Industrial facilities across Ontario operate complex machinery, automated systems, and production lines that introduce significant safety risks. To control these risks, Ontario’s Occupational Health and Safety Act (OHSA) and Regulation 851 – Industrial Establishments require Pre-Start Reviews (PSRs) in specific situations.
A Pre-Start Review is not a suggestion or best practice—it is a legal requirement when prescribed conditions exist. Below are the key reasons why PSRs are not optional for Ontario industrial workplaces.
1. PSRs Are Required by Ontario Regulation 851
Ontario Regulation 851 clearly identifies circumstances where a PSR must be conducted before equipment or processes are put into use. If a triggering condition exists, employers must obtain a PSR.
2. PSRs Verify Machine Guarding Compliance
Many PSRs focus on safeguarding systems. The review confirms that guards, interlocks, and protective devices meet Ontario requirements.
3. PSRs Identify Hidden Hazards
New or modified equipment may introduce risks that are not obvious during installation. A PSR evaluates pinch points, crushing hazards, and exposure to moving parts.
4. PSRs Must Be Completed Before Operation
Equipment subject to PSR cannot be operated until the review is complete and recommendations are addressed.
5. PSRs Reduce Employer Liability
Failure to complete a required PSR can lead to Ministry of Labour orders, fines, and prosecution.
6. PSRs Support Due Diligence
Documented PSRs demonstrate that employers took reasonable steps to protect workers.
7. PSRs Apply to New and Modified Equipment
PSRs are required not only for new machinery but also for modifications that affect safety.
8. PSRs Improve System Reliability
Properly reviewed systems experience fewer failures and shutdowns.
9. PSRs Build a Strong Safety Culture
PSRs reinforce the importance of safe design and operation.
Conclusion
In Ontario industrial establishments, Pre-Start Reviews are a legal requirement under specific conditions. They verify compliance, prevent injuries, and protect employers. Treating PSRs as optional exposes organizations to serious risk. Completing PSRs before startup is essential for safe and compliant operations.
