code explains these duties and the consultation process.

For the packing-crew example, the host could resolve competing production instructions and nominate the person who sets priorities. The provider could check privately with workers whether the new arrangement is clear and raise continuing problems with the host. Both would need to follow through on their respective actions.

Four farm situations worth examining

The following are illustrative examples for discussion, not findings about an Orchard Tech workplace or a complete risk assessment.

1. The target stays the same after the crew shrinks

Several workers are absent, but the remaining crew is expected to complete the same volume. Breaks become difficult to take and supervisors keep asking people to hurry.

Look at the workload against the available people, equipment and time. Possible responses include revising the target, re-sequencing work or arranging suitable additional resources. Ask workers which part of the shift is becoming unmanageable, rather than assuming the difficulty is a lack of effort.

2. A new starter has nobody available to help

The worker received an induction, but the nominated supervisor is usually in another block. When a task changes, the worker guesses what to do.

Check whether assistance is actually available during the shift. Arrange reliable cover, clarify who can answer task questions and revisit supervision when duties change. WorkSafe’s practical guidance on poor support discusses clear reporting lines, help with demanding tasks and constructive feedback.

3. The only reporting contact is the subject of the concern

A worker wants to raise repeated humiliating remarks by a supervisor. The induction sheet directs every concern to that same supervisor.

Provide another accessible contact and explain how a concern will be handled. Check immediate safety needs, respond fairly and limit disclosure to what is needed for the response. Do not promise absolute confidentiality that the process cannot deliver. Workers should be able to understand the reporting route without having to describe a personal matter in front of the crew.

4. The roster overlooks isolated work

A late task places one worker away from the rest of the team. The roster identifies the location but says nothing about communication or available assistance.

Examine whether the work needs to be done alone, how support will be reached and what happens if contact fails. A phone number on a noticeboard is of limited use where reception is unreliable or nobody is assigned to respond.

Change the source of the risk

Regulation 15 gives priority to eliminating risk. Where that is not reasonably practicable, employers must reduce risk through the permitted controls, including changes to work management, plant, systems, work design or the workplace environment.

Employers may rely solely on information, instruction or training only where none of those other controls is reasonably practicable. If controls are combined, information, instruction or training must not be the predominant measure. WorkSafe explains the control requirements here.

For example, clearer instructions will help the packing crew only if the supervisors also agree on priorities and stop issuing incompatible directions. Support services may help an individual, but employers must still address the work conditions creating the risk.

Ask about the work, then listen to the answer

Useful questions can be specific: “When do you receive conflicting instructions?” “Can you get help when the task changes?” “Is there a part of the shift where the expected pace becomes difficult to manage safely?”

Make the conversation accessible across shifts and languages. Explain proposed changes, allow workers to raise concerns and take their views into account. A briefing that only announces a decision gives workers little opportunity to influence it.

WorkSafe cautions that few or no incident reports do not establish that hazards are absent. People may be reluctant to report. Look at how work is performed and how hazards interact, as well as the formal records.

A supervisor checklist for the next shift

This is a suggested discussion aid, not a prescribed form or proof of compliance:

• Are priorities clear, including who resolves conflicting instructions?
• Does the planned workload reflect today’s staffing and equipment?
• Can every worker reach someone who can provide practical help?
• Is there an alternative contact for concerns about a supervisor?
• Have affected workers and any HSR been involved in relevant decisions?
• Who will check whether the agreed changes worked?

Record the hazard, agreed control, action owner and follow-up result. Keep personal allegations and medical information out of a broadly circulated shift checklist. For wider operational planning, see our Victorian harvest workforce checklist.

Review when circumstances change

Regulation 16 includes review triggers such as a report of a psychosocial hazard or psychological injury, new information, proposed changes to work likely to alter the risk, controls that are inadequate, relevant notifiable incidents and qualifying HSR requests. Review controls before relevant work changes, and review and revise them where necessary when other triggers arise; do not wait for an annual policy review. WorkSafe sets out the triggers and HSR provisions.

In the packing-crew example, follow-up could ask whether conflicting instructions have stopped and whether workers can raise a problem without being dismissed. If the answer is no, an updated procedure has not resolved the problem.

Two common points of confusion

Is WorkSafe’s prevention-plan template compulsory? No. WorkSafe encourages its use, but the template itself is not mandatory. The duties to identify hazards and control risks still apply.

Do these regulations determine WorkCover eligibility? No. Workers compensation eligibility is governed separately by the Workplace Injury Rehabilitation and Compensation Act 2013. Prevention duties should not be confused with whether a particular claim is accepted. Both points are covered in WorkSafe’s frequently asked questions.

Build the discussion into the placement

When planning a labour hire placement, discuss workload, supervision, communication and how concerns will be resolved alongside the tasks and worker numbers. Our October labour hire licensing article covers the separate supplier checks. To discuss your workforce requirements, visit Orchard Tech’s employer enquiry page.

General information for Victorian workplaces, checked 8 September 2026. Examples require assessment against the actual work and workforce. This article does not replace the legislation, a workplace risk assessment or advice on a specific situation.