When is a Pre-Start Health & Safety Review required in Ontario?

A Pre-Start Health & Safety Review (PSR or PSHSR) is a machine safety compliance review for equipment or processes being installed or modified in a manufacturing environment, prior to its commissioning at the final user’s location in Ontario. A PSR is required in Ontario by Section 7 of Regulation 851 of the Occupational Health and Safety Act (S.7 of O.Reg. 851), under 8 specific circumstances, to be performed by an Ontario Licensed Professional Engineer. The review is typically done at the final manufacturing location, however a preliminary review at the machine manufacturer’s location, before installation, can be advantageous as changes or modifications are more easily fabricated and integrated.

The Pre-Start Health & Safety Review includes a written report detailing measures necessary to bring the machine or process into compliance with applicable standards. The report typically contains a risk and hazard analysis as prescribed in CSA Standards. Recommendations can include minimum design parameters such as safety circuit schematic revisions, component suggestions and conceptual sketches of physical guarding modifications required to achieve compliance to the Act and its regulations plus applicable sections of electrical and/or machine guarding standards.

The following items are examples requiring a Pre-Start Review, based on the list of 8 circumstances in the Regulation:

1. When a building, room or area is used to store or dispense flammable liquids
2. When the following protective elements are used:
   • light curtains and screens
   • area scanning systems
   • radio frequency systems and capacitance systems
   • safety mat systems
   • two hand controls
   • barrier guards using interlocked electrical or mechanical safeguards
3. When racking or stacking structures are used to store material
4. Where processes that involve a risk of ignition or explosion are installed or modified
5. When a dust collector is used that involves a risk of ignition or explosion
6. When a factory produces aluminum or steel, or a factory that is a foundry
7. When a lifting device, traveling crane or automobile hoist is installed or modified
8. When a process uses or produces a substance (i.e. chemical) that may result in the overexposure of a worker to limits prescribed by Ontario regulations

A Letter of Compliance can also be provided following a final inspection of equipment, prior to operation, although it is optional and is not required by Ontario Legislation. This includes a final review of the installation, after non-compliance issues have been addressed, to determine compliance with Ontario Regulations, including Ontario Regulation 851 and current applicable standards for machine guarding. The Letter of Compliance is prepared if issues have been resolved, and is signed & sealed by a Professional Engineer.