Managing Change Under Scrutiny: Lessons from the UTS SafeWork NSW Intervention
Author: Alex Tillman, Principal Consultant
Safe Work NSW Improvement Notice and Managing Risks of Change: Lessons from the UTS Frontline
UTS was in the news in September 2025 for all the wrong reasons. During a major organisational restructure, SafeWork NSW issued a prohibition notice halting aspects of the change process. The regulator intervened over concerns that the proposed redundancy program posed a serious and imminent risk of psychological harm to staff.
This case demonstrated a clear shift in regulatory behaviour. Work Health and Safety (WHS) regulators are no longer waiting for incidents to occur—they are proactively intervening to assess how psychosocial risks are being managed in real time.
The issue is not isolated. It reflects broader concerns across the university sector, highlighted in public commentary such as the recent 60 Minutes episode which examined workplace culture within several universities, including serious cases involving alleged toxic environments and the tragic consequences that can arise. These issues are complex, but they reinforce one point: psychosocial risks can have significant and enduring impacts.
As the Head of Health, Safety and Wellbeing at UTS at the time, I had first-hand experience of what inspectors focus on, how quickly situations escalate, and what organisations must demonstrate under scrutiny
The Context: Organisational Change as a Psychosocial Risk
When I joined UTS in late 2024, a large-scale transformation—the Operational Sustainability Initiative (OSI)—was already underway due to financial pressures. A workforce reduction of approximately 450 roles (close to 10% of FTE) had been announced, creating widespread uncertainty.
As expected, the psychosocial impacts varied. Some employees accepted the direction, while others strongly opposed it. This led to increased tension, heightened emotions, rising workloads, and ongoing engagement with unions and Fair Work.
Organisational change is a well-recognised psychosocial hazard. However, while the risk was acknowledged early by senior management, the formal psychosocial risk assessment did not begin until more than six months into the process.
At the same time, concerns were being raised by staff externally—including directly to SafeWork NSW.
Regulator Involvement: How Quickly Things Can Escalate
By mid-2025, SafeWork NSW had issued formal notices, including two Section 155 requests, requiring UTS to provide detailed evidence of how psychosocial risks were being managed.
The inspector’s initial focus was clear and relatively typical: they were seeking evidence of a structured psychosocial risk assessment process, insight into the previous year’s engagement survey outcomes, and—most importantly—demonstration that identified risks were being actively managed and not simply acknowledged. There was also a strong emphasis on the breadth and quality of consultation with staff.
While the tone of engagement was generally collaborative, the level of scrutiny should not be underestimated. Expectations were high, the detail required was significant, and timelines were often tight. Internally, this created considerable pressure, particularly for teams already managing a complex organisational change.
What followed was an intensive period of regulatory oversight. Inspectors were on site frequently—at times multiple times per week—and communication was ongoing, sometimes daily. Requests for documentation were constant and often required rapid turnaround. At the same time, staff continued to raise concerns directly with SafeWork, often anonymously, which triggered further lines of inquiry and additional requests for evidence.
This flow of external complaints significantly influenced the trajectory of the regulator’s involvement. It reinforced SafeWork’s concerns about whether consultation processes were effective and whether psychosocial risks were being adequately controlled. It also meant that the organisation was not just responding to regulator expectations, but to a continually evolving set of issues being raised from within the workforce.
A key point of tension centred on the psychosocial risk assessment of the proposed changes. Although the assessment had been undertaken in consultation with workforce representatives, there was strong disagreement between management and unions about its broader release. Unions pushed for the assessment to be shared widely with staff before formal change announcements, while management took a different view. This dispute became a focal point in discussions with the regulator and further complicated the consultation narrative.
At the same time, unions were actively encouraging staff to bypass internal channels and raise concerns directly with SafeWork. This contributed to a sustained level of external reporting and ongoing scrutiny. Combined with already high job demands on change and project teams, this created a situation where both the operational and regulatory pressures were escalating in parallel.
Ultimately, it was the combination of delayed formal risk assessment, contested consultation approaches, high workload demands, and continued external escalation that led SafeWork NSW to issue a prohibition notice (the first to be issued in Australia that was directly linked to the management of psychosocial risk), preventing UTS from progressing planned change activities until concerns were addressed. This action—preventing further progress on aspects of the change—highlighted the regulator’s position that psychosocial risk was not being adequately managed at that point in time.
The key takeaway is straightforward: psychosocial risks can result in the same regulatory consequences as physical safety failures, including the cessation of work.
Responding Under Pressure: What Compliance Actually Requires
Once the prohibition notice was issued, the response required immediate, coordinated action across the organisation.
WHS, People & Culture, the Project Management Office, Legal, and operational leaders were all drawn into an intensive response effort. This was not a simple exercise in producing documentation—it required rapidly strengthening consultation processes, clarifying risk controls, and demonstrating, in a way that satisfied the regulator, that risks were being actively managed.
Engagement with SafeWork was continuous throughout this period. Feedback was direct, expectations were explicit, and there was limited tolerance for gaps or ambiguity. Internally, this required a significant uplift in coordination and alignment across functions that do not always operate in a fully integrated way.
The notice was lifted within a week, but only after substantial effort, long hours, and a clear shift in how psychosocial risk management was being demonstrated.
One of the most important lessons from this experience was the regulator’s reliance on evidence. It was repeatedly reinforced that if something was not clearly documented, it was effectively treated as not having been done.
What Regulators are Actually Looking For
This experience made it clear that regulators are not simply assessing whether risks exist. Their focus is on whether organisations can demonstrate a structured, credible, and evidence-based approach to managing those risks.
In practice, this means showing that consultation is both broad and meaningful, not limited to formal committees or representative groups. It also requires risk assessments that are not static documents, but that evolve over time and clearly inform decision-making.
There must also be a demonstrable link between identified risks and the controls implemented, along with clear alignment to psychosocial Codes of Practice and legislative requirements. Without these elements, organisations will struggle to satisfy regulatory expectations.
Key Lessons for Organisations
Psychosocial risk assessments must start early in any change process. Waiting until later stages significantly limits their effectiveness and increases exposure. These assessments are intended to evolve and should be embedded from the outset.
Consultation must be genuine. Regulators are increasingly attuned to the difference between procedural consultation and meaningful engagement. Evidence of real dialogue, responsiveness, and workforce involvement is essential.
Organisations should also expect regulator involvement during major change. It is increasingly common for concerns to be escalated externally, often anonymously, and once regulators become engaged, their involvement can intensify quickly.
Documentation is another non-negotiable. Organisations must be able to clearly demonstrate what has been done, why decisions were made, and how risks have been managed. Without this, even well-intentioned efforts may not stand up to scrutiny.
Finally, effective management of psychosocial risk requires true cross-functional coordination. WHS, HR, legal, project teams, and operational leaders all play a role, and the absence of alignment between these functions will quickly become visible under regulatory review.
Moving Forward
Psychosocial risk management is now firmly established within WHS regulation, and expectations will continue to increase—particularly in the context of organisational change.
Regulator intervention is no longer an outlier. For organisations undergoing complex transformation, it is an increasingly likely scenario.
The challenge is not simply recognising psychosocial risks, but being able to demonstrate—clearly, consistently, and under pressure—that they are being effectively managed.
If you need advice or assistance coordinating your organisation’s response to change, do reach out to me at alex@sharedsafetyandrisk.com.au
