When Is a Pre-Start Health and Safety Review Required?

Posted by  On June 16, 2022
Ontario Regulation 851 (the Industrial Establishments Regulation)

In Ontario, all ‘factories’ are required to comply with all applicable sections of Ontario Regulation 851 (the Industrial Establishments Regulation) under the Occupational Health & Safety Act (OHSA). Under Section 7 of Regulation 851, companies are obligated to ensure that a Pre-Start Health and Safety Reviews (commonly referred as PSHSRs, PHSRs or PSRs) is conducted to keep workers safe. These reviews assess key equipment and processes for compliance with specific regulatory requirements prior to their introduction into the workplace.

While this obligation is broadly placed on the organisation, it is important to realise it also falls on the shoulders of not just owners, but employers, supervisors and the workers themselves. Here we look at what a PSR involves and when they are required.

Note: The OHSA contains a specific and comprehensive definition of a factory, but in summary, a factory is any workplace where energy is used in the manufacturing, assembling, preparing, inspecting, finishing, repairing, warehousing, cleaning, adapting, or maintaining of any goods, products, articles or thing. If this sounds like your facility, you need to be familiar with PSRs.

What is a PSR?

A PSR is an in-depth examination of an apparatus, structure, protective element, or process to ensure the applicable provincial and national safety requirements are being met.These reviews must be conducted by a qualified professional, typically a licensed Professional Engineer, who meets the qualifications outlined by the Industrial Establishments Regulation.

Their role is to examine an apparatus, structure, protective element or process (identified by the 8 specific circumstances described in Section 7) and determine if the relevant requirements have been satisfied. It is their responsibility to perform the assessment and provide a report satisfying all the required elements described in the Industrial Establishments Regulation.

What is the purpose of PSRs?

PSR’s serve the purpose of identifying hazards associated with specific types of equipment, structures, and processes that could expose a worker to injury during typical operations. The goal of a PSR is to facilitate the elimination or control of a hazard before the equipment, structure, or process under review is used.

When are PSRs required?

The criteria for determining when a PSR is required starts first with confirming the facility meets the definition of a factory. If so, one of the 8 circumstances listed in the Table in Section 7 of Ontario Regulation 851 must be applicable, and at least one of the corresponding provisions must apply.

If this is the case, Section 7 describes two situations within which a PSR must be completed:

  1. When a new process will be used or a new apparatus, structure or protective element will be constructed, added or installed.

  2. When an existing apparatus, structure, protective element or process will be modified, and the modifications will require one of the following changes to remain in compliance with the applicable provisions of the Industrial Establishments Regulation:
    • new or modified engineering controls
    • other new or modified measures

When applicable, it is often most efficient to have a PSR completed at the design or planning stage as this provides ample opportunity to identify non-compliance allowing issues to be corrected prior to implementation and often avoiding costly or inconvenient retrofits..

Can maintenance affect compliance?

Generally speaking, maintenance does not affect compliance. However, this is only true when the required maintenance does not include altered parts. In other words, any maintenance that involves identical or “like for like” replacement of components would not trigger a PSR.

If, for example, you are maintaining a piece of older equipment for which parts are no longer available and you have to use a replacement part that is not identical or add additional components to make up for missing parts, this would require a PSR.

What is considered a modification?

Modifications are any activities or work performed on an apparatus, structure, protective element or process that could interfere with compliance.

For example, in the case of an apparatus or protective element, replacing a part with something that is not identical to the original part could lead to a deviation from the original design intent or performance of the system.. In the case of a process, a chemical might be replaced with one that requires different handling and storage procedures..

In either case, these changes may lead to unexpected hazards that were not accounted for the in the original design of the system / process. A PSR serves the purpose of ensuring these hazards are identified and addressed, if necessary.

Can equipment be moved without a PSR?

This is an important question. In order to avoid a PSR the move would have to include the following three factors:

  • The new location is within the same facility/workplace
  • No modifications to the apparatus, structure or process that would trigger a PSR are required during the move
  • Engineering controls and/or measures to deal with hazards introduced by changing the location are not required.

If any of these statements are not true, then a PSR is required once the apparatus, structure or process is installed in the new location.

What are the benefits of PSRs during design and planning?

Early introduction of a PSR is the most cost-effective approach for your company. By being proactive, you eliminate costly delays that can disrupt operations. You also prevent worker injury and avoid non-compliance fines. The benefits of early PSRs include:

  • Reducing costs associated with retrofitting later in the process
  • Avoiding downtime due to shutdowns when equipment or processes are not up to the proper standards
  • Costly replacement of non-compliant equipment and apparatuses
  • Mitigated risk for savings in insurance claims and fines

However, your company also maintains health and safety in the workplace to improve productivity as well as worker morale.

Why are Pre-Start Health & Safety Reviews important?

Simply put, Pre-Start Health & Safety Reviews help ensure worker safety.

Workplaces today operate on a dynamic landscape of ever changing standards and regulations. PSR’s help ensure that these workplaces stay compliant and, by employing professional that stay focused and educated on safety engineering, continue to implement ever more reliable ways of maintaining safe work environments.

We at HITE Engineering understand and advocate for every individual’s right to feel and be safe at their place of work. Safety is not optional.

If you would like more information about our Pre-Start Health And Safety Reviews or other safety engineering services, please contact our team today.

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