Understanding Pre-Start Health and Safety Reviews: What Is It and When Is It Triggered?

May 21, 2020 | 4 min read

A Pre-Start Health and Safety Review (PSHR) is an Ontario requirement, governed by the Occupational Health and Safety Act, for certain industrial structures, apparatuses, and processes to undergo a formal safety review prior to construction, installation, or modification.

Specific details about PSHRs can be found in the Occupational Health and Safety Act R.R.O. 1990, Regulation 851 for Industrial Establishments, under Section 7. <Read Here>

A PSHR must be completed prior to any new or modified apparatus, structure, or process undergoing operation. Only a professional engineer can perform the review on these trigger events, with the exception of item 8 which can be completed by a “knowledgeable person.”

Trigger Mechanisms

PSRs are only triggered by the following potential hazards:

  1. When flammable liquids are located or dispensed in a building, room, or area
  2. When the following protective elements are used:
    • Light curtains and screens
    • Area scanning safeguard systems
    • Radiofrequency systems and capacitance safeguarding systems
    • Safety mat systems
    • Two-hand control and/or tripping systems
    • Single or multiple beam systems
  3. When racking or stacking structures are used to store materials
  4. When a process involves any risk of ignition or explosion that can result in hazard to a person’s health and safety
  5. When a dust collector presents any risk of ignition or explosion that can result in a hazard to a person’s health and safety
  6. When a factory produces aluminum or steel or is a foundry that melts material or handles molten material
  7. When any type of lifting device, traveling crane system, or automobile hoist is newly constructed, installed, or modified
  8. When a process uses or produces a hazardous substance that can result in the overexposure of a worker to limits prescribed by Ontario regulations


All reviews must include a written report that contains the following details:

  • Specific measures are undertaken to bring the apparatus, structure, protective element, or process in compliance with Section 7
  • Details of protective measures taken prior to testing being carried out
  • Specific details about the structural adequacy of the apparatus or structure if item 3 or 7 applies
  • Date and signature of the person performing the review
  • If a professional engineer performed the review, his or her seal is required
  • If not an engineer (for item 8), details of his or her expert knowledge or qualifications

Safety Is Always the Employers Responsibility

Under Ontario Guidelines for Applying Pre-Start Health and Safety Reviews, the document specifically states even when a PSHR is not required, the employer must “ensure that workers will be protected when they use any apparatus, structure, protective element, or process in the workplace.”

In the event of an incident involving plant machinery or processes, the first thing the Ministry of Labour will investigate is if the employer did everything reasonably possible to ensure their employees’ safety? In other words, the employer will have to prove their “due diligence.”

The best way to prove due diligence is to have a professional engineer at Industrial Inspection & Analysis perform a safety review on any structure or machinery that presents some form of risk to your employees. Once reviewed, our engineers provide you with a safety letter or letter of compliance, similar to a PHSR; essentially a formal document that provides recommendations for, or determines that, the structure, apparatus, or process poses no risk to a worker.

Operating an Unsafe Workplace Is Costly

In 2013-14, the Ministry of Labour charged a total of $9.3 million in fines for safety infractions under the OHS. While the fiscal penalty is heavy, it pales in comparison to the emotional stress that occurs when the life of an employee is affected, or even lost due to workplace accidents. A corporation that is convicted of noncompliance could face a maximum fine of $500,000 per count. For individuals, the maximum fine is $25,000 per count, plus a 20% victim surcharge levied on all fines imposed by the courts, and/or imprisonment for up to 12 months.

Schedule a phone call/video conference to discuss how IIA has the process in place to help you navigate PSHRs and mitigate your company risk.