Pre-start health and safety reviews

When an employer introduces new equipment or procedures to the workplace, conducting a safety review mitigates risk and, in some jurisdictions, liability.

In Ontario, employers are required to conduct a Pre-Start Health and Safety Review (PSR) under the Ontario Occupational Health and Safety Act (OHSA). The engineering review outlines any potentially hazardous components on the new item or process for unfamiliar users. In British Columbia, legislation requires a similar review, but there is no official name for the document.

“An OHS professional would be looking to do a pre-start health and safety review when they’re bringing in new equipment, machinery, process or if they happen to be modifying an existing piece of machinery or process,” says Michael Wilson, a machine guarding specialist with Mississauga, Ont.-based Workplace Safety and Prevention Services.

Conducting a PSR is important because it identifies and assesses risk before workers are exposed to new equipment or perform a new process. It provides documented due diligence, Wilson says.

Professionals should use the term “regulated” PSR because a PSR can be conducted in almost any situation, but the regulated PSR applies to specific hazards under specific circumstances, according to Franco Tomei, a guarding specialist with Mississauga, Ont.-based Industrial Accident Prevention Association (IAPA).

To determine whether a “regulated” PSR is required, employers can ask themselves whether their new machine or process may require an automatic signal to stop it in case of an emergency, Tomei says.

“If there is no signal, technically, a pre-start review is not required,” he explains. “In terms of machine guarding… the circumstances are a protective element that signals the machine to stop.”

Employer responsibilities

According to Ontario legislation, an employer is responsible for providing a safe workplace and ensuring a professional has provided a PSR or equivalent documentation that shows the racking structure of a machine is in compliance with OHSA.

There are some cases when a PSR may not be required, Wilson says.

“For doing the pre-start review, you would be consulting an engineer or a knowledgeable person, but the legislation outlines the eight specific triggers that they’d be looking at,” Wilson says. “If I’m looking at a new piece of equipment or a new process and it’s handling flammables or dispensing flammables, if it’s machine guarding with interlocking devices to control a safety stop, (then) those are examples of the criteria that would be listed in the table under section seven of the industrial regulations.”

There is a table under section seven of the act that outlines the legal responsibilities of the employer (see table). Items one through seven of the table needs to be conducted by an engineer, according to Tomei.

The eighth and final point, which concerns itself with overexposure to workplace chemicals, can be done by someone who is deemed fit by the owner, leaser or employer.

“The people that would be qualified would be people like industrial and occupational hygienists,” Tomei says. “Those would be people considered competent.”

Employers should keep in mind they may be exempt from having to complete a PSR under items two, three, four and seven of the table, Tomei says.

“If you get… a machine manufactured in accordance with current applicable standards and it’s been installed according to instructions and current manufacturing applicable standards, then a pre-start review is not required,” he says.

In order to curb costs, employers should assess whether what is being implemented is governed by section seven of the table.

“Once you determine if section seven applies, then within that you can determine whether a pre-start review is required,” he says. “That assessment does not need to be done by professional engineers — it can be done by the employer.”

PSRs should be kept readily accessible within the workplace along with any supporting documentation, according to Wilson.An Ontario Ministry of Labour inspector may ask to review the documentation.

British Columbia

In British Columbia, employers are required to complete reports somewhat similar to the PSR in Ontario, according to Ian Rood, a principal with Vancouver-based UBSafe, a machine safety consulting company.

“We have legislation that says you have to adequately safeguard your machinery and then we have legislation that says those safeguards have to be designed and performed per Z432-94,” says Rood.

According to B.C.’s OHS Reg. 12.3, employers are required to safeguard new equipment and machinery in accordance with CSA Standard Z432-94, Safeguarding of Machinery.

“Basically, you have to build your guards to stop anybody from getting to a point of a hazardous operation, but as soon as you use those safeguards as a control system isolation device,” employers need to apply to WorkSafeBC with their safety plan and request approval, he says.

“There is no name for it, it’s just an approval under regulation 10.10 for a CSID, (which is) a control system isolation device as an alternate form of lockout.”

For the approval, employers will need to submit a risk assessment, a statement on the performance level of the circuits and all the documentation on the performance level of the devices, Rood says.

“All the steps of the pre-start safety review is essentially what this is,” he says.

Employers are required to submit the report to WorkSafeBC and await approval, Rood says.

OHSA SECTION 7: GUIDELINES FOR PRE-START HEALTH AND SAFETY REVIEWS

Legal responsibilities of Ontario employers