31 August 2026
For a psychological injury return to work, the document regulators ask for is the one you own
Queensland's work health and safety regulator has set out, in plain terms, the two documents behind a safe return to work after a psychological injury, and the distinction matters more than it looks.
The first is the rehabilitation and return to work plan. It is a collaborative roadmap, usually led by the insurer with the worker, the employer and treating providers. It covers return to work goals, treatment, current work capacity, suitable duties, restrictions, workplace adjustments and review dates.
The second is the suitable duties program. This one is the employer's to build. It is a practical, task-level plan: what the worker can safely do, how many hours and days, over what timeframe, with what restrictions, and how duties step back up as capacity improves. It sits inside the return to work plan and gives it day-to-day structure.
Here is the part worth underlining. The return to work plan is largely driven by people outside your organisation. The suitable duties program is not. If an inspector or a tribunal asks how you managed a psychological injury claim, the suitable duties program, and the record of how it was reviewed and adjusted, is the evidence that is yours to produce or yours to be missing.
In Queensland the duty to provide suitable duties in writing sits in section 228 of the Workers' Compensation and Rehabilitation Act. Other jurisdictions frame it differently, but the direction is the same: written, specific, reviewed.
A simple test for your own process. For your last psychological injury matter, can you produce a dated suitable duties plan, the named person who owned it, and the review points where it changed as the worker recovered? If that record is a folder of emails, it will not read as a managed process when it matters.
This is the same discipline psychosocial risk management already asks for on the prevention side: named hazards, named owners, dated reviews, monitoring you can show. Return to work is the other end of the same evidence chain.
General information only, not legal advice. Correct as at 31 August 2026. Seek independent advice for your specific circumstances.