Pre-Start Health and Safety Review (PHSR)

As of October 2000, any new or modified piece of equipment* to be used in an industrial establishment in the province of Ontario must have a Pre-Start Health & Safety Review (PHSR) completed before it is put into use.

This requirement is the result of an amendment to the Ontario Occupational Health and Safety Act that came into effect on October 7, 2000. Its goal is to ensure worker protection.

Ontario safety standards have become increasingly stringent over the last decade. The trend continues in 2011, as the Ministry of Labour is working to enhance workplace education about and compliance with this law.**

*The focus of a PHSR could be “an apparatus, structure, protective element or process.” For the purpose of this document, we refer to the PHSR subject as a ‘piece of equipment’ or ‘machine’.

**Bill 160 Occupational Health and Safety Statute Law Amendment Act, 2011

http://www.ontla.on.ca/web/bills/bills_d...

In this document we outline:

1. PHSR: Basic Definitions & Requirements,
2. Benefits of Integrating PHSR in Design/at Point of Purchase
3. Wexxar PHSR Option Packages
4. Illustrations

Essentially, a PHSR (a Pre-Start Health & Safety Review) is a professional risk-assessment.

It details corrective actions/design controls needed to bring equipment into compliance with Section 7 of the Regulation for Industrial Establishments section of the Ontario Occupational Health and Safety Act.¹

By law in the province of Ontario, employers must:

• assure the review is completed and
• any necessary measures taken to bring the equipment into compliance
• before the machine is put into use.¹

PHSR-required modifications often include:

Guarding, interlocking devices, safety gates, Emergency Stop features, electrical safety circuit designs, and electrical and pneumatic lock-out procedures—all designed to eliminate or control the risk to worker safety.

Inspections are machine-specific, and are required for each new or modified piece of equipment to be used in the province of Ontario.

PHSR is only required once; before integrating a new or modified item. For example, if a PHSR is completed for a machine and later the PHSR requirements change; a new PHSR would not be required. However, if a modification is later made to the machine, a new PHSR would need to be performed against the most updated PHSR requirements.

A Professional Engineer registered in the province of Ontario must perform the PHSR. In rare cases where specific knowledge is required, such as in the handling of toxic substances, an expert in that field may be required.

Each complete PHSR should be:

1. “kept readily accessible in the workplace together with supporting documents, and
2. Be provided to the Joint Health and Safety Committee or Health and Safety Representative, if any, before the [machine] is operated or used.”²

The maximum penalties for breaches of the Ontario Occupational Health and Safety Act (OHSA) regulations (including the PHSR) are set out in OHSA Section 66. A successful prosecution could, for each conviction, result in:

• A fine of up to $25,000 for an individual person and/or up to 12 months imprisonment;
• A fine of up to $500,000 for a corporation.³

“The Ministry's goal is for all workplaces to achieve self-compliance with OHSA.”

“Inspectors are the enforcement arm of the Ministry of Labour; their role includes the following: inspection of workplaces, issuing of orders where there is a contravention of OHSA or its regulations, investigation of accidents and work refusals, resolution of disputes, recommendation of prosecution.”³

The sources for the PHSR references in this document are: ¹ The Occupational Health and Safety Act’s R.R.O. 1990, Regulation 851 for

Industrial Establishments can be found in its entirety at:

http://www.e-laws.gov.on.ca/html/regs/en...

Note that “Pre-Start Health and Safety Reviews” is Section 7 of the above.

² Ontario Ministry of Labour: PSR Guidelines, http://www.labour.gov.on.ca/english/hs/p...

³ Ontario Ministry of Labour: The Occupational Health and Safety Act: FAQs http://www.labour.gov.on.ca/english/hs/f...

According to the Ontario Ministry of Labour;

“The Pre-Start Health and Safety Review is undertaken before start-up and ideally at the design stage.”²

“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…”

“Direct savings include:

• minimizing retrofitting
• less downtime [loss of production] & replacement of equipment,
• savings in workplace insurance claims due to fewer illnesses and injuries,
• and most important, maintaining productivity, health and safety in the workplace.”²

Purchasing equipment that is already PHSR-Certified has additional benefits:

Wexxar's PHSR option packages include:

1. The Review: a complete PHSR:

• Performed by an Ontario-registered Professional Engineer in compliance with the Occupational Health and Safety Act,
• covering the entire machine; the mechanical and electrical safeguarding
• conducted in our facility before shipment (machine arrives at Ontario site legal, ready-to-install & operate).

2. The Construction & Assembly

The PHSR Option components are designed, created, and assembled by the same team that designs and builds all other aspects of our machines. This makes for full integration of these safety features, and takes advantage of economies of scale in labor and in purchasing materials.

3. Additional Guarding

PHSR requires guarding that prevents access to the machine’s moving parts which may endanger the safety of any worker.¹

Wexxar PHSR guarding is designed specifically to satisfy PHSR requirements while maintaining machine functionality.

Examples of PHSR-specific guarding:

• Sliding guarding under the magazine assures operators can still easily adjust the machine dimensions as needed to run different case sizes.
• Outfeed guarding door(s) (depending on model) include(s) electrical switch(es) that disconnect(s) power if moved.
• Sheet metal skirt guarding not above 6” from the floor prevents access to moving parts from below.
• Lexan doors/panels extend to 6” from the floor.
• Panel alongside the magazine prevents access to moving feedbelts.

See drawing(s) on the following pages.

4. Added/Modified Electrical Safety Switch

In addition to the interlocking safety switches included in our standard machines, our PHSR models include additions or modifications (depending on model) to our electrical safety switch(es) attached to guarding on the outfeed end of the machine. This also corresponds changes to our standard electrical design and wiring.

End-user Site-specific Safety Requirements

The PHSR included in Wexxar’s option packages covers the machine itself.

It does not cover any other OSHA requirements regarding the site where the machine will be installed, such as building code, ventilation requirements or relationships with other machines/processes.

These and other site-specific safety requirements are the responsibility of the machine’s owner/end user.

The following is Wexxar pricing for our PHSR options per machine model:

Taking advantage of experience:

From our experience building machines for our customers in Ontario, Wexxar has acquired expertise in PHSR compliance. Through this, we are able to offer our customers the following through our PHSR machine packages:

• knowledge of PHSR as it applies to our machines & familiarity with the certification process,
• PHSR-specific mechanical & electrical engineering (hardware & software designs) created & tested for each model
• established relationships with Ontario Professional Engineers who know our machines and our PHSR record, and
• experience, skills, materials & tools on hand to perform the modifications in-house.

We hope that his information was of use in understanding PHSR and how it relates to Wexxar machinery.

Regardless of your decision whether or not to opt for a Wexxar PHSR option package; we highly recommend that each of our Ontario customers perform a cost-benefit analysis of all of the options available when purchasing or modifying achinery—carefully considering their legal obligations to bring equipment into compliance with Ontario’s Occupational Health and Safety Statutes.

Feel free to contact Wexxar’s specialized team with any questions related to our PHSR packages and how Wexxar can help your company fulfill legal obligations to meet Ontarios stringent safety requirements in a way that is efficient, thorough, and cost-effective.

Wexxar/BEL

Delta, BC, Canada

1 604 930 9300

1 888 565 3219

sales@wexxar.com