Pre- December 1997, Section 7 of The Regulation for Industrial Establishments required owners or lessees to submit plans and drawings for new, used or modified processes, systems, equipment or structure to the Ministry of Labour for review.  This was known as a Pre-Development Review (PDR) and was provided by a Ministry licensed professional engineer.

In December 1997 The Provincial Government transferred the PDR function to the private sector and amended Regulation 851 to require an employer to obtain an engineering review from a licensed professional engineer stating that the equipment, structure, device or process would comply with the Ontario Occupational Health and Safety Act (OHSA) and it’s regulations.

Effective, October 2000, Section 7 was once again amended to address the concern that the PDR requirements was too broad.  The new amendment, now called a Pre-Start Health and Safety Review (PSR), clarifies the requirements and focuses on specific, highly hazardous structures, processes and equipment.

A PSR is required to provide a professional review of high risk structure, equipment or process to insure hazards are removed or controlled before workers are exposed and to provide documented due diligence.

Section 7, Table 1 refers to clause 45 (b) of OHSA and states that when material, articles or things are stored on a structure that is a rack or stacking structure, will require a PSR or equivalent documentation from the manufacturer.

By Law, the employer or lessee is responsible to provide a safe work place and to insure that a professional has provided a PSR or equivalent documentation, showing the racking structure is in compliance with the relevant sections of OHSA Section 7.

Federal Law, Bill C45, in short says that an individual, in the undertaking to direct how another person does work (i.e.:  supervisor, manager, owner) contravenes his or her duty to take reasonable steps to prevent bodily harm, and show wanton or reckless disregard for the lives or safety of others may be charge with Criminal Negligence, i.e.:  if you are aware of any racking that is considered to be unsafe (does not meet the design  standards) and you do not have it inspected, repaired to the code of standards or replaced and someone is injured due to a rack failure, you will be charged with Criminal Negligence and most likely go to jail and have a criminal record along with a hefty fine.

A PSR is required whenever a new, used or modified structure, piece of equipment or process is constructed, added or installed into the workplace.  In the case of Steel Pallet Racking, if the racking is used, if existing racking has been disassembled and then reassembled, if beam heights have been changed or if the racking has been repaired, it will require a PSR.  An engineer or the manufacturer should be consulted for acceptable repair methods before any repairs are made.

A PSR is to be conducted by a Professional with expert knowledge of racking and an engineer (P. Eng.), who has received a Certificate of Authorization from the Professional Engineers Ontario organization (PEO) certifying that he/she is competent to perform such work for the public and that he/she has Personal Liability Insurance as required by the Professional Engineering Act.

A PSR report for steel pallet racking must be dated and signed by the reviewer and include details of the measures required to insure the racking is in compliance with the relevant provisions listed under Section 7 of OHSA.  A study of beam loading conditions is done and the maximum allowable beam and skid load is provided.  The loading conditions apply only to racking frames and beams that are compliant with the appropriate storage rack design and installation codes.  A professional engineer must affix his or her seal to the report.

PSR reports shall be kept readily accessible in the workplace together with any supporting documentation and be provided to the joint health and safety committee or health and safety representative before the apparatus, structure or process is put in use.

The PSR report and documentation may be reviewed, on request, a Ministry of Labour inspector or by the company’s joint health and safety committee or health and safety representative.

Damage to a rack frame or beam will reduce its load capacity.  The greater the damage,  the greater the reduction in the load carrying capacity.  Damage to the frame bracing will reduce the capacity of the frame to withstand accidental impact to the front post and will also reduce the axial load carrying capacity of the frame.  Damage to the beam/frame connection will reduce the load capacity of the beam.

There are two main Safety Codes that apply to the design, installation and maintenance of steel storage rack structures.

(a)  Rack Manufacturer’s Institute (RMI) – Specification for the design, testing and utilization of  industrial steel storage racks.
(b)  SEMA Code of Practice for the design of static racking

The RMI Code states that “Upon any visible damage, the pertinent portions of the rack shall be unloaded immediately by the user and the damaged portion shall be adequately repaired or replaced”.

The SEMA specification allows for measurable amount of damage and provides a method of measuring the damage.

For damage to frames and bracing members:

1. Any frame with a tear, split, buckle or bend should be replaced.
2. A frame with a bend in the direction of the rack beam should be measured using straight edge 1.0 meters long.  Placed against the concave edge, the gap between the edge and the rack at the bend should not exceed 5.00mm.
3. For a frame bent in the plane of the frame bracing the maximum gap between the frame and the straight edge should not exceed 3.00mm.
4. For a frame with damage in both directions deformation should be measured as above and the appropriate limits maintained.
5. For bracing members bent in either plane the gap between the straight edge and the member should not exceed 10mm.

If the damage exceeds any of these tolerances the damaged member should be replaced or repaired.  Any repairs to a rack frame must be done according to the manufacturer’s specifications or by a method approved by an engineer.

For damage to beams:

1. Beams showing signs of cracks in the welds between the end connector and the beam section should be replaced.
2. Beams with end connectors showing deformation should be unloaded and the supplier consulted.
3. Beams will naturally deflect under normal loading to a maximum vertical deformation not to exceed the measure of the beam length in inches divided by 180 (L”/180).  This deflection should disappear when the beam is unloaded.  With the load removed, the maximum vertical deformation should not exceed 20% of the normal deflection while under load.  The lateral deformation should not exceed 40 % of the normal vertical deflection under load.

If the damage exceeds any of these tolerances the damaged beam should be replaced.  Damaged beams should not be repaired.