Transcription
Guidelines for Pre-Start Healthand Safety Reviews:How to Apply Section 7 of theRegulation for IndustrialEstablishmentsApril 2001Health and Safety Guidelines
For more copies, please contact:Publications SectionMinistry of Labour400 University Ave., 7th FloorToronto ON M7A 1T7Tel: (416) 326-7731Toll-free: 1-800-268-8013Fax: (416) 326-7745E-mail: pubsale@gov.on.caWeb: http://www.gov.on.ca/lab/main.htmPublished April 2001Queen’s Printer for Ontario, 2001 ISBN 0-7794-1238-9Le présent document est aussi disponible en français sous le titre «Directives surl’examen préalable de santé et de sécurité : application de l’article 7 du règlement relatifaux établissements industriels» [ISBN 0-7794-1239-7]
Guidelines for Pre-Start Health and SafetyReviews: How to Apply Section 7 of theRegulation for Industrial Establishments
Table of Contents1.INTRODUCTION .12.PURPOSE OF THESE GUIDELINES .23.THE PRE-START HEALTH AND SAFETY REVIEW .34.THE REVIEWER CARRYING OUT A PRE-START HEALTH ANDSAFETY REVIEW.215.APPLICABLE REGULATIONS, CODES AND STANDARDS .22APPENDIX I - TABLES .24TABLE 1: SECTION 7 TABLE .24TABLE 2: APPLICABLE STANDARDS FOR EXEMPTION OR REVIEW .25APPENDIX II - RECOGNIZED STANDARDS .27APPENDIX III - THE REVIEWER .35MINISTRY OF LABOUR FIELD OFFICES .36
1. IntroductionThese guidelines provide information on the levels of diligence, methodology andreporting required to comply with section 7 of the Regulation for IndustrialEstablishments. In addition to these guidelines, the Ministry is producing a“Frequently Asked Questions” document to assist employers in conducting a PreStart Health and Safety Review. This document will be made available through theMinistry of Labour’s Publications Office.The employer, owner, lessee or reviewer needs to consider the following points: The employer is responsible for ensuring that all requirements of theOccupational Health and Safety Act and regulations are complied with in theworkplace. Even where a Pre-Start Health and Safety Review is not required oran exemption from the requirements of section 7 applies, the employer mustensure that workers will be protected when they use any apparatus, structure,protective element or process in the workplace. The section 7 Table (Table 1) in Appendix I specifies the provisions of theregulation that apply and circumstances under which a Pre-Start Health andSafety Review is required. There may be other compliance requirements that needto be met before any apparatus, protective elements, structures, and/or processesare used. Even if a Pre-Start Health and Safety Review is not required, it is stillthe employer’s responsibility to meet these requirements. To avoid a costlyretrofit the employer may broaden the scope of a regulated Pre-Start Health andSafety Review to include these requirements. The details outlined in Table 2Appendix I may provide an effective way to help ensure compliance. Integrating health and safety at the design stage and before operations begin is acost-effective and proactive way to prevent workplace illness or injury. Thebenefits are numerous. They include direct savings from minimizing retrofitting;less downtime and replacement of equipment; savings in workplace insuranceclaims due to fewer illnesses and injuries; and, most important, maintainingproductivity, health and safety in the workplace. These guidelines do not prescribe how a Pre-Start Health and Safety Review(PSR) is to be done, and the regulation allows for flexibility in that it does notspecify any one report format. Where employers have existing review systemsand processes to comply with health and safety requirements prior to start-up,they may use them to satisfy PSR requirements, provided that the evaluation,review and written report are done by an appropriate person as required insubsections 7 (11) and (12). The report or reports must indicate that theapparatus, structure, protective element or process complies with the applicablesections of the Regulation for Industrial Establishments referenced in section 7.PSR Guidelines-1-April 30, 2001
2. Purpose of these GuidelinesThe purpose of these guidelines is to clarify the intent and requirements of section 7of the Regulation for Industrial Establishments regarding Pre-Start Health and SafetyReviews.Within the guidelines, the term “Pre-Start Health and Safety Review” includes awritten report as required by Regulation 528/00, which amends section 7 of theRegulation for Industrial Establishments, Regulation 851.Adhering to the guidelines complies with the intent of section 7 of the Regulation forIndustrial Establishments. However, the guidelines are not intended to replace section7. In any case where these guidelines may differ from section 7, the section 7provisions prevail.IntentThe intent of section 7 of the Regulation for Industrial Establishments is to ensurethat a timely professional review identifies specific hazards, or hazards associatedwith exposure to chemicals and other designated substances, in certaincircumstances. Section 7 is intended to ensure that such hazards are removed orcontrolled before the apparatus or process is started up. The Pre-Start Health andSafety Review ends when the apparatus or process is put into production.The Pre-Start Health and Safety Review is intended to ensure worker protection asrequired under the applicable provisions of the Regulation for IndustrialEstablishments.Effective DateThe amended section 7 became effective October 7, 2000. If a review was done priorto the effective date, then another review is not necessary, unless modifications1 to anexisting machine, equipment, device, structure, protective element or process are tobe undertaken. These guidelines will assist in making that determination. If theinstallation of any new equipment, machine, or device is planned for after October 7,2000, then a review will be required prior to start-up for production, if section 7applies.For projects initiated before October 7, 2000 but not yet started up and to which theamended section 7 applies, a review completed under either the terms of the previoussection 7 or the current section 7 will be acceptable.1Not all modifications require review. For details, refer to Flow Chart 2, Existing Equipment.PSR Guidelines-2-April 30, 2001
3. The Pre-Start Health and Safety ReviewWhat is a Pre-Start Health and Safety Review?A Pre-Start Health and Safety Review includes a written report on the construction,addition or installation of a new 2 apparatus, structure, protective element or process3,or modifications to an existing apparatus, structure, protective element or process. Thereport details the measures (steps, actions or engineering controls) necessary to bringthe construction, addition, installation or modification into compliance with theapplicable provisions of the Regulation for Industrial Establishments as listed in thesection 7 Table (Table 1) in Appendix I.The Pre-Start Health and Safety Review is undertaken before start-up and ideally atthe design stage. The employer must address any measures necessary to bring theconstruction, addition, installation or modification into compliance before productionbegins.When is a Pre-Start Health and Safety Review required?The requirements for a Pre-Start Health and Safety Review are triggered when theapplicable sections of the Regulation for Industrial Establishments and theircircumstances as listed in Table 1 apply.Subsection 7 (2) of the Regulation for Industrial Establishments requires a Pre-StartHealth and Safety Review for the construction, addition or installation of a newapparatus, structure, protective element or process, or the modification to an existingapparatus, structure, protective element or process. Please refer to Flow Chart 1,“When Is a Pre-Start Health and Safety Review Required?”2A new apparatus, structure, protective element or process includes newly installed or addedapparatus, structure, protective element or process in the workplace.3For the purpose of this section, the term “process” refers only to those processes listed andidentified in Table 1 under items 4 and 8.PSR Guidelines-3-April 30, 2001
Flow Chart 1 - When Is a Pre-Start Health and Safety Review Required?NODoes the facility meet the definition of afactory?YESYESIs it a logging operation?NONOAre applicable provisions and circumstances ofthe Regulation for Industrial Establishmentslisted in Table 1?YESIs the apparatus, structure orprotective element or processnew or newly installed inthe workplace or is itexisting in the workplaceand is to be modified?EXISTINGRefer to FlowChart 2 forexistingequipmentNEWDoes an exemption apply - per subsections 7(5), (7), (8) or (9)? If so go to Flow Charts 3,4, 5 & 6NOYESYESIs the documentation required by subsection 7(10) that establishes the exemption available inthe workplace?NONOYESCan the documentation be obtained?Pre-Start Health and Safety ReviewNOT requiredPSR GuidelinesPre-Start Health and SafetyReview IS Required-4-April 30, 2001
What about modifications to existing equipment?There are several steps to consider if the employer is planning modifications to anexisting apparatus, structure, protective element or process and the provisions andcircumstances in Table 1, Appendix I apply. If one of the three steps described insubsection 7 (2) (b) of the Regulation for Industrial Establishments must be taken toachieve compliance, a Pre-Start Health and Safety Review is required.Note that if there is a lack of compliance due to intended modifications, butengineering or other control measures would restore compliance, a Pre-Start Healthand Safety Review would still be required before an apparatus, structure, protectiveelement or process is used. This requirement is subject to the exemptions specified inthe regulation.The shaded boxes in Flow Chart 2, Existing Equipment, are to be evaluated by aperson familiar with the Regulation for Industrial Establishments. Note that anevaluation is not a Pre-Start Health and Safety Review, but merely a way ofdetermining whether a Pre-Start Health and Safety Review is required. For thisreason, the person is not required to be a professional engineer.The employer should have a process in place to ensure that an evaluation is conductedto determine whether a Pre-Start Health and Safety Review is required on themodification, or establish the process through documentation.What are “new or modified measures”?New or modified measures are those measures referred to in section 87.3 of theRegulation for Industrial Establishments regarding molten material. These measuresare to be used in a foundry if engineering controls to prevent spillage are notreasonably possible in the circumstances.The term “measures” is also used in the Regulation Respecting Control of Exposure toBiological or Chemical Agents (Regulation 833), and regulations respectingdesignated substances such as Regulations 835 through 846 of the Revised Regulationsof Ontario, 1990. For the purposes of section 7 of the Regulation for IndustrialEstablishments, however, “measures” do not include respirators, work practices,hygiene facilities and practices, or administrative controls.PSR Guidelines-5-April 30, 2001
Flow Chart 2 - Existing EquipmentWas a Pre-Start Health and Safety Reviewcarried out when the apparatus, structure,protective element or process originallyinstalled or was exemption documented?YESNOIs the apparatus, etc. currently in compliancewith the Regulation for IndustrialEstablishments?YESNOEnsure compliance with the Regulation forIndustrial EstablishmentsNOAre the modifications to the apparatus, structure,protective element, or process such that new ormodified engineering controls or other new or modifiedmeasures (see page 5) would be required to complywith the applicable provisions of the Regulation forIndustrial Establishments?YESNODoes an exemption apply - per subsections 7(5), (7), (8) or (9)?YESYESIs the documentation required by subsection 7(10) that establishes the exemption available inthe workplace?NOYESNOCan the documentation be obtained?Pre-Start Health and Safety ReviewNOT RequiredPSR Guidelines-6-Pre-Start Health and SafetyReview IS RequiredApril 30, 2001
Are there “exemptions” from the Pre-Start Health and Safety Reviewrequirement?Even where there is a new apparatus, structure, protective element or process, or oneintended to be modified, a Pre-Start Health and Safety Review may not be requireddepending on certain criteria. Refer to the following Flow Charts 3, 4, 5 and 6.PSR Guidelines-7-April 30, 2001
Flow Chart 3 - Guarding Provisions ExemptionsIs either of the following used as a protective element in connectionwith an apparatus?1. a safeguarding device that signals the apparatus to stop, or2. a barrier guard that uses an interlocking mechanical or electricalsafeguarding deviceNOYESNOWas the apparatus manufactured in accordance with and does it meet currentapplicable standards, or has it been modified to meet them?YESNOWas the apparatus installed in accordance with the manufacturer’sinstructions and current applicable standards?YESWas the protective element manufactured in accordancewith current applicable standards, does it meet them orhas it been modified to meet them?NOYESYESWas the protective element installed at the timethat the apparatus was manufactured?NOWas the protective element installed in accordance withthe manufacturer’s instructions and current applicablestandards, if any?NOYESYESIs the documentation required by subsection 7 (10) thatestablishes the exemption available in the workplace?NOYESNOCan the documentation be obtained?Pre-Start Health and SafetyReview IS RequiredPre-Start Health and Safety ReviewNOT requiredPSR Guidelines-8-April 30, 2001
Guarding Provisions and StandardsItemApplicableprovisions ofthisregulationCircumstancesOther Ontariocodes forexemption orto supportcomplianceGenericstandards (‘A’& ‘B’) forexemption orto supportcomplianceMachinespecificstandards ‘C’forexemption orto supportcomplianceOther codes,andstandards,for reference2Sections 24,25, 26, 28, 31and 32Any of the following are usedas protective elements inconnection with an apparatus:1. Safeguarding devicesthat signal the apparatusto stop, including butnot limited to safetylight curtains andscreens, area scanningsafeguarding systems,radio frequency systems,two-hand controlsystems, two-handtripping systems andsingle or multiple beamsystems2. Barrier guards that useinterlocking mechanicalor electricalsafeguarding devicesOntarioElectricalSafety CodeCSA-Z432*ANSI B11.19ISO 14121ISO 12100Parts 1 & 2ISO 13851ISO 13852ISO 13853ISO 13854ISO 13855ISO 13856ISO 14119ISO 14120IEC 61496Parts 1, 2, 3ISO 4413ISO 4414CSA Z142*CSA Z434*CSA Z615*ANSI B11.1*ANSI B11.2ANSI B11.3ANSI B11.6ANSI B11.8ANSI B11.10ANSI B11.20ANSI B11.21ANSI B65.1ANSI B65.2ANSI B65.5ANSI 15.06ANSI B151.1ANSI Z245. 1 MOL GuideANSI Z245.2ANSI Z245.5See listings ofcodes,standards,manuals andhandbooks inAppendix II* Standard is under review, revised standard to be released shortlyA & B standards are generic safety standards that give basic concepts and principles for design and general aspects, or deal with onesafety aspect or one type of safety related device that can be applied to machinery/processesC standards are safety standards that deal with detailed safety requirements for a particular machine or group of machines orprocessesPlease note that the use of generic machine guarding standards type A and B shownabove requires that a risk assessment be conducted as part of this exemption. Should adispute or uncertainty arise regarding the applicability of standards listed, a Ministry ofLabour engineer may be contacted for clarification.For the purpose of this section, a manufacturer is:1. The original equipment manufacturer; and/or2. An employer (systems integrator) who is responsible for integrating equipment/agroup of machines or safety devices that have been procured to comply with currentapplicable standards, and/or items manufactured in house to those standards. Suchequipment integration shall be subject to a documented risk assessment review ifrequired by the applicable standard.If no Pre-Start Health and Safety Review is required due to the guarding provisionsexemption, the owner, lessee or employer must keep documentation supporting theexemption.PSR Guidelines-9-April 30, 2001
The following documents are acceptable to establish such an exemption:1.A notice in writinga) from the manufacturer declaring that the apparatus and protectiveelement have been manufactured or modified to meet currentapplicable standards. (Procurement/purchasing documentationverifying that the apparatus and protective element have beenmanufactured or modified to meet current applicable standards may beacceptable.)andb) from the installer stating that the apparatus and protective elementwere installed in accordance with the manufacturer’s instructions andcurrent applicable standards, if applicable; and2.If the protective element was not installed when the apparatus was manufactured,a notice in writing from the installer stating that the protective element is installedin accordance with the manufacturer’s instructions and current applicablestandards, if any.orCertification from an accredited organization verifying that the apparatus andprotective element have been manufactured or modified to meet currentapplicable standards may be acceptable, where such organizations are available.Such accredited organizations include: Standard Council of Canada - (CANADA) National Recognized Testing Laboratory (NRTL) – (USA) Approved Body for EC Type Examination (as listed in the EuropeanCommunity (EC) Machine Directive) – (EUROPE)PSR Guidelines-10-April 30, 2001
Flow Chart 4 – Rack & Stacking Structure ExemptionsNOAre material, articles or things placed or storedon a structure that is a rack or stackingstructure?YESIs the rack or stacking structure designed andtested for use in accordance with currentapplicable standards?NOYESYESIs the documentation required by subsection 7(10) that establishes the exemption available inthe workplace?NOYESCan the documentation be obtained?Pre-Start Health and Safety ReviewNOT requiredPSR GuidelinesNOPre-Start Health and SafetyReview IS required-11-April 30, 2001
Item3Applicableprovisions of thisregulationCircumstancesStandards forexemption or tosupport complianceOther codes, standards andpractices for referenceClause 45 (b)Materials, articles or things areplaced or stored on a structure thatis a rack or stacking structureRMI-Specificationfor the design, testingand utilization ofindustrial steelstorage racks Steel storage racking As 40841993SEMA Code of Practice for thedesign of static rackingPallet racks JIS Z 0620See listings of codes, standards,manuals and handbooks inAppendix IIFor the purpose of section 7, rack and stacking structures are industrial pallet racks,moveable shelf racks, stacker racks, drive-in and drive-through racks and cantileverracks. They are made of cold-formed, hot-rolled steel, wood, aluminum or concretestructural members. They are not other types of racks, such as portable racks orcontainers, or racks made of materials other than steel, wood, aluminum or concrete.In the case where a Pre-Start Health and Safety Review would be triggered by item 3 ofthe Table above (i.e. a rack), a Pre-Start Health and Safety Review would not be requiredif the rack or stacking structure is designed and tested for use in accordance with currentapplicable standards.If no Pre-Start Health and Safety Review is required due to the rack exemption, theowner, lessee or employer must keep documentation supporting the exemption. Thefollowing documents are acceptable to establish such an exemption:1.A document from the manufacturer, supplier or vendor of the rack or stackingstructure that indicates the requirements for its safe use, and contains a statementoutlining the loading conditions and design standards used to design and build therack or stacking structure. The requirements can take the form of, but are notlimited to, capacity tables, capacity charts, structural drawings or a writtenstatement specifying the capacity. The document must bear the seal and signatureof a professional engineer,or2.A notice in writing from the manufacturer declaring that the rack or stackingstructure is designed and tested for use in accordance with current applicablestandards.PSR Guidelines-12-April 30, 2001
Flow Chart 5 - Spray Booth Exemption - Subsection 7 (8)Is the process conducted inside a spray booththat is manufactured and installed inaccordance with current applicable standards?NOYESDoes the spray booth meet the definition of aspray booth in Ontario Regulation 388/97 madeunder the Fire Protection and Prevention Act,1997?NOYESYESIs the documentation required by subsection 7(10) that establishes the exemption available inthe workplace?NOYESCan the documentation be obtained?Pre-Start Health and Safety ReviewIS requiredPre-Start Health and Safety ReviewNOT requiredPSR GuidelinesNO-13-April 30, 2001
What is a spray booth?A spray booth as defined in the Ontario Fire Code “means a power-ventilatedstructure that encloses or accommodates a spraying operation so that spray vapour andresidue can be controlled and exhausted.”Item4Applicableprovisions ofthis regulationCircumstancesOther Ontariolegislation forcomplianceStandards forexemption or tosupportcomplianceOther codes, standards,practices for reference, seelistings in Appendix IISection 63A process involves a risk ofignition or explosion thatcreates a condition ofimminent hazard to a person’shealth or safetyOFC, OBC, ONGasoline HandlingAct/Code;ON- Energy ActPropane Codes,Natural GasCodes; ONMechanicalRefrigerationCode;ON-Boiler,Pressure Vessel,and PressurePiping Code; ONElectrical SafetyCodeNFPA-33 for spraybooth exemptions.MOL-EDS 4-12Wood workingoperationsNFC Part 4 & 5NFPA-30NFPA-34NFPA-68 & 69NFPA-86NFPA-497NFPA-499NFPA-505NFPA-820ANSI/API 500ANSI/ASHRAE 15Factory MutualIndustrial VentilationManual (ACGIH)In the case where a Pre-Start Health and Safety Review would be triggered by item 4 ofthe Table above (i.e., a potentially explosive process), a Pre-Start Health and SafetyReview would not be required if the process is conducted in a spray booth manufacturedand installed in accordance with current applicable standards. It should be noted that thisexemption does not apply to equipment installed inside the spray booth (e.g. robots).If no Pre-Start Health and Safety Review is required due to the above exemption, theowner, lessee or employer must keep documentation supporting the exemption. Thefollowing documents are acceptable in establishing such an exemption:1.A notice in writing from the manufacturer, or certification from an accreditedorganization, declaring that the spray booth is manufactured to current applicablestandards,and2.A notice in writing from the installer stating that the spray booth is installed inaccordance with the manufacturer’s instructions and current applicable standards.PSR Guidelines-14-April 30, 2001
Flow Chart 6 - Lifting Device Exemption - Subsection 7 (9)Does the construction, addition, installation ormodification relate to a lifting device or travellingcrane?NONOYESDoes the construction,addition, installationor modification relateto an automobilehoist?Is the lifting device ortravelling crane in or on asupporting structureoriginally designed for it,and does its capacity notexceed the capacityprovided for in thatoriginal design?YESIs the automobile hoistcertified to meet currentapplicable standards?NOYESYESYESNOIs the documentation required by subsection 7(10) that establishes the exemption available inthe workplace?NOYESNONOCan the documentation be obtained?Pre-Start Health and Safety ReviewNOT requiredPSR GuidelinesPre-Start Health and SafetyReview IS required-15-April 30, 2001
ItemApplicableprovisionsof thisregulationCircumstancesMachine-specific standards (‘C’) for exemption or to supportcompliance7Sections 51and 53The construction, addition, installationor modification relates to a liftingdevice, travelling crane or automobilehoistANSI-ALI ALCTV-1998,Exemption, third-party certification for automobile hoistsIn the case where a Pre-Start Health and Safety Review would be triggered by item 7 ofthe Table above, a Pre-Start Health and Safety Review would not be required:1.If the lifting device or travelling crane is in or on a supporting structure originallydesigned for it, and its capacity does not exceed the capacity provided for in thatoriginal design.2.For an automobile hoist, if it is certified that it meets current applicable standards.If no Pre-Start Health and Safety Review is required due to the above exemption, theowner, lessee or employer must keep documentation supporting the exemption. Thefollowing documents are acceptable in establishing such an exemption:1.Design drawings or a report containing the design loading capacity of the originalsupport structure for the lifting device or travelling crane. The design drawings orreport must bear the signature and seal of a professional engineer,or2.Certification from an accredited organization declaring that the automobile hoistmeets current applicable standards,and3.A notice in writing from the installer stating that the automobile hoist is installedin accordance with the manufacturer’s instructions.PSR Guidelines-16-April 30, 2001
What is a “process that involves a risk of ignition or explosion”?A process that involves a risk of ignition or explosion is a process that is likely toproduce a hazardous gas, vapour, dust or fume to such an extent as to be capable offorming an explosive mixture with air.Processes involving flammable liquids, flammable gases or combustible dusts arepotentially explosive processes.What is an “easily ignitable dust” in the text of section 65 of theRegulation for Industrial Establishments?Whether a dust would be classified as “easily ignitable” can normally be determinedby making reference to the Material Safety Data Sheet (MSDS) for the product.An easily ignitable dust also means a “combustible dust” as listed in Table 2-5 ofNational Fire Protection Association (NFPA) 499-97.If a dust is not listed in Table 2-5, classify it as a combustible dust if it has been groupclassified by the supplier as in the Ontario Electrical Safety Code or if tested forignition sensitivity and severity. Classification is not considered necessary for dustshaving an ignition sensitivity of less than 0.2 and an explosion severity of less than 0.5(ref. 3-6.2.5. and A-1-3 of NFPA 499-97).What must the Pre-Start Health and Safety Review report include?When a Pre-Start Health and Safety Review is carried out, a written report is requiredthat must contain the following:1.Details of measures that must be taken to bring the apparatus, structure,protective element or process into compliance with the specified provisions ofthe Regulation for Industrial Establishments listed in Table 1.Note: If the reviewer has used standards, specifications, calculations, riskanalyses or other parameters other than the requirements of the Regulation forIndustrial Establishments, he or she must list the details of all those referencesor parameters, upon which the Pre-Start Health and Safety Review is based.2.If testing is required before the apparatus, or structure can be operated or usedor before the process can be used, details of measures to protect the health andsafety of workers that are to be taken before testing is carried out.Note: For the purposes of this section, “testing” includes debugging,commissioning and similar operations prior to production.3.Details of the structural adequacy of the apparatus or structure if item 3 or 7 ofTable 1 applies.4.The date and signature of the person performing the Pre-Start Health andSafety Review (see subsection 7(13)).PSR Guidelines-17-April 30, 2001
5.If a professional engineer performed the Pre-Start Health and Safety Review,his or her seal.6.If the person performing the Pre-Start Health and Safety Review is not aprofessional engineer, details of his or her special expert knowledge orqualifications.Where do I keep the Pre-Start Health and Safety Review Report?Subsection 7(14) requires that the report:1.Be kept readily accessible in the workplace together with any supportingdocumentsand2.Be provided to the Joint Health and Safety Committee or Health and SafetyRepresentative, if any, before the apparatus, structure, protective element orprocess is operated or used.For example, if the paper copy of the report were located at head office in another city,and could not be sent by fax, there might not be compliance with this provision, sincethe report would not be readily available. However, if the report were availableelectronically at the workplace where the machine, equipment, device or process islocated, there would be compliance as long as it is accessible, and sealed whererequired.The Pre-Start Health and Safety Review report and supporting documentation shouldbe kept readily accessible in the workplace for as long as the apparatus, structure,protective element or process remains in the workplace.What do I do with the documentation est
3. The Pre-Start Health and Safety Review What is a Pre-Start Health and Safety Review? A Pre-Start Health and Safety Review includes a written report on the construction, addition or installation of a new 2 apparatus, structure, protective element or process3, or modifications to an existing apparatus, structure, protective element or process. The
