Pre-start Health and Safety Reviews: What you need to know

A Pre-start Health and Safety Review (PSR) is the law in Ontario, and must be performed on any new, modified or relocated equipment, or equipment that has been moved into a new workplace or where a safety control has been added or modified. This is a requirement of the Ontario Health and Safety Act Reg 851 section 7. Failure to comply with this law results in fines.

It’s not a new requirement, but there are still many questions around when it’s required and who can perform it. With that in mind, Engineered Lifting Systems addresses some important questions about PSRs below.

What is a PSR?

A Pre-start Health and Safety Review is a specific audit of a process or piece of equipment and the interaction with its surrounding environment. The review seeks to identify safety concerns and evaluate potential hazards. It also defines what measures need to be taken to bring the identified deficiencies into compliance.

Who can perform PSRs?

PSRs must be performed by a professional engineer registered in Ontario. It is strongly recommended that PSRs be assigned to persons who are competent by virtue of education and experience in the respective discipline that the PSR entails. Firms that offer engineering services, including those who perform PSRs, must hold a Certificate of Authorization issued by Professional Engineers Ontario (PEO).

When is a PSR required?

A PSR is required for the following applications:

• Storage and dispensing of flammable liquids;
• Guarding when safeguarding devices signal an apparatus to stop;
• Racking or stacking structure;
• Potentially explosive processes;
• Dust collectors;
• Molten metal and foundries; and
• Lifting devices – in instances where construction, addition, installation or modification relates to lifting devices, travelling cranes or automobile hoists.

Are there exemptions?

An exemption may apply for lifting devices if the supporting structure was originally designed for the loading. In the case of this exemption, the owner, lessee or employer must keep supporting documentation, including:

• A letter of exemption specifying the specific clause of O.Reg.851; and
• Design drawings containing the design loading of the original support structure, sealed by a Professional Engineer registered in Ontario.

The above documents are over and above any certification for the new and or modified equipment itself.

What if you don’t do a PSR?

Whether a PSR is not done because a company is not aware of the law or they choose to ignore the requirement, the company is at significant risk of having operations come to a halt. A simple visit by the Ministry of Labour to investigate an incident or as a result of a complaint from an employee can quickly stop all production. Failing to observe basic due diligence can also result in personal fines or imprisonment if a serious injury occurs.

For more information, visit: Ontario Ministry of Labour – Pre-Start Health and Safety Review Guidelines.

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