Safety First: Prepare to pre-start

by Michael Wilson

Pre-start health and safety reviews are a legal requirement only in Ontario, but why should Ontario businesses be the only ones to benefit?

Michael Wilson is a machine safety and robotics expert at Workplace Safety & Prevention Services (WSPS).

Pre-start health and safety reviews (PSRs), legally mandated under section 7 of Ontario’s Industrial Establishments Regulation, are safety examinations that may be required before new apparatus, protective elements, structures or processes are installed, used or modified. They are usually conducted by a professional engineer.

So far, PSRs are unique to Ontario. The requirement has been in place since 2000, with periodic updates since then. The most recent changes took effect January 1.

The intent behind PSRs is to prevent injuries by building safety into new equipment or processes starting at the design stage. In your workplace, this could apply to new or modified racking and stacking structures, lifting devices, robotic palletizing systems, and more.

While the PSR requirement is unique to Ontario, I’ve worked with businesses that also operate in other parts of the country and conduct the PSR process in locations with no legal requirement to do so.

Business benefits

One could argue that these businesses are just living up to the spirit of the law: health and safety legislation in every province and territory has a “general duty clause” requiring employers to take all reasonable steps to protect the health and safety of workers. In this context, PSRs help employers to identify and eliminate or control hazards.

Conducting PSRs when not required by law may also generate business benefits. They demonstrate the workplace’s commitment to safety. They reduce or eliminate the need for potentially costly retrofits. They also help sustain safety and productivity.

Under Ontario law, PSRs are required only in “factories”, which by definition encompass warehouses and distribution centres. A workplace meets the definition if machinery or devices are used to warehouse products. It also qualifies if there is an assembly process, such as an assembly line, to make goods or products that use machinery.

PSRs are typically conducted by an expert or team of experts who assess the equipment, structure, protective element or process for hazards that could injure a worker, and submit a written report. Among other things, the report outlines areas of concern and details the measures necessary to bring the apparatus, structure, protective element or process into compliance.

Key considerations

If you’re thinking of introducing PSRs into your workplace, keep these considerations in mind.

Your workplace doesn’t need in-house expertise to conduct a PSR, but it does need to manage the process. That’s because PSRs are usually contracted out. Few workplaces have staff with the necessary qualifications or experience.

Get the right person or team to conduct the PSR. When selecting them, ask about their qualifications, background and familiarity with the process to ensure they can provide effective guidance.

Make sure you can establish a good working relationship with the report provider. Once the report is issued, there will be questions and possibly a need for more guidance on potential solutions to address the issues identified. A solid working relationship will help ensure questions are addressed.

Avoid costly retrofits by beginning early and involving key players. I strongly encourage workplaces to involve staff and ensure safety is a high priority in the preliminary stages of planning changes. Participating employees may include safety coordinators, safety managers, engineering staff, purchasing and accounting staff, as well as equipment operators and maintenance staff. Ask the latter two groups if they have safety concerns, and encourage input on solutions.

Implement the measures identified in the PSR report. As an engineer, I rarely issued a report that didn’t have measures required for compliance. More recently as a health and safety consultant, I’ve known of situations in Ontario where inspectors see a new racking set-up or process and ask to see the PSR report. If you haven’t acted on the measures identified in the report, the inspector will likely ask more questions.

And maintain the safety of new or modified equipment or processes after they go into operation. Ensure you have a good maintenance program and operating procedures to maintain the safety integrity of the equipment or process.

Final words

PSRs have been a legal requirement in Ontario for over 20 years. It’s a prudent approach to eliminating or controlling hazards in any workplace introducing a new or modified apparatus, structure, protective element or process. For those of you outside of Ontario, the concept is worth exploring.