The PHSR Process: Step-by-Step Guide to a Pre-Start Health and Safety Review in Ontario
If your industrial facility is installing new equipment, modifying existing machinery, or introducing a new process, you may need a Pre-Start Health and Safety Review (PHSR) before the equipment is put into operation.
But what actually happens during a PHSR?
The PHSR process is an engineering assessment designed to identify applicable health and safety requirements, evaluate the equipment or installation, document deficiencies or recommendations, and help the employer achieve compliance before startup.
While every project is different, the process generally involves several key stages: initial consultation, site assessment, engineering analysis, reporting, corrective action, ongoing consulting, and final compliance.
Understanding these steps in advance can make the review more efficient and help prevent delays during installation and commissioning.
What Is the PHSR Process?
A PHSR is more than a simple equipment inspection.
The process involves reviewing the equipment, process, workplace conditions, and applicable requirements to determine whether the installation meets the relevant health and safety requirements before it is placed into service.
The exact scope of a PHSR depends on the project. A straightforward machine installation may require a different assessment than a complex automated production line, dust collection system, conveyor system, spray booth, or other industrial process.
The overall objective is to identify issues early, address deficiencies where necessary, and arrive at a completed PHSR report that supports final compliance.
Contact Us
How Long Does a PHSR Take?
There is no universal timeframe for a PHSR.
A relatively straightforward project may be completed quickly, while a complex industrial installation can require considerably more time. Factors that can affect the timeline include:
A relatively straightforward project may be completed quickly, while a complex industrial installation can require considerably more time. Factors that can affect the timeline include:
- Equipment complexity
- Number of machines involved
- Size of the installation
- Availability of documentation
- Whether the equipment is already installed
- Number and type of deficiencies
- Required corrective actions
- Availability of contractors or equipment suppliers
- Need for additional engineering
- Project commissioning schedule
The PHSR Process at a Glance
A typical PHSR can be understood as five main stages:
Initial Consultation
Site Assessment and Information Gathering
Engineering Analysis and Review
Reporting, Recommendations and Ongoing Consulting
Final Compliance
The exact sequence and amount of work can vary depending on the equipment and project.
Let’s look at each stage in more detail.
Let’s look at each stage in more detail.
The PHSR process begins by understanding what you are installing, modifying, or bringing into operation.
During the initial consultation, the engineering team gathers information about the project and determines the likely scope of the review.
This can include questions such as:
During the initial consultation, the engineering team gathers information about the project and determines the likely scope of the review.
This can include questions such as:
- What equipment is being installed?
- Is the equipment new or modified?
- Where will it be installed?
- What process will it perform?
- What materials will be handled?
- Has the equipment been installed already?
- When does the equipment need to be commissioned?
- Are there existing engineering drawings or documentation?
- Has a previous PHSR been completed?
- Are there known safety or compliance concerns?
What should you provide to the engineer?
Depending on the project, useful information may include:- Equipment specifications
- Manufacturer documentation
- Equipment drawings
- Layout drawings
- Electrical schematics
- Control-system information
- Guarding details
- Process descriptions
- Installation information
- Previous inspection or engineering reports
- Previous PHSRs
- Information about hazardous or combustible materials
Once the project scope is understood, the next step is assessing the equipment and its installation.
A site assessment allows the engineer to evaluate the equipment in the environment where it will actually operate.
This is important because compliance cannot always be determined from manufacturer documentation alone.
The engineer may need to examine:
For example, a machine may appear compliant when considered by itself, but its connection to another machine, conveyor, automated system, or process may introduce additional hazards.
That makes the site assessment an important part of understanding how the system actually operates—not just how it was designed to operate on paper.
For projects that are still being designed or installed, engineering documentation may also be reviewed before the site visit to identify potential issues early.
A site assessment allows the engineer to evaluate the equipment in the environment where it will actually operate.
This is important because compliance cannot always be determined from manufacturer documentation alone.
The engineer may need to examine:
- Equipment installation
- Machine guarding
- Safety devices
- Emergency stops
- Control systems
- Electrical components
- Access points
- Operator areas
- Material handling
- Connections to other equipment
- Process conditions
- Surrounding equipment
- Workplace layout
- Potential hazards
For example, a machine may appear compliant when considered by itself, but its connection to another machine, conveyor, automated system, or process may introduce additional hazards.
Why the site assessment matters
A PHSR is intended to evaluate the equipment and process in the context of the workplace.That makes the site assessment an important part of understanding how the system actually operates—not just how it was designed to operate on paper.
For projects that are still being designed or installed, engineering documentation may also be reviewed before the site visit to identify potential issues early.
After gathering the necessary information, the engineer performs the technical analysis.
This is the stage where the equipment, installation, process, and applicable requirements are evaluated in detail.
The review may consider relevant requirements under Ontario occupational health and safety legislation as well as applicable engineering and safety standards.
Depending on the project, this can involve reviewing:
In reality, the engineering review needs to reflect the equipment and hazards involved.
For example, a PHSR involving a conventional piece of production equipment may focus heavily on machine guarding and controls.
A PHSR involving a dust collection system may require additional consideration of combustible dust hazards, system design, equipment integration, and explosion protection.
Similarly, a process involving flammable materials may involve different technical considerations from a conventional machine installation.
The goal is to identify the requirements relevant to the actual installation.
This is the stage where the equipment, installation, process, and applicable requirements are evaluated in detail.
The review may consider relevant requirements under Ontario occupational health and safety legislation as well as applicable engineering and safety standards.
Depending on the project, this can involve reviewing:
- Safeguarding
- Safety controls
- Electrical systems
- Mechanical hazards
- Access and egress
- Emergency-stop systems
- Lockout considerations
- Hazardous substances
- Combustible materials
- Fire and explosion hazards
- Equipment integration
- Process-specific risks
- Applicable CSA standards
- Applicable ANSI standards
- Other relevant technical requirements
PHSRs Are Not One-Size-Fits-All
A common misconception is that every PHSR follows an identical checklist.In reality, the engineering review needs to reflect the equipment and hazards involved.
For example, a PHSR involving a conventional piece of production equipment may focus heavily on machine guarding and controls.
A PHSR involving a dust collection system may require additional consideration of combustible dust hazards, system design, equipment integration, and explosion protection.
Similarly, a process involving flammable materials may involve different technical considerations from a conventional machine installation.
The goal is to identify the requirements relevant to the actual installation.
Following the engineering assessment, the findings are documented in the PHSR report.
The report is an important part of the process because it provides a written record of the engineering assessment and identifies issues that need to be addressed.
Depending on the project, the report may document:
The objective is to work through the assessment and corrective actions so that the equipment can achieve the required level of compliance.
This is why reporting, recommendations, and follow-up are closely connected parts of the PHSR process.
The report is an important part of the process because it provides a written record of the engineering assessment and identifies issues that need to be addressed.
Depending on the project, the report may document:
- Equipment reviewed
- Scope of the assessment
- Applicable requirements
- Standards considered
- Observations
- Identified deficiencies
- Required corrective actions
- Recommendations
- Supporting engineering information
The Goal Is a Clean PHSR Report
The ultimate objective is not simply to produce a report containing a list of problems.The objective is to work through the assessment and corrective actions so that the equipment can achieve the required level of compliance.
This is why reporting, recommendations, and follow-up are closely connected parts of the PHSR process.
A PHSR may identify items that need to be corrected before equipment can be considered compliant.
These issues can range from relatively straightforward corrections to more substantial engineering or equipment modifications.
Examples might include:
In some cases, the equipment supplier or installation contractor may be able to make the correction.
In other cases, additional engineering, design, fabrication, controls work, or consultation may be required.
Identifying problems before startup is one of the reasons the review is performed.
The engineering team can communicate the findings to the employer and other project stakeholders, explain what needs to be addressed, and provide appropriate recommendations or ongoing consulting support.
The equipment can then be reassessed as necessary once corrective measures have been completed.
These issues can range from relatively straightforward corrections to more substantial engineering or equipment modifications.
Examples might include:
- Missing or inadequate guarding
- Safety-control issues
- Inadequate emergency-stop arrangements
- Access concerns
- Electrical deficiencies
- Inadequate safety devices
- Issues with equipment integration
- Documentation gaps
- Process-specific hazards
In some cases, the equipment supplier or installation contractor may be able to make the correction.
In other cases, additional engineering, design, fabrication, controls work, or consultation may be required.
What Happens If Deficiencies Are Found?
Finding deficiencies does not mean the PHSR process has failed.Identifying problems before startup is one of the reasons the review is performed.
The engineering team can communicate the findings to the employer and other project stakeholders, explain what needs to be addressed, and provide appropriate recommendations or ongoing consulting support.
The equipment can then be reassessed as necessary once corrective measures have been completed.
Not every PHSR is completed in a single visit.
Complex industrial projects may require communication between the engineer, employer, equipment supplier, contractors, controls specialists, and other parties.
Ongoing consulting can help resolve questions that arise during the correction process.
For example, a project may require clarification about:
Complex industrial projects may require communication between the engineer, employer, equipment supplier, contractors, controls specialists, and other parties.
Ongoing consulting can help resolve questions that arise during the correction process.
For example, a project may require clarification about:
- How a guarding issue should be corrected
- Whether a proposed modification addresses a deficiency
- Whether a control-system change is adequate
- How equipment should be integrated
- What additional documentation is required
- Whether a completed correction should be reassessed
The final stage is confirming that the identified requirements have been addressed and completing the PHSR documentation.
The objective is to reach final compliance based on the scope of the review.
Depending on the project, this may involve:
The important point is that the PHSR process should not be viewed as complete simply because an initial inspection has occurred. Where deficiencies are identified, they need to be appropriately addressed and documented.
The objective is to reach final compliance based on the scope of the review.
Depending on the project, this may involve:
- Completing corrective actions.
- Providing additional documentation.
- Reassessing modified equipment.
- Confirming that identified deficiencies have been addressed.
- Finalizing the engineering report.
- Completing the applicable professional engineering documentation.
The important point is that the PHSR process should not be viewed as complete simply because an initial inspection has occurred. Where deficiencies are identified, they need to be appropriately addressed and documented.
When Should You Start a PHSR?
Ideally, PHSR requirements should be considered before equipment is installed or commissioned.
Waiting until the last minute can create problems if deficiencies are discovered that require equipment modifications.
Starting early allows the engineer to identify potential issues while there is still time to make changes.
For major equipment purchases or industrial projects, consider discussing PHSR requirements during the planning and procurement stages.
Can a PHSR Be Completed After Installation?
A site assessment can often be performed after equipment has been installed, but the timing of the PHSR matters.
The purpose of a pre-start review is to identify applicable issues before equipment is put into operation.
If equipment has already been commissioned, the employer should not simply assume that a retrospective inspection is equivalent to completing the required pre-start process.
If you are already at the installation or commissioning stage and are unsure about your PHSR obligations, seek professional advice as soon as possible.
What Happens After the PHSR?
Once the PHSR has been completed and applicable deficiencies have been addressed, the employer should maintain the relevant engineering documentation and compliance records.
The PHSR should form part of the equipment’s safety and compliance documentation.
It is also important to recognize that future modifications may change the compliance picture.
It is also important to recognize that future modifications may change the compliance picture.
If equipment is later:
- Modified
- Relocated
- Automated
- Integrated with other equipment
- Connected to a new process
- Changed to handle different materials
A completed PHSR is not necessarily a permanent blanket approval for every future modification.
Contact Us
How to Prepare for a PHSR
You can help make the process more efficient by preparing information before the engineer arrives.
Before the assessment:
- 1Identify the equipment being reviewed.
- 2Gather manufacturer documentation.
- 3Provide available drawings and schematics.
- 4Identify the intended operating process
- 5Explain any modifications that have been made.
- 6Provide previous PHSRs if available.
- 7Identify known safety concerns.
- 8Make the equipment accessible for assessment.
- 9Identify the project commissioning timeline.
Good preparation allows the engineer to spend more time evaluating the actual installation and less time tracking down basic project information.
PHSR Process for Different Types of Equipment
The general process remains similar, but the technical focus can vary significantly.
Machinery and Automated Equipment
Reviews may focus on guarding, safety controls, emergency stops, operator access, and integration with other machinery.
Conveyors and Material-Handling Systems
The review may consider guarding, access, nip points, emergency stops, interfaces with other equipment, and material-handling hazards.
Dust Collection Systems
Dust collection projects can involve additional considerations related to combustible dust, system design, equipment integration, and explosion protection.
Spray Booths and Flammable Processes
The review may involve considerations associated with flammable materials, ventilation, ignition sources, electrical equipment, and fire or explosion hazards.
Industrial Process Equipment
Mixers, processing systems, production machinery, and other industrial equipment may require a review tailored to the specific process and hazards.
This is why the PHSR process should be treated as an engineering assessment, rather than a generic inspection.
FAQs About PHSR Process
What are the steps of a PHSR?
A typical PHSR involves initial consultation, information gathering and site assessment, engineering analysis, reporting, corrective actions, ongoing consulting or follow-up, and final compliance.
Who performs a PHSR?
A PHSR is an engineering assessment and must be completed and signed by an appropriately qualified Professional Engineer where required by the applicable Ontario requirements.
Is a PHSR just an inspection?
No. A PHSR involves engineering analysis of the equipment, installation, process, and applicable requirements. A site inspection or assessment can be one component of the overall process.
What happens if the engineer finds deficiencies?
The deficiencies are documented and appropriate corrective actions are identified. Once corrections have been completed, further review may be required before the PHSR can be finalized.
Does the equipment have to be running during a PHSR?
Not necessarily. The appropriate assessment conditions depend on the equipment and project. The engineer needs sufficient access and information to evaluate the relevant safety and compliance requirements.
How long does a PHSR take?
The timeframe varies according to equipment complexity, project scope, documentation, deficiencies, corrective actions, and other factors.
Can a PHSR be started before equipment arrives?
Yes. Beginning the process during planning and installation can help identify potential issues before commissioning and may reduce delays.
What is the end goal of a PHSR?
The goal is to complete the required engineering assessment, address applicable deficiencies, and achieve final compliance for the equipment or process within the scope of the review.
Why Choose PHSR.com for Your PHSR?
PHSR.com is focused specifically on Pre-Start Health and Safety Reviews and related engineering compliance services in Ontario.
The service is supported by Wintek Engineering, an established engineering company that has been operating since 1994.
That experience supports a practical approach to industrial engineering assessments, with an emphasis on identifying issues, explaining what needs to be addressed, and helping clients move toward final compliance.
The PHSR.com approach is built around:
- Practical engineering advice
- Regulatory expertise
- Clear reporting
- Responsive consulting
- A focus on final compliance
Need a PHSR?
If you are not sure whether your equipment requires a PHSR, start with our guide.
If you already know a PHSR is required, contact PHSR.com with your project type, location, and contact information to discuss the next step.
If you already know a PHSR is required, contact PHSR.com with your project type, location, and contact information to discuss the next step.