PSR - All Must-Knows on Ontario Pre-Start Health and Safety Reviews

In Ontario (Canada), a PSR process is required by the Ontario Health and Safety Act to identify any safety concerns regarding warehouse equipment. It's an equipment evaluation to determine if it's safe for use. It is also a way to identify unsafe practices or working conditions, as standards set forth by the Ministry of Labor have become more stringent. Regarding pallet racking systems, a PSR is required when certain conditions are met. If you wish to know more about what it is and when it is needed, read on.

What does PSR stand for?

'PSR' stands for Pre-start Safety Review, also called PHSR for Pre-start Health and Safety Review. For pallet rack systems, a knowledgeable person must inspect and create a report that defines whether the racking systems are safe to use. The report must contain recommendations on what to do if they are not. Last but not least, the PSR report must be signed by an engineer.

Since October 2000, a PSR is required by law in Ontario, under Section 7 of Ontario’s Regulation for Industrial Establishments, (O. Reg. 851), Clause 45 (b).

Inspecting new or modified equipment before it is used in a work environment is basic common sense. Ontario is the only Canadian province to have legislation on such a procedure, but other provinces, like British Columbia and WorkSafeBC, are following its lead.

When is a PSR required?

If one of the following conditions is met, a PSR must be executed for the racking system:

• Documentation from the original manufacturer on the load capacity and safe operation of the rack - sealed engineering report or LARC drawings cannot be found.
• The rack has undergone modifications (i.e., a change in beam elevations) since the previous PSR report.
• There is damage to a rack part or component.
• The rack has been repaired with a rack repair kit.

Who can perform a PSR and create a report?

If there is existing documentation on the rack's load capacity, a person with professional expertise in assessing rack hazards can issue a PSR; however, an engineer's signature is required. Only a professional engineer can calculate or determine a system's load capacity.

What’s in a PSR report for a rack system?

It should contain the following:

• The design codes, specifications, and parameters used to evaluate the condition of the racks.
• If load capacity is identified, details of the structural capability of the rack.
• The signature of the inspector(s) and collaborator(s), and the inspection date.
• An Engineer's seal of approval.

Where and why do I need to keep my PSR reports?

PSR reports must be kept on hand and made available for review if requested by a Ministry of Labour (MOL) inspector, a warehouse health and safety committee, or a representative before a rack system is put into use. The report must include the signature of the Engineer who reviewed the rack and concluded that it is safe to use.

What is excluded from a PSR Report?

A PSR does not include a follow-up to confirm that corrections were performed for identified deficiencies or operating compliance. The ongoing maintenance of a rack is outside the scope of the PSR.

The 8 steps of the PSR Process

1. Identify new or modified equipment/structures – Determine if changes in your facility (e.g., new racking, lifting devices, or machinery) could impact safety.

2. Determine if a PSR is required – Check Ontario’s OHSA Regulation 851 to confirm whether the installation or modification triggers a mandatory review.

3. Hire a licensed Professional Engineer (P.Eng.) – Only a qualified engineer in Ontario can conduct and sign a PSR.

4. Engineer reviews the equipment/process – The P.Eng. evaluates potential hazards for compliance.

5. Engineer prepares the PSR report – The report outlines findings, compliance checks, and recommendations for corrective measures if needed.

6. Implement corrective actions – The company addresses any issues identified in the PSR to bring equipment into compliance.

7. File and retain the PSR report – Maintain a copy of the signed report in compliance with OHSA requirements for future inspections or audits.

8. Safe commissioning and workplace use – Once compliant, the equipment or structure can be safely delivered.

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References

Occupational Health and Safety Act and Regulations for Industrial Establishments, R.R.O. 1990, Reg. 851 as amended by O. Reg. 528/00, Toronto: Queen’s Printer.

Guidelines for Pre-Start Health and Safety Reviews: How to Apply Section 7 of the Regulation for Industrial Establishments, Toronto: Ministry of Labour, April 2001