Frequently Asked Questions: Machine Safety Consulting

A Pre-start Health and Safety Review (PSR or PHSR) is a report written and normally required to be stamped by an experienced engineer. It follows requirements of Ontario Industrial Establishments Regulation 851 Section 7. The purpose of the report is to ensure worker safety by auditing compliance with the identified applicable sections of Regulation 851. For example: the machine guarding PHSR (Circumstance 2) verifies that the safeguarding system is designed to prevent access to moving hazards.

A PHSR is required when an Ontario factory legislated under Ontario Regulation 851 Industrial Establishments has a new or modified machinery/process that meets 1 or more of 8 Circumstances. The circumstances are outlined in Ontario Regulation 851 Section 7 of the Industrial Establishments Regulation. Lucid Engineering specializes in Circumstance 2 (machine guarding) where the applicable provisions of the regulations are O.Reg 851 Sections 24, 25, 26, 28, 31 and 32.

Per the Ontario Ministry of Labour guidelines, if you relocate a machine within your facility without modifying it, you normally do not require a new PHSR. However, if you move the machine to another facility, even if it is owned by you, a PHSR is required.

When in doubt, please feel free to contact one of our consultants. We would be happy to assist you with your application or answer any additional questions you may have.

We schedule all our work and onsite visits on a first come first serve basis. Once we understand your project a quotation will be prepared, the onsite evaluation is scheduled, and a consultant assigned to your project. We may request additional information to be more prepared for the visit. If requested, a draft version of the report can be sent to you, prior to the finalized stamped report being issued. To contact our consultants directly, please visit our Consultants page on our website. You can also call our central office at 647-224-5032 or email us at info@lucidengineering.ca.

Information that you should prepare for your PHSR, if available, includes control system documentation, machine details including manufacturer’s manuals, summary of safety PLC program functions, and any risk assessments, functional safety and/or SISTEMA summary reports that have been completed.

Please note that if this information is not all available, we can still complete an assessment given the electrical drawings. The more detailed information provided, the better the prepared our consultants can be, and the faster they can produce the report due to less duplication of work.

When in doubt, please feel free to contact one of our consultants. We would be happy to assist you with your application or answer any additional questions you may have.

To properly assess the safety of the machines and potential hazards, the onsite visit must be conducted in person. This is in correlation with best practices outlined in the PEO Guideline for Engineers Completing Pre-start Health and Safety Reviews. The length of time an onsite review takes varies on factors including the type of machine, how many machines there are, how much information was given prior to the onsite review, etc. Typically, the onsite portion of a review will take between 30 minutes to 3 hours, depending on complexity.

If a risk assessment has already been completed, another risk assessment is unnecessary. However, if no risk assessment has been completed, our team will conduct one to determine the appropriate functional safety requirements. This assessment will consider the severity of potential injury, exposure to the hazard itself, if the hazard is avoidable.

Our consultants can issue revisions on PHSRs they have completed. If an audit of a PHSR conducted by another engineer is requested, Lucid Engineering follows the guidelines outlined by Professional Engineers Ontario and Ontario Ministry of Labour.

When in doubt, please feel free to contact one of our consultants. We would be happy to assist you with your application or answer any additional questions you may have.