The purpose of this knowledge file is to provide a basic overview of what a pre-start health and safety review (PSR or PSHSR) is in order to facilitate the planning and coordination of PSR projects.

PSRs and the law.

Section 7 (2) of Ontario Regulation 851 states:

“An owner, lessee or employer shall ensure that a pre-start health and safety review is conducted if, in a factory, an applicable provision applies and a corresponding circumstance described in the Table* will exist:

(a) because a new apparatus, structure or protective element is to be constructed, added or installed or a new process is to be used; or
(b) because an existing apparatus, structure, protective element or process is to be modified and one of the following steps must be taken to obtain compliance with theapplicable provision:
(i) New or modified engineering controls are used.
(ii) Other new or modified measures are used.
(iii) A combination of new, existing or modified engineering controls and other new or modified measures is used.”

*The “Table” is in the Regulation and lists circumstances when a PSR is required. It will be reviewed later in this presentation.

What is a PSR?

A PSR is an in-depth examination of equipment or processes to identify areas and features of non-compliance which create hazards during routine operations (Note that some maintenance and housekeeping activities are considered routine operations).

Except for the applicable provisions in Section 7 of the Regulation for Industrial Establishments (O.Reg. 851), a PSR is NOT a review of compliance with all the requirements under the said Regulation or any other Act or Regulation.

The goal of a PSR.

The goal of a PSR is hazard elimination or control before the equipment or process is operated or used. This includes testing, commissioning and start up after modifications. Thus, PSRs must be conducted before the equipment or processes are used, preferably at the design stage.

When is a PSR required?

PSRs are typically required when buying or modifying equipment as well as before setting up or modifying processes. However, O.Reg. 851 only requires a PSR under the following eight circumstances:

1. Storage and dispensing of flammable liquids.
2. Use of Safety Instrumented Systems (e.g., safety mats, light curtains, interlocked door switches, safety logic devices, etc.).
3. Racks/stacking structures.
4. Processes that involve the risk of ignition or explosion.
5. Dust collectors that involve the risk of ignition or explosion.
6. Production and processes that handle molten materials.
7. Cranes.
8. Ventilation systems related to the handling of hazardous biological or chemical agents.

Even when the mentioned circumstances exist, certain conditions must be met for a PSR to be required under O.Reg. 851.

Nevertheless, even if a PSR is NOT required per O.Reg. 851, JNE clients will need and request Safety Reviews to ensure compliance with other parts of O.Reg. 851 or other
Regulations. In these cases, Safety Reviews are typically conducted and reported under the PSR process and format.

PSR exemptions.

When a PSR is required, an exemption can be established for
circumstances 1, 2, 3, 4, 7 and 8. However the exemption must be
properly justified and documented; a ‘Letter of Exemption’ issued by the Industrial Safety group would be recommended.

For instance, a PSR exemption for a traveling crane is possible if there is documentation, bearing the signature and seal of an engineer, containing the design loading capacity of the original support structure for the travelling crane. In this case the Industrial Safety group would review all the documentation and, if satisfactory, would issue a stamped letter of exemption.

How are PSRs conducted?

PSRs are conducted and documented as per the Pre-Start Health and Safety Review Guideline issued by Professional Engineers Ontario (PEO).

https://www.peo.on.ca/sites/default/files/2022-06/PSRGuideline.pdf

PSR Reports

A PSR is documented in a report that includes all the elements required by the Industrial Establishments Regulation (O.Reg. 851) for the specific circumstance.

The report is typically a report of deficiencies that need to be addressed to bring the equipment into compliance. The report also indicates what measures are necessary for such purpose. However, a PSR report is NOT a list of specific actions, designs, and / or changes necessary to make the equipment or process compliant.

Common misconceptions.

• A PSR is an equipment / process safety certificate.
• A PSR is required for all new equipment.
• Fixed guards require a PSR.
• A PSR must have no deficiencies for the PSR to be complete, stamped, and closed.
• A PSR is a final safety review.
• PSRs cover the competencies of the Electrical Safety Authority and the Technical Standards and Safety Authority.