Emerging Robotic Systems Prompt OSHA to Reevaluate Lockout/Tagout Standard

March 28, 2023

The world of manufacturing is undergoing a seismic shift, and it’s all thanks to the emergence of increasingly advanced robotic systems.

These technological marvels have made the Occupational Safety and Health Administration’s (OSHA) standard for the Control of Hazardous Energy (Lockout/Tagout) impractical and even obsolete in many workplaces.

OSHA’s Lockout/Tagout Standard was proposed in September 1979 and finalized 10 years later, but since then, the proliferation of robotic systems has complicated the standard’s implementation.

It’s not hard to see why the standard needs a revamp. The latest robotic systems, particularly mobile robots and collaborative robots that work alongside human workers, can move independently and adapt to new circumstances and information in a workplace.

These machines “think” while they work, and shutting them down is a lot different and more complex than “locking out” a traditional, standalone piece of industrial equipment.

Unfortunately, enforcement of the Lockout/Tagout standard when applied to robotics can have serious consequences.

OSHA can penalize “Serious” violations up to $15,625 per infraction, and an even more significant threat lies in abatement requirements. If the agency requires a manufacturer to discontinue the use of its robotic systems, it could effectively debilitate operations.

But it’s not just about the penalties. Strict adherence to the standard could also introduce logistical problems, with some newer systems having such precise calibrations that de-energizing them could introduce inaccuracies that would render the system ineffective.

To deal with this, many robotic systems have been designed to undergo maintenance without de-energizing them, a potential violation of the standard.

In response to these challenges, OSHA has issued a Request for Information in 2019 seeking “information regarding two areas where modernizing the Lockout/Tagout standard might better promote worker safety without additional burdens to employers: control circuit type devices and robotics.”

The request is intended to help the agency determine the conditions under which control circuit type devices could safely be used for the control of hazardous energy.

This request is a potential precursor to an update of the standard to accommodate the use of the evolving technology of robotics, as well as the use of control-circuit type devices to isolate energy.

In the meantime, employers using robotic systems may need to continue to seek variances to ensure the agency deems their processes safe and compliant. It’s a challenging time for manufacturers, but it’s also an exciting one, as they have the opportunity to be at the forefront of the next industrial revolution.

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