Ontario PHSR Requirements: What You Need to Know
If your business is installing new industrial equipment, modifying existing machinery, or introducing a new process in Ontario, understanding the Ontario PHSR requirements should be part of your project planning.
A Pre-Start Health and Safety Review (PHSR) is an engineering review used in specific circumstances to assess whether applicable health and safety requirements have been addressed before certain equipment, processes, or protective measures are put into service.
Ontario’s PHSR requirements are primarily established through Section 7 of Ontario Regulation 851, the Industrial Establishments Regulation, under the Occupational Health and Safety Act (OHSA).
However, determining whether a particular project requires a PHSR is not as simple as asking whether the equipment is new. The circumstances of the installation or modification, the hazards involved, and the specific provisions that apply all matter.
This guide explains the Ontario PHSR requirements, who performs a PHSR, what the review covers, what documentation may be required, and how businesses can prepare.
What Are the Ontario PHSR Requirements?
Ontario PHSR requirements are intended to ensure that certain industrial equipment, processes, protective structures, and installations are assessed for applicable health and safety requirements before they are put into service.
The requirements are found primarily in Ontario Regulation 851 (Industrial Establishments) under Ontario’s Occupational Health and Safety Act.
The regulation identifies circumstances in which a pre-start health and safety review is required and establishes requirements concerning the review.
A PHSR may involve examining whether applicable requirements relating to equipment and worker protection have been addressed.
Depending on the project, this can include considerations such as:
Machine guarding
Safeguarding systems
Safety controls
Emergency stops
Electrical hazards
Mechanical hazards
Safeguarding systems
Safety controls
Emergency stops
Electrical hazards
Mechanical hazards
Material handling
Ventilation
Fire hazards
Explosion hazards
Protective devices
Applicable engineering standards
Ventilation
Fire hazards
Explosion hazards
Protective devices
Applicable engineering standards
The precise scope depends on the equipment and circumstances.
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What Is Ontario Regulation 851?
Ontario Regulation 851 is commonly known as the Industrial Establishments Regulation.
It is a regulation made under Ontario's Occupational Health and Safety Act and establishes requirements relating to occupational health and safety in industrial establishments.
For businesses investigating PHSR requirements, Section 7 of Regulation 851 is particularly important.
Rather than treating a PHSR as a generic safety inspection, businesses should consider the specific regulatory provisions that apply to their equipment, process, and installation.
The regulation is therefore an important starting point when determining whether a PHSR is required.
It is a regulation made under Ontario's Occupational Health and Safety Act and establishes requirements relating to occupational health and safety in industrial establishments.
For businesses investigating PHSR requirements, Section 7 of Regulation 851 is particularly important.
Rather than treating a PHSR as a generic safety inspection, businesses should consider the specific regulatory provisions that apply to their equipment, process, and installation.
The regulation is therefore an important starting point when determining whether a PHSR is required.
Does Ontario Regulation 851 Require a PHSR for All New Equipment?
No.
This is an important distinction.
The fact that equipment is new does not automatically mean that a PHSR is required.
This is an important distinction.
The fact that equipment is new does not automatically mean that a PHSR is required.
PHSR requirements apply in specified circumstances. The equipment, process, protective measures, installation, and other circumstances must be considered to determine whether the applicable requirements are triggered.
For example, a new machine may involve safeguarding, controls, or other features that require consideration. A new production process may introduce hazardous materials or combustible dust. A modification to an existing system may change how workers interact with equipment.
The correct approach is therefore to assess the project against the applicable requirements rather than relying on a blanket rule that all new equipment requires a PHSR.
When Does a PHSR Become Necessary?
The circumstances that can lead to a PHSR requirement vary.
Examples can include projects involving:
- New industrial machinery
- Machinery modifications
- Safeguarding devices
- Protective systems
- Certain material-handling equipment
- Certain storage or racking installations
- Equipment involving flammable materials
- Processes involving combustible dust
- Modified production systems
- Equipment integrated into an existing production line
The specific circumstances need to be evaluated against Ontario’s requirements.
This is particularly important for complex projects because one change can affect several systems simultaneously.
For example, installing a new machine may involve mechanical equipment, electrical controls, guarding, ventilation, and integration with an existing production line. A PHSR assessment needs to consider the relevant aspects of the actual installation.
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Who Can Perform a PHSR in Ontario?
A PHSR must be performed by a person who meets the qualifications specified under Ontario's requirements.
For engineering reviews, this commonly means a Professional Engineer (P.Eng.) who has appropriate expertise for the equipment, process, and hazards involved.
The appropriate engineer should understand the technical requirements associated with the project—not simply be able to complete a standard form.
Depending on the application, this may require knowledge of:
- Mechanical engineering
- Electrical engineering
- Controls
- Machine safeguarding
- Industrial ventilation
- Fire protection
- Explosion protection
- Applicable CSA standards
- Applicable ANSI standards
- Ontario occupational health and safety requirements
The complexity of the equipment should therefore be considered when selecting an engineering professional.
What Does a PHSR Engineer Review?
The scope of an Ontario PHSR depends on the particular project.
An engineer may review technical documentation and assess the equipment or installation against applicable regulatory and engineering requirements.
Areas of review may include:
An engineer may review technical documentation and assess the equipment or installation against applicable regulatory and engineering requirements.
Areas of review may include:
Machine guarding
The engineer may assess access to hazardous moving parts, points of operation, guards, interlocks, and other protective measures.
Safety controls
Control systems, emergency stops, interlocks, and other safety-related functions may need to be considered.
Electrical systems
Where electrical hazards or safety-related electrical systems are relevant, the applicable requirements and standards may need to be assessed.
Mechanical hazards
Moving components, stored energy, pinch points, crushing hazards, and other mechanical risks can require evaluation.
Process hazards
The process in which the equipment operates can be just as important as the machine itself.
Fire and explosion hazards
Processes involving combustible dust, flammable liquids, gases, or other hazardous materials can introduce additional engineering considerations.
Integration
A machine that is safe in isolation may create different risks once connected to conveyors, production lines, controls, ventilation, or other equipment.
What Documentation Is Required for a PHSR?
The documentation required depends on the scope and complexity of the project.
Information that may be useful to a PHSR engineer includes:
- Equipment specifications
- Manufacturer documentation
- Engineering drawings
- Equipment layouts
- Electrical drawings
- Control-system documentation
- Safeguarding information
- Installation details
- Operating information
- Material information
- Existing engineering reports
- Photographs of the installation
For some projects, the engineer may also need to review applicable standards, manufacturer’s instructions, or other technical information.
Good documentation helps the engineer understand what has been installed and how the equipment is intended to operate.
If important information is missing, the review may take longer or require additional investigation.
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Is a Site Visit Required for a PHSR?
A site visit may be appropriate depending on the nature and complexity of the review.
For a straightforward project, available engineering documentation may provide much of the information required for the assessment.
For other installations, the engineer may need to see the equipment in its actual environment.
A site review can help establish:
- How equipment has been installed
- Access and egress conditions
- Guarding arrangements
- Equipment interfaces
- Surrounding hazards
- Actual installation conditions
- Relationship between equipment and other systems
What Standards Apply to an Ontario PHSR?
Ontario PHSR requirements are based on applicable regulatory requirements, but other engineering standards may also be relevant.
Depending on the project, these may include applicable CSA and ANSI standards, as well as standards and codes related to particular equipment or hazards.
For example, machinery may require consideration of standards relating to safeguarding and safety systems.
A dust collection installation may require additional consideration of ventilation and combustible-dust hazards.
An installation involving flammable materials may require consideration of applicable fire, electrical, and process-safety requirements.
The engineer determines which standards are relevant to the particular project.
A PHSR should therefore not be characterized simply as a “CSA inspection” or “ANSI inspection.” It is an engineering review of the applicable requirements for the specific installation.
What Happens If the PHSR Finds a Deficiency?
A PHSR can identify deficiencies or areas requiring corrective action.
Examples might include:
Examples might include:
Inadequate guarding
Missing safety devices
Control-system concerns
Electrical issues
Ventilation deficiencies
Equipment integration problems
Fire protection concerns
Explosion protection deficiencies
Insufficient documentation
The engineer should clearly document the issue and identify the appropriate corrective action.
The goal is to address applicable safety requirements before equipment is placed into service.
Importantly, a deficiency does not necessarily mean the entire project needs to be redesigned. The appropriate corrective action depends on the nature of the finding.
Where additional engineering is necessary, the PHSR can become one part of a larger engineering solution.
PHSR Requirements for Dust Collection Systems
Dust collection systems can present unique engineering and safety considerations.
Industrial facilities may generate dust from:
- Wood processing
- Food production
- Agricultural operations
- Metalworking
- Pharmaceutical manufacturing
- Chemical processing
Depending on the material and process, combustible dust may create fire or explosion hazards.
Wintek Engineering provides dust collection engineering that includes source capture design, ductwork and airflow analysis, fan and blower selection, dust collector sizing, controls and automation, system upgrades, and evaluation of combustible-dust risks.
Wintek Engineering provides dust collection engineering that includes source capture design, ductwork and airflow analysis, fan and blower selection, dust collector sizing, controls and automation, system upgrades, and evaluation of combustible-dust risks.
Wintek’s explosion protection services also include PHSR support for applicable equipment such as dust collectors and conveying systems for combustible powders.
This combination of PHSR and industrial engineering expertise can be particularly useful when a project involves both compliance requirements and technical system design.
This combination of PHSR and industrial engineering expertise can be particularly useful when a project involves both compliance requirements and technical system design.
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PHSR Requirements for Explosion-Sensitive Equipment
Equipment involving combustible dust or flammable materials may require additional engineering attention.
Wintek provides explosion protection assessments and engineering solutions involving:
Wintek provides explosion protection assessments and engineering solutions involving:
Explosion vents
Rupture panels
Suppression systems
Isolation systems
Flame arrestors
Spark detection
Explosion-proof electrical equipment
Dust collection upgrades
Its PHSR services include support for applicable explosion-sensitive equipment and processes.
This is an example of why choosing an engineering firm with experience across related disciplines can be advantageous. If the PHSR identifies an issue involving dust collection, controls, mechanical systems, or explosion protection, the same engineering team may be able to help develop an appropriate solution.
This is an example of why choosing an engineering firm with experience across related disciplines can be advantageous. If the PHSR identifies an issue involving dust collection, controls, mechanical systems, or explosion protection, the same engineering team may be able to help develop an appropriate solution.
When Should You Start a PHSR?
Ideally, PHSR requirements should be considered during project planning, rather than immediately before startup.
Starting early provides more opportunity to:
- Identify applicable requirements
- Review equipment specifications
- Assess design decisions
- Identify missing documentation
- Coordinate with equipment suppliers
- Address deficiencies
- Incorporate changes into installation
- Avoid last-minute commissioning delays
Waiting until equipment is completely installed can make corrective changes more disruptive and expensive.
For equipment being purchased from an outside manufacturer, PHSR considerations should ideally be discussed before the equipment arrives at the facility.
What Are the Employer's Responsibilities?
Employers have responsibilities under Ontario's occupational health and safety legislation.
A PHSR should not be viewed as a way of transferring the employer's overall health and safety responsibilities to an engineering consultant.
Instead, the PHSR is one component of a broader workplace health and safety program.
Employers should ensure that appropriate requirements are identified, engineering reviews are completed when applicable, deficiencies are addressed, and equipment is not placed into service contrary to applicable requirements.
The precise responsibilities depend on the workplace and circumstances.
A PHSR should not be viewed as a way of transferring the employer's overall health and safety responsibilities to an engineering consultant.
Instead, the PHSR is one component of a broader workplace health and safety program.
Employers should ensure that appropriate requirements are identified, engineering reviews are completed when applicable, deficiencies are addressed, and equipment is not placed into service contrary to applicable requirements.
The precise responsibilities depend on the workplace and circumstances.
How Can You Prepare for an Ontario PHSR?
A simple preparation checklist can help.
Before contacting a PHSR engineer, gather:
Before contacting a PHSR engineer, gather:
Equipment information
Manufacturer, model, specifications, and intended use.
Drawings
Layouts, engineering drawings, electrical drawings, and control information where available.
Process information
What the equipment does, what materials it handles, and how it will operate.
Safety information
Guarding, interlocks, emergency stops, safety devices, and other protective measures.
Hazard information
Combustible dust, flammable liquids or gases, chemicals, stored energy, or other relevant hazards.
Installation information
Where the equipment will be located and how it will interact with other systems.
Project schedule
When installation and commissioning are expected to occur.
Providing this information early can help establish an efficient scope for the review.
FAQs about Ontario PHSR Requirements
Is a PHSR mandatory in Ontario?
A PHSR is mandatory in the circumstances specified by Ontario’s applicable occupational health and safety requirements. The exact applicability depends on the equipment, process, installation, and circumstances.
What regulation covers PHSRs in Ontario?
PHSRs are primarily associated with Section 7 of Ontario Regulation 851, the Industrial Establishments Regulation, under the Occupational Health and Safety Act.
Does every new piece of equipment require a PHSR?
No. The requirement depends on the circumstances and applicable provisions of the regulation.
Does modified equipment require a PHSR?
Certain modifications can trigger PHSR requirements. The nature and extent of the modification must be considered.
Who signs a PHSR?
The review must be completed and documented by a person who meets the qualifications specified by Ontario’s requirements. For engineering reviews, this commonly involves a qualified Professional Engineer.
Can a PHSR be done after equipment starts operating?
The purpose of a pre-start review is to assess applicable requirements before equipment or a process is put into service. If equipment is already operating and its PHSR status is uncertain, qualified engineering advice should be obtained.
What if I don't know whether my equipment requires a PHSR?
Do not rely on assumptions. Gather the equipment, process, installation, and hazard information and have the circumstances assessed against the applicable Ontario requirements.
Choose an Experienced Ontario Engineering Partner
Wintek Engineering has been in business since 1994, providing an established engineering resource for industrial projects in Ontario.
Its PHSR capabilities are supported by broader industrial engineering expertise, including dust collection, explosion protection, mechanical and electrical engineering, and controls.
That multidisciplinary capability is particularly useful when a PHSR is part of a larger equipment installation or process change.
Wintek’s approach is focused on practical engineering advice and solutions that address the actual equipment and operating environment. Its explosion protection work, for example, combines risk assessment and gap analysis with engineering and implementation support.
Need Help With Ontario PHSR Requirements?
Ontario PHSR requirements can be complex because applicability depends on the specific equipment, process, installation, and circumstances.
If you are planning a new installation, modifying existing equipment, or preparing to commission industrial machinery, determining your PHSR requirements early can help you address potential issues before they affect your project schedule.
Contact Wintek Engineering to discuss your equipment or project and determine whether a PHSR review may be required.
If you are planning a new installation, modifying existing equipment, or preparing to commission industrial machinery, determining your PHSR requirements early can help you address potential issues before they affect your project schedule.
Contact Wintek Engineering to discuss your equipment or project and determine whether a PHSR review may be required.