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Pre-Start Health and Safety Reviews

Ontario legislation requires a Pre-Start Health and Safety Review (PHSR) for when a new apparatus, structure, or process is to be constructed, added or installed or a new process is used, or modifications to and existing apparatus, structure, protective element or process is performed.

Kleinfeldt Consultants Limited is proud to offer engineering review, health and safety review, and a PHSR report that indicates what would be necessary to bring the construction, addition, installation or modification into compliance with the applicable provisions of the Regulation for Industrial Establishments.

Our Pre-Start Health and Safety Review Includes the following Services:

  • Review for complance against the Occupational Health and Safety Act
  • Hazard Analysis where appropriate
  • Detailed explanations of any non-compliance issues and the relevant codes, acts and/or standards.

Health and Safety review identifies hazards by comparing installations against the most up to date: codes, acts and standards. Not only is PHSR the law but; it is good practice in reducing the potential for accidents. Reducing accidents saves money. According to the Workplace Safety and Insurance Board (WSIB) the indirect cost of each lost-time injury in 2007, including re-hiring, re-training, lost productivity, etc. was $85,200. The direct cost to the WSIB of each lost-time injury in 2007, on average, is $21,300. Reducing accidents can also have a direct impact on insurance costs.

The Ministry of Labour has in recent years greatly increased the number of inspectors from approximately 230 in 2004 to approximately 430 in 2007. Don't wait until an inspector knocks on your door and issues orders for PHSR. Having the threat of fines or shut down, plus the impact on insurance of having outstanding orders against a facility is not a good situation to be in.

Questions and Answers:

Does a PHSR have to be done by an Engineer?

A professional Engineer registered in Ontario must complete the PHSR. It is a signed and stamped engineering document. (Some exceptions apply.)

I have a Professional Engineer, why should I hire Kleinfeldt to do my PHSR?

  • By contracting a reputable outside firm like Kleinfeldt to do a PHSR, an impartial third party reviews the equipment or process for safety.
  • The liability for the PHSR is shared with the contracted firm.
  • A PHSR references many codes, acts, regulations and standards. The Ministry of Labour identifies over 50 different documents for review, many of which are available only at cost. Most of the documents required are date sensitive so updated versions must be acquired where appropriate. It may be cheaper to contract out the PHSR then to acquire the relevant documentation for review.
  • Section 31(2) of the OHSA and the accompanying Professional Engineers Act identify two important things.
    • There are personal liabilities incurred by an engineer who gives advice and provides reports required under the Act. These liabilities are those of the engineer whose seal and signature are found on the PHSR and not of his or her employer. Professional liability insurance coverage may be required.
    • For an engineer, "undertaking work the practitioner is not competent to perform by virtue of the practitioner's training and experience" is professional misconduct. Just because someone bears the title "ENGINEER" doesn't mean they are automatically qualified for an engineering task.

You can read more about Pre-Start Health and Safety Reviews here.