Are You at Risk of OSHA Citations for Robot Safety?
Robots have been a part of the industrial landscape for decades. As the world of industrial automation progresses, the number of employees and robots working in close quarters with each other continues to grow. With the increase in automation and the use of mobile and industrial robots, regulations are being updated to address the potential hazards posed by the changes in equipment and routine and non-routine tasks around robots in the workplace. The Occupational Safety and Health Administration (OSHA) is training their inspectors to be aware of these regulatory changes and become familiar with industrial robot use. Not being aware of your facility’s requirements or of the changes in robot regulations could cost you.
Recently, CTI attended the annual International Robotics Safety Conference, hosted by the Robotics Industries Association (RIA). At the conference, we spoke with representatives from OSHA, who explained the plans and actions put in place to train inspectors to better identify the hazards around industrial robots, as well as a plan to work on updating regulations to better protect employees from these identified hazards.
Robots are machines, and as such must be safeguarded in ways like those presented for any hazardous remotely controlled machine. As with any other machine, there are countless hazards that could be present in and around a robot system. These hazards could vary depending on the design of the robot cell, placement inside the facility, level of interaction with employees, program or software being run, or end effector being used. Some common hazards are slip, trip, and fall inside the cell, contact with moving parts, dropped parts or end effectors, being pinned by the robot arm, etc. These hazards could be magnified while in Teach mode, unless mechanical and engineering safeguards are in place. The most effective way of identifying hazards is by conducting a comprehensive risk assessment before the system is operational, and after all parts, guards, and work practices are in place.
ARE THERE ANY REGULATIONS FOR ROBOTS?
While there is currently no OSHA standard specifically covering industrial robots, there are several consensus standards, that OSHA refers to, covering safeguarding performance criteria, risk assessment methodologies, and general safety requirements. Consensus standards are voluntary standards developed through the cooperation of multiple parties, typically governing agencies and industry groups, who have an interest in participating in the development and/or use of the standards. OSHA commonly refers to consensus standards when there is no specific regulation covering the topic (e.g. NFPA standards on combustible dust). OSHA is very aware that they do not know everything about every subject for every industry. RIA and the American National Standards Institute (ANSI) have put together the current robot safety standards and have partnered with the National Institute for Occupational Safety and Health (NIOSH) to further promote and update regulations on the topics related to robot safety.
If OSHA were to arrive at your facility and inspect a robot or robot system, the first thing the inspector would ask for is a copy of the last risk assessment conducted on the system. If a risk assessment has not been conducted on the system, they could push for a willful violation, as the risk assessment is required by law. Despite no standard in 29 CFR 1910 governing industrial robots, violations and citations can and have been issued on robot system. The primary regulations to be cited for violations with a robot system are Lockout/Tagout and the Control of Hazardous Energy (1910.147), Machine Safeguarding (1910.212), and the General Duty Clause (Section 5(a)(1)). OSHA does also regularly contact original equipment manufacturers (OEMs) and robot system integrators to determine the level of safety provided at installation of the equipment as compared to the hazards present at the time of the inspection or injury. As is the way of industrial safety, the employer is the party with the legal responsibility to recognize and mitigate hazards in the workplace.
HOW DOES OSHA SEE ROBOT SAFETY?
OSHA’s view on robot safety is that if the employer is meeting the requirements of the consensus standards, specifically ANSI/RIA R15.06 – Safety Requirements for Robots and Robot Systems, then there will not be any issues. However, one of the primary findings from inspections is that, while machine safeguarding and the control of hazardous energy are typically front of mind for employers, comprehensive risk assessments are not being conducted or revised after the installation of new equipment. A risk assessment is required by R15.06 and specified further in ANSI/RIA B11.0 – Safety of Machinery – General Requirements and Risk Assessment. Some facilities have them done by the robot integrators and installers, but fail to conduct them after changes to equipment, policies or procedures, or tooling and layout specifications.
Many robot accidents and violations do not usually occur during normal operation and practices. These incidents typically occur during non-routine operating conditions (e.g. programming, maintenance, setup, part/tool changes, and while in Teach mode). It is imperative to select an effective safety system for your robots that is based on all jobs and tasks conducted by the robot and within the robot system. This can be done through safety controls, limiting boundaries, safeguards, etc. Through a comprehensive risk assessment all tasks and corresponding hazards can be identified, hazard ratings applied, and corrective actions can be determined and prioritized.
HOW TO ENSURE COMPLIANCE
CTI has years of experience conducting both qualitative and quantitative risk assessments on robots and robot systems. CTI is also a member of the R15.06 rule making committee and is in contact with OSHA representative on how the updating of rules and regulations impact employers and industry sectors. Contact CTI for more information on risk assessments and how to ensure your facility’s industrial robots and robot systems are in compliance with all governing standards and regulations.