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In Ontario, it is required by the Occupational Health and Safety Act that industrial machinery or equipment have a Pre-Start Health and Safety Review (PSHSR) carried out by a licensed professional engineer. This includes racking and lifting devices such as cranes (for more information, click here). What is a PSHSR? A Pre-Start Health and Safety Review is an assessment by a professional engineer of any industrial apparatus, protective element, process, or structure, to ensure compliance with applicable standards as laid out in Section 7 of Regulation 851, R.R.O. 1990 of the Occupational Health and Safety Act. The assessment involves an inspection of equipment followed with a written report indicating measures required to bring the equipment into compliance with the applicable standards. The purpose of a PSHSR is to identify and eliminate workplace hazards through proper safeguarding of the equipment.
For example, the following CNC machine, unguarded, exposes the operator to pinch hazards along the linear guides and hazards associated with the operating tooling. The PSHSR would identify these hazards and then recommend proper safeguarding solutions. In this example, to guard the CNC machine without hindering production, it would be recommended to use a combination of fixed perimeter guarding and safety mats as illustrated below: The
perimeter guarding physically prevents access to hazardous machine
parts, while the safety mats allow the operator access to the work
area without exposure to any hazardous motions. An interlocked rear
access gate allows access for maintenance and cleaning. Note: a
PSHSR goes beyond simply identifying an obvious hazard; the review
will ensure that all safety measures are in place in accordance with
standards specific to the machine. Also, electrical schematics of
safety circuits should be reviewed to ensure proper design in
accordance with determined risk levels. When is a PSHSR required? A PSHSR is required when installing or modifying new or existing apparatus, protective elements, structures, or processes in an industrial establishment, and the provisions of the Table (in Section 7 of Regulation 851) apply. These provisions can be viewed at: http://www.e-laws.gov.on.ca/DBLaws/Regs/English/900851_e.htm In general, a PSHSR is required for the following:
For further information, download the Ontario Ministry of Labour's "Guidelines for Pre-Start Health and Safety Review: How to Apply Section 7 of the Regulation for Industrial Establishments"
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A Pre-Start Health and Safety Review (PSHSR) is a design review of plans, drawings and specifications to confirm compliance with the OHSA and regulations. The OEM safeguarding provided with the equipment is not necessarily adequate under Ontario law. It is important that a professional review of existing safety measures be completed to ensure compliance. Even when proper safeguarding is in place, it is important to have a PSHSR carried out; a review of the safety circuit electrical schematics may reveal incorrect implementation of the of the safeguarding. |
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