PSR Principles

It’s well known in Ontario that industrial establishments, owners, lessees and employers must obtain a Pre-Start Health & Safety Review (PSR) report signed and sealed by a professional Ontario engineer stating compliance to the Occupational Health and Safety Act.

PRSs are needed whenever companies upgrade or bring in new equipment. A large pool of engineering companies provide services to achieve the necessary compliance to the regulation. That can make it challenging when you need to find such a firm. When selecting a PSR provider, one needs to take the following points into consideration.

Disclaimers. Some engineers place disclaimers in their reports to minimize their liabilities. As a purchaser of PSR services, you should not accept any disclaimers. The engineer who signs and seals the report must assume full responsibility for the content of the report.

Hazard assessment. This must be a part of any PSR report, especially one dealing with machine guarding issues. Some reports do not include a hazard assessment and it is therefore impossible to assess the electrical circuitry architecture of the machine to establish the degree of safety redundancy necessary.

Conclusive statements. Some reports do not have any conclusive statements or recommendations to achieve compliance. The report may just indicate non-compliance issues based on a simple physical examination of the machine. Drawings, which show the architecture of the electrical circuitry, are sometimes not examined. When selecting a provider, specify that a conclusion is to be part of the report.

Multiple disciplines. The majority of PSR providers specialize in one discipline only. However, owners and employers have to make sure that all issues of concern — flammable liquids handling, potentially explosive atmospheres, dust collectors, racking, molten metal in foundries and hazardous substances — will be addressed by the provider. Therefore, a firm with a multi-discipline capability should be given consideration.

Liability insurance coverage. The owner and employer should clearly specify the insurance coverage expectations, including general liability, professional errors and omissions, and WSIB insurance.

Advice. Some PSR providers are not capable of directing clients on how to achieve compliance, so employers are left in the dark about how to upgrade their equipment. When selecting a provider, one needs to make sure that such help is available. Needed services may include design and project management capabilities.

Here is an example of a typical specification — in this case for machine guarding — that lists the capabilities and qualifications that should be provided by a PSR provider.

Technical specifications: The supplier shall ensure that the machine guarding and safety interlocks/circuits comply with the Ontario Occupational Health & Safety Act by getting a pre-PSR sign-off prior to shipment of the equipment to the purchaser. CSA approval can be completed on site, but the supplier will arrange for and cover the cost of the inspection, as well as the cost to rectify any deficiencies noted in the inspection.

The supplier must ensure that once the installation of the equipment is complete, the PSR can be signed off on the equipment. The supplier is to bear the costs associated with compliance to the PSR and with changes necessary for the equipment to comply with the PSR.

Performance specifications: PSR providers shall be a multi-discipline professional engineering firm holding a Certificate of Authorization issued by Professional Engineers Ontario (PEO). The firm shall have minimum professional liability insurance of $1,000,000, general liability insurance of $5,000,000, and a WSIB clearance certificate.

The firm shall employ mechanical, electrical, fire protection, chemical and structural engineers and industrial hygienists capable of assessing the following issues: storage and dispensing of flammable liquids; machine guarding; racks and racking systems; potentially explosive processes; dust collectors; lifting devices; and occupational exposure to hazardous substances. The firm must be capable of assisting the supplier by providing mechanical and electrical design and project management, if necessary.

The firm must be capable of coordinating activities with global equipment suppliers.

PSR reports must be signed and sealed by a professional engineer registered in Ontario; include a comprehensive hazard analysis; be conducted in accordance with guidelines published by PEO; have no disclaimers of liability; and have a clear statement of compliance to the requirements of Section 7 of the Occupational Health and Safety Act of Ontario.

Installation and commissioning: The final PSR report is released to the purchaser’s Joint Health and Safety Committee (JHSC).

By following this simple format, employers can ensure that they have transferred their equipment design liability to the PSR provider, that they have fully followed the due diligence process, and that they are capable of upgrading their equipment.

Simon Fridlyand, P.Eng., president of S.A.F.E. Engineering, can be reached 416-447-9757 or simonf@safeengineering.ca. For more information, visit www.safeengineering.ca.