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Pre-Start Health and Safety Review (PSR)




As of October 7, 2000, the government of Ontario amended the Occupational Health and Safety Act (OHSA) regulation concerning Pre-Development Reviews(PDRs). These amendments are now incorporated into Regulation 851, R.R.O. 1990 of the Industrial Establishments section of the OHSA. Employers are now required by law to perform Pre-Start Health and Safety Reviews (PSRs) on qualifying new or modified equipment.


What is a PSR?

Prior to any worker being permitted to operate any machinery, equipment, or a process in a hazardous environment before they are put into production, an employer is responsible for ensuring that a thorough report is prepared that shows that the equipment is safe. This PSR report is required to review all of the relevant regulations pertaining to that particular type of equipment.

Where do PSRs apply?

PSRs must be completed when:

  • 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, or (3) a combination of new, existing or modified engineering controls and other new or modified measures are used.
  • triggers one of the eights items in Ontario Regulation 851 Section 7 Table 1 Items below:

Item Applicable Provisions Circumstances
1. Subsections
22 (1), (2) and (4)
Flammable liquids are located or dispensed in a building, room or area.
2. Sections
24, 25, 26, 28, 31 and 32
Any of the following are used as protective elements in connection with an apparatus:

1. Safeguarding devices that signal the apparatus to stop, including but not limited to safety light curtains and screens, area scanning safeguarding systems, radio frequency systems and capacitance safeguarding systems, safety mat systems, two-hand control systems, two-hand tripping systems and single or multiple beam systems.

2. Barrier guards that use interlocking mechanical or electrical safeguarding devices.
3. Clause 45 (b) Material, articles or things are placed or stored on a structure that is a rack or stacking structure.
4. Section 63 A process involves a risk of ignition or explosion that creates a condition of imminent hazard to a person's health or safety.
5. Section 65 The use of a dust collector involves the risk of ignition or explosion that creates a condition of imminent hazard to a person's health or safety.
6. Sections 87.3, 87.4, 87.5 and 88, subsections 90 (1), (2), (3);
Sections 91, 92, 94, 95, 96, 99, 101, and 102
A factory produces aluminum or steel or is a foundry that melts material or handles molten material.
7. Sections 51 and 53 The construction, addition, installation, or modification relates to a lifting device, travelling crane or automobile hoist..
8. Sections 127 and 128 A process uses or produces a substance that may result in the exposure of a worker in excess of any occupation exposure limit set out in Regulation 833, 835, 836, 837, 838, 839, 840, 841, 842, 843, 844, 845 or 846 of the Revised Regulation of Ontario, 1990.

When is a PSR conducted?

  • Can be undertaken during design stage to determine measures for compliance.
  • During construction.
  • During testing and commissioning.
  • Has to be completed before putting into production.


Who can perform a PSR?


As mandated by the OHSA, the review must be conducted by a Professional Engineer (licensed in the province of Ontario) that possesses special expert or professional knowledge or qualifications. The only exception permitted is for circumstances that fall under Item 8 in the Table located within section 7 of Regulation 851. The Professional Engineer must have received a Certificate of Authorization from the Professional Engineers Ontario (PEO) to supply engineering services to public and have Personal Liability Insurance as required by the Professional Engineering Act.




PSR reports shall be kept readily accessible in the workplace together with any supporting documentation and be provided to the joint health and safety committee or health and safety representative before the apparatus, structure or process is put in use.




The PSR report and documentation may be reviewed, on request, by a Ministry of Labour inspector or by the company's joint health and safety committee or health and safety representative.

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