Robots and OSHA

In Will Smith’s hit movie, I, Robot set in 2035 robots were allegedly governed by the Three Laws of Robotics which were originally created by Isaac Asimov. The first law states, “[a] robot may not injure a human being or, through inaction, allow a human being to come to harm.” This law is not followed in the movie (or at least only a very strained interpretation of it) by certain robots and Will Smith needs to come to the rescue of humanity. 

Since we are still some years away from 2035 and perfect implementation of the first law of robotics, OSHA has made some materials available to assist employers in creating a safe work environment while using robotics in the workplace which can be accessed at https://www.osha.gov/SLTC/robotics/index.html.

Industrial robots are programmable multifunctional mechanical devices designed to move material, parts, tools, or specialized devices through variable programmed motions to perform a variety of tasks. OSHA’s compliance assistance is divided into four categories: (1) standards; (2) hazard recognition; (3) hazard evaluation and solutions; and (4) additional resources.

Although there are currently no specific OSHA standards for the robotic industry, OSHA identifies several standards that could apply including but not limited to: 1910.147 (control of hazardous energy); 1910 Subpart O (machinery and machine guarding); and 1910 Subpart S (electrical).

In addition to OSHA, other guidelines for robot safety include the American National Standards Institute (ANSI) ANSI-RIA R15.06-1986, “American National Standard for Industrial Robots and Robot Systems – Safety Requirements,” and the National Institute for Occupational Safety and Health (NIOSH) December, 1984 Alert “Request for Assistance in Preventing the Injury of Workers by Robots.”

Safety issues surrounding the use of robots is highlighted by the usual need to use a “corrective maintenance worker,” i.e., the individual normally present during all operations of a robotics system and who is responsible for the continuing operation, e.g., adjusting speeds, correcting grips, and freeing jam-ups. As such, it is often necessary for this employee to be in close proximity to the robot from time to time which may present certain safety concerns.

OSHA notes that according to certain studies, many robot accidents do not occur under normal operating conditions but rather during non-routine operating conditions such as programming, adjustment, testing, cleaning, inspection, and repair periods. OSHA provided the following examples of typical accidents including but not limited to:

  • Welding robot malfunctioned and its arm flung a worker against a machine
  • Worker removed the cover of an operating assembly robot to retrieve a fallen part and caught his hand in the robot’s drive train
  • Robot’s arm malfunctioned during programming and struck the operator
  • Co-worker accidentally tripped the power switch while a maintenance worker was servicing a robot and the robot’s arm struck the maintenance worker’s hand
  • Robot operator made a manual adjustment without stopping the robot and was hit in the head by one of the robot’s moving parts

OSHA cautions that the proper selection of an effective robotics safety system must be based on the hazard analysis of the operation of the specific robot. Factors that should be considered include the task a robot is programmed to perform, the start-up and the programming procedures, environmental conditions and the location of the robot, requirements for corrective tasks to sustain normal operations, human errors, and possible robot malfunctions. OSHA identifies a number of hazards sources including human error, control error, unauthorized access, mechanical hazards, environmental hazards, and electric, hydraulic, and pneumatic power sources.

There is little doubt that as technology continues to advance, businesses will likely continue to use robots in the workplace on an increasing level. Accordingly, it would be prudent to ensure robotics safety is part of a company’s overall safety and health program.

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