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 workers to crush hazards from the raising and lowering of the loading conveyor, and shear hazards from material transfer mechanism.

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 light curtains as illustrated below:

The  perimeter guarding physically prevents access to the shear hazards of the transfer mechanism, while the light curtains allow safe loading of material onto the rear loading conveyor.

(see previous example)
 

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:
you are an industrial establishment, and;

• you are installing new apparatus (i.e. machinery) that utilizes safeguarding devices which signal the apparatus to stop (i.e. interlocks, light curtains, two hand safety systems, safety mats, etc…), or;

• you are modifying or installing existing apparatus, or;

• you use racking or a stacking structure, or;

• you have a lifting device, traveling crane, or automobile hoist.

• you have a process which uses or produces substance(s) that may result in the exposure of a worker in excess of any occupational exposure limit.

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"

Adobe PDF format [ 313kb / 42 pages ]:    click here 
Online Version:  click here

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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