Pre start health and safety review

Pre-start Health and Safety Reviews (PSR) are a Ministry of Labour requirement. This regulation requires the owner, lessee, or employer to have proper documentation for new or used storage equipment. Concept Storage Solutions Ltd. has provided hundreds of Pre-start Health and Safety Reviews for our customers and also for owners of storage equipment who have received a Ministry of Labour “Order to Comply”. Making sure your storage system complies with Ontario Health & Safety Act is important. Our experienced staff members are happy to review your site.

Workplaces with racking and storage facilities may contain potentially serious hazards. The improper use, selection and installation, or maintenance of racking and storage systems may put workers at risk of injury.

The Ministry of Labour inspects racking and storage facilities used by workers at industrial workplaces across Ontario. The stepped-up enforcement is part of the ministry’s Safe At Work Ontario strategy, launched in June 2008.

Ministry of Labour inspectors will check whether the required precautions are being met by all who work in and around racking systems, as specified in the Occupational Health and Safety Act (OHSA) and the Regulations for Industrial Establishments (R.R.O. 1990, Reg. 851).

Changes to Ontario's pre-start health and safety review requirements that took effect January 1 have streamlined the process and made it more understandable for workplaces.

Under Section 7 of the Industrial Establishments Regulation (O. Reg. 851), pre-start health and safety reviews (PSRs) may be required in a factory* before new apparatus, protective elements, structures or processes are installed, modified or used. The intent, which remains unaffected by the recent changes, is to identify and eliminate or control hazards before the apparatus, protective element, structure or process goes into use. Although these reviews are conducted by professional engineers, business owners, employers, supervisors and workers should be familiar with and comply with PSR requirements.

WSPS Specialized Services Lead Michael Wilson explains PSRs this way: "If you are going to install something new or make modifications that might impact the safety of your workers, then look at it from a design and integration standpoint to ensure that you haven't missed any hazards. Be sure you’re making changes prudently, and you're not introducing new hazards."

Essentially, says Michael, “It’s just good business. If you know you’re going to be making changes, then make them in accordance with good engineering practices.”

How workplaces benefit from conducting PSRs

A PSR guideline from the Ministry of Labour, Training and Skills Development identifies four benefits:

• maintaining health and safety in the workplace.
• direct savings from minimizing retrofitting.
• less downtime and replacement of equipment.
• savings in workplace insurance claims due to fewer illnesses and injuries.

What's changed as of January 1

Here’s a sampling of changes:

1. a modification to the that lists eight circumstances under which a PSR is required. A new column was added showing the exemptions to each requirement, if applicable.
2. A new exemption for storing flammables (table item 1), providing that these requirements are met:
   • no more than 235 litres of flammable liquids are stored per adequate cabinet.
   • no more than three cabinets containing flammable liquids are in a group of cabinets.
   • there is a minimum distance of 30 metres between groups of cabinets containing flammable liquids.
3. a new exemption specific to table item eight related to worker exposure. The exemption refers to the use of a portable ventilation filtration system that does not exhaust to the outdoors. As an example, portable systems are sometimes used to collect and filter welding fumes.
4. individual flowcharts for each table item in the ministry's PSR guideline.

These changes are based on a consultation process with stakeholders. “From what I heard, there were plenty of people willing to share their thoughts and experiences,” says Michael.

How WSPS can help

Employers are responsible for ensuring all workplace parties understand and fulfil their duties under the Occupational Health and Safety Act and applicable regulations. To help workplaces better understand PSRs, explore these resources:

In Ontario, all ‘factories’ are required to comply with all applicable sections of Ontario Regulation 851 (the Industrial Establishments Regulation) under the Occupational Health & Safety Act (OHSA). Under Section 7 of Regulation 851, companies are obligated to ensure that a Pre-Start Health and Safety Reviews (commonly referred as PSHSRs, PHSRs or PSRs) is conducted to keep workers safe. These reviews assess key equipment and processes for compliance with specific regulatory requirements prior to their introduction into the workplace.

While this obligation is broadly placed on the organisation, it is important to realise it also falls on the shoulders of not just owners, but employers, supervisors and the workers themselves. Here we look at what a PSR involves and when they are required.

Note: The OHSA contains a specific and comprehensive definition of a factory, but in summary, a factory is any workplace where energy is used in the manufacturing, assembling, preparing, inspecting, finishing, repairing, warehousing, cleaning, adapting, or maintaining of any goods, products, articles or thing. If this sounds like your facility, you need to be familiar with PSRs.

What is a PSR?

A PSR is an in-depth examination of an apparatus, structure, protective element, or process to ensure the applicable provincial and national safety requirements are being met.These reviews must be conducted by a qualified professional, typically a licensed Professional Engineer, who meets the qualifications outlined by the Industrial Establishments Regulation.

Their role is to examine an apparatus, structure, protective element or process (identified by the 8 specific circumstances described in Section 7) and determine if the relevant requirements have been satisfied. It is their responsibility to perform the assessment and provide a report satisfying all the required elements described in the Industrial Establishments Regulation.

What is the purpose of PSRs?

PSR’s serve the purpose of identifying hazards associated with specific types of equipment, structures, and processes that could expose a worker to injury during typical operations. The goal of a PSR is to facilitate the elimination or control of a hazard before the equipment, structure, or process under review is used.

When are PSRs required?

The criteria for determining when a PSR is required starts first with confirming the facility meets the definition of a factory. If so, one of the 8 circumstances listed in the Table in Section 7 of Ontario Regulation 851 must be applicable, and at least one of the corresponding provisions must apply.

If this is the case, Section 7 describes two situations within which a PSR must be completed:

1. When a new process will be used or a new apparatus, structure or protective element will be constructed, added or installed. or
2. When an existing apparatus, structure, protective element or process will be modified, and the modifications will require one of the following changes to remain in compliance with the applicable provisions of the Industrial Establishments Regulation:
   • new or modified engineering controls
   • other new or modified measures

When applicable, it is often most efficient to have a PSR completed at the design or planning stage as this provides ample opportunity to identify non-compliance allowing issues to be corrected prior to implementation and often avoiding costly or inconvenient retrofits..

Can maintenance affect compliance?

Generally speaking, maintenance does not affect compliance. However, this is only true when the required maintenance does not include altered parts. In other words, any maintenance that involves identical or “like for like” replacement of components would not trigger a PSR.

If, for example, you are maintaining a piece of older equipment for which parts are no longer available and you have to use a replacement part that is not identical or add additional components to make up for missing parts, this would require a PSR.

What is considered a modification?

Modifications are any activities or work performed on an apparatus, structure, protective element or process that could interfere with compliance.

For example, in the case of an apparatus or protective element, replacing a part with something that is not identical to the original part could lead to a deviation from the original design intent or performance of the system.. In the case of a process, a chemical might be replaced with one that requires different handling and storage procedures..

In either case, these changes may lead to unexpected hazards that were not accounted for the in the original design of the system / process. A PSR serves the purpose of ensuring these hazards are identified and addressed, if necessary.

Can equipment be moved without a PSR?

This is an important question. In order to avoid a PSR the move would have to include the following three factors:

• The new location is within the same facility/workplace
• No modifications to the apparatus, structure or process that would trigger a PSR are required during the move
• Engineering controls and/or measures to deal with hazards introduced by changing the location are not required.

If any of these statements are not true, then a PSR is required once the apparatus, structure or process is installed in the new location.

What are the benefits of PSRs during design and planning?

Early introduction of a PSR is the most cost-effective approach for your company. By being proactive, you eliminate costly delays that can disrupt operations. You also prevent worker injury and avoid non-compliance fines. The benefits of early PSRs include:

• Reducing costs associated with retrofitting later in the process
• Avoiding downtime due to shutdowns when equipment or processes are not up to the proper standards
• Costly replacement of non-compliant equipment and apparatuses
• Mitigated risk for savings in insurance claims and fines

However, your company also maintains health and safety in the workplace to improve productivity as well as worker morale.

Why are Pre-Start Health & Safety Reviews important?

Simply put, Pre-Start Health & Safety Reviews help ensure worker safety.

Workplaces today operate on a dynamic landscape of ever changing standards and regulations. PSR’s help ensure that these workplaces stay compliant and, by employing professional that stay focused and educated on safety engineering, continue to implement ever more reliable ways of maintaining safe work environments.

We at HITE Engineering understand and advocate for every individual’s right to feel and be safe at their place of work. Safety is not optional.

If you would like more information about our Pre-Start Health And Safety Reviews or other safety engineering services, please contact our team today.

What is a PSR in safety?

In Ontario factories, pre-start health and safety reviews ( PSHSRs or PSRs ) are required before certain equipment or processes are put into operation to keep workers safe.

What is a PSR in manufacturing?

Employers are now required by law to perform Pre-Start Health and Safety Reviews (PSRs) on qualifying new or modified equipment.

Where in the Ontario legislation does it mention pre

Section 7 of the Industrial Establishments regulation (Regulation 851) under the Occupational Health and Safety Act (OHSA) requires that a pre-start health and safety review be carried out on certain machinery, protective elements, structures and processes before they are put into service for the first time or if ...