産業保健法学会誌 英文誌
Online ISSN : 2758-4755
Print ISSN : 2758-4771
Position Paper
The Governance Gap in Psychosocial Risk Evaluation
Yannick A. Metzler Svenja MüllerLuis TorresAditya Jain
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2026 年 5 巻 2 号 論文ID: pp.26-004

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The assessment and management of work-related psychosocial risks is mandated across many jurisdictions, yet a critical governance gap persists: there is little consensus on the point at which measured psychosocial hazard exposure constitutes an actionable risk requiring intervention. While physical and chemical risk assessment benefits from occupational exposure limits established through transparent, deliberative processes, psychosocial risk evaluation currently lacks equivalent mechanisms. The question of when exposure becomes an unacceptable risk is answered implicitly through methodological choices that are seldom articulated or justified. This position paper addresses this governance gap by distinguishing three logics of risk evaluation: predictive (risk as a statistical association with outcomes), normative (risk as a deviation from reference standards), and weighted (risk as frequency × severity prioritization). We analyze the conceptual foundations, governance implications, and practical trade-offs of each approach. Because each logic embeds different assumptions about when intervention is warranted, method choice is not a neutral technical decision but a governance choice that encodes assumptions about acceptable working conditions and employer obligations. We call for explicit governance processes that make methodological choices visible, debatable, and accountable, including documentation requirements, sector-level guidance on method selection, and inspector training on methodological adequacy. The challenge is not a lack of knowledge but the need for coordinated action to develop governance infrastructure for psychosocial risk evaluation comparable to that achieved in chemical and physical risk assessment.

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© 2026 The Japan Association of Occupational Health Law
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