PHSR Frequently Asked Questions: Ontario Pre-Start Health and Safety Reviews

If you are installing, modifying, or commissioning industrial equipment in Ontario, you may have questions about Pre-Start Health and Safety Reviews (PHSRs).
What is a PHSR? When is one required? Who can perform one? What equipment may need a review? How long does the process take? And what happens if the engineer finds deficiencies?
We’ve answered the most common PHSR questions below.
If you are looking for a more detailed explanation of a particular topic, visit our Ultimate Guide to PHSRs in Ontario or explore the related resources throughout this page.
Important: This FAQ provides general information about PHSRs in Ontario. Whether a PHSR is required for a particular piece of equipment or installation depends on the specific circumstances and applicable requirements. When in doubt, consult a qualified Professional Engineer before equipment is put into operation.

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General PHSR Questions

PHSR stands for Pre-Start Health and Safety Review.
It is an engineering assessment used to evaluate specified industrial equipment, processes, structures, or protective measures against applicable health and safety requirements before they are put into operation.
A PHSR is a formal engineering review intended to identify potential health and safety issues associated with specified equipment or processes before startup.
The review considers the equipment, its installation, applicable requirements, relevant hazards, and appropriate engineering standards.
A PHSR is more than a basic equipment inspection. It involves an engineering assessment and documentation of the findings.
Learn more on our What Is a PHSR? page.
The purpose of a PHSR is to identify potential hazards and compliance issues before equipment or a process is put into operation.
Finding and correcting problems before startup can help protect workers and prevent costly interruptions after production has begun.
PHSR requirements are primarily associated with Section 7 of Ontario Regulation 851, Industrial Establishments, under Ontario’s Occupational Health and Safety Act. The specific provisions that apply depend on the equipment, process, installation, and circumstances.
For more information, see Ontario PHSR Requirements.

When Is a PHSR Required?

No.
A machine being new does not, by itself, determine whether a PHSR is required.
The equipment, installation, hazards, modifications, and applicable requirements need to be considered to determine whether the PHSR provisions apply.
See Do I Need a PHSR? for a decision-oriented guide.
Start by identifying:
  • What equipment or process is being installed or modified
  • Whether the equipment is new, modified, relocated, or integrated
  • What hazards are involved
  • What safeguarding or protective systems are present
  • What Ontario requirements apply
  • Whether a previous PHSR exists
  • Whether the equipment has been changed since any previous review
If the answer remains unclear, a qualified Professional Engineer can assess the circumstances and advise on the appropriate engineering review.
A modification may trigger the need for additional engineering review depending on the nature of the modification and the applicable requirements.
Changes involving safeguarding, controls, automation, equipment integration, operating conditions, or process hazards should be carefully evaluated.
A previous PHSR does not automatically mean that every future modification is covered.
Used equipment is not automatically exempt from PHSR consideration.
The equipment should be evaluated in the context of its new installation and intended operation in Ontario.
Its previous history, existing documentation, modifications, safeguarding, and integration with other equipment may all be relevant.
Imported equipment should be evaluated against the requirements applicable to its Ontario installation.
Documentation or certification from another jurisdiction can be useful, but it does not automatically determine whether an Ontario PHSR is required.
Manufacturer documentation is useful, but it does not necessarily determine whether the equipment requires a PHSR in Ontario.
The equipment must be considered in the context of the workplace where it will be installed and operated.
The installation, surrounding equipment, process, safeguarding, controls, and other factors can affect the engineering assessment.

Who Performs a PHSR?

A PHSR is an engineering assessment and, where required by the applicable Ontario provisions, must be completed and signed by an appropriately qualified Professional Engineer.
The engineer should have the appropriate technical knowledge and experience for the equipment and hazards being assessed.
Yes.
Where it is unclear whether a PHSR requirement applies, a qualified Professional Engineer can review the equipment, installation, process, and circumstances and provide engineering advice.
This can be particularly useful for complex machinery, modifications, automated systems, dust collection, combustible-dust processes, and other industrial installations.
The appropriate assessment method depends on the equipment and project.
A site assessment can be an important part of understanding how equipment is installed and how workers interact with it.
For complex industrial equipment, an engineer may need to observe the actual installation rather than relying solely on manufacturer documentation.

What Does a PHSR Review?

The scope depends on the equipment and hazards, but a review may consider:
  • Machine guarding
  • Safety devices
  • Emergency stops
  • Safety-related controls
  • Electrical systems
  • Mechanical hazards
  • Operator access
  • Maintenance access
  • Equipment integration
  • Hazardous materials
  • Combustible materials
  • Fire and explosion hazards
  • Applicable regulatory requirements
  • Applicable engineering standards
The review is tailored to the actual equipment and installation.
No.
An inspection generally focuses on observing the condition of equipment.
A PHSR is an engineering assessment that considers applicable health and safety requirements and relevant technical standards in the context of the equipment and installation.
A site inspection or assessment can be part of the PHSR process, but the PHSR itself involves engineering analysis and documentation.
The information required depends on the project. Useful documentation can include:
  • Equipment specifications
  • Manufacturer manuals
  • Engineering drawings
  • Layout drawings
  • Electrical schematics
  • Control-system information
  • Guarding details
  • Process descriptions
  • Installation information
  • Previous PHSRs
  • Existing inspection reports
  • Certification documentation
  • Information about hazardous or combustible materials
Providing documentation early can help make the assessment more efficient.

PHSR Standards Questions

The applicable standards depend on the equipment, process, hazards, and installation.
Depending on the project, an engineer may consider relevant:
  • CSA standards
  • ANSI standards
  • NFPA standards
  • Other recognized engineering or safety standards
  • Manufacturer requirements
  • Applicable Ontario regulatory requirements
There is no single standards list that applies to every PHSR.
Learn more in CSA & ANSI Standards Explained.
CSA refers to the Canadian Standards Association, now operating as CSA Group.
ANSI stands for the American National Standards Institute.
CSA is primarily associated with Canadian standards, while ANSI is part of the U.S. standards system. However, industrial standards can overlap, be harmonized, or be used across jurisdictions.
The applicable standard depends on the equipment and project.
Not automatically.
A CSA standard is not necessarily a law simply because it carries a CSA designation.
The legal requirements applicable to a PHSR come from the relevant legislation and regulations. Technical standards may also be relevant to the engineering assessment.
The specific legal and technical requirements need to be determined for each project.
No.
CSA certification and a PHSR serve different purposes.
CSA certification or evaluation can provide valuable information about equipment, but it does not automatically determine whether the equipment requires a PHSR for its installation in an Ontario workplace.
No.
ANSI standards may be relevant to industrial machinery, particularly equipment designed for the U.S. market, but compliance with an ANSI standard does not automatically establish compliance with all applicable Ontario requirements.

PHSR Equipment Questions

Equipment that may require PHSR consideration includes:
  • Industrial machinery
  • Automated production equipment
  • Robotic systems
  • Conveyors
  • Material-handling equipment
  • Dust collection systems
  • Equipment handling combustible dust
  • Spray booths
  • Mixing and processing equipment
  • Flammable-material systems
  • Machine safeguarding systems
  • Industrial production lines
The presence of a particular type of equipment does not automatically establish that a PHSR is required. The specific circumstances must be assessed.
See Common Equipment That Requires a PHSR.
It depends on the conveyor, installation, hazards, modifications, and applicable requirements.
A conveyor may be part of a larger production or material-handling system, so its relationship with other equipment should also be considered.
A dust collection system may require PHSR consideration, particularly when it is part of an industrial process involving combustible dust or other significant hazards.
The assessment may also involve broader engineering considerations such as system design, equipment integration, explosion protection, and controls.
A spray booth installation may require PHSR consideration depending on the equipment, materials, process, ventilation, hazards, and applicable requirements.
Flammable liquids, vapours, ignition sources, electrical equipment, and fire protection can all be relevant considerations.
A robotic system or automated work cell may require PHSR consideration depending on its installation and applicable requirements.
The assessment can include the robot, tooling, guarding, safety devices, controls, restricted-access areas, and integration with surrounding machinery.
Whether a CNC machine requires a PHSR depends on the specific equipment, installation, modifications, and applicable requirements.
The assessment may involve machine guarding, access, controls, emergency stops, tooling, moving components, and interaction with operators.
A production line may require a PHSR depending on its equipment, configuration, hazards, and applicable requirements.
Because production lines often integrate multiple machines, conveyors, controls, and safety systems, the interaction between individual components can be an important part of the assessment.

PHSR Process Questions

A typical PHSR process includes:
  • Initial consultation
  • Information gathering and site assessment
  • Engineering analysis
  • Reporting and recommendations
  • Corrective actions and ongoing consulting
  • Final compliance
The exact process depends on the equipment and project.
See The PHSR Process for a detailed step-by-step explanation.
There is no standard timeframe for every PHSR. The duration can depend on:
  • Equipment complexity
  • Number of machines
  • Project scope
  • Documentation availability
  • Site conditions
  • Number of deficiencies
  • Corrective actions
  • Required follow-up
  • Project commissioning schedule
Starting the PHSR process early can help reduce the risk of commissioning delays.
Ideally, PHSR requirements should be considered during the planning, purchasing, design, and installation stages, rather than waiting until the equipment is ready to start production.
Early engineering input can help identify issues before they become expensive or time-consuming to correct.
Some parts of the process can begin before equipment arrives.
Manufacturer documentation, drawings, schematics, specifications, and project information can be reviewed in advance.
However, the appropriate assessment method depends on the equipment and project, and an actual installation may need to be assessed once it is available.
The deficiencies are documented and appropriate corrective actions are identified.
Depending on the finding, corrections may involve:
  • Equipment modifications
  • Additional guarding
  • Changes to safety controls
  • Electrical changes
  • Additional safety devices
  • Engineering changes
  • Additional documentation
  • Other corrective measures
Once corrections have been completed, further assessment may be required before the PHSR can be finalized.
A PHSR is intended to identify applicable health and safety issues before equipment is put into operation.
If deficiencies are identified, the appropriate corrective actions should be addressed before the equipment is placed into service where required by the applicable requirements.
The specific implications depend on the nature of the findings and the applicable regulatory requirements.

PHSR Exemption Questions

The question is better approached as whether the PHSR requirements apply to the specific circumstances.
Not every new machine automatically requires a PHSR, and businesses should not rely on a generic list of equipment that is supposedly “exempt.”
The equipment, installation, process, modifications, hazards, and applicable requirements should be considered.
See PHSR Exemptions for more information.
Not necessarily.
Certification may demonstrate compliance with particular standards, but it does not automatically determine whether an Ontario PHSR is required.
Not necessarily.
Routine maintenance or repair can be different from a modification that changes the equipment’s function, safeguarding, controls, hazards, or integration.
The nature of the work should be considered when determining whether additional engineering review is appropriate.

PHSR Documentation Questions

The contents depend on the project and scope.
A PHSR report may document:
  • Equipment reviewed
  • Scope of the assessment
  • Applicable requirements
  • Relevant standards
  • Engineering observations
  • Identified deficiencies
  • Recommendations
  • Corrective actions
  • Supporting engineering information
The final documentation should accurately reflect the engineering assessment performed.
Where a PHSR is required under the applicable Ontario provisions, the review must be completed and signed by an appropriately qualified Professional Engineer.
Employers should maintain the applicable engineering and compliance documentation associated with equipment and processes.
The PHSR forms part of the safety and compliance record for the equipment within the scope of the review.
Future modifications can change the safety and compliance characteristics of equipment.
Changes such as new automation, safeguarding, controls, process conditions, equipment integration, or relocation should be evaluated to determine whether additional engineering review is required.
A previous PHSR should not automatically be assumed to cover every future modification.

PHSR and Combustible Dust

Combustible dust can create serious fire and explosion hazards.
Industries that may handle combustible dust include:
  • Wood products
  • Food processing
  • Agriculture
  • Grain handling
  • Chemical processing
  • Pharmaceutical production
  • Certain metalworking operations
Dust collection and process equipment may therefore require additional engineering consideration.
PHSR.com’s industrial engineering capabilities include dust collection and explosion protection, allowing these issues to be considered as part of broader industrial engineering requirements where appropriate.

Hiring a PHSR Engineer

Look for an engineer or engineering firm with:
  • Appropriate Professional Engineer qualifications
  • PHSR experience
  • Industrial equipment experience
  • Knowledge of applicable Ontario requirements
  • Understanding of relevant engineering standards
  • Experience with the types of equipment being assessed
  • Ability to provide practical corrective-action guidance
For complex installations, multidisciplinary industrial engineering experience can be particularly valuable.
There is no single price for every PHSR. The cost depends on factors such as:
  • Equipment type
  • Equipment quantity
  • Project complexity
  • Site conditions
  • Documentation
  • Required engineering analysis
  • Number of deficiencies
  • Follow-up requirements
  • Travel and project location
The best way to obtain an accurate estimate is to provide the engineer with basic information about the equipment and project.
PHSR.com is the specialized PHSR service associated with Wintek Engineering.
Wintek’s engineering experience includes industrial equipment and PHSRs, along with related industrial engineering services such as dust collection, explosion protection, and equipment integration.
This broader industrial experience can be useful when a PHSR involves complex machinery or process systems rather than a standalone piece of equipment.

PHSR Questions for Equipment Manufacturers

Yes.
Manufacturers, machine builders, system integrators, contractors, and industrial facilities can all benefit from addressing PHSR requirements early in a project.
Providing engineering documentation and identifying potential Ontario requirements before equipment reaches the customer’s facility can help streamline the commissioning process.
Ideally, yes.
Considering applicable safety and engineering requirements during design can help reduce the likelihood of discovering significant issues during final commissioning.
Early engineering involvement can be particularly useful when designing:
  • Automated machinery
  • Production lines
  • Robotic cells
  • Conveyors
  • Dust collection systems
  • Process equipment
  • Safety systems
You do not need to have every technical detail prepared before contacting a PHSR engineer.
Start with:
  • Project location
  • Description of the project
  • Whether the equipment is new or modified
  • Expected commissioning date
  • Manufacturer, if known
  • Available drawings or documentation
Additional information can be provided as the scope is established.

Still Have a PHSR Question?

PHSR requirements can become complicated when equipment, processes, modifications, and multiple safety standards overlap.
If you cannot determine whether your project requires a PHSR or you need help understanding the engineering requirements professional guidance can help you make the decision before commissioning.
PHSR.com provides specialized Pre-Start Health and Safety Review services throughout Ontario, supported by the industrial engineering experience of Wintek Engineering.
The goal is straightforward:
Identify the applicable requirements. Assess the equipment. Document the findings. Address deficiencies. Help you reach final compliance.
Contact PHSR.com

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