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Pre-Start Health & Safety Reviews (PHSRs)


As of October 7, 2000, the government amended the Occupational Health and Safety Act (OHSA) regulation concerning Pre-Development Reviews (PDRs).  These changes are now formalized as Regulation 851, R.R.O. 1990 of the Industrial Establishments section of the OHSA.  Employers are now required by law to perform Pre-Start Health and Safety Reviews (PHSRs) on qualifying new or modified equipment.

What is a Pre-Start Health and Safety Review (PHSR) ?

Prior to any worker being permitted to operate any machinery, equipment, or a process in a hazardous environment, an employer is responsible for ensuring that a thorough report is prepared that shows that the equipment is safe.  This PHSR report is required to review all of the relevant regulations pertaining to that particular type of equipment.

Where in the workplace do PHSRs apply ?

PHSRs must be completed when:

  • a new “apparatus”, structure, or “protective element” is to be constructed, added or installed, or a new process is to be used;  or
  • an existing “apparatus”, structure, “protective element”, or process is to be modified and to comply with applicable provisions whereby either:
      • new or modified engineering controls are used
      • other new or modified measures are used, or
      • a combination of new, existing or modified engineering controls and other new or modified measures are used.

Who can perform a PHSR ?

As mandated by the OHSA, the review must be conducted by a Professional Engineer (licensed by the province) that possesses special expert or professional knowledge or qualifications.

Is a PHSR review always required ?

As outlined by the regulations in the OHSA, there are certain exceptions whereby a PHSR conducted by a Professional Engineer is not required.  In such situations, the employer is responsible for ensuring that an exemption is properly completed.  This includes keeping and maintaining documents establishing the exemption, and making them readily accessible in the workplace for as long as the equipment remains in existence.

What happens with the PHSR documents upon completion of a review ?

Upon the satisfactory completion of a PHSR, the employer is required to:

  • Ensure that the report is kept readily accessible in the workplace (including any supporting documentation).
  • Ensure that the report is provided to their Joint Health and Safety Committee for review prior to the operation of the equipment.

What are some typical applications whereby a PHSR is completed ?

The criteria that triggers the requirement for a PHSR is fairly detailed, and varies depending on the circumstances.  In industry, any equipment whether new or modified, fitted with the following protective elements usually requires a PHSR:

  • safeguarding devices that signal the apparatus to stop (i.e. safety light curtains, area scanning systems, two-hand control systems, etc.)
  • physical barriers or safety fence that use interlocking mechanical or electrical safeguarding devices (i.e. key entry systems)

Some key points to consider during a PHSR are:

  • safety circuits should be hardwired or controlled by a safety PLC
  • safety circuits should be properly designed for the application (i.e. typically dual channel or control reliable)
  • safety guarding must be the correct:  height, distance away from equipment, correct size openings
  • equipment must be fitted with a safe entry mechanism
  • pneumatic / hydraulic circuits must be functionally safe during power out and equipment entry situations (i.e. de-energized to prevent injury)
  • equipment must be designed to safely withstand load capacities
  • safeguards must be failsafe - tolerant of single faults that may occur

The above examples are only a select few that must be considered during a PHSR.  An assessment of these types of applications would involve a review of established standards and regulations (i.e. ANSI, CSA, MOL, ISO, etc.) as well as the professional expertise and experience of the reviewer.

What are my responsibilities and obligations as an Employer?

An owner, lessee, or employer, should follow a systematic procedure when considering any piece of equipment for a PHSR.  An overview of this process is illustrated in the flow chart below.  It is the obligation of the employer to follow the principles of due diligence and take all necessary steps to ensure safety.

What is Due Diligence ?

Due diligence is a management strategy to protect workers and prevent accidents, as well as reduce financial and legal risk.  It involves the establishment and maintenance of a corporate system that manages health and safety in the workplace.  In exercising due diligence, an employer is essentially showing that they have taken all necessary and reasonable precautions to avoid a particular incident.  Often, in a legal sense, due diligence is used as a successful defence; however, a statutory due diligence defence does not cover all charges under the OHSA.  In other words, it is important for an employer to demonstrate the use of due diligence to ensure safety, but does not guarantee immunity from the regulations of the OHSA.
In cases where defences of due diligence have been successfully demonstrated, the accused party has:

  • identified all actual and potential occupational hazards (as applicable to the offence) – often consulting the expertise of a professional engineer
  • assessed the risk of exposure to identified hazards
  • implemented controls, where necessary, to minimize the risk of exposure
  • communicated the hazards, risks, and controls, to workers
  • monitored workers, work practices, and the workplace, for hazards
  • corrected unsafe work practices and remedied hazardous situations

An employer can facilitate the process of due diligence by hiring an outside consultant to provide assistance in analyzing equipment for inherent risks as well as performing risk assessments.  Advanced Engineering Safety Inc. will provide an employer with these types of services, in addition to relieving some of the stress and liability normally associated with equipment safety.

Are there any business benefits or incentives in performing PHSRs ?

While the main purpose of PHSRs is to ensure worker safety, there are certainly other benefits to consider, as seen in the illustration below.

Our Proposal…

Advanced Engineering Safety Inc. is dedicated to providing businesses with the expert professional knowledge necessary to achieve compliance with all obligatory regulations and standards.  We will utilize our engineering expertise in both the automotive and manufacturing industries to provide our clients with Pre-Start Health and Safety Reviews, as well as innovative design solutions.  Our goal is to provide you with all of the necessary services to assess your equipment systems for OHSA compliance, as well as design and implement the necessary changes for you to meet the applicable regulations.  Advanced Engineering Safety Inc. will not only provide you with high quality, low cost services, but will give you the confidence that your workplace equipment is safe for your employees.

The Benefits of using Advanced Engineering Safety Inc.

  • Advanced Engineering Safety Inc. can work with equipment integrators and suppliers to ensure that your equipment is compliant before it is delivered to you.
  • We can support you in conducting full risk assessments of your new or existing equipment to determine whether it meets the necessary regulations and is safe.
  • We will conduct complete and thorough Pre-Start Health and Safety Reviews at a reasonable cost that is within your budget.
  • Our engineers are very experienced at providing safety solutions that will achieve a balance between overall cost and production effectiveness.
  • We put your needs ahead of our own.  Many engineers are more concerned over their own personal liability and will lead you to implement excessive solutions that are unnecessary.  We are committed to making realistic determinations that yield the best possible outcome for your business while achieving compliance.
  • We guarantee the utmost level of discretion and privacy and will not relinquish trade secrets or confidential information to anyone.
  • Advanced Engineering Safety Inc. will readily provide any of the above engineering and safety services for entire plants – we will devise a plan to check all of your equipment systems as an entire turn-key project that is set to a schedule accommodating your needs.
  • In providing effective safety solutions, you can rest assured that your workers are less likely to sustain equipment related injuries.  Ministry of Labour audits are always more positive when they know that PHSRs are being provided from a competent and reliable source.
  • Monetary savings as a result of fewer equipment related injuries and reduced lost time in manpower.
  • In having us provide you with our engineering services, you will be exemplifying the process of due diligence and showing your employees that you take safety very seriously and take no short-cuts.

Ministry of Labour Guidelines for Pre-Start Health and Safety Reviews

Advanced Engineering Safety Inc. holds a valid Certificate of Authorization through the Professional Engineers of Ontario. Each of our engineers is a licensed professional maintaining a valid P. Eng. designation in Ontario.

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