In Ontario’s industrial establishments, safety compliance is built on proactive engineering, not afterthoughts. When new machinery or process changes are introduced, the PSHSR (Pre-Start Health and Safety Review) ensures that all hazards are assessed before operation begins. Unfortunately, many facilities still conduct reviews too late in the project timeline, creating unnecessary risks and expenses.
A pre-start up safety review is not simply a formality; it is a legal requirement under Ontario Regulation 851. Treating it as a last-minute task can delay production, require costly redesigns, and attract the attention of the Ministry of Labour.
The Problem: PHSRs Are Often Done Too Late
Too often, a pre-start review is requested only after machinery has been installed or modifications completed. At that stage, problems such as inadequate guarding, missing interlocks, or unsafe electrical connections have already been built into the system.
This late timing leads to avoidable rework, inspection delays, and increased costs. Worse, operations might unknowingly run non-compliant equipment, leaving employers exposed to liability if an incident occurs before the review is complete.
Cost of Late Compliance for Ontario Manufacturers
A delayed PSR assessment can have serious financial and operational consequences. Common impacts include:
- Downtime while waiting for engineering corrections and approval
- Redesign costs for equipment that fails to meet regulatory standards
- Missed production targets due to unplanned project extensions
- Penalties for operating non-compliant machinery under OHSA
When a review identifies critical safety issues post-installation, correcting them may involve structural changes or costly retrofits that could have been avoided with early planning.
Why Compliance Must Begin in the Design Phase
The most efficient time to integrate compliance is at the design stage. Engineers can incorporate safety measures, such as guarding, control reliability, and safe access, before equipment is built or installed.
A properly timed pre-start up safety review ensures:
- Hazards are identified before procurement or construction
- Equipment layouts meet Ontario Regulation 851 requirements
- Guarding, control systems, and electrical interfaces comply with OHSA
- Time and budget are allocated for potential corrective measures
Building compliance into design minimizes disruption later in the project and supports faster commissioning.
Common Retrofit Scenarios in Ontario Plants
Older facilities frequently undergo retrofits to modernize equipment, integrate automation, or expand capacity. These changes often trigger the need for a PSHSR, especially when modifications affect worker exposure to hazards.
Examples include:
- Upgrading machinery with new control systems or robotics
- Replacing mechanical guards with automated barriers
- Installing new dust collection or ventilation systems
- Introducing flammable liquid handling equipment
Each of these scenarios carries potential compliance triggers that a licensed engineer must review before startup.
Advantages of Early Design Review
Integrating a PSR assessment early brings multiple benefits:
- Prevents design flaws that could cause rework later
- Reduces costs tied to retrofitting safety components
- Shortens project timelines by aligning design with OHSA standards
- Improves coordination between design, construction, and commissioning teams
- Ensures regulatory confidence during inspections
By addressing safety engineering upfront, manufacturers gain smoother approvals and fewer interruptions.
How SAFE Engineering Inc. Helps
SAFE Engineering Inc. provides comprehensive pre-start review services across Ontario. Their licensed engineers collaborate with design teams early in the project to identify hazards, evaluate compliance requirements, and prepare certified PSHSR reports.
Services include:
- Early-stage design assessments
- Equipment layout and guarding reviews
- Coordination of regulatory documentation
- Engineering recommendations for hazard mitigation
By engaging early, SAFE Engineering Inc. helps manufacturers avoid last-minute compliance challenges and achieve safe, efficient project execution.
Conclusion
Delaying a pre-start up safety review creates unnecessary costs, project setbacks, and compliance risks. Ontario manufacturers can avoid these challenges by embedding PSHSR planning at the design stage.
By working with trusted engineering partners like SAFE Engineering Inc., organizations can complete every assessment on time, ensuring safety, compliance, and uninterrupted productivity. Contact us today!
