Many employers remain confused by the legal requirements for a Pre-Start Health and Safety Review (PSR) for new or modified equipment, says Michael Wilson, a machine safety specialist. “They may not know the requirements exist, even though it’s been around for over 15 years. Or they confuse it with their own company’s pre-start equipment check before each shift.”
Nevertheless, says Michael, it’s up to employers to wade through the complex, legal language around “triggers” and “exemptions” to determine if a PSR is required.
A brief definition
According to the Ministry of Labour, a PSR is an in-depth examination of new or modified equipment or processes for specific hazards by a professional engineer. Its goal is to ensure the safety of workers before the equipment or process goes into use.
The PSR includes a written report that outlines areas of non-compliance and the measures necessary to achieve compliance (steps, actions or engineering controls).
Section 7 of Regulation 851 lists the circumstances under which an employer needs to do a PSR. Michael explains it this way: “Typically we tell people, ‘If you’ve got a brand new piece of equipment or you’re looking to modify something, and one of the eight triggers identified in Section 7 apply, you should probably be taking a closer look at the PSR process.’”
Even when a PSR is triggered, it may be possible to get an exemption, depending on certain criteria also found in Section 7. Some of the exemption criteria pertain to the standards and codes used in the creation or modification of the equipment or process.
6 tips for employers
Since the onus is on you to determine if you need a PSR or whether you are exempt, it’s important to do your homework and follow up, says Michael.
- Have a good understanding of the requirements around PSRs. Michael points employers to the recently revised MOL document, Guidelines for Pre-Start Health and Safety Reviews: How to Apply Section 7 of the Industrial Establishments Regulation. Written in plain language, the comprehensive guidelines clarify when a PSR is needed and when exemptions apply, and answer frequently asked questions.
- If a supplier presents a solution as already compliant, don’t be afraid to ask why. “They should be able to tell you which standards were used to design the equipment or process. It’s really important to ask questions up front, because it’s a lot harder and expensive to fix when the project is complete.”
- Choose a qualified engineer to do your PSR. “You must hire a professional engineer licensed in the province of Ontario.” Not sure where to find one? “Start with Professional Engineers of Ontario, tell them what you are looking for and ask for recommendations. Or check out the standards that apply to your trigger. They will list committee members and some of them may be engineers with expertise in the subject area.”
- Document everything. “If you are exempt from a PSR because the manufacturer and installer say the equipment meets applicable codes, make sure you have the right paperwork.” An MOL inspector can order an engineering review if they are not satisfied that the exemption has been met.
- Don’t forget your other health and safety obligations. “Even if you don’t think a pre-start is triggered, you still need to comply with the applicable codes, acts and regulations for whatever process, equipment or structure you are looking to install.”
- Follow the engineer’s recommendations. The PSR report from the engineer is not the last step. “You must address the issues in the engineer’s report and document steps taken to comply before you use the equipment or process.”
How WSPS can help
Ontario's PSR requirements changed in January 2022. Read this article to find out more
Watch the short video, Machine Safeguarding - Understand the Pre-Start Health and Safety Review, for more tips.
- Sign up for our half-day Managing Pre-Start Reviews onsite or classroom training.