Do I Need a PHSR? How to Determine If a PHSR Is Required in Ontario
Quick Answer: Do I Need a PHSR?
Contact Us
When Is a PHSR Required?
A review may need to be considered when a project involves:
- New industrial machinery
- Significant equipment modifications
- New or modified safeguarding systems
- Certain protective structures or devices
- New production processes
- Equipment involving hazardous materials
- Equipment or processes involving combustible dust
- Certain flammable-liquid applications
- Material-handling or storage systems
- Changes that affect how machinery operates or is safeguarded
This means that determining whether a PHSR is required should involve looking at what is changing, how it will operate, what hazards are present, and which regulatory provisions apply.
Does Every New Machine Need a PHSR?
The question is therefore not simply:
“Is this a new machine?”
It is:
“Does this particular installation or change fall within the circumstances for which Ontario requires a Pre-Start Health and Safety Review?”
Can Modifying Existing Equipment Trigger a PHSR?
- Changing machine controls
- Adding or changing guarding
- Installing a safeguarding device
- Altering a production process
- Changing equipment capacity
- Adding equipment to an existing production line
- Relocating or substantially changing equipment
- Introducing new hazardous materials
- Changing the way equipment interacts with other machinery
Contact Us
Does Adding a Safety Device Mean I Need a PHSR?
- Machine guards
- Interlocks
- Light curtains
- Safety controls
- Emergency-stop systems
- Other protective devices
What About Dust Collection Systems?
- Collection hoods
- Ductwork
- Fans and blowers
- Dust collectors
- Airflow controls
- Electrical controls
- Explosion protection
- Isolation systems
- Fire protection measures
- Automated monitoring
What About Combustible Dust and Explosion Risks?
- Dust collectors
- Spray booths
- Mixing and blending operations
- Conveying systems for combustible powders
- Solvent dispensing or recovery systems
Contact Us
Does Adding a Safety Device Mean I Need a PHSR?
- Added to an existing production line
- Integrated with other machines
- Modified significantly
- Used to transport combustible powders or other hazardous materials
- Connected to new control or safeguarding systems
Do I Need a PHSR for a Spray Booth?
A spray booth can involve several potential hazards, including flammable materials, ventilation requirements, electrical considerations, fire risks, and interaction with other facility systems.
Whether a particular spray booth installation requires a PHSR depends on the circumstances and applicable requirements.
Because spray applications can involve multiple engineering disciplines and potentially hazardous materials, it is important to evaluate the complete installation rather than looking at the booth in isolation.
Wintek's explosion protection services include PHSR support for applicable spray booth installations.
Do I Need a PHSR for a Dust Collector?
It depends on the specific installation.
A dust collector can involve mechanical, electrical, ventilation, fire, and explosion considerations.
For systems handling combustible dust, additional protective measures may be necessary depending on the material and process.
A PHSR may form part of the engineering and compliance requirements for a particular dust collection installation.
If you are installing a new dust collector or significantly modifying an existing system, determining the PHSR requirements early can help avoid problems during commissioning.
Does Imported Equipment Need a PHSR?
Imported equipment should not automatically be assumed to be exempt from Ontario requirements.
Machinery designed or manufactured outside Ontario may have been built to standards or regulatory requirements applicable in another jurisdiction. Once that equipment is installed in an Ontario workplace, the applicable Ontario requirements still need to be considered.
The engineer may need to review manufacturer documentation, drawings, safeguarding, electrical systems, controls, and other aspects of the equipment.
This can be particularly important when equipment is being integrated into a larger production system.
What If the Equipment Manufacturer Says a PHSR Isn't Required?
Manufacturer information can be useful, but it should not necessarily be treated as the final determination of Ontario PHSR requirements.
Manufacturers may design equipment for multiple jurisdictions, and the requirements applicable to the equipment in its original configuration may differ from the requirements that apply once it is installed in an Ontario industrial establishment.
The Ontario employer has responsibilities under the applicable occupational health and safety requirements.
If there is uncertainty, an appropriately qualified engineering professional can assess the specific application.
What If I'm Not Sure Whether I Need a PHSR?
- What equipment is being installed or modified?
- What does the equipment do?
- Where will it be installed?
- Is it being integrated with other machinery?
- What safety devices or safeguarding are involved?
- What materials are being processed?
- Are flammable liquids, gases, or combustible dust present?
- Has the equipment been substantially modified?
- What drawings and manufacturer documentation are available?
- When is the equipment expected to start operating?
What Happens If I Need a PHSR?
Depending on the project, this may include:
- 1Reviewing project information and documentation
- 2Identifying applicable regulatory requirements
- 3Reviewing relevant engineering standards
- 4Assessing equipment and safety systems
- 5Conducting a site review where appropriate
- 6Identifying deficiencies or required changes
- 7Documenting the engineering findings
- 8Addressing outstanding issues before startup
If a PHSR is first considered when installation is complete and the equipment is scheduled to begin production the next day, there may be little opportunity to make changes without affecting the project schedule.
What If a PHSR Finds a Deficiency?
The purpose of the review is to identify issues so they can be addressed.
Depending on the finding, corrective action might include:
Modifying guarding
Adjusting controls
Adding safety devices
Changing equipment layout
Correcting electrical issues
Improving ventilation
Modifying dust collection
Adding explosion protection
Providing additional engineering
Wintek’s industrial engineering services extend beyond PHSR documentation to areas including mechanical and electrical engineering, dust collection, explosion protection, and controls and automation. Its approach is therefore suited to projects where identifying a compliance issue may lead to a need for an engineered solution.
The Bottom Line: Do I Need a PHSR?
Contact Us
PHSR Decision Checklist
Equipment
Is this new equipment?
Has existing equipment been significantly modified?
Is it being integrated with other machinery?
Safety
Have guarding or safeguarding systems been added or changed?
Are there new emergency stops, interlocks, light curtains, or other safety devices?
Process
Is the production process changing?
Are new materials being introduced?
Hazards
Are there mechanical, electrical, fire, or explosion hazards?
Is combustible dust present?
Are flammable liquids or gases involved?
Documentation
Do you have equipment drawings and specifications?
Do you have manufacturer documentation?
Are electrical and control-system drawings available?
Timing
Has the equipment already been commissioned?
When is it scheduled to enter service?