OSHA Updates the Safety Guidance for Industrial Robots

The Occupational Safety and Health Administration (OSHA) — in collaboration with The National Institute for Occupational Safety and Health (NIOSH) and the Association for Advancing Automation (A3) —recently updated its safety guidance for Industrial Robot Systems.

The updated guidance explores the hazards associated with robotic systems and represents the latest thinking about the robot-human interface in industrial settings. The publication provides designers, implementation professionals, and employers with a new resource for ensuring safety during each step of the development and implementation process.

Industrial robots

The World Robotics 2021 Industrial Robot report estimates that over 310,000 industrial robot systems currently operate in factories throughout the United States. As robotic systems become more collaborative and mobile, their industrial use is increasing — enhancing workforce capabilities and introducing new hazards.

While most industrial robots include safety features that reduce the risk of injury — sensors and other electronic devices that detect and respond to environmental signals — fatal injuries resulting from human-robot interaction have occurred. NIOSH research identified 61 robot-related deaths between 1992 and 2015, and researchers believe this number will go up as the use of robots in industrial settings increases.

Robots are now being designed, manufactured, and implemented to perform a range of hazardous and repetitive tasks and work round the clock, without breaks, in harsh environments. The rise of cobots — dexterous collaborative machines designed to work alongside humans and perform tasks such as welding, painting, inspection, die casting, drilling, grinding, and glass-making — fundamentally change how things get made and work gets done. Rapidly evolving robotic technology — along with powered exoskeleton development and autonomous vehicles — is transforming a range of businesses, including the automotive, aerospace, medical, military, pharmaceutical, plastics, and wood processing industries.

Not a rule

Section IV: Chapter 4 of the OSHA Technical Manual is not a rule. Entitled “Industrial Robot Systems and Industrial Robot System Safety,” the publication is intended to be an educational tool for OSHA staff about emerging robotic technology and related safety issues, as well as a guide for employers to use when integrating robotic systems into the workplace.

OSHA may also use this publication as the basis for a possible citation under rule 1910.147 (the control of hazardous energy) or 1910 Subpart O (machine guarding), as well as the General Duty Clause.

What is safe?

OSHA’s traditional “hierarchy of controls“ to address workplace hazards — elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE) — isn’t appropriate for robotics. Instead, OSHA articulates a three-factor approach to safety that places responsibility on the robot designer/manufacturer, the system integrator, and the employer.

Design and Manufacture: The inherently safe design includes limiting human interaction and eliminating (or substituting) hazards.

System Integration: Safety-related parts of the control system (SRP/CS) review and other preventative systems — like emergency stop functions and devices; guardrails, platforms, other fall protection safeguards; escape and rescue planning; and energy dissipation and isolation protocols.

End-User/Employer: Information and training that includes hazard awareness, administrative controls, and PPE equipment when necessary.

The industry consensus safety standard for robots is Part-1 and Part-2 of the American National Standards Institute (ANSI)/Robotic Industries Association (RIA) ANSI/RIA R15.06-2012, Industrial Robots and Robot Systems – Safety Considerations.

The standard specifies basic requirements and guidelines for the “inherent safe design, protective measures, and information for the use of industrial robots.” The publication also describes the hazards associated with robots and provides recommendations for eliminating or reducing the risks associated with those hazards.

The employer’s responsibilities

Besides ensuring that the system integrator has implemented a safe robotic system, the employer is responsible for training, testing, and maintenance. Users must have a general knowledge of all robotic systems in the facility and the regulations and industry standards that apply to those systems.

The employer must also ensure that system integration includes site acceptance testing (SAT). This process confirms that the robotic equipment is doing what it is supposed to do and performs as expected, considering the site’s machine interfaces, environmental characteristics, and utilities.

Employers integrating any robotic system should maintain records of all testing performed and track robotic system safety over time. These records become valuable during any future safety inspection.

If you have any questions or concerns about OSHA compliance and workplace safety — or have received a citation for any reason – don’t hesitate to contact Orr & Reno for assistance.

About the Author: James Laboe

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