The Ministry of Labour defines a PSR as an in-depth examination of new or modified equipment or processes for specific hazards by a professional engineer.
This may involve a range of materials, including a written report outlining the areas of non-compliance (if any are found) and the required measures to achieve compliance. Ultimately, the aim behind these exams is to ensure the safety of workers before the equipment or process goes into use.
PSRs must be completed when one or more of these circumstances is true:
- A new “apparatus”, structure, or “protective element” is to be constructed, added, or installed, or a new process is to be used; or
- An existing “apparatus”, structure, “protective element”, or process is to be modified and to comply with applicable provisions whereby either: (1) new or modified engineering controls are used; (2) other new or modified measures are used; and (3) a combination of new, existing, or modified engineering controls and other new or modified measures are used.
- Triggers one of the eight items in Ontario Regulation 851, Section 7, Table 1.
A PSR can be conducted at various stages of a project’s completion. This may include:
- During the design stage to determine measures for compliance
- During construction
- During testing and commissioning
- Completed before putting into production (mandatory)
Individuals deemed qualified by the Industrial Establishments Regulation will be responsible for conducting the overall examination and determining compliance with the necessary processes and restrictions.
Determining PSR Requirements
Application of PSRs
Not only are PSRs required by law, but they are also crucial for maintaining a safe work environment for everyone involved. Business owners and organizations must ensure they comply with the requirements laid out by the regulating bodies both before and after the report is complete.
Exemptions
Currently, an exemption can be established using design and manufacturing documentation. Engineering drawings exist for a reason, and the quality of installation can
Properly executed exemptions can offer equal value to a PSR in protecting the workplace. Their purpose would be to provide an opportunity for streamlining, clever understanding, improved triggering, and burden relief.
Conducting PSR Reviews
A professional engineer is required to carry out the PSRs related to items 1 to 7 in the regulations chart. These individuals possess the technical knowledge needed to perform this task effectively.
The engineering community responsible for conducting PSR reports has the expertise, legal and ethical obligation, insurance, network, employee base, and legal standing to indemnify the employer for liability. However, engineers should continue independently developing their expertise to assess established codes and practices properly.
Consider the Guidelines
- The employer is responsible for ensuring that all requirements of the Occupational Health and Safety Act and regulations are complied with in the workplace.
- The Section 7 Table in Appendix 1 specifies the provisions of the applicable regulation and the circumstances under which a PSR is required.
- Integrating health and safety at the design stage and before operations begin is a cost-effective and proactive way to prevent workplace illness or injury.
- The regulation allows for flexibility because it does not specify any report format.
Conducting PSRs Step by Step
What must be included in a PSR report?
- Table 1 lists details of measures that must be taken to bring the apparatus, structure, protective element, or process into compliance with the specified provisions of the Regulation for Industrial Establishments.
- If testing is required before the apparatus or structure can be used (or before the process can be used), measures to protect the health and safety of workers must be taken before testing is carried out.
- Details of the apparatus or structure’s structural adequacy if item 3 or 7 of Table 1 applies.
- The date and signature of the person performing the PSR.
When is the PSR complete?
The PSR ends when all the measures identified in the PSR report have been taken, and the apparatus, structure, or protective element is put into production. Suppose the owner, lessees, or employer needs to take some or all of the measures specified in the PSR. In that case, they must notify the Joint Health and Safety Committee (JHSC) of what alternate measures have been taken to comply with the relevant provision of the regulation (see Section 7 Table).
Who gets a copy of the PSR report?
A copy will initially need to go to the employer, owner, or lessee whose responsibility is to obtain the report. Then, a second copy must be sent to the JHSC. It’s important to note that the obligation to supply the information is not the responsibility of the professional engineer who conducts the PSR.
Roles and Responsibilities in PSR Compliance
Responsibilities of the Practitioner
- Must know the Ontario Occupational Health and Safety Act and applicable regulations.
- Educate clients on the various requirements outlined by a Pre-Start Health and Safety Review in Ontario.
- Identify and address non-compliance issues with the application sections of O. Reg. 851.
Responsibilities of the Client
- Ensuring that all requirements of the Occupational Health and Safety Act and Regulations are complied with within the workplace.
- Ensuring that all persons are protected before operating any apparatus, structure, protective element, or process in the workplace.
In addition, the client is required to complete the following:
- Provide the practitioner with all applicable documentation and drawings such as electrical, mechanical, hydraulic, and pneumatic.
- Ensure the new or modified apparatus, structure, protective element, or process is not operated or used until a review has been conducted.
- Ensure all measures identified in the PSR required for compliance have been implemented, or provide a written notice to the JHSC or the HSR if any actions are not taken and what steps are in place to comply with the relevant provisions.
- Keep all PSR reports and exemption documentation in a readily accessible location in the workplace.
- Ensure that all documentation is provided to the JHSC or the HSR for review before the apparatus, structure, protective element, or process is operated or used.
Maintaining Ongoing PSR Compliance
- Understand your role within the PSR compliance requirements.
- Conduct regular inspections of equipment and workplace environment.
- Review the compliance requirements considered in a PSR report.
- Develop working relationships with qualified, professional engineers.
- Keep all records readily available and accessible within the workplace.
- Learn about the various governing bodies and regulations in place.
Be Prepared for a PSR
Knowing the PSR requirements outlined in section 7 of Ontario’s Regulation for Industrial Establishments ensures that you and your employees will operate in a safe work environment.
Although complex and technical, the compliances listed in this review are meant to prevent injuries before they happen, identify hazards, and implement the proper control measures ahead of time. By knowing exactly how to comply with the requirements of a PSR, you can save yourself a headache and take responsibility for your job site.
