The Australian Journal of Public Administration, vol. 69, no. 1, pp. 47–60 doi:10.1111/j.1467-8500.2010.00669.

RESEARCH AND EVALUATION

Workplace Bullying Policy in the Australian Public

Sector: Why Has Gender Been Ignored?

Jacquie Hutchinson and Joan Eveline

UWA Business School

This article examines the question of gender-neutral workplace bullying policy in the Aus-
tralian context. It draws on the international workplace bullying literature and interview data
gathered from policy actors located in Australian public service administrations, including
managers, policy implementors and employee advocates. Our findings show that both the
literature and the policy actors tend to present workplace bullying as a product of individu-
alised behaviour, overlooking the nuances and dimensions of organisational power relations
that include gender. As part of this tendency, policy actors insisted that workplace bullying
be represented as gender-neutral. Our analysis reveals two key factors underpinning the
defence and dissemination of workplace bullying as a gender-neutral problem: the tendency
to individualistic remedies in public sector policies; and the idea among policy actors that
if workplace bullying was portrayed as needing gender analysis, its current support as an
important organisational issue would dissolve.

Key words: workplace bullying, gender-neutral policy, gendered organisation

As a theme in workplace bullying, the ques-
tion of gender shows an intriguing contradic-
tion. On the one hand considerable effort goes
into producing the idea of workplace bullying
as gender-neutral, and indeed Australian poli-
cies are developed strictly on that basis. On the
other hand there is substantial evidence from
around the world that the organisational con-
text in which workplace bullying arises is pro-
foundly gendered, which begs the question of
why and how workplace bullying policies can
and should be developed as if gender has no
relevance.
This article examines that question of
gender-neutral workplace bullying policy in the
Australian context. It draws on two key sources:
the international workplace bullying literature;
and interview data with policy actors in the
Australian public sector, including senior man-
agers, policy implementors and employee ad-
vocates. We show that both the literature and
the policy actors tend to deny the relevance of
gender to workplace bullying policy.

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Our argument for how and why they do so
draws on the theory of the gendered organi-
sation (Acker 1990), and methodologically on
Carol Bacchi’s (1999) ‘what’s the problem rep-
resented to be’ (WPR) framework for assessing
policy development. These help provide what
we see as a necessity – an organisational and
gender analysis applied to the topic of work-
place bullying.
By using these frameworks, the article is able
to show the effort that goes into situating work-
place bullying policy as gender-neutral. The
analysis is particularly concerned with how
such a representation is subsequently dissemi-
nated and defended. We argue that behind the
effort to defend workplace bullying as a gender-
neutral problem lie two key factors: the ten-
dency to individualise problems and remedies
in public sector policies; and the apparent as-
sumption among policy actors that if workplace
bullying was portrayed as needing a gender
analysis then current support for it as an im-
portant organisational issue would dissolve.
48 Workplace Bullying Policy in the Australian Public Sector
The article is organised to make our case
through an examination of how workplace bul-
lying policy is shaped by the gender-neutral
frameworks of occupational health and safety
and workplace discrimination. A central aspect
of this examination is the role of policy actors
in advocating and defending the importance
of a gender-neutral construction of workplace
bullying.
Literature Review
Workplace bullying, despite its comparatively
short history as an issue for academic enquiry,
has generated a significant body of research,
that is nonetheless within a narrow band of the-
orisation. The dominant theorisation of work-
place bullying individualises the phenomenon,
and emphasises its interpersonal nature and a
set of specific characteristics. Not surprisingly,
this individualising of the behaviour has also
shaped the ways in which organisations have
responded to workplace bullying. There are
two important indicators that point to the gen-
eral ineffectiveness of such approaches: a very
small ‘take-up’ by workers (Hoel, Sparks and
Cooper 2001; Rayner, Hoel and Cooper 2002);
and the under-reporting of incidents (Chappell
and Di Martino 2000). Further, in reviewing
the available European research literature into
workplace bullying and examining the absence
of effective policy interventions, the European
Foundation for the Improvement of Living and
Working Conditions concluded that the domi-
nance of traditional theoretical perspectives and
their methodologies have had limited impact on
prevention of workplace bullying (Di Martino,
Hoel and Cooper 2003).
Concerned researchers have attributed pol-
icy failure to a ‘gap’ between these dominant
problem representations of workplace bullying
and the way workers represent the problem
themselves (Liefooghe and Mackenzie-Davey
2003; McCarthy 2003). As Liefooghe and
Olafsson (1999) argue, the result of this gap has
been to legitimate the ‘expert’ definition and
to disregard, and therefore invalidate and make
invisible, the experiences of ordinary people.
For example, policies reduce workplace bul-
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lying to problems that are observable individ-
ual behaviours, rather than systemic, less vis-
ible acts, and therefore overlook the nuances
and dimensions of power relations (Liefooghe
and Mackenzie-Davey 2003) such as gen-
der (Jones 2006; Simpson and Cohen 2004)
and cultural factors (Dale and Acik 2005).
These representations are linked to a ‘normali
sing’ of workplace bullying in high-pressured,
competitive working environments (McCarthy,
Sheehan and Kearns 1995; Ironside and Seifert
2003), where the line is blurred between legit-
imate organisational behaviour and workplace
bullying.
The material effect of narrow representa-
tions of workplace bullying that fail to en-
compass broader themes such as gender is
demonstrated by a recent Victorian study into
women and workplace violence. Five factors
were seen to contribute to women’s reluctance
to seek protection through organisational inter-
vention policies. These factors were: violence
was seen as a workplace norm and therefore an
accepted aspect of organisational culture and
behaviour; fear of victimisation including esca-
lating violence; job loss; the traumatic nature
of the intervention processes; and ‘. . .a lack
of faith in the system, often believing the vi-
olence is known and condoned by managers’
(Dale and Acik 2005:50). The absence of a
deeper gender analysis of workplace bullying
obscures the gendered character of organisa-
tions and the ways that gender inequality is en-
trenched in organisational cultures, structures,
policies and daily practices (Hearn and Parkin
2001; Simpson and Cohen 2004) that produce
unequal outcomes for women and men (Acker
1990; Eveline and Bacchi 2005).
Gender and Workplace Bullying
Several critics have charged the workplace bul-
lying literature with failing to provide a satis-
factory analysis of gender (Simpson and Cohen
2004; Jones 2006; McGinley 2007). For a start
many researchers maintain that sex and gender
have minimal relevance to bullying. Part of the
problem here is that such scholars narrowly de-
fine gender by ‘focusing on the biological sex
of the perpetrators and the victims’ (McGinley
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 Hutchinson and Eveline
2007:14). Thus, while the majority of studies
identifies men as bullies and women as tar-
gets (Hoel, Sparks and and Cooper 2001; Salin
2001), they nonetheless tend to represent work-
place bullying as gender-neutral.
A closer look at these studies reveals consid-
erable differences between men and women.
For example, men are more likely to be bul-
lied by other men, while women are also
bullied largely by men but also by women
(Einarsen 2000). Those industries and organ-
isations where there is a predominance of
women, such as education and health, are
consistently identified as high risk working
environments (Thompson 2002; Di Martino,
Hoel and Cooper 2003; Keashly and Jagatic
2003). In addition, a number of researchers
have pointed to women in senior manage-
ment roles experiencing higher levels of bul-
lying, from supervisors, colleagues and sub-
ordinates, than their male peers (Salin 2001;
Tehrani 2004; Jones 2006). Further, there is a
growing body of evidence that there are dif-
ferent types of workplace bullying directed
towards women and men (Mayhew and
Chappell 2001; Salin 2001; Simpson and Co-
hen 2004). For example, women are more likely
than men to be subjected to what Cortina et al.
(2002) describe as ‘gender incivility’. These
behaviours include public disparagement and
condescension that is often sexist in nature such
as calling women ‘honey’ or ‘sweetie’. Men,
however, rarely report this type of personalised
behaviour.
When it comes to bullying policies, how-
ever, the workplace bullying prevention liter-
ature largely ignores these particularities and
opts for a gender-neutral approach. Gender is
dismissed as an issue, with researchers observ-
ing that women and men can be both perpetra-
tors and targets. Below we look at how policy
actors account for this contradiction in the way
that bullying policy represents ‘the problem’ of
workplace bullying. First, however, we outline
Acker’s theory of the gendered organisation,
which critiques a gender-neutral analysis of or-
ganisational practices, and Bacchi’s critique of
the current problem-solving paradigm that un-
reflexively constitutes problems in and through
policy.
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Theory and Methodology
Acker’s theory of the gendered organisation has
provided a touchstone for the dialogue between
organisational and feminist theorists for almost
two decades, and has been augmented to inte-
grate the sociological dimensions of class and
race. Her original account outlines five sets of
processes through which organisations are gen-
dered (Acker 1990). The first is the construc-
tion of gendered divisions of work, such as the
segregation of occupations and masculinisa-
tion of upper management, all of which dictate
acceptable behaviours, allocation of resources,
and distribution of power. These divisions are
linked to and actively reinforce gendered divi-
sions that are present within the family, the state
and the labour market. The second set of pro-
cesses is concerned with the construction and
dissemination of symbols and images that rein-
force, communicate and occasionally challenge
the divisions of work. Many of these represen-
tations are derived from the media and popular
culture and include images of managers as em-
bodying strong masculine attributes. The third
set of processes contributes to gendered rela-
tions between women and women, women and
men, men and men. These interactions encom-
pass power relations and reflect the social roles
of men as being active doers and women as
passive supporters and consumers. The fourth
group of processes contributes to the gendered
nature of an individual’s identity and is influ-
enced by how gender is represented in an organ-
isation through processes such as occupational
choice, clothing, language and the aligning of
one’s self with the gendered norms of the or-
ganisation. Acker’s final set of organisational
processes is concerned with the ‘ongoing pro-
cesses of creating and conceptualising social
structures’ (Acker 1990:147).
Acker’s theory has been widely used for un-
derstanding how an organisation is gendered
and to counter the production of gender in-
equalities. However, Acker herself puzzles that
even when the gendered organisation is repre-
sented empirically ‘. . .why is it so difficult to
make organisational changes that will contin-
ually generate gender equity in work organi-
sations?’ (Acker 2000:625). In answering this
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50 Workplace Bullying Policy in the Australian Public Sector
question, we have applied a gender lens ap-
proach (Kolb and Merrill-Sands 1999:196) to
extend our view beyond the visible organisa-
tional policies and processes to consider the
less visible gender dynamics that produce the
inherent inequalities between women and men
and produce gendered power relations that un-
derpin workplace bullying. While the visible
structural barriers to equity have been removed,
a ‘gender lens’ allows us to concentrate on
problems that remain invisible and subtle. As
Meyerson and Fletcher (2000:127) state: ‘Most
of the barriers that persist today are insidi-
ous – a revolution couldn’t find them to blast
away’. The second salient feature of a gen-
der lens approach is that it provides a practical
framework by which people in an organisation
develop ‘. . .new ways of understanding and
talking about gender equity, norms and work
practices in the organisation’ (Kolb and
Merrill-Sands 1999:9).
A key element in understanding how an or-
ganisation is gendered is to assess the role
of policy in determining organisational prac-
tices, and for that we turn to policy analyst
Carol Bacchi (1999). Bacchi’s methodology
for evaluating policy effectiveness, which she
calls the ‘what’s the problem represented to
be?’ approach, draws on the conceptual frame-
works of post-structuralism, including Fou-
cault’s power/knowledge nexus (Bacchi 1999).
Theoretically she poses the proposition that
policy proposals that purportedly ‘address’ a
particular ‘problem’, such as workplace bully-
ing, contain implicit representations of how the
‘problem’ is to be understood. The corollary of
this proposition is that if the problem represen-
tation is too narrow then the postulated solution
will also be too narrow, and will indeed make
the policy ineffective and/or faulty.
Bacchi’s methodology provides a framework
for considering the links between theory, pol-
icy and politics (as with all political scientists,
‘the political’ is Bacchi’s way of talking about
‘power’). The ‘what’s the problem represented
to be’ (WPR) approach is built on three prin-
ciples. First, inherent in all policy is a spe-
cific representation of a problem. Second, this
representation establishes a theory about the
causes of the problem and ways to implement
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change. The WPR approach requires the con-
sideration of competing representations of a
problem and therefore a range of competing
supposed causes. Third, for Bacchi, as for Fou-
cault, theories are types of political action and
intervention. Theorising is ‘a political practice
always and inescapably implicated with power’
(McClure 1992:365 in Bacchi 2006:1). Bacchi
(1999) argues that a problem representation ap-
proach provides a means of identifying theories
that drive policies, and for exploring the po-
litical and practical implications of theoretical
choices.
Bacchi’s post-structural approach represents
a major shift away from traditional policy anal-
yses which hold that ‘. . .public policy ad-
dresses societal problems and is about what
governments do, why they do it and what dif-
ference it makes’ (Edwards 2001:1). Underpin-
ning this traditional view is the assumption that
societal problems exist in an absolute and fixed
way and that governments respond or react to
them with the primary intention of solving what
is ‘out there’. Conversely, Bacchi (1999) argues
that it is through policy that governments shape
social problems and that ‘. . .problem represen-
tations are the variety of shapes given to spe-
cific social issues’ (Bacchi 2006:2).
For Bacchi, how a problem is represented
determines what actions are to be taken, or
not taken. A policy defines a problem to be
solved and therefore within each policy is a di-
agnosis that provides the course of action to
be adopted to address that problem (Bacchi
1999). The implications of this ‘representation
of the problem’ approach are demonstrated in
a number of ways. A problem’s representation
influences the way that the issues are under-
stood and used in a broad range of discourses.
The problem representation imposes limits or
boundaries around what is ‘in’ and what is ‘out’
in terms of being considered as part of the prob-
lem. Finally, there are the practical effects of the
problem representation or how this representa-
tion actually works and impacts on people’s
lives.
The ways in which problems are represented
have other effects: limiting what can be talked
about as relevant; affecting the ways in which
responsibility is attached to some political
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 Hutchinson and Eveline
subjects rather than others; and shaping so-
cial attitudes about these issues. These ef-
fects are political (Bacchi 1999:6). In other
words, dominant policy representations rein-
force existing power inequities. While insti-
tutions such as governments actively produce
particular problem representations, this does
not necessarily translate into an explicit inten-
tion. Certainly, there are instances where issues
are purposely shaped in specific ways to gen-
erate support. However, the factors that drive
problem representation are much more com-
plex and ‘. . .involve investments, conscious
and unconscious, in deep conceptual and epis-
temological schema and, hence, are not always
obvious’ (Bacchi 2006:3).
Bacchi’s framework for applying a WPR
analysis comprises five questions (Bacchi
1999, 2006:4-5):
1. What is the problem represented to be in a
specific policy proposal and/or in policy
debate?
2. What presuppositions or assumptions un-
derpin this representation of the problem?
3. What effects are produced by this repre-
sentation of the problem? What is likely
to change with this representation of the
‘problem’? What is likely to stay the
same? Who is likely to benefit from this
representation of the ‘problem’?
4. What is left unproblematic in this problem
representation? Where are the silences?
How would ‘responses’ differ if the ‘prob-
lem’ were thought about or represented
differently? (Here it is useful to think
about shifts in representation of ‘the prob-
lem’ over time or across cultures).
5. How/where are dominant problem rep-
resentations disseminated and defended?
How could they be challenged?
The first two questions enable the exami-
nation of the links between policy, theory and
politics. In short, they assist in the identifica-
tion and understanding of the theoretical per-
spectives underlying policies. The final three
questions highlight the political implications
of these theoretical commitments.
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Bacchi has applied her model to a range
of different policies that purport to benefit
women. For example, she notes that Equal Em-
ployment Opportunity (EEO) policies make it
unlawful for women to be denied access to any
occupation, and women are encouraged to gain
the skills necessary to access the full range of
employment options. In this problem represen-
tation, there is no critical gender analysis of
the male norms which require women to com-
pete in a labour market and in workplaces that
are structured around the lives, experiences and
position of men: ‘Meanwhile, the social pro-
cesses which shape women’s lives . . . which
create them as outcasts in particular work envi-
ronments, go unaddressed’ (Bacchi 1999:203).
We use the WPR approach to examine the
two dominant workplace bullying policy frame-
works applied in Australia: a) occupational
health and safety(OHS) and b) workplace dis-
crimination. Bacchi’s first four questions help
to identify the theories that underpin the poli-
cies and to explore the practical and polit-
ical gender implications of these theoretical
assumptions. We then use Bacchi’s final ques-
tion to explore how policy actors defend and
disseminate these policy representations.
Method
This article draws material from a larger study
into workplace bullying in Australian pub-
lic service administrations (Hutchinson 2008).
The term ‘public service administration’ refers
to that aspect of each public service jurisdic-
tion that is concerned with how government
policy is executed. The central issues for pub-
lic service administration include the organisa-
tion, efficiency and effectiveness of the public
services, including all aspects of employment
(Jaensch and Teichmann 1984). We chose the
public service as the site for our study for two
reasons. First, although limited, much of the
Australian research into workplace bullying has
focussed on public sector organisations (Omari
2003; McCarthy 2004; Mayhew and McCarthy
2005). Second, all public service administra-
tions around Australia have introduced work-
place bullying policies so we were interested
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52 Workplace Bullying Policy in the Australian Public Sector
in how these were being applied and their re-
spective outcomes. In order to understand how
workplace bullying is constructed within the
social policy setting context of an organisation,
we chose semi-structured interviews with pol-
icy actors. Rather than develop conclusive ev-
idence, our study aimed to expand knowledge
about workplace bullying, by building themes
and strands of meaning (Patton 1990).
Three design issues framed the study. First,
different policy interests and perspectives
needed to be represented. Second, women and
men were to be equally represented. Third, the
study was seeking to draw conclusions about
Australian public service organisations, rather
than being confined to one particular adminis-
tration or agency. Thus the subject group com-
prised people working in public service agen-
cies from four Australian states, one Australian
Territory and the Commonwealth public ser-
vice. All 32 interviewees have played some
role in the development and implementation of
workplace bullying policies in public service
agencies, and 13 are women.
The interviewees comprised three groups: 11
senior managers, 10 employee advocates and
11 policy implementors. Senior managers are
people who occupy first or second tier man-
agement positions in an agency. Employee ad-
vocates are union organisers or people from
independent workers’ advocacy centres. Pol-
icy implementors are professionals drawn from
either human resources, industrial relations,
occupational health and safety or equity con-
texts. The interviews were face-to-face and
conducted over an eight month period. As a
means of identifying the informants yet ensur-
ing anonymity, we allocated each person with
a pseudonym plus an occupational descriptor.
It is worthwhile noting that identifying and
securing the participation of interviewees for
this study was recognised as a major challenge.
Workplace bullying is a sensitive issue, capable
of attracting wide media attention and public
comment. Much of this public focus has high-
lighted extreme consequences for individuals
and organisations, often represented in highly
emotive and sensational ways. Therefore, reluc-
tance on the part of policy actors to participate
in the study was anticipated. As a result, build-
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ing trust with potential and actual informants
from the earliest stages of the study was a pri-
ority. A dialogue about workplace bullying and
the study was established with a range of peo-
ple including academics, bureaucrats, health
professionals, lawyers, unions, community ad-
vocates and employment professionals. This
dialogue was instrumental in identifying po-
tential interviewees and in some cases recom-
mending participation by individuals.
Since this study was aimed at exploring
broader representations of workplace bullying
that exist in the both academic and policy lit-
erature, it was particularly important to focus
on interviewees’ own language and perspec-
tives. Relationships were traced across the data
highlighting common views, differences and
contradictions between groups, individuals and
within individuals themselves. In addition to
the spoken aspects of the data, interviewees’ re-
actions including body language, tone of voice,
silences and the ‘temperature’ of the interview
were also considered, drawn from careful notes
made during and after the interviews. For ex-
ample, some interviewees became quite emo-
tional when relating particular stories, while
others became quite hostile to the discussion
of gender. Finally, the data were analysed using
the five questions of the ‘what’s the problem’
model.
We outline our findings in three sections be-
low. The first two look at how OHS and work-
place discrimination based policies frame ‘the
problem’ of workplace bullying in ways too
narrow to deal effectively with the gender di-
mensions of the issue. The third section ex-
amines how and why Australian policy actors
circulate and defend the exclusion of a gender
analysis from workplace bullying policies.
Findings
Workplace Bullying as an Occupational
Health and Safety Problem
Over the past 20 years, the safety of workers
has become a central labour relations issue in
Australia. OHS legislation places an obligation
on employers to ensure the health and safety
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 Hutchinson and Eveline
of workers. Not surprisingly, therefore, OHS
frameworks have been a dominant influence
on workplace bullying policies (Barron 2002;
Mayhew 2000).
More recently, OHS has undertaken a new
significance related to the parallel, but separate,
regulatory regimes of the Australian industrial
relations system. At both state and federal lev-
els, these regimes have been weakened through
the increased deregulation of labour, a narrow-
ing role for centralised wage fixing, a reduced
role for unions and a declining union member-
ship. This weakening has resulted in fewer reg-
ulatory protections for workers. Consequently,
many unions have sought to extend the scope
of existing OHS policy to provide protection
and relief for workers in matters traditionally
covered by industrial instruments.
Occupational health and safety represents the
problem of workplace bullying in ways that are
underpinned by a functional view of power re-
lations that sees organisations as predictable,
logical and rational. These perspectives over-
look alternative dimensions of power such as
gender inequity, racism and context. They as-
sume that only the most obvious demonstra-
tions of hierarchical power, such as a boss
bullying a worker, are relevant. They ignore
the more subtle and often invidious manifesta-
tions of power, such as women and minorities
seeking to be out of the organisational spotlight
or having limited opportunities and confidence
to respond to criticism or unfair treatment.
Bacchi’s question two, which asks what as-
sumptions underpin problem representations,
proves useful here. The assumptions underpin-
ning OHS strategies are that injuries are phys-
ical and they can be prevented by adopting an
orderly, rational and systematic approach to the
identification of potential risks and eliminating
them. This representation of the problem relies
on the assumption that cause and effect rela-
tionships are clearly identifiable, and that once
they are pointed out, they can be addressed ex-
pediently. OHS problems are premised on the
individual as the basic unit of analysis. Like
many Human Resources Management (HRM)
practices, the individual becomes ‘. . .an es-
sential human subject whose nature is to be
discovered and uncovered and who is to be
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motivated by the correct procedures of recruit-
ment, selection, appraisal, training, develop-
ment and compensation’ (Townley 1993:522).
Bacchi’s third question highlights the effects
of particular problem representations, and we
use it to show the limits in an OHS represen-
tation of ‘the problem’ of workplace bullying.
OHS strategies are based on the idea of rational
decision-making and generally ignore or min-
imise the effect of underlying power relations.
The focus is on the individual. Policies such as
employee assistance programs and grievance
procedures explicitly target individuals, as do
policies that offer stress management training
for targets of bullying, alongside training and
counselling for perpetrators. To demonstrate
the limitations of this approach, with some rel-
evance to workplace bullying, Steele (1995)
observes that explanations of work related ill-
nesses such as stress emphasise the individual
worker’s conduct. Therefore, policies that draw
on OHS perspectives are unlikely to address
some of the organisational factors that con-
tribute to stress (Reynolds, and Briner 1994).
This is because OHS policies avoid ‘. . .issues
concerning power, autonomy and work organi-
sation that are critical factors in understanding
the development of occupational illness’ (Nytro
et al. 2000:217).
So what goes missing when a problem rep-
resentation is shaped by the assumptions of an
OHS framework? Bacchi’s question four high-
lights the importance of interrogating problem
representations for what they don’t say. By ap-
plying this question to OHS policy and linking
it with a gender analysis, the dangers of repre-
senting workplace bullying as an OHS problem
are revealed. Indeed, Henneberry (1997:6) ob-
serves in her account of Canadian workplaces
that a gender analysis is silenced in an OHS
framework:
The evaluation of risks and hazards in the work-
place has focussed on the more obvious and
traumatic accidents and diseases associated with
traditional male employment . . . while women’s
work is less likely to produce fatal accidents com-
pared with the jobs that men do, women’s work-
ing conditions cause serious health problems and
even death. Due to a narrow conception of dan-
gerous work centered on a masculinist language,
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54 Workplace Bullying Policy in the Australian Public Sector
women’s work is propagandised as safe and clean.
As Yola Grant points out, ‘offices have been pre-
sumed to be safe working environments because
they generally appear clean, unlike factories and
mines, and hazardous machines and chemicals
are noticeably absent’.
Henneberry’s analysis highlights a number of
implications for the representation of work-
place bullying as an OHS problem.
First, occupational risk is constructed as
physical trauma occurring in high-risk indus-
tries such as mining and construction, the
places that men work, doing tasks that men
do. Occupational health and safety policy prob-
lems are not represented as being about slowly
developing conditions such as chronic mus-
culoskeletal problems, stress-related illnesses
or insidious cancers (Messing et al. 2003).
Such illnesses are more likely to be associ-
ated with repetitive, mundane work, often seen
as women’s work (Punnett and Herbert 2000).
Women working in textiles, electronics and
clerical work are far more likely to develop long
term, subtle, and less visible conditions, which
demand a systematic and monitored approach
over a sustained period of time that can be both
costly and time consuming. Further, women are
often employed on a part-time, casual, home-
based or seasonal basis, forms of employment
that are generally overlooked in the collection
and analysis of OHS data (Messing et al. 2003).
Thus, research into OHS has mostly ignored
gender and therefore hazards associated with
women’s work have been ignored and underes-
timated. Consequently, little is known empiri-
cally about women’s occupational injuries and
illnesses. This has resulted in narrow conceptu-
alisations of injury and risk (Courtenay 2000).
To be precise, gendered power relations impact
OHS policy representations. Women workers’
lesser degree of control over their environment
may influence their health through the infre-
quency of rest breaks, ability to position tools,
equipment, and work surfaces, and ability to
vary tasks over time (Messing et al. 2003).
Women tend not to report pain or discomfort for
fear of dismissal (Messing et al. 2003). Stress-
related ailments, to which women are more sus-
ceptible as many have less control in their jobs,
Journal compilation 
C 2010 National Council of the Institute of Public Administration Australia
March 2010
are under-reported. Women are less likely than
men to be unionised and protected by union in-
fluence. In countries where awards for safety
performance are prevalent, women are likely to
be intimidated into not reporting accidents or
injuries (Messing et al. 2003). Women are more
liable to be exposed to sexual discrimination at
work, including sexism and sexual harassment
(Gutek 2001), associated with a wide range of
adverse physical and mental health outcomes
(Fitzgerald et al. 1997). In summary, when a
WPR analysis is applied to OHS approaches, it
is clear that the health and safety framework re-
sponds to multi-causal aspects in a limited way.
For a start, OHS approaches cannot cope with
inequalities of power and with what Eveline
(1994) calls male advantage.
Second, with OHS problem representations
focussed on physical and measurable risks that
are easily identifiable and measured, injuries
are usually assumed to be the result of a sin-
gle activity, action or accident, rather than a
long developing condition. Third, OHS repre-
sentations have traditionally concentrated on
masculinised industries, jobs and full-time em-
ployment patterns. Representations of work-
place bullying as a problem of individual
behaviour that can be ‘fixed’ through the ap-
plication of rational systems, overlook the sig-
nificance of power relations in the production
of workplace bullying. Further, an OHS frame-
work, with its primary focus on a narrow set
of jobs, industries and easily observable risk
factors, appears to lack the capacity to respond
to the gendered dimensions of organisational
power relations. It is reasonable to conclude
that such a framework is limited in its capacity
to respond to new issues of worker well-being,
such as work-related stress and workplace bul-
lying, as well as to the gender dimensions of
both.
Workplace Bullying as a Workplace
Discrimination Problem
Workplace discrimination policy is the sec-
ond and less dominant influence on how
the ‘problem’ of workplace bullying is rep-
resented. Anti-bullying policies influenced by
anti-discrimination policy draw on EEO policy
C 2010 The Authors
 Hutchinson and Eveline
and sexual harassment policy, both of which
encompass individualistic premises.
When EEO legislation was introduced in
Australia 30 years ago, it was assumed that
the removal of structural barriers to women’s
entry into traditionally male dominated occu-
pations and industries was all that was required
to reduce the segregated nature of the Aus-
tralian labour market. Three decades on, while
there has been improvement in the numbers
of women entering some male-dominated ar-
eas (Charlesworth 2007), there is a significant
body of evidence that many women do not stay
either in the recruiting organisation or the in-
dustry for a sustained period (Summers 2003).
While EEO legislation has removed the
structural barriers to women’s participation in
employment, it has failed to acknowledge and
respond to the inherent power of masculine cul-
tures and different levels of men’s resistance.
Where the masculinisation of fields such as
mining (Eveline 1994), police (Eveline and
Harwood 2002), defence (Burton 1996) and
printing (Cockburn 1991) prevails, researchers
have identified the need to address the pro-
found embedding of masculinised norms, as a
significant aspect of any initiatives to overcome
discrimination against women (Acker 2000;
Eveline and Booth 2002). Women’s low levels
of entry to, and high rate of departures from,
these jobs and industries have been attributed
to cultures ‘. . .where men are reacting strongly
and negatively to the “invasion” of women into
their domain’ (Burton 1996:76).
Sexual harassment has emerged as the most
visible form of this resistance to the ‘invasion’
of women into masculinised work domains.
However, workplace discrimination problem
representations separate EEO and sexual ha-
rassment into two distinct ‘problems’, rather
than presenting them as integral aspects of
a broader problem related to gendered power
relations in workplaces. Like EEO, sexual
harassment policies do not acknowledge the in-
herently gendered nature of the workplace and
therefore the extent to which masculine resis-
tance to women’s entry and advancement can
be mobilised (Burton 1996). Instead, policies
tend to assume that the aberrant conduct of in-
dividual workers is the problem. Hence they
Journal compilation 
C 2010 National Council of the Institute of Public Administration Australia
55
tend to draw attention to more explicit cases
such as quid pro quo situations (‘do this or I
will block your career!’), missing a good deal
of harassing behaviour.
We can clarify the above point by ask-
ing whether a particular representation of a
problem silences talk about something else.
In most sexual harassment, the emphasis on
individual behaviour creates ‘. . . a risk of
over-concentrating on what are essentially
sensational, though rarely enacted, forms’
(Perrone 1999:18), leaving the more com-
mon forms of gender harassment largely un-
addressed (Bryson 1994). Excluded from the
discussion also is the possibility that particu-
lar work environments foster harassment and
bullying at all levels (Thornton 1990). For ex-
ample, workers have represented employment
policies, such as performance management and
increased workloads, as workplace bullying be-
cause of their detrimental effects (Ironside and
Seifert 2003) but policies remain silent on this
topic.
Policy on both EEO and sexual harassment
often assume that problems arise out of the
actions of individuals. Operating on that as-
sumption, the only power relations that tend
to be recognised are those that are organisa-
tionally hierarchical, with a manager bully-
ing a subordinate. These assumptions are clear
in interventions that are directed at individual
workers through training and development,
codes of personal conduct and procedures for
making individual complaints about other in-
dividuals. The effect of this problem represen-
tation is that the organisation is assumed to
play no part in the problem formation. There-
fore, there is no rationale for focussing on how
organisational processes or gendered power re-
lations might contribute to the problem.
When workplace bullying is represented as a
workplace discrimination problem the onus is
placed on individuals to prove that a problem
exists. This means that a complainant needs
to be able to demonstrate some personal detri-
ment or degree of harm. The underlying as-
sumption in this problem representation is that
bullying only occurs where there is proof of
‘pathological’ harm (Bacchi 1999:186). By ap-
plying Bacchi’s question three about the effects
C 2010 The Authors
56 Workplace Bullying Policy in the Australian Public Sector
of particular problem representations, two im-
portant issues emerge. First, policies tend to
focus on the resolution of a complaint once
harm can be shown, rather than on preventing
and minimising the cause of the harm. Second,
vulnerable workers are even less likely to take
advantage of organisational policies than those
with some institutional authority since:
. . .many employees, and in particular women,
may feel constrained to remain silent about their
victimisation because of fear of reprisals being
taken against them, including the possibility of
losing their jobs. Unequal power relationships be-
tween employers and employees can undoubtedly
influence reporting behaviours, and increase the
risks of exploitation (Chappell and Di Martino
2000:27).
In summary, representing the problem of work-
place bullying through an anti-discrimination
framework leads to inadequate and ineffec-
tive policy. The emphasis on the individual in
such policies stems from assumptions about the
cause of workplace bullying that exclude key
dimensions of organisational power relations,
gender, racism and organisational culture. Such
a framework fails to acknowledge other factors
that contribute to the targeting of women, pre-
senting them as ‘. . .outcasts in particular work
environments, [in which gender and culture]
go unaddressed’ (Bacchi 1999:203). As a con-
sequence of such representations, the targets
of workplace bullying are individualised and
isolated from adequate empathy, understanding
and support.
How and Why Policy Actors Defend the Need
for Gender-Neutrality
The interview data collected through this
project reveal a consistent contradiction for
policy actors dealing with workplace bullying.
On the one hand many interviewees described
workplace bullying as a product of multiple
intersecting factors, which were impossible to
encompass in existing policies based on OHS
and workplace discrimination principles. In-
deed, interviewees expressed little confidence
in either policy approach to respond effectively
to the wide range of practices that workers cur-
Journal compilation 
C 2010 National Council of the Institute of Public Administration Australia
March 2010
rently describe as workplace bullying (such as
organisational processes and work effort de-
mands). Nonetheless, they were adamant that
to widen the policies to include a gender analy-
sis would not be in the interests of anti-bullying
policy. Indeed when it came to the question
of how workplace bullying policies should be
framed, policy actors expressed strong sup-
port for using only well-considered and famil-
iar approaches. In most cases this meant they
opted for an OHS based policy, which they saw
as a framework acceptable to most managers
and employees. As we have argued above, this
framework represents OHS as gender-neutral in
its premises and effects, an assumption which
ignores the deep gendering of organisational
practices.
Interviewees gave three reasons for address-
ing the ‘problem’ of workplace bullying using a
policy approach they had previously described
as too narrow. These reasons all related to
their defence of a gender-neutral anti-bullying
policy, and incorporated the need to manage
three features of their organisations: practi-
tioner workloads; organisational resistance to
gender equity policies; and organisational sup-
port for anti-bullying policy.
The question of practitioner workloads was
particularly important for the policy imple-
mentors, who spoke of the need for simple,
clearly defined procedures for, and categories
of, workplace bullying that would not escalate
their workloads. Their reluctance to consider
a gender dimension to workplace bullying was
related to a fear of widening the scope of work-
place bullying representations to encompass
issues that were complex, complicated and con-
tentious. Policy implementors were generally
adamant that EEO and sexual harassment poli-
cies already covered the ‘gender territory’, so
there was no cause to ‘narrow’ workplace bul-
lying policy with attention to gender issues. For
example, policy implementor Carrie described
the question of gender as ‘a Pandora’s box of
trouble’ that would make anti-bullying policy
impossible to manage. To muddy workplace
bullying policies with talk of gender inequal-
ity, therefore, would not only cover similar ter-
rain to sexual harassment and EEO policies,
it would also increase avenues for complaint
C 2010 The Authors
 Hutchinson and Eveline
and add unnecessarily to duties for implemen-
tors. Further to increasing policy implemen-
tor workloads, linking workplace bullying with
gender and EEO would require a much more co-
ordinated organisational response, mobilising
parts of the organisation that are routinely kept
relatively powerless by isolation and lack of
resources.
Policy actors felt that, personally and pro-
fessionally, they could be vulnerable to organ-
isational resistance and backlash if their anti-
bullying policies portrayed gendering practices
as a key source of power inequality. In contrast
to the topic of workloads, which mainly con-
cerned implementors, senior managers and em-
ployee advocates were equally keen that their
workplace bullying policies avoid the suspicion
and resistance that those implementing EEO
had faced. Indeed, the thoughtfulness that in-
terviewees showed in our general discussions of
workplace bullying tended to disappear when
the interviewer raised the question of a link be-
tween workplace bullying and gendered power
relations. Many interviewees (both women and
men) appeared uncomfortable with the ques-
tion, fidgeting and losing direct eye contact
with the interviewer. Some adopted a defen-
sive tone, while others failed to acknowledge
any relevance. Several insisted that bullying
wasn’t ‘just a women’s issue’. As Carl, a se-
nior manager, commented: ‘I think women get
sexually harassed more than men but bullying
happens to everyone’. Similarly, Steve, a pol-
icy implementor, defended this gender-neutral
stance with the point: ‘men can be bullied as
much as women’ while Samantha, also a policy
implementor, contended: ‘. . . women and men
are bullied equally’.
Interviewees indicated that representing and
defending workplace bullying as a gender-
neutral problem was a necessary requirement
for the policy to achieve and retain organisa-
tional priority. As part of their wide-ranging
exposition, interviewees identified an imbal-
ance of power as a central aspect of workplace
bullying. They acknowledged that power de-
rived from a wide range of sources such as
hierarchy, informal and formal organisational
status, and access to knowledge and member-
ship of influential networks. However, while
Journal compilation 
C 2010 National Council of the Institute of Public Administration Australia
57
many interviewees agreed that women were
less likely than men to claim these sources of
power, they were generally reluctant to impli-
cate gendered power relations in workplace bul-
lying. Although a few interviewees could see
that gender was an important factor in work-
place bullying which went largely unaddressed,
they cited political expediency as a reason for
ensuring their anti-bullying policies remained
untainted by the ‘woman’ question. For exam-
ple Kate, a policy implementor, argued: ‘If staff
thought for a moment that this was a women
versus men thing, we couldn’t get any support
for our policies’. According to Sean, a policy
implementor, any identification with women
needs to be carefully avoided: ‘The reality is
that once you mention gender, everyone thinks
you are talking about women so we don’t draw
attention to women at all’.
Exploring how and why interviewees’ de-
fend a gender-neutral problem representation
of workplace bullying reveals that what they
claim to be gender-neutral is mostly gender-
blind. While they may recognise complexity,
policy actors are unlikely to challenge these
dominant yet narrow problem representations.
Motivated by a wish to manage workplace
bullying policy with minimal resistance, pol-
icy actors justify and defend limited, step-by-
step administrative procedures by excluding a
gender analysis from policy development and
implementation.
The response of practitioners can be seen
in many ways as rational and shrewd. That
is, they recognise that gender and EEO are
marginalised concerns in many workplaces. A
focus on workplace bullying has acquired legit-
imacy in some organisations but is at the same
time fragile. As these workers are already in
a potentially marginalised organisational role,
why would practitioners further compromise
their position and reduce their efficacy by link-
ing bullying to the discourse of gender and
EEO? However, to focus too much on the ac-
tions of policy actors runs the risk of reify-
ing the individualisation of problems, rather
than investigating the influence of organisa-
tional and broader social political factors that
work against the recognition of gendered di-
mensions of workplace bullying.
C 2010 The Authors
58 Workplace Bullying Policy in the Australian Public Sector
Conclusion
This study has revealed that the deeply gen-
dered premises of OHS policies, and to a lesser
extent anti-discrimination policies, allow pol-
icy actors to represent workplace bullying as
gender-neutral. As we have argued above, such
representations of ‘the problem’ of workplace
bullying are inadequate. First, they lack the ca-
pacity to examine the power imbalances pro-
duced by gendered organisational processes
that support and facilitate workplace bullying.
Second, representing workplace bullying as a
gender-neutral ‘problem’ masks the effort that
goes into justifying that gender-neutrality, and
begs an important question. Why is it so impor-
tant strategically to exclude a gender analysis
from the issues of power and status at play in
workplace bullying?
Sinclair (2000) shows the organisational and
political advantages that can accrue by down-
playing gender. Such strategies can promote
inclusiveness and reduce backlash (Sinclair
2000). Our policy actors, women and men,
when interviewed put considerable effort into
portraying and defending the view that work-
place bullying is gender-neutral, suggesting
that gender-neutrality has strategic value for re-
taining the policy’s organisational status and re-
sourcing. The danger is that ‘gender issues may
remain untouched in this process’ of exclud-
ing gender questions, cautions Sinclair (2000:
242).
In summary, despite substantial evidence to
the contrary, policies and policy actors repre-
sented workplace bullying as a gender-neutral
problem. Indeed the survival and viability of
some form of successful workplace bullying
policy is seen to depend on denying gender
effects. Our analysis reveals that these expla-
nations of gender-neutrality, as well as their
defence and dissemination, are themselves ex-
amples of how the gendered power relations of
organisational processes and outcomes are ac-
complished. In order to generate more effective
and responsive policy, we advocate a different
focus for researchers and policy actors that ex-
amines the organisational processes producing
the power imbalances underpinning workplace
bullying. Such transformation is dependent on
Journal compilation 
C 2010 National Council of the Institute of Public Administration Australia
March 2010
the capacity and willingness of organisations to
critically examine the way in which workplace
bullying is conceptualised and represented. Re-
thinking workplace bullying necessitates the
difficult task of talking about and revealing
the unspoken/invisible workings of power and
gender.
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