Ontario industrial establishments rely on several types of safety reviews to ensure compliance with regulatory requirements and protect workers from hazards. Two of the most frequently discussed processes are the PHSR and the engineering safety audit. Although these reviews may appear similar, they serve different purposes and are triggered by different conditions.
Understanding the distinction between these tools is important for organizations operating under Ontario’s Occupational Health and Safety Act and Ontario Regulation 851. Knowing when a pre-start health and safety review is required and when an engineering audit is appropriate helps facilities avoid compliance gaps and regulatory orders.
Two Different Tools, Two Different Triggers
A PHSR in Ontario is a legally mandated engineering review that must be completed when specific conditions are present in an industrial establishment. It is designed to ensure that hazards associated with equipment or processes are properly controlled before operations begin.
An engineering safety audit, on the other hand, is a proactive evaluation of existing conditions within a facility. While it may identify hazards or compliance gaps, it is not necessarily triggered by regulation. Instead, it is typically performed to improve safety performance or prepare for inspections.
Understanding these two different triggers helps facilities apply the correct safety process at the appropriate time.
When a PHSR Is Legally Required
Ontario Regulation 851 outlines the circumstances in which a pre-start health and safety review must be conducted. These requirements are intended to prevent worker exposure to hazards associated with machinery, processes, or protective elements.
A PHSR is typically required when new equipment is installed or when existing equipment is modified in a way that could affect worker safety. Changes to machine guarding, process layout, or protective systems may also trigger a review.
The purpose of the review is to verify that the equipment or system has been designed and implemented in accordance with regulatory expectations. A completed PHSR in Ontario provides documented evidence that hazards have been identified and controlled before operation begins.
What Engineering Audits Typically Include
Engineering safety audits evaluate how well existing systems meet safety expectations. While these audits are not tied to a specific regulatory trigger, they provide valuable insight into operational safety.
An engineering audit may review machine guarding conditions, electrical installations, equipment layouts, storage practices, and hazard control systems. The goal is to identify areas where safety controls could be improved or where regulatory requirements may not be fully met.
Unlike a pre-start health and safety review, which is required before equipment is put into service, an audit evaluates the current state of a facility. This allows organizations to address potential risks before they become compliance issues.
Who Can Perform Each Type
Another key difference between these reviews involves who is permitted to perform them. A PHSR must be completed by a licensed professional engineer. The engineer evaluates the equipment or process and prepares a report documenting whether hazards have been adequately addressed.
Engineering audits, however, may be performed by internal safety personnel, external consultants, or engineering professionals. Because audits are not always tied to regulatory triggers, organizations have greater flexibility in selecting the auditors.
However, when engineering design or hazard control is involved, professional engineering oversight is often beneficial to ensure accuracy and reliability.
Documentation and Inspection Readiness
Both processes contribute to regulatory readiness, but the documentation they generate serves different purposes. A pre-start health and safety review produces formal engineering documentation confirming that equipment meets regulatory expectations.
Engineering audits generate internal reports that identify hazards, recommend improvements, and document corrective actions. These reports help organizations prepare for inspections and demonstrate proactive safety management.
When combined, these tools support a comprehensive compliance approach within industrial establishments.
Choose the Right Tool for Your Compliance Needs
Although the PHSR and engineering safety audit both contribute to workplace safety, they are designed for different purposes. A pre-start health and safety review addresses hazards before equipment begins operation, while audits evaluate existing systems and identify opportunities for improvement.
Ontario facilities that understand when to apply each process are better prepared to meet regulatory expectations and maintain safe operations.
SAFE Engineering Inc. supports industrial establishments with compliant pre-start health and safety review services to help organizations meet PHSR requirements in Ontario and maintain strong safety practices. Contact us today!
