This document summarizes the key events and legal cases related to managing psychosocial hazards and vicarious trauma in the workplace. It discusses the case of Zagor Kozarov, a worker who developed PTSD after repeated exposure to trauma survivors' stories. The document outlines the legal precedent set by Kozarov v Victoria, which established that employers have a duty to protect workers' mental health from known risks. It then presents interventions for primary, secondary and tertiary prevention of vicarious trauma, including education, reflective group work, and clinical support.

1. Psychosocial hazards - Managing an emerging trend
Welcome to ASIS International Victoria's
Brett Bridges
Andrew Carroll
Presented by
Sponsors
www.asisvictoria.org.au/

2. 1
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3
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The suffering of others
Kozarov and other drivers of change
Workable Interventions
.
Discussion
Agenda

3. 1
4
3
2
The suffering of others
Agenda

4. A common workplace challenge… EXPOSURE
TO THE
SUFFERING
OF OTHERS

11. • Seeing (e.g. injury, violence; live or
photograph/video)
• Hearing (e.g. screams, crying)
• Smell / taste (e.g. burns)
SENSORY
• Accounts given by others –verbal or
written (e.g. trauma histories, witness
statements, plaintiff statements)
NARRATIVE
Routes of exposure

16. Part of observer’s emotional brain
is activated (‘amygdala’):
• “heightened emotions”
• “adrenalin”
Woodruff & Stevens, 2018

17. Parts of observer’s ‘pain network’ is activated
(‘Insula’ & ‘Cingulate Cortex’):
• ‘flinching’
• Contagion / mirroring Woodruff & Stevens, 2018

18. Parts of observer’s
‘movement brain’ is
activated (‘premotor
cortex’) :
• Impulse to
approach sufferer
Woodruff & Stevens, 2018

21. It is possible to become “stuck”
in this stage…
Woodruff & Stevens, 2018

22. Woodruff & Stevens, 2018

23. Prefrontal cortex
activated :
• more
deliberative
• less rapid
• “what is going
on ?”
• Self-other
differentiation
Woodruff & Stevens, 2018

24. Activation of these higher
centres of the brain 
transition to “helping the
other”
Woodruff & Stevens, 2018

26. “Hyper-
eversion of the
foot +
Fractured
tibia”

27. Repeated exposure to
the suffering of others:
Vicarious
Traumatisation
A wide range of
outcomes (not
mutually exclusive; not
an exhaustive list)
Personal growth:
resilience ;
enhanced
compassion
Compassion
fatigue
Altered sense of
self, world
Clinical disorders:
PTSD, Major
Depression

28. “Vicarious
Trauma”
Exhaustion
Cynicism
Altered thinking
about safety, trust,
power and
intimacy
Apathy
Irritability
Disillusionment
Isobel, S & ANGUS-LEPPAN, G. 2018

29. Vicarious
Trauma
Exhaustion
Cynicism
Altered thinking
about safety, trust,
power and
intimacy
Apathy
Irritability
Disillusionment

30. 1
4
3
2 Kozarov and other drivers of change
Agenda

31. 2005
Koehler v Cerebos (Australia)
Ltd [2005] HCA 15
• Sales rep developed psychiatric
injury after multiple complaints of
excessive workload
“the employer engaging an employee
to perform stated duties is entitled to
assume, in the absence of evident signs
warning of the possibility of
psychiatric injury, that the employee
considers that he or she is able to do
the job.”

32. 2005 2007
Koehler v Cerebos
(Australia) Ltd
[2005] HCA 15
OPP SSOU established
By 2008 had a ‘Vicarious Trauma Policy’,
which identified that vicarious trauma
was an OH&S issue : “an unavoidable
consequence of undertaking work with
survivors of trauma … in particular, the
survivors of sexual assault" and that VT
could have "detrimental, cumulative and
prolonged effects".

33. 2005 2007
June
2009
Ms Kozarov
starts work at
SSOU
“The appellant's work in
the SSOU routinely
involved interaction with
survivors of trauma and
exposure to their traumatic
experiences.”
Koehler v Cerebos
(Australia) Ltd
[2005] HCA 15
OPP SSOU
established

34. 2005 2007 June
2009
Late
2010
Ms Kozarov discloses symptoms
“became increasingly vocal at staff meetings …about
how work was affecting her daily life, including
describing feelings of paranoia about leaving her
children with other people, including at activities and
with school teachers, her refusal to allow her son to
be an altar boy, and dreaming of her children being
the complainants in her matters.”
.
Koehler v Cerebos
(Australia) Ltd
[2005] HCA 15
OPP SSOU
established
Ms Kozarov
starts work at
SSOU

35. 2005 2007 June
2009
Late
2010
April
2011
Psychiatric Injury
“Ms Kozarov's mental illness
manifested in April 2011
when she began to suffer
from post-traumatic stress
disorder ("PTSD").”
Koehler v Cerebos
(Australia) Ltd
[2005] HCA 15
OPP SSOU
established
Ms Kozarov
discloses
symptoms
Ms Kozarov
starts work at
SSOU

36. 2005 2007 June
2009
Late
2010
2011 2012
Employment
terminated
“February 2012, the appellant requested
that she be moved out of the SSOU.
Thereafter, there were attempts to return
the appellant to work at the OPP in
different areas until 20 April 2012. Those
attempts were unsuccessful and,
consequently, the appellant's
employment was terminated.”
Koehler v Cerebos
(Australia) Ltd
[2005] HCA 15
OPP SSOU
established
Psychiatric Injury
Ms Kozarov
discloses
symptoms
Ms Kozarov
starts work at
SSOU

37. ZAGI KOZAROV v
STATE OF VICTORIA
[2020] VSC 78
Dixon J
• Ms Kozarov awarded
>$400,000
• “knowledge of the VT
policy by staff and
management was
desultory.”

38. ZAGI KOZAROV v STATE OF
VICTORIA
[2020] VSC 78
Dixon J
A safe system of work should have included:
• “an active OH&S framework”
• “more intensive training for management
and staff regarding the risks to staff posed by
by vicarious trauma and PTSD”
• “welfare checks and the offer of referral for
a work-related or occupational screening, in
in response to staff showing heightened risk”
risk”
• “a flexible approach to work allocation,
especially where required in response to
screening, including the option of temporary
temporary or permanent rotation from the
SSOU where appropriate".

39. STATE OF VICTORIA
v ZAGI KOZAROV
[2020] VSCA 301
Successful appeal by
State on causation
grounds
 Ms Kozarov takes
matter to the High
Court

40. Kozarov v Victoria [2022] HCA 12
Date of Judgment: 13 April 2022
“Koehler was concerned with the extent to which
reasonable care for the mental health of an
employee may require the employer to be alert
for signs that, by reason of the exigencies of the
employee's work, the employee is at risk of
mental illness. On the undisputed findings of fact
in this case, no question truly arose as to whether
the employer was duty-bound to be alert in this
regard.”

41. Kozarov v Victoria [2022] HCA 12
Date of Judgment: 13 April 2022
“management of the SSOU were duty-bound to exercise
reasonable care to protect Ms Kozarov against risks to
her mental health that were actually known to the
respondent. That this was so is readily apparent from
the terms of the Vicarious Trauma Policy adopted by the
respondent for the protection of the psychiatric health of
employees within the SSOU before Ms Kozarov's
employment commenced. No further warning signs were
necessary to establish that the content of the duty of
care owed by the respondent to Ms Kozarov included
active steps for the care of the psychiatric health of Ms
Kozarov and her fellow employees within the SSOU.”

42. Kozarov v Victoria [2022] HCA 12
Date of Judgment: 13 April 2022
“the circumstances of a particular type of
employment may be such that the work to be
performed by the employee is inherently and
obviously dangerous to the psychiatric health of
the employee (just as other kinds of work are
inherently and obviously dangerous to the
physical health of the employee). In any such
case, the employer is duty-bound to be proactive
in the provision of measures to enable the work
to be performed safely by the employee. The
present was such a case.”
Appeal succeeded

43. PRIMARY prevention
(Universal: reduce risk of
disease e.g. vaccines)

44. PRIMARY
SECONDARY
prevention
(Targetted: intervene
early when early signs
of disease emerge)

45. PRIMARY
SECONDARY
TERTIARY
prevention
(Treat disease to reduce complications
and disability)

46. PRIMARY
prevention
SECONDARY
prevention
TERTIARY
prevention
Employer duties
under Koelher ?

47. PRIMARY
prevention
SECONDARY
prevention
TERTIARY
prevention
Employer duties,
in some
circumstances,
after Kozarov ?

48. Drivers for
workplace
change
Case Law:
Kozarov
Boland Review of Model Work H&S Laws 
OH&S Amendment (Psychological Health)
Regulations  requirements:
• Identify psychosocial hazards inc.
“exposure to traumatic events or content”
• Control associated risks to H&S by:
1. “altering the systems of work…”; or
2. “using information, instruction or training”; or
3. “a combination of (1) and (2)”.
Impacts of COVID:
• recruitment/retention crisis
• increase in workers’ power
• cultural shift re: workplace mental health
Productivity Commission
Inquiry Report Mental Health
2020 :
Recognition that better mental health
 higher productivity:
Priority recommended reforms include:
• Equip workplaces to be mentally healthy
• Elevate importance of psychological H&S
in workplaces

49. 1
4
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Workable Interventions
.
Agenda

50. PRIMARY
prevention
(Universal)
SECONDARY
prevention
TERTIARY
prevention • Access to clinical supports:
psychology, psychiatry
• Policies re: sick leave, supported returns
to work etc.

51. PRIMARY prevention
(Universal)
SECONDARY
prevention
• EAP
• Other management measures

52. PRIMARY prevention
(Universal: ALL STAFF)
• Basic education and training for all staff in VT
• Access to group reflective work
• Specific debriefing (caution!)
• Integrated within broader measures:
e.g. wellbeing, culture, work demands…

53. PRIMARY prevention
(Universal: ALL STAFF)
• Basic education and training for all staff in VT

54. 1
2
3
Online seminar in form of
mp4s
Complimented by live
masterclasses
Augmented by reflective
group work
Basic education and training for all staff in VT

55. PRIMARY prevention
(Universal: ALL STAFF)
• Access to group reflective work

56. Cascade model
Consulting mental health professional:
• expert group facilitator
• provides ongoing reflective work /
training / support for Group Leaders
• mainly in Group format

57. Cascade model
Group Leaders:
• experienced staff peers with extra training and support
• each lead a small number of Reflective Work Groups

58. Cascade model
All workers can access small, regular, Reflective Work groups

59. Why ‘Reflective Work’ ?
• Best defence against prolonged, unhelpful
responses to transferred trauma =
becoming aware of effects as they occur
Based on Isobel, S & Angus-Leppan, G. 2018

60. Why ‘Reflective Work’ ?
• Best defence against prolonged, unhelpful responses to
transferred trauma = becoming aware of effects as they occur
• Recognition of automatic responses 
higher cortical centres recruited 
integrate and contextualise responses to
trauma  resolution.
Based on Isobel, S & Angus-Leppan, G. 2018

61. Why ‘Reflective Work’ ?
• Best defence against prolonged, unhelpful responses to
transferred trauma = becoming aware of effects as they occur
• Recognition of automatic responses  higher cortical centres
recruited  integrate and contextualise responses to trauma 
resolution.
Woodruff & Stevens, 2018
Reflective work / peer support processing 
further understanding of responses 
compassionate (focus on helping the other) and
effective working
Based on Isobel, S & Angus-Leppan, G. 2018

62. Our diverse skills can bring unique awareness to a particular
issue or particular knowledge gap and potential responses
Reflection creates opportunities to catch repetitious,
unhelpful responses along with potential ‘blind spots’
Diverse values become a valuable resource once
overted and equally considered
A supportive and inquiring process supports new learnings and
desired culture underpinned by organisational values
Thinking ‘outside the square’, ‘devil’s advocate’ and
‘challenging the status quo’ are all encouraged as a valuable
guard against ‘groupthink’ and ‘hierarchical stances’

63. Effective and pragmatic
Meets regulatory guidance
Affordable
NOT ‘pathologising’ or ‘clinical’
Internal co-workers / professional peers NOT
external mental health/wellbeing experts are
at the core
Building a workable approach to vicarious
trauma in the workplace…

64. 1
4
3
2
The suffering of others
Kozarov and other drivers of change
Workable Interventions
.
Discussion
Agenda

65. www.ourcuriousminds.com