Guideline for pre-start health and safety reviews
Learn about pre-start health and safety reviews, when they’re required, who can do them and how they keep workers safe.
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. This guideline will help workplace parties understand their obligations to comply with Section 7 of Regulation 851, Industrial Establishments, (the Industrial Establishments Regulation) under the Occupational Health and Safety Act (OHSA).
Owners, employers, supervisors and workers have responsibilities under the OHSA and its regulations. They must be familiar with and comply with those requirements, including the PSR requirements. For information about the OHSA, refer to the Guide to the Occupational Health and Safety Act.
This guideline is intended for someone carrying out a PSR, such as an engineer, and to help people understand the requirements for PSRs, such as:
- an owner
- a lessee
- an employer
- a health and safety representative
- members of the joint health and safety committee
This resource does not replace the Occupational Health and Safety Act (OHSA) and its regulations and should not be used as or considered legal advice. Health and safety inspectors apply and enforce these laws based on the facts they find in the workplace.
Purpose of PSRs
An owner, lessee or employer must ensure that workers will be protected when they use any apparatus, structure, protective element, or process in the workplace, in accordance with the OHSA and its regulations.
Section 7 of the Industrial Establishments Regulation may additionally require that a PSR be carried out before an apparatus, structure, protective element, or process is used in a factory, and preferably at the design stage, to identify any areas of non-compliance.
A PSR identifies hazards associated with the equipment, structure or process that could expose a worker to injury during routine operation. The goal of a PSR is hazard elimination or control before the apparatus, protective element, structure or process is started up or used in a factory.
Integrating health and safety early—at the design stage and before the equipment is used—is a cost-effective and proactive way to prevent worker illness or injury. The benefits include:
- direct savings from minimizing retrofitting
- less downtime and replacement of equipment
- savings in workplace insurance claims due to fewer illnesses and injuries, and
- most importantly, maintaining health and safety in the workplace
There are several terms used in Section 7 of the Industrial Establishments Regulation which are defined only for the purpose of Section 7:
- Equipment, machine or device.
- Applicable provision
- An applicable provision of this Regulation that is listed in the Table.
- Protective element
- A shield, a guard, an operating control acting as a guard, a locking device or any other device preventing access.
- Spray booth
- A spray booth as defined in O. Reg. 213/07 (Fire Code) made under the Fire Protection and Prevention Act, 1997.
- The Table to section 7. In this guideline, wherever the term “Table” is used, it means the Table to section 7.
The following terms are not defined in regulation but are explained here for the purpose of this guideline.
- Activities or work on an existing apparatus, structure, protective element or process that restore it to its original state as designed and installed.
- Activities or work on an apparatus, structure, protective element or process that change it from its original or current design and installation parameters. A modification could be the replacement of a part with a non-identical part or changing the chemicals used in a process. Modifications may result in non-compliance with the applicable provisions and new control measures, such as engineering controls, may be required to restore compliance.
- To operate the equipment or machine for the purpose it was built or operating in production mode.