PSR - What You Should Know About Pre-Start Health and Safety Reviews

Posted by Charles Carbonneau, P. Eng. on May 20, 2019
Charles Carbonneau, P. Eng.
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In Ontario (Canada), a PSR process is required by the Ontario Health and Safety Act, to identify any safety concerns with regards to equipment in the warehouse. It's an evaluation of the equipment 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. When it comes to 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.

'PSR' stands for Pre-start Safety Review, also referred to as PHSR for Pre-start Health and Safety Review. When it comes to pallet rack systems, it’s an inspection process and report done by a knowledgeable person to determine if the systems are safe for use. It must contain recommendations on what to do if they are not.

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 they are used in a work environment is basic common sense. Ontario is, so far, the only Canadian province to have legislation on such a procedure, but other provinces, like British Columbia and WorkSafeBC are following their lead.

When do I need a PSR?
If one of the following conditions is met, you must have a PSR executed on the rack:

  • You cannot find documentation from the original manufacturer on the load capacity and safe operation of the rack - sealed engineering report or LARC drawings;
  • The rack has undergone modifications (i.e., change in beam elevations);
  • There are damages to elements of the rack;
  • The rack has been repaired;
  • The rack has been modified since the previous PSR report.

Who can execute a PSR?
If there is existing documentation on the load capacity of the rack, a person who possesses professional knowledge in assessing the potential hazards related to racks can issue a PSR. If the load capacity of the system must be determined, only a Professional Engineer can do so.

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 determined, details of the structural capability of the rack.
  • The signature of the inspector(s) and collaborator(s), date of the inspection and the report.
  • Engineer seal if performed by an engineer.
  • Details of the inspector’s qualifications if not an engineer.

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 representative before a rack system is put into use. It has to state somewhere in there that a qualified knowledgeable person reviewed the rack and concluded that it is safe to use.

What it's not?
A PSR does not include follow-up to confirm correction of deficiencies or operating compliance. The ongoing maintenance of the rack is outside of the scope of the PSR.

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

Topics: Rack Load Capacity, Pallet Racks, Pallet Rack Safety, Rack Conformity

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