Regulation 851 PSR Trigger Determination in Ontario (Section 7 Guide)
Regulation 851 PSR Trigger Determination in Ontario (Section 7 Guide)
Under Ontario Regulation 851 – Industrial Establishments, Section 7 requires a Pre-Start Health & Safety Review (PSR) when specific hazard categories listed in Table 1 apply.
Determining whether a PSR is required is not optional — it is a legal compliance obligation under the Occupational Health and Safety Act (OHSA). A PSR must be conducted or approved by a Professional Engineer licensed in Ontario (P.Eng.) before workers are exposed to regulated hazards.
HITE Engineering provides structured Section 7 trigger determination and full PSR services across Ontario:
Pre-Start Health & Safety Review Services.
Compliance Snapshot – Regulation 851 Section 7
- Applies To: Factories (as defined under OHSA)
- Trigger Basis: One of eight hazard categories in Table 1
- Engineer Requirement: Ontario-licensed P.Eng.
- Timing: Prior to startup or worker exposure
- Documentation: Written engineering report
The Eight PSR Trigger Categories (Table 1 Overview)
- Storage or dispensing of flammable liquids
- Safeguarding devices for machinery
- Processes with a risk of ignition or explosion
- Dust collection systems with a risk of ignition or explosion
- Racking and stacking structures
- Lifting devices, cranes, and hoists
- Molten material processes
Processes with a risk of hazardous exposure to biological or chemical agents
Each trigger has technical thresholds and exemption criteria that must be evaluated carefully.
Common Situations That Require Trigger Evaluation
- Installing new automated production equipment
- Importing machinery not originally designed to Canadian standards
- Modifying existing safeguarding systems
- Installing industrial racking systems
- Adding flammable liquid dispensing operations
- Installing dust collectors or explosion-prone systems
Related HITE resources:
- When Is a Pre-Start Health & Safety Review Required?
- History of Section 7 Regulation 851
- How a Professional Engineer Addresses a PSR Request
Who Should Perform PSR Trigger Determination?
Trigger analysis should be performed by a Professional Engineer licensed in Ontario. Incorrect exemption assumptions are a common cause of compliance failure and enforcement action.
Consequences of Failing to Complete a Required PSR
- Stop-work orders
- Startup delays
- Retrofit costs
- Regulatory penalties
- Increased liability exposure
Contact HITE Engineering before commissioning new or modified industrial equipment.
FAQ: Regulation 851 PSR Trigger Determination
When is a PSR required under Regulation 851?
A PSR is required when one of the hazard categories listed in Table 1 of Section 7 applies to a new or modified installation.
Can a risk assessment replace a PSR?
No. A risk assessment does not replace a PSR when a Section 7 trigger condition applies.
Does every new machine require a PSR?
No. Applicability depends on whether a regulated hazard category applies and whether exemption criteria are met.
Who can approve a PSR in Ontario?
A Professional Engineer licensed in Ontario must conduct or approve the review.
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