THE FIRST QUESTION

Do you need a Pre-Start Health and Safety Review?

Section 7 of Regulation 851 has required Ontario factories to obtain an engineering review before certain equipment is operated since 2000. The duty sits with the owner, and it attaches to modifications, not only to new installs.

Run the check

Tick anything that applies to your new or modified equipment.

Start by ticking a box

Section 7 lists the circumstances that trigger a review in an Ontario factory.

Indicative only. A formal trigger determination is made by the reviewing professional engineer against the full Table to section 7, and we do that at no charge anywhere in Ontario.

Modifications are the trigger everyone misses

Guarding removed during a rebuild and never reinstated is the single most common finding we make on a first visit. So is a control system rewired by a contractor who has since left, a machine relocated to a new bay, or a line repurposed for a different product.

None of those look like a new install, and none of them arrive with paperwork. All of them can attach the obligation. If any of that sounds familiar, send photographs. The determination costs you nothing.

What a review actually involves

The review is not a walk around with a clipboard. It is a documented comparison of the equipment as installed against the applicable provisions of Regulation 851 and the standards that give those provisions technical content: CSA Z432 for safeguarding, ISO 13849-1 for the safety related control system, ISO 13855 for safety distance, CSA Z460 for hazardous energy, NFPA 660 where combustible dust is present, and CSA A344 where racking is involved.

Where measurement is required, we measure. Guard opening dimensions against reach distances, light curtain position against calculated minimum safety distance, stopping performance against the assumptions in the safety distance calculation. A finding that cannot be traced to a measurement or a clause is not a finding we will write.

Send us the details

Let's find out what needs a review.

Send drawings or photographs and we will tell you plainly whether a review is required, before any fee is discussed. We work across all of Ontario.

Pre-Start Health and Safety Review, trigger checklist

Safeguard Engineering Inc. · 613-983-2642 · info@safeguardengineering.ca
Prepared

Indicative only. This checklist paraphrases the circumstances in the Table to section 7 of R.R.O. 1990, Reg. 851 (Industrial Establishments) under the Occupational Health and Safety Act. A formal trigger determination and any Pre-Start Health and Safety Review must be carried out by a Professional Engineer licensed in Ontario with expertise relevant to the hazard. Safeguard Engineering Inc. performs trigger determinations at no charge. Call 613-983-2642.
Call SGE, 613-983-2642