Givens Engineering provides PSR services for safeguarded machines. Machines, automated or not, that use safeguards such as (but not limited to) light curtains, area scanning, safety mat systems, two-hand control systems, mechanical or electrical interlocking systems will require a PSR (or PSHSR) in the province of Ontario. Some examples of machines that might use these safeguards are presses, robot cells, automated machinery, conveyor systems, and assembly machines.
When is a Machinery PSR Required?
A PSR is a Prestart Health and Safety Review which is required by the Ontario Health and Safety Act, Reg 851, Section 7 for “any of the following are used as protective elements in connection with an apparatus: Safeguarding devices that signal the apparatus to stop, including but not limited to safety light curtains and screens, area scanning safeguarding systems, radio frequency systems and capacitance safeguarding systems, safety mat systems, two-hand control systems, two-hand tripping systems and single or multiple beam systems” and “Barrier guards that use interlocking mechanical or electrical safeguarding devices.”
Normally, an Emergency Stop button is not considered “a safeguarding device that signals the apparatus to stop”.
Paradoxically, Section 7 does not require a PSR on a machine that does not have interlocked safety devices, even though a machine may be hazardous. For example, if a machine can cut off a worker’s fingers and does not have any protective safety devices, no PSR is required! But in the case of a serious injury, or death, the owner or supervisor may still be found to be negligent for not installing protective equipment. It is better to perform the PSR and to discover what safety equipment is necessary than to proceed without a PSR.
Common Problems Found in Foreign Machines
Many machines that originate outside Canada have common controls problems that violate our standards, and especially the largest applicable standard, the CSA Z432. Common problems in foreign machines include:
- Emergency stops are routed through a PLC or HMI, which is not allowed in Ontario.
- A lack of CSA electrical certification or ESA electrical inspection.
- Basic safety devices, such as light curtains, emergency stops, 2-hand control circuits, safety interlock switches, etc. are controlled by “black boxes”, which sometimes are programmable, sometimes are proprietary and usually cannot be accessed or understood by the PSR engineer. In general, it is not permissible to have safety devices controlled by “black boxes”, instead, separate external hard- wired devices such as safety relays must be installed to control them, which can be costly.
- Machines originating outside North America and Europe may also have basic, fundamental problems, such as open access of a worker’s hands to unsafe machine parts.
Generalizations About Machinery PSRs
In general, any machine that operates automatically, even for short periods, must be completely guarded.
In general, if the machine in question must be assessed for strength, the engineering calculations to determine the strength will be requested in the PSR; they are not part of the PSR.
What Happens During a Machinery PSR?
The PSR would consist of a site visit to look at the machine and how it is installed, followed up by a report.
The report would consist of 3 parts:
- Scope of Work, describing the machine requiring the PSR and delineating what surrounding equipment is not part of the PSR.
- Observations and Deficiencies, which is the bulk of the report, contains written observations, layouts, photographs, etc., and ends with a list of deficiencies, if there are any.
- Letter of Compliance, which is what a Ministry of Labour inspector will ask to see as proof that a PSR has been done, and which usually states that the machine is compliant with the Occupational Health and Safety Act providing that a number of deficiencies are corrected.
Maintain Health and Safety with a Machinery PSR
Not sure if your machine requires a PSR? Contact us to get your questions answered or to get a quote for a PSR report.
Our automation and machinery division, Givens Machine Systems, offers design and fabrication for automated machinery, special purpose machinery, fixtures, conveyors, and more. Contact us for a quote on your next project!