When hazard reporting increases, Boards should lean in – not push back
Recently, a fellow LinkedIn member shared an example of what can happen when hazard reporting starts to work too well. Their organisation had introduced a new mobile hazard identification system across multiple sites. Staff embraced it…hazard reports went up, and injuries went down.
But instead of celebrating the Board Chair instructed the team to "stop finding problems".
That reaction is telling. What was actually a sign of an engaged workforce and a potentially safer workplace was reframed as an inconvenience to the Board. And it highlights a critical gap – some Boards still don’t understand their officer duties under Work Health and Safety legislation.
Officer duties under Work Health and Safety legislation
Under the Work Health and Safety (WHS) Act, Officers have a duty to exercise due diligence to ensure that the business meets its WHS duties to protect workers and other persons against harm to health and safety. This means they must:
· Understand WHS risks in their organisation
· Ensure appropriate resources and processes are in place to eliminate or minimise risks to health and safety
· Verify that these processes are both implemented and effective.
Australian WHS Regulators are clear. If an Officer fails to exercise due diligence, they can be held individually liable. Penalties can include significant fines and in the most serious cases, imprisonment. Discouraging staff from reporting hazards or creating a culture where reporting WHS issues is seen as a nuisance could be considered evidence of a breach of WHS legislation if an investigation occurs.
When More Hazards = More Safety
When a new hazard identification platform is introduced, it’s normal to see an initial spike in hazard, near miss and incident reports coming through. Far from being a problem, this is actually a sign of a successful ‘go live’. For example:
· Staff engagement – people feel empowered to speak up.
· Better data – hazards and risks that were invisible now become visible.
· Opportunities for action – Leadership and the Board have real information to assist guide decisions, allocation resources and prevent harm before it happens.
Handled well, we would expect to see fewer injuries, a stronger safety culture, more efficient business processes and reduced organisational risk.
What if the spike isn’t related to the new platform?
Not every increase in hazard reporting is linked to a new platform. Sometimes it reflects a deep shift in culture. Perhaps a new leader who’s modelling psychological safety. A recent incident that’s prompted reflection or a growing sense of trust that speaking up will lead to action. But it can also signal that WHS controls are slipping, or that the safety culture is under strain. Either way, Boards should treat a spike as a prompt to lean in.
Ask: ‘What’s changed in our environment? What are workers trying to tell us?’
A rise in reporting, regardless of the trigger, is an opportunity to listen, learn and lead. It’s also a practical moment to verify that WHS risks are being identified, controls are effective and compliance with WHS legislation remains strong.
What Boards should do
When your organisation rolls out a new hazard reporting system, or sees a spike in reports for any reason:
1. Expect a spike after the implementation of a new reporting system. An increase in reports means the system (or culture) is doing its job. It’s a sign that risks are being surfaced, not created.
2. Ask the right questions. What patterns are emerging? What corrective actions are being taken? Could this signal that WHS controls or culture are slipping?
3. Treat it as a governance checkpoint: Use a spike to verify that WHS risks are being identified, controls are effective and compliance with WHS legislation is being maintained (preferably exceeded).
4. Back your staff. Make it clear that raising hazards is encouraged and contributes to safer outcomes. Psychological safety starts at the top.
5. Invest in your own learning. Non-Executive Directors should undertake some type of Officer training so you understand both your duties, what regulators expect and so you can confidently lead through complexity.
Final Thought
Discouraging hazard reporting does not reduce risk… it conceals it.
A strong reporting culture is one of the tools a Board can use to understand what’s happening ‘on the ground’ and to help meet their WHS obligations with confidence.
As regulators sharpen their focus on Officer duties, Boards must ensure they not only welcome hazard reports but ensure their Leadership Teams actively use them to strengthen systems, verify controls and support safer outcomes. Anything less puts both the workforce, and the Officers themselves, at risk.
I’d love to hear your thoughts How has your Board approached hazard reporting spikes? And if your Board would benefit from practical guidance on Officer duties, I’d be happy to help.