Pre-start Health and Safety Review - Frequently Asked Questions

Understanding PHSR's

As of October 2000, a Pre-start Health and Safety Review (or PHSR) must be performed on any new or used process or equipment which has been moved into a new workplace or where a safety control has been added or modified. This is a requirement of the Ontario Health and Safety Act. In effect, it is law. Many companies have not adopted the practice of performing PHSR's when they are required. This has a number of very negative consequences. A large part of the problem is that the PHSR process is not very well understood. Here we hope to shed some light on the PHSR process and the new responsibilities faced by industries.

What is a Pre-start Health and Safety Review?

A PHSR is a specific audit of a process or piece of equipment which may uncover deficiencies with respect to relevant sections of the Ontario Health and Safety Act. The safety concerns are identified and evaluated for hazard potential. Measures to bring the deficiencies into compliance are defined. The results are then presented to management and the Joint Health and Safety Committee and are used to establish an action plan for the implementation of the measures.

What is the purpose of a Pre-start Health and Safety Review?

There are many instances of equipment which is presently in an unsafe operating condition. The standards of safety are increasing every year. This process is a means to improve the safety of new or modified equipment, to enhance the visibility of these standards, and to educate. The goal is to apply these standards to existing equipment to bring the whole standard up to enhanced levels.

When are they required?

A Pre-start Health and Safety Review is required when new or used equipment or process is moved to a new workplace. Exemptions are possible under certain specific conditions.

Who can perform PHSR's?

PHSR’s must be performed by a professional engineer registered in the Province of Ontario. However, in rare cases a competent technical person can do them. Firms which offer engineering services, including those who perform of PHSR’s, must hold a Certificate of Authorization issued by Professional Engineers Ontario (PEO).

What are the benefits of PHSR's?

On the positive side, the PHSR process identifies equipment safety concerns and proposes practical measures which are necessary to place the equipment in a safe and reliable operating condition. It also identifies unsafe working practices and can uncover areas of inefficiency or waste.

A structured action plan allows safety deficiencies to be corrected in an organized and cost effective manner. A side benefit is renewed motivation from employees when they realize their employer is taking an active step towards ensuring their safety. Obviously, a safer operation means fewer injuries, less lost time, and lower insurance premiums, as well as higher worker morale.

What happens if a PHSR isn’t performed?

Many companies are not aware of the legislation. Many others are aware but choose to adopt a head in the sand posture. In either case, due diligence is not being served in ensuring that the workers are reasonably protected from unsafe work situations. Unfortunately, doing nothing can foster a false sense of security. This "don’t ask, don’t tell" policy creates a fragile situation. A simple visit by the Ministry of Labour to investigate an incident or as a result of a complaint from a concerned employee can quickly stop all production. Usually this entails significant loss of production, high material costs, overtime labour, and requires an engineer to sign-off. Failing to observe basic due diligence can also result in personal fines or imprisonment if a serious injury occurs. In fact, sections 66(1) and 66(2) of the Occupational Health and Safety Act state that, if convicted under the Act, an individual can be fined up to $25,000 and/or imprisoned for up to 12 months. The maximum fine for a corporation is $500,000. Of course, these penalties are only material. It is far more difficult to carry the burden of knowing that an accident could and should have been prevented. Damage to a human life has an immeasurable price that no one should have to bear due to negligence. So take a proactive stance: get your equipment certified!

Where do you start?

Engage a professional engineering firm utilizing experienced senior engineers to explain the Pre-start Health and Safety Review process and evaluate the equipment and whether a PHSR is required. Adopt a plan of action to achieve the necessary level of due diligence. Perform the PHSR. Involve the employees; get the input from operators, maintenance, and supervision. Work with the engineer to come up with reasonable, but effective solutions. Develop practical solutions that will maximize the safety of the machinery or process and yet be workable so the machine can be operated at regular production speeds and can be maintained with little obstruction of maintenance.

The right team will come to realistic and common sense solutions. WINTEK has experienced senior engineers to identify and analyze potential safety hazards. Discuss the safety concerns of operators and maintenance personnel. Be sure that you get the senior expertise to do the job right the first time. Get experienced engineers who can work with you to come with a safe, practical solution.