WSPS’ PSR Summit Part 2: best practices from an expert panel

April 22, 2019

WSPS’ PSR Summit

How to leverage the full value of your Pre-Start Health and Safety Reviews (PSRs) was the goal of an expert panel session at WSPS’ recent PSR Summit.

PSRs are legally mandated safety examinations, conducted by a professional engineer, of new or modified apparatus, structures or protective elements before they go into use. The intent is to prevent injuries by building safety into the equipment or process.

The panel session gave a capacity crowd access to five health and safety professionals with PSR experience and expertise:

Adrian Khan, Senior Manager, Environmental, Health Safety and Security, Mother Parkers Tea and Coffee
Chuck Leon, Warehouse and Racking Specialist, WSPS
Dave Smith, Equipment & Construction Safety Specialist, Honda of Canada Manufacturing
Miles Purvis, President, ProSafe Inc. (an engineering firm that provides PSRs and compliance evaluations)
Rob Vomiero, Machine and Robotics Safety Specialist, WSPS

The resulting two-way discussion of challenges and solutions touched on multiple stages in the PSR process, from selecting an engineer to maintaining safety once the equipment or process is operating. Here are some highlights of the session.

Finding the right engineer to conduct a PSR

Rob Vomiero: On the Professional Engineers Ontario (PEO) website, you can look up engineers and find basic information on their discipline and whether the engineer or the firm has a certificate of authorization. The Ministry of Labour’s PSR guidelines provide workplaces with additional clarity and understanding of the PSR legislation (O.Reg. 851 - Section 7), including their obligations, due diligence considerations and guidance regarding report contents.
Adrian Khan: Look for an engineering firm that has PSR experience compatible with your equipment or processes. Ask for sample PSR reports and review them to see if they meet your requirements. Request references so you can speak to end users.
Chuck Leon: “Bring in the most competent people possible. I work with engineers weekly and you need to be sure that you work with qualified engineers on any of these projects.”
Dave Smith: “We have a vendor expectation document that must be signed by the president of the engineering firm. It’s to ensure they meet all our expectations, including quality and consistency requirements throughout the 14 departments and four plants on our site. We also make sure that the vendor reviews our drawings and risk assessments in detail at the concept or design stage.”

Ensuring recommendations are read and implemented

A common misconception is that the PSR process ends when the employer receives the engineer’s report. Reports may contain recommendations that must be acted on to ensure compliance with legal requirements. Panelists offered the following tips:

Miles Purvis: “We send electronic documents notifying recipients that the reports contain recommendations that must be addressed. We also supply an “approved-for-use” document for sign-off that indicates all previous deficiencies (if any) are complete.”
Rob Vomiero: Have the engineer present an overview of the report to your team, your Joint Health & Safety Committee and other stakeholders.
Adrian Khan: “We review the PSR when we receive it and if there are recommendations we make sure we comply with them. We also go over this document with the Joint Health & Safety Committee and then do a field evaluation just to make sure all the guarding is in place and complies with requirements.”
Dave Smith: “We have the engineer attend the equipment start-up to ensure all compliance measures are complete, which must be confirmed via a dynamic check of the equipment’s safety performance.” (This is just the beginning of a comprehensive process to ensure compliance at Honda of Canada Manufacturing. Watch for more on this in the May issue of WSPS eNews.)

Keeping track of the report

Adrian Khan: “We have labels on our equipment with the date of the report and a file number. It provides a trail if we need to access the report.”

Keeping equipment safe after the PSR process has wrapped up

Your PSR report reflects a specific moment. Keynote speaker Frank O’Rourke, Vice President, Safety, Health, Environment and Sustainability for Weston Foods, observed that “things happen over time. The equipment vibrates, things loosen, guards are removed.” So how do you maintain the safety standard set by your PSR? Here’s what two panelists suggested:

Miles Purvis: Once a PSR has been signed off, establish a way to identify whether a hazard is introduced later. Someone in your organization must be able to identify and assess potential new hazards.
Adrian Khan: “We make sure proper procedures are being followed and regularly conduct internal checks.”