Safety Q&A: Important questions to ask machine builders when buying new equipment
By Michael Wilson
By Michael Wilson
The requirements for Pre-Start Health and Safety Reviews (PSHSR) have been around for over a decade, yet some companies still struggle with the process.
When purchasing new equipment or integrating a new process, the employer should integrate the PSHSR requirements as early as possible. This should include asking if the manufacturer understands the PSHSR process, which is unique to Ontario. In some cases, a pre-start review will mean different things to different people. When reviewing the PSHSR requirements, ensure that the machine builder/supplier understands that the requirements are included in Section 7, Regulation 851 made under the Occupational Health and Safety Act. A similar statement should be part of the purchase order or related procurement documents.
After the machine builder/supplier presents their solution, ask what standards the system or process was designed to meet. Remember that inspections performed by the Electrical Safety Authority (ESA) or Canadian Standards Association (CSA) may only be for compliance to the Electrical Safety Code. While this is a requirement, these organizations will not check for measures in related safeguarding standards when it comes to a PSHSR. The Ministry of Labour (MoL) created a PSHSR guidance document that outlines what standards could be used to support compliance or exemption. In this document, several CSA, ANSI, NFPA and ISO standards are referenced — some of the documents are equipment-specific and others are considered generic or ‘A’-type standards.
When a machine builder/supplier presents a solution as compliant to a given piece of legislation or standard, don’t be afraid to ask how. Which standards were used to design the equipment or process? Are they familiar with the legislation/regulation that applies to your particular operation? Do not be afraid to acquaint yourself with the code and standards that apply to the equipment or process you are looking at installing/modifying. This awareness can be helpful, not only when you are deciding which builder/supplier to select, but also if you receive a PSHSR report.
Remember if you, as the end user, obtain exemption documents for a given machine or process, you do not have to hire an engineer to conduct the PSHSR. Always be cautious when you receive documents to support an exemption from the PSHSR. What do they look like? It depends on which element of the PSHSR process you are dealing with. The MoL’s PSHSR guidance document gives basic elements that should be provided for the exemption. If you find yourself pursuing exemption, scrutinize every element of that document. Remember the exemption document is essentially excusing you from hiring an engineer to conduct a full PSHSR. Don’t be afraid to do more than the bare minimum.
In the case of a racking exemption, drawings bearing the signature and seal of a professional engineer are one of the ways to establish the exemption. How that particular racking system is installed would greatly determine its stability. Even though the exemption does not explicitly state a document is required from the installer, ensure that the person installing the racking system is competent to do so.
Another thing to consider: if a machine builder/supplier states that a machine does not require a PSHSR because it is compliant to CSA Z432 (General Safeguarding of Machinery), for example, ask for a copy of the risk assessment. If a generic or type ‘A’ standard(s) is used for PSHSR exemption, a risk assessment must be completed. Without the risk assessment, you could not pursue the exemption from the PSHSR process.
Where will things become complicated? Be cautious if the machine builder/supplier tells you the system or process is compliant but has nothing to back that statement. At this point, if you know a PSHSR is required, you could either execute the PSHSR once you have the machine or process, or make the builder/supplier conduct the PSHSR. If your choice is the latter, that can come with its own challenges.
Ask who is conducting the PSHSR. Don’t forget section 7 requires the use of a professional engineer — a person who is licensed by the Professional Engineers Ontario (PEO). Even though a person could be licensed in another jurisdiction, the person executing the PSHSR must also be licensed in Ontario. Is the builder/supplier using someone who is competent to conduct the PSHSR? This is critical, especially if there are a number of related codes and standards that could be referenced for the review. The engineer conducting the PSHSR should be well versed in the supporting documents to provide a quality assessment.
Another potential trap of having the builder/supplier execute the PSHSR is identifying the appropriate path to address any measures required for compliance. Picture a scenario where you have the PSHSR executed by the builder/supplier, the equipment arrives along with the PSHSR report, and the PSHSR outlines 18 measures required for compliance. Are those changes part of the original purchase agreement or an extra cost? Ensure that there is a clear process to address this scenario once you enter an agreement to purchase equipment.
If you, as the end user, decide to execute the PSHSR, keep the requirements in mind right from the theoretical start of the project. In many cases, the PSHSR is executed after installation has been completed. At that point, many things can occur — the best case scenario for you is that the engineer finds little to no issues with the equipment or process. However, more often several issues are noted and now you must determine how to address these issues. Once equipment has been installed, the cost of making changes rises. Building the PSHSR protocol into your development cycle could have avoided additional costs associated with retrofits and, in all likelihood, downtime.
If you have or expect to conduct a PSHSR, it is beneficial to have a good relationship with the engineer(s) involved. In many cases, an employer gets the PSHSR report and elects to address the issues internally. For organizations that may not have internal support to address the measures required for compliance, partnering with the engineer(s) for guidance can prove to be useful. It is important to note that only the employer is responsible for addressing measures required for compliance in the PSHSR report. But for companies without the expertise on staff, the support of PSHSR engineers can be valuable.
The PSHSR process is a requirement for workplaces that fall under the industrial regulations in Ontario. There are many other workplaces that follow this process even though it is not specifically mandated within their governing legislation. This process is one of many ways to show your willingness to take reasonable precautions for the safety of your workers and to ultimately keep them productive so they can help grow your business.
Michael Wilson is a machine safety specialist with Workplace Safety and Prevention Services. He primarily supports clients with hazard identification, risk assessment and safeguarding audits. Wilson also provides safety training on machine safeguarding, robot safety, press safety, pre-start reviews, hazardous energy control and conveyor safety. He is an active member of the Professional Engineers Ontario and a Canadian Registered Safety Professional.
This column originally appeared in the May 2014 issue of Manufacturing AUTOMATION.