Robot End User's Responsibilities When It Comes To Robot Safety

When it comes to Robot Safety in the United States, organizations like the Robotic Industries Association (RIA) and Underwriters Laboratories (UL) have developed numerous standards around robots and robotic systems. Many of these standards focus on the manufacturers and the integrators to ensure that they are building safe robots and systems. The RIA does give guidance to end users which we will touch on in this article. However, it is really OSHA that will ultimately hold an end user of a robot responsible for its safe use. Unfortunately, if OSHA is there to hold the end user responsible, more than likely something very bad has already happened to have them pay the user a visit.

This means that it is in the best interest of end users of robots to follow best practices that ensure safe operations of their robots over the lifecycle of the unit and the application that is is being used for. By doing this, not only are they keeping their team members safe, but they are also making themselves active participates in the larger case that everyone from manufacturer to end user play an important role in safe robot-human interactions at all times.

Being An Active Participant In The Safety Process

ANSI/RIA R15.06 is a national adoption of two International Standards (ISO 10218-1:2011 and ISO 10218-2:2011). R15.06-2012 provides information for the safe design, manufacturing, installation, operation, maintenance and decommissioning of industrial robots and robot systems. It is directed to a variety of stakeholders including the manufacturer, integrator and supplier of robots and robot systems. These suppliers are required to produce machines (robots and robot systems) with the intent of providing the capabilities, functionality, and information needed for the user to safely use the robot systems. The standard addresses the entire supply chain of the robot systems, but does not include requirements or guidance to the user who is responsible for the safety of the robot system in use. It does not address compliance to national and local regulations. The user is responsible for identifying and complying with all local codes and regulations that apply to the robot system(s) being furnished. It is these codes and regulations where and how OSHA and state regulators will hold the end user responsible for the safe use of their robots and their systems.

A task-based risk assessment is the key element in robot application safety. Identifying, understanding and then mitigating the potential hazards workers are exposed to in a robotic setting are essential to providing the safest work place. Every robot application system is unique. Each individual system shall be assessed for hazards. The RIA R15.06 standard calls for a task-based risk assessment for each system. RIA TR R15.306 Task-based Risk Assessment Methodology provides a step-by-step process for conducting task-based risk assessments. The responsibility for conducting the risk assessment has been assigned to the integrator (party designing the system) because the integrator has the best knowledge of the machines that have been selected and their integration, and the potential hazards thereof. The user, however, has responsibility to provide key information about the intended use of the robot, its application, and the tasks necessary to be performed by the operators.

In 2019, the RIA published RIA TR R15.706 User Responsibilities to help address some of the gaps in R15.06 when it came to the role of end users in the overall safety process. When it came to the task-based risk assessment, R15.706 made the following recommendation:

The user is strongly encouraged to participate in the risk assessment process. The integrator is directed to invite this participation. The user should select risk assessment team members from stakeholder areas such as process engineers, tooling designers, environmental/health/safety (EHS), operations, operators, and maintenance. Such individuals each possess knowledge of different aspects of a system or process, and their inclusion can help to ensure a thorough analysis of risks and risk reduction measures. The risk assessment should be an iterative process beginning with initial system design and going through implementation, improving as the system design is solidified. The user may consult with a third party facilitator to review the risk assessment, and to lead future iterations of the risk assessment process. 

RIA 15.706 also made it clear that after the robot application was installed that it would be the responsibility of the end user to hold on to the risk assessment as a matter of record. The end user should consider it a living document that needed to be updated over the course of the robot application's life as parts of the robot and its supporting apparatus changed. Integrators come and go, but the user will always have the ultimate control over the robot application and its day-to-day safety to individual team members.

It should be stated that the risk assessment will probably be the first thing an OSHA Inspector will ask for upon arrival at the end user's facility. This may be for a scheduled visit or after an incident. So it is key that the end user not only has the risk assessment in their possession, but understands how it was produced and why certain safety features were installed on the application.

But Wait There's More....

There is much more to be discussed about end user responsibilities when it comes to robot safety. At this year's RIA International Robot Safety Conference, you can learn from numerous experts in the field of robot safety over three days (Oct. 6-8) completely from the comfort of your desktop. On Oct. 7th at 2:45 pm ET, I will be giving a presentation on end user responsibility where we will dive more into not only R15.706, but other resources that can help end users to be more engaged in the overall safety of their robots and applications. To see the whole agenda for the Conference, click here. There are going to be some amazing presentations that will show you the best practices in the industry around robot safety and how new technologies can assist you in protecting your team members in their interactions with your robot applications.

In closing, robot safety concerns and responsibilities do not end after a robot cell is installed. Safety is an ongoing process. Any change, even the smallest one, requires the end user to re-evaluate the overall safety of the robot and the application it is doing. That regulators are ultimately going to hold the end user responsible for any incident involving the robot, it is in the end user's interest to take a very active role in the safety process from selection of the robot, to its installation, to its uses. I look forward to "seeing" many of you online at the International Robot Safety Conference this year to talk more about the role of the end user when it comes to overall robot safety.