What is a Pre-Start Health and Safety Review?

Posted by  On August 8, 2017

PSR or PHSR is an acronym for the term Pre-Start Health and Safety Review. This phrase is the title for Section 7 of Regulation 851 of Industrial Regulations, a section of the Occupational Health and Safety Act.

As per its name, the purpose is to provide a health and safety review prior to start up (Pre-Start) of the equipment/system or operation. The regulation goes on to say that this review pertains to a factory, other than a logging operation and should a provision of the regulation apply and the associated circumstances exist then a PSR is required. The regulation takes a few pages to say this.

Lets consider an example as it does a better job of wading through the weeds.

If you look at Section 7 of the Regulation, there is a table which lists 8 items with the associated Regulation and Circumstances which pertain to it.

So back to the example.

Most factory situations involve “Machine Guarding” which is Section 24, 25, 26, 28 of the Regulation. This is item 2 of the Table. Considering these sections, the table then lists circumstances which may relate to these regulations. In this case let us consider a guard which shields an employee from injury. The Circumstance for item 2 of the Table says: ‘Any of the following are used as protective elements in connection with an apparatus: ( Where apparatus is earlier defined in the regulation as meaning equipment or a machine or device)

Lost yet?

  1. Safeguarding devices that signal the apparatus to stop, including but not limited to safety light curtains and screens, area scanning safeguarding systems, radio frequency systems and capacitance safeguarding systems, safety mat systems, two-hand control systems, two hand tripping systems and single or multiple beam systems.

  2. Barrier guards that use interlocking mechanical or electrical safeguarding devices

So did you get all that? So much for a simple example. Leave it to the government to make something simple…hard.

In short you need a PSR if you have a guard which is interlocked and causes the machine to stop should the guard be opened.

Now to make it even more confusing an E-Stop does not trigger ( a term the MOL likes to use) a PSR. On top of it an E-stop is not a safety device

Go figure!!

–Tom Riedel, B.Eng. P.Eng. / Senior Consultant has over 20 years of experience as an electrical engineer. In addition, he has a diploma in electrical engineering technology and holds an industrial electrician’s license. Prior to joining HITE, Tom worked for 10 years as a private engineering consultant doing Pre-Start Health and Safety reviews. During his extensive career, he has worked in industrial field service; medium voltage engineering design and system startup and medium voltage drive marketing. In addition, he has spent 5 years working at the Bruce Nuclear Power station in Tiverton Ontario. His skill set includes Product Support, Project Engineering Design, Marketing, Field service and Project Management.

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