FAQ

  1. How does CEI help clients achieve the ability to demonstrate due diligence?

    It is a 5-step process.
    1. IDENTIFY the regulations, standards, codes, etc. that apply to a particular industry.
    2. EXAMINE the operations to assess the general level of compliance.
    3. COMPARE the operations to the standard using a checklist.
    4. PLAN a schedule for compliance.
    5. MONITOR progress according to established milestones.

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  2. How does CEI help clients mitigate liability?

    Liability results from failure to recognize potential risks and take preventive action.

    Those who spend 5 days a week working in their familiar industrial environment may become complacent and/or lose objectivity when it comes to recognizing hazards. They are, however, very capable of recognition when they are given the opportunity of seeing their environment through an outsider’s eyes.

    CEI offers a diverse and very experienced set of eyes to stimulate that recognition as well as provide insight to the problems that may not be recognized by the workers.

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  3. What aspects of environmental compliance does CEI offer?

    In addition to the concerns involving occupational exposure to chemical and biological agents, we conduct Designated Substance Assessments, prepare applications for Environmental Compliance Approval for air emissions as well as annual reports for National Pollutants Release Inventories and Mandatory Air Emissions.

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  4. What is HEMS?

    HEMS is the acronym for Hazardous Energy Management System. CEI developed this program approximately 30 months in advance of the new CSA Z460 standard for Lockout/Tagout. It was developed in concert with the City of Orillia Environmental Services and implemented throughout their Water Filtration and Waste Water Treatment Facilities.

    The program provides an instant customized procedure for the client and placarded Lockout/Tagout procedures for all unique pieces of equipment in the client’’ facility.

    System training is included for all workers required to use the system

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  5. What is a WSIB pre-audit?

    Companies who become targeted by WSIB for an audit usually only have about 30 days to prepare. If they have not been preparing for such an event, it can be very disruptive to the production process while the focus is on assembling documentation and writing procedures and processes. If compliance is not achieved in the required timeframe, the fines can be quite high.

    The pre-audit is an inexpensive way to proactively determine the likelihood of passing an audit and finding out where to focus energies with the biggest return and the least effort.

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  6. When is a Pre-Start Health & Safety Review required?

    Pre-Start Health & Safety Reviews are required any time equipment (new or used) or processes are installed or modified.

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  7. Do I need a PSR if I'm just moving an existing piece of equipment without making any changes to it?

    Yes. The change of location is considered a modification and triggers a complete review of the operation or process.

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  8. Can I ask my machine suppliers to provide their equipment with a report saying that the equipment complies with the requirements of a Pre-Start Health & Safety Review?

    A report from the supplier can only state that the machine or apparatus meets all current applicable safety standards but the report only applies to the machine and does not provide any liability protection for hazards that may relate to specific circumstances resulting from its installation and/or operation in your facility.

    A supplier report is not necessarily a complete PSR.

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  9. What is a protective element?

    A protective element is either
    1. a device which signals the apparatus to stop, or
    2. a barrier guard that uses mechanical or electrical safeguarding interlocks

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  10. Do I still need a PSR if the equipment or machine doesn’t have any protective elements?

    Only if the following documentation is available to provide exemption:
    1. The manufacturer provides a document stating that the machine or apparatus meets all current applicable safety standards and identifies what they are.
    2. The installer provides a document stating that the machine or apparatus is installed in accordance with all current applicable safety standards and identifies what they are.

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  11. What if the manufacturer or installers are not willing to provide this documentation?

    Then a Risk Assessment (RA) must be performed to identify and mitigate all risks associated with the tasks performed by the machine and the operator(s). If the RA results in protective elements being required as part of the mitigation techniques, then the PSR is triggered.

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  12. How does one conduct a Risk Assessment?

    The process is outlined in CSA Z432-04, Section 5. It is a group discussion involving at least the following personnel:
    1. Operator(s)
    2. Supervisor and/or manager
    3. JHSC representative(s)
    4. Maintenance and/or engineering rep. with technical knowledge of the equipment
    It is recommended that the reviewing engineer be the facilitator for this process.

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  13. What does the PSR involve if a protective element is required?

    The reviewing engineer is required to identify the appropriate type of protective element and ensure that it is properly installed. This may involve stop-time testing and/or safe-distance calculations.

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  14. What are the 8 circumstances that trigger a PSR?

    Circumstance 1 triggers a PSR if flammable liquids are stored and/or dispensed as part of the installation or modification.

    Circumstance 2 triggers a PSR if machine safeguarding is involved but only if protective elements are installed on the machine.

    Circumstance 3 triggers a PSR if storage racks or stacking structures are involved and engineering documents are not provided from the manufacturer stating that they were manufactured in accordance with the Racking Manufacturers Institute standard.

    Circumstance 4 triggers a PSR if a process involves risk of ignition or explosion. Exemption is only available for spray booths if they are made and installed in accordance with current applicable standards. A report from the manufacturer and installer is required for verification.

    Circumstance 5 triggers a PSR if a dust collector is involved with the collection of an “easily ignitable dust” such as aluminum powder or sawdust or other such substances.

    Circumstance 6 triggers a PSR if the process involves the production and handling of molten steel or aluminum.

    Circumstance 7 triggers a PSR if a lifting device is involved (cranes, lift truck attachments, etc.) and is primarily concerned with the adequacy of the supporting structure(s), for example the building or the floor or the lift truck.. Engineering reports are again required.

    Circumstance 8 is triggered if the process involves chemicals which contain substances listed in Ont.Reg. 833 or any of the 11 Designated Substance Regulations.

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  15. Why were these 8 specific circumstances targeted?

    At the time of the regulation, these circumstances were triggering a significant number of serious injuries and warranted specific attention.

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