Psychosocial Safety, Managerial Conduct and Disciplinary Decision Making

A recent Queensland Industrial Relations Commission (QIRC) decision highlights a growing focus on psychosocial safety, and the role leadership conduct plays in workplace health and safety.

In Lawrie v State of Queensland (Queensland Health) [2026] QIRC 148, the Commission confirmed that poor managerial behaviour, even without prior disciplinary history, can justify suspension and disciplinary action where it creates risks to employee wellbeing.

Ms Lawrie, a long-serving senior manager at Queensland Health, was subject to disciplinary action following concerns about how she managed and interacted with her team.

While she had no prior disciplinary issues, her employer found that aspects of her leadership raised workplace health and safety concerns, particularly in relation to staff wellbeing.

Ms Lawrie was employed by Queensland Health in a senior managerial role (since 2008) with responsibility for the supervision, development and wellbeing of several direct reports. Disciplinary findings were made against Ms Lawrie, and the matter came before the QIRC on appeal. Ms Lawrie was suspended on pay and extended multiple times, citing workplace health and safety risks to colleagues.

The Commission’s findings were substantiated in part and centred on a pattern of leadership behaviours that, when taken together, fell short of expected standards of a senior manager.

Failure to consult and explain decision‑making

The Commission found that the Appellant failed to genuinely consult with staff or clearly explain key decisions, contrary to the expectations imposed by the Public Sector Code of Conduct. In particular, the obligation to treat colleagues with courtesy and respect and to apply procedural fairness in decision‑making (cll 1.5 and 4.1) was not met.

While the Appellant was not required to adopt the preferences of staff, the evidence supported a conclusion that she did not meaningfully consider their views, or articulate the reasons for the ultimate decisions made. The manner in which decisions were communicated was found to be unfair, unreasonable and discourteous, particularly given staff involvement in prior consultation processes.

Inequitable and inflexible decision‑making

The Commission determined that decisions affecting staff were not always applied consistently or adapted to individual circumstances, including where employees worked part‑time or had caring responsibilities or other protected attributes.

Failure to accommodate flexible work and pregnancy‑related requests

The Commission found that the Appellant failed to appropriately accommodate a request for flexibility made by a pregnant employee. In particular, she did not conduct a risk assessment, consider alternative duties, or properly apply the Parental Leave Policy, despite being responsible for ensuring a safe working environment for pregnant employees. The Commission made clear that reliance on HR advice does not remove a manager’s responsibility for ensuring compliance.

Failure to manage psychosocial risk and uphold WHS obligations

Importantly, the Commission found the manager’s conduct had the potential to negatively impact employees’ psychological health, reinforcing that leadership behaviour itself can be a psychosocial hazard. In light of her seniority, the decision maker was entitled to find that she failed to meet her obligation under section 28 of the Work Health and Safety Act 2011 (Qld), which requires workers to take reasonable care that their actions or omissions do not adversely affect the health and safety of others.

Legislation/Policies applied

• Public Sector Act (2022) – s91(1)(h)
• Queensland Public Service Code of Conduct – Clause 1.5 , Clause 4.1, Clause 4.5
• Parental Leave Policy
• Work Health and Safety Act (2011) (Qld) – s28

This decision outlines that disciplinary findings may be appropriate where managerial conduct undermines staff wellbeing, breaches policy obligations, and gives rise to psychosocial risk.

The case underscores the central role of leadership behaviour, consultation and procedural fairness in maintaining a safe and healthy workplace.

Elevated expectations of senior leaders

Senior managers are held to a higher standard of conduct, including greater awareness, insight and compliance with their obligations. This includes taking reasonable care that their acts or omissions do not adversely affect the health and safety of others. Lengthy tenure or an otherwise unblemished record does not diminish these expectations.

Psychosocial safety extends to process:

Failures in consultation, communication and development support may create psychosocial risk, even in the absence of overt misconduct.

Equity requires engagement:

Equitable treatment does not mandate identical outcomes but does require genuine consultation and evidence‑based reasoning.

Policy compliance is not delegable:

Reliance on HR advice does not absolve managers from responsibility for ensuring policy requirements are met.