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The Reviewer Carrying Out a Pre-Start Health and Safety Review

  • Issued: November 23, 2016
  • Content last reviewed: November 2016

Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.

Who may perform a pre-start health and safety review?

A pre-start health and safety review (PSR) required under items 1, 2, 3, 4, 5, 6, or 7 of the section 7 table must be conducted by a professional engineer.

In other words, in the following circumstances the PSR must be conducted by a professional engineer:

  1. Flammable liquids are located or dispensed in a building, room or area.
  2. Any of the following are used as protective elements in connection with an apparatus:
    • 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.
    • Barrier guards that use interlocking mechanical or electrical safeguarding devices.
  3. Material, articles or things are placed or stored on a structure that is a rack or stacking structure.
  4. A process involves a risk of ignition or explosion that creates a condition of imminent hazard to a person’s health or safety.
  5. The use of a dust collector involves a risk of ignition or explosion that creates a condition of imminent hazard to a person’s health or safety.
  6. A factory produces aluminum or steel or is a foundry that melts material or handles molten material.
  7. The construction, addition, installation or modification relates to a lifting device, travelling crane or automobile hoist.

A PSR required under item 8 of the section 7 table must be conducted by a professional engineer or by a person who possesses special, expert or professional knowledge or qualifications appropriate to assess any potential or actual hazards [section 7(12)]. This person may have a specific qualification, such as being a Certified Industrial Hygienist (CIH) or Registered Occupational Hygienist (ROH), when the following circumstances exist:

Can the PSR involve more than one person?

If a team of reviewers carries out the PSR, more than one discipline may be required. The names and disciplines of the people involved should be included in the report.

Who would do the review of a process that may be both explosive and toxic?

In the case of a process with explosion and toxicity hazards, there likely would be more than one person conducting the PSR.

One of these people would have to be a professional engineer. A best practice may be to include a chemical engineer as part of the review team.

Can a professional engineer from another jurisdiction conduct the PSR?

A professional engineer, or P. Eng., is defined in the Industrial Establishments Regulation as "a member or licensee of the Association of Professional Engineers of Ontario (PEO) under the Professional Engineers Act." Therefore, an engineer from another jurisdiction can only conduct the PSR if they are granted a licence, limited licence or temporary licence by the PEO to practice in Ontario. They must follow the Code of Conduct as set out in the Professional Engineers Act and its regulations.

Where can I get a list of engineering consultants who can perform a PSR?

You may wish to contact your safe workplace association, depending upon your sector, to enquire if they can perform a PSR or provide you with referrals.

You may also want to contact the Consulting Engineers of Ontario (CEO) for a list of consulting firms.

You may also contact the Professional Engineers of Ontario which has a publication called "Engineering Dimensions" with advertisements from various engineering firms.

May a company engineer do a PSR?

Yes, a company engineer may carry out a review provided he/she is a professional engineer licensed by the PEO, and must follow the Code of Conduct as stated in the Professional Engineers Act and its regulations.

Who can sign the pre-start health and safety review report?

If a professional engineer conducts the review, she or he must sign, seal and date the report [subsection 7(13)]. If a team of engineers is involved in the review, then either the lead engineer or each member of the team must sign, seal and date the report.

If a person other than a professional engineer produces the report, she or he must sign and date the report, and the report must include details of his or her special, expert or professional knowledge or qualifications [subsection 7(13)]. If a team is involved in the review, either the team leader or each member of the team must sign and date the report.

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Disclaimer: This web resource has been prepared to assist the workplace parties in understanding some of their obligations under the Occupational Health and Safety Act (OHSA) and the regulations. It is not intended to replace the OHSA or the regulations and reference should always be made to the official version of the legislation.

It is the responsibility of the workplace parties to ensure compliance with the legislation. This web resource does not constitute legal advice. If you require assistance with respect to the interpretation of the legislation and its potential application in specific circumstances, please contact your legal counsel.

While this web resource will also be available to Ministry of Labour inspectors, they will apply and enforce the OHSA and its regulations based on the facts as they may find them in the workplace. This web resource does not affect their enforcement discretion in any way.