CanadaOntarioPre-Start Health and Safety Reviews

Guidelines for Pre-Start Health and Safety Reviews: How to Apply Section 7 of the Regulation for Industrial Establishments


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Own­er: Doug Nix

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Last Updated: 12-05-2019 9:27


1. Intro­duc­tion

These guidelines provide inform­a­tion on the levels of dili­gence, meth­od­o­logy and

report­ing required to com­ply with sec­tion 7 of the Reg­u­la­tion for Indus­tri­al


The employ­er, own­er, less­ee or review­er needs to con­sider the fol­low­ing points:

The employ­er is respons­ible for ensur­ing that all require­ments of the

Occu­pa­tion­al Health and Safety Act and reg­u­la­tions are com­plied with in the

work­place. Even where a Pre-Start Health and Safety Review is not required or

an exemp­tion from the require­ments of sec­tion 7 applies, the employ­er must

ensure that work­ers will be pro­tec­ted when they use any appar­at­us, struc­ture,

pro­tect­ive ele­ment or pro­cess in the work­place.

The sec­tion 7 Table (Table 1) in Appendix I spe­cifies the pro­vi­sions of the

reg­u­la­tion that apply and cir­cum­stances under which a Pre-Start Health and

Safety Review is required. There may be oth­er com­pli­ance require­ments that need

to be met before any appar­at­us, pro­tect­ive ele­ments, struc­tures, and/or pro­cesses

are used. Even if a Pre-Start Health and Safety Review is not required, it is still

the employer’s respons­ib­il­ity to meet these require­ments. To avoid a costly

ret­ro­fit the employ­er may broaden the scope of a reg­u­lated Pre-Start Health and

Safety Review to include these require­ments. The details out­lined in Table 2

Appendix may provide an effect­ive way to help ensure com­pli­ance.

Integ­rat­ing health and safety at the design stage and before oper­a­tions begin is a

cost-effect­ive and pro­act­ive way to pre­vent work­place ill­ness or injury. The

bene­fits are numer­ous. They include dir­ect sav­ings from min­im­iz­ing ret­ro­fit­ting;

less down­time and replace­ment of equip­ment; sav­ings in work­place insur­ance

claims due to few­er ill­nesses and injur­ies; and, most import­ant, main­tain­ing

pro­ductiv­ity, health and safety in the work­place.

These guidelines do not pre­scribe how a Pre-Start Health and Safety Review

(PSR) is to be done, and the reg­u­la­tion allows for flex­ib­il­ity in that it does not

spe­cify any one report format. Where employ­ers have exist­ing review sys­tems

and pro­cesses to com­ply with health and safety require­ments pri­or to start-up,

they may use them to sat­is­fy PSR require­ments, provided that the eval­u­ation,

review and writ­ten report are done by an appro­pri­ate per­son as required in

sub­sec­tions 7 (11) and (12). The report or reports must indic­ate that the

appar­at­us, struc­ture, pro­tect­ive ele­ment or pro­cess com­plies with the applic­able

sec­tions of the Reg­u­la­tion for Indus­tri­al Estab­lish­ments ref­er­enced in sec­tion 7.

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