4 changes to pre-start reviews you need to know about
Changes to Ontario's pre-start health and safety review requirements that took effect January 1 have streamlined the process and made it more understandable for workplaces.
Under Section 7 of the Industrial Establishments Regulation (O. Reg. 851), pre-start health and safety reviews (PSRs) may be required in a factory* before new apparatus, protective elements, structures or processes are installed, modified or used. The intent, which remains unaffected by the recent changes, is to identify and eliminate or control hazards before the apparatus, protective element, structure or process goes into use. Although these reviews are conducted by professional engineers, business owners, employers, supervisors and workers should be familiar with and comply with PSR requirements.
WSPS Specialized Services Lead Michael Wilson explains PSRs this way: "If you are going to install something new or make modifications that might impact the safety of your workers, then look at it from a design and integration standpoint to ensure that you haven't missed any hazards. Be sure you’re making changes prudently, and you're not introducing new hazards."
Essentially, says Michael, “It’s just good business. If you know you’re going to be making changes, then make them in accordance with good engineering practices.”
How workplaces benefit from conducting PSRs
A PSR guideline from the Ministry of Labour, Training and Skills Development identifies four benefits:
- maintaining health and safety in the workplace.
- direct savings from minimizing retrofitting.
- less downtime and replacement of equipment.
- savings in workplace insurance claims due to fewer illnesses and injuries.
What's changed as of January 1
Here’s a sampling of changes:
- a modification to the Section 7 table that lists eight circumstances under which a PSR is required. A new column was added showing the exemptions to each requirement, if applicable.
- A new exemption for storing flammables (table item 1), providing that these requirements are met:
- no more than 235 litres of flammable liquids are stored per adequate cabinet.
- no more than three cabinets containing flammable liquids are in a group of cabinets.
- there is a minimum distance of 30 metres between groups of cabinets containing flammable liquids.
- a new exemption specific to table item eight related to worker exposure. The exemption refers to the use of a portable ventilation filtration system that does not exhaust to the outdoors. As an example, portable systems are sometimes used to collect and filter welding fumes.
- individual flowcharts for each table item in the ministry's PSR guideline.
These changes are based on a consultation process with stakeholders. “From what I heard, there were plenty of people willing to share their thoughts and experiences,” says Michael.
How WSPS can help
Employers are responsible for ensuring all workplace parties understand and fulfil their duties under the Occupational Health and Safety Act and applicable regulations. To help workplaces better understand PSRs, explore these resources:
- Ministry of Labour's Guidelines for Pre-Start Health and Safety Reviews, which includes a flow chart for determining when a PSR is required
- Machine Safeguarding: Understand the Pre-Start Health and Safety Review (2-minute video)
- Managing Pre-Start Reviews (in-person or virtual half-day training course)
- PSR insights from Honda of Canada Manufacturing (article)
- 6 things you need to know about PSRs (article)
The information in this article is accurate as of its publication date.
