Almost 10,000 submissions in 7 years: what one operator's consultation process actually proves

Daryl Marshall, National Safety and Compliance Manager at Asplundh Tree Expert Australia, put the underlying problem with most consultation processes better than most regulators have: "if workers can't tell you the truth, no dashboard, procedure, audit or KPI will give you a complete picture of risk." Asplundh's response wasn't a new policy. It was a change to how consultation actually happens. Field workers, often dispersed across remote and regional sites, submit near-misses, hazards and improvement ideas through anonymous online tools rather than up a chain of supervisors. Over seven years, that's produced almost 10,000 submissions. The number itself isn't the point. What it demonstrates is the difference between a consultation obligation that exists on paper and one that produces an actual evidence trail. Under WHS Regulation Part 3.1A, consultation with workers about psychosocial hazards isn't a box to tick once a year, it's an ongoing duty, and increasingly the question a regulator or a court will ask isn't "did you consult," it's "what did workers tell you, what did you do about it, and what changed as a result." A verbal open-door policy can't answer that question. A dated, attributable submission record can. For organisations with dispersed or field-based workforces, hierarchy is often the biggest barrier to honest consultation, not apathy. A worker raising an issue with a direct supervisor who controls their shifts is in a structurally different position to one submitting anonymously through a tool nobody can trace back to them. Asplundh's model removes that barrier and, as a side effect, builds exactly the kind of documented record that supports a defensible position under s.19(1) of the WHS Act: not just that controls exist, but that they were built on what workers actually said. The practical test for any PCBU reviewing their own consultation process: if an inspector asked to see what workers raised about a specific hazard in the last twelve months, and what was done in response, could you produce it? If the honest answer is "we'd have to ask around," that's the gap Asplundh's approach has already closed.