DSS237: Robotics Standards for Safety and Compliance with Adam Haroz

In today’s episode of the Dust Safety Science podcast, we’re discussing the robotics standards for safety and compliance with Adam Haroz, Director of Engineering at Conversion Technology Inc., based out of Norcross, Georgia.

Although this episode slightly diverges from our usual focus on combustible dust, it addresses a topic of equal importance and relevance. In today’s context, many sites dealing with combustible dust are also witnessing a growing implementation of robotics and automated equipment. Adam, who is actively engaged in the standards development process for robotic standards, plays a significant role in this evolving landscape.

“My role in the industry is a little all over the place. So I’m a voting member of the R1506 Standard, which is the overarching standard on robotics safety, as well as the R1508 Standard Committee – which is the standard on mobile robotics,” Adam says.

Adam is also a member of A3, also known as the Association for Advancing Automation. Specifically, he serves on the R1506 Committee, which collaborates with OSHA, NIOSH, and representatives from A3. Their main objective is to combine industry expertise, standards, safety regulations, and data to enhance safety in the robotics industry and across different facilities.

Within this alliance group, Adam has been actively contributing to updating OSHA’s Technical Manual Chapter related to robotics. Additionally, he took the lead in developing training materials for OSHA, aiming to equip their personnel with a comprehensive understanding of robotics. This training covers aspects such as robot functionalities, movement patterns, and essential points to consider during on-site inspections.

Robotics and Compliance: a Summary

R1506, also known as ANSI R1506, is an adoption of the international standard ISO 10218, specifically tailored for the United States. When the International Standards Committee revises the ISO 10218 Standard, the R1506 Committee adopts these changes for the U.S. market, with some adjustments to ensure compatibility with U.S. practices. The revised 10218 Standard is expected to be ready by 2024, and the corresponding R1506 Standard is scheduled for publication in the following year.

The R1506 Standard consists of several parts. Part one caters to manufacturers or OEMs, while part two focuses on integrators responsible for system design, installation, and implementation at facilities. In addition, the committee is introducing Part three, which will outline end-user requirements.

As for R1508, it is in a more advanced stage compared to R1506 and doesn’t directly align with ISO standards. Currently, part one of R1508 is under review or balloting, while part two is undergoing its final revision. The subsequent release of part three is expected to follow shortly after. These standards are on track for publication, and R508 might potentially be released by the end of this year, while both standards are likely to be fully published by 2024.

Does OSHA Have a Standard on Robotics?

Adam explained that OSHA lacks specific regulations dedicated solely to robotics; instead, they often combine various electrical, fire, and slip-trip-fall regulations. However, the updated OSHA Technical Manual (OTM) serves as a valuable guidance document in the absence of dedicated regulations. Though not a standard or regulation, OSHA’s training efforts equip them with necessary knowledge.

Exosuits or exoskeletons are emerging technologies, sparking discussions within the standards community about their classification and inclusion. ASTM’s standard ASTM F48 is one such effort to address these concerns. Typically, industry adoption of technologies drives the development of corresponding standards, often with a lag of a few years, unlike combustible dust standards that may take a decade to evolve.

Over the years, compliance in the robotics field has shown an encouraging increase. Manufacturers, as well as OEMs (Original Equipment Manufacturers), actively contribute to compliance efforts, driving innovations in technology and safety requirements. They are particularly leading the way in sensor technologies, essential for functional safety, and in advancing vision technologies, enabling sophisticated system perception capabilities.

Integrators, responsible for designing, installing, and implementing automated systems, have also shown more interest in ensuring safe designs and adherence to standards. Many integrators seek consultation to ensure they meet the requirements of part two of R1506, striving to deliver the safest systems to their customers.

On the end-users’ side, the facilities implementing these robotics technologies, there has been a consistent interest in safety and compliance. Challenges arise for both end-users and integrators, influencing each other in the pursuit of safety and compliance goals, but overall, the robotics industry demonstrates a significant push towards prioritizing safety and compliance, fostering a positive trend in the field.

Is There a Single Standard for Robotics?

“There isn’t a single standard when it comes to robotics and systems. In fact, there’s an extensive array of standards to consider,” says Adam. “For instance, there’s the R1506 standard, specific to the U.S., while Canada has its own set of standards called the CSA standards.”

Different countries also have their unique standards. In the U.S., there is an overarching standard, along with a separate one that focuses solely on validating safety functions. Moreover, there are standards related to PLCs (Programmable Logic Controllers) and relays, as well as specific standards concerning certain end effectors.

“It’s quite intricate, resembling a web of interrelated standards,” Adam says.

What Hazards Are Involved With Robotics?

During my DHA (Design Hazard Analysis) walkthrough at a food plant, Adam came across massive robots involved in the packaging process, capable of lifting substantial weights, even entire pallets if programmed accordingly. It was evident that if these robots were to collide with a person, the impact could be deadly, making it a significant hazard.

Another hazard to consider is the possibility of a person getting pinned by the robot within its enclosed cell. If someone gains access to the area where the robot operates, they could be trapped against the perimeter fence or other equipment, leading to severe consequences.

The risk assessment extends to various scenarios, including maintenance and cleaning tasks within the cell, where slip-trip-fall incidents might occur. Adam is currently assessing a smaller system where the end effector or gripper responsible for maneuvering the work could face emergency conditions, such as a sudden loss of air pressure. This situation could lead to the unexpected release of a 400-pound table being handled.

“These are just some of the major hazards I closely examine during my assessments,” Adam explains. “The goal is to identify potential dangers and implement necessary safety measures to safeguard against any unfortunate incidents.”

What Are the Current Challenges?

Challenges arise when keeping up with advancing technology, as updating existing standards takes years while new innovations emerge rapidly. In the industrial domain, manufacturers of robots and systems wield significant influence over the standards. Nevertheless, consultants representing facilities on the standards committee acknowledge that manufacturers generally demonstrate a good understanding of safety needs.

However, one of the major challenges stems from a lack of understanding, although it is gradually improving. For example, Adam recalled an ongoing risk assessment involving a collaborative robot or “cobot.” Many mistakenly assume that cobots are inherently safe straight out of the box due to marketing claims. In reality, there is no true “collaborative robot”; instead, it refers to a robot working in a collaborative application.

Adam frequently reminds people that even these apparently safe cobots require a risk assessment. Appropriate safeguarding measures need to be implemented since cobots are designed to stop if they collide with a person. Nonetheless, the goal is to prevent such incidents entirely, aligning with OSHA’s perspective.

Over the past four to five years since cobots entered the market, this challenge has persisted. The term “cobot” itself is a marketing invention from several years ago. In practice, any robot can be utilized in a collaborative application, but specific standards outline the layout and requirements for such applications. These applications involve a robot operating alongside a person within the cell, with considerations such as lower payload and reduced speed. It’s possible to apply collaborative principles even to large car-moving robots, although the complexity increases with their size.

As a mechanical engineer with a passion for machine guarding, Adam emphasizes the significance of different technologies, such as area scanners, in addition to traditional fences. Area scanners operate similarly to light curtains but shine a two-dimensional plane over a designated angle, typically covering around 200 degrees. This allows for precise control in a collaborative setting, where the robot can slow down or stop when a person enters specific zones within the 2D field.

One important aspect Adam addresses, particularly concerning maintenance operations, is the requirement for a three-position enabling device or dead man switch in the presence of people within the robot’s reach during manual operation. This switch must be held by each person, and if released or held too tightly, it triggers the system to stop. Adam finds that this is an area where improvement is needed, and he often advises maintenance teams to ensure compliance with this safety requirement during their maintenance tasks. The goal is to make the collaborative systems as safe as possible, even during manual operation, considering the necessary power requirements for actuation.

User vs. Integrator Standards

There are distinct standards for integrators and users of robotic systems, and a notable challenge arises when determining the point at which a user might transition into the role of an integrator, thereby needing to comply with the integrator part of the standard.

Adam provided an example. “Suppose a user has a robot operating efficiently in their packaging line, but then they need to introduce a new product, requiring modifications to the end effector. In this case, the user’s maintenance team or a fabrication shop might undertake the task of creating a new end effector with different specifications or actuation methods, such as transitioning from a gripper to a vacuum-style tool.”

When the user proceeds to adjust the robot’s program to accommodate the changes in the end effector, they technically become the integrator of their own system. Consequently, they must now adhere to the requirements outlined in part two of the standard, which tend to be more rigorous than those in part three. The assumption that once the integrators have installed the system, the user can make any alterations without consequences is incorrect. After becoming the integrator, the user must comply with part two of the standard.

Moreover, similar to conducting a DHA (Design Hazard Analysis) and adhering to management of change requirements, the user-turned-integrator must update their risk assessment to account for the potentially altered reach of the robot. This entails ensuring that the fencing and other safety measures align with the new reach, as the standard contains specific requirements regarding distances and safety considerations. Such adjustments are vital to maintaining a safe and compliant robotic system.

How Well Do Users Understand Robotics Standards?

“Unfortunately, I don’t think that the critical standards knowledge is where it is on the robot side as much as it is on the combustible dust side,” Adam admits. “When I’m walking through a facility for a DHA, people are pretty aware of what the 652 requirements are. If I’m at a food plant, obviously 61 comes into play, but maybe it’s similar to how people’s potential understanding of 68 and 69 for NFPA are. But with our 1506 mostly, I think people read it and know it’s very complicated because it is. And that’s kind of the way it is.”

In discussing consensus standards, Adam notes that the ANSI Standard serves as the national consensus standard, while OSHA lacks specific regulations for robotics. This absence of a regulation poses a challenge as it might hinder awareness and understanding of the applicable standards among users and facilities. While most people at a facility, particularly in EHS (Environment, Health, and Safety), are familiar with OSHA’s general industry regulation, many may not be well-versed in R1506, its parts, or other related standards for collaborative systems.

As a third-party consultant and a committee member, Adam often assists others in understanding the standards. He emphasizes that even in the absence of a specific OSHA regulation, the agency is gradually learning to evaluate robot systems. While incident reports related to robotics are available, they aren’t as effectively tracked by the Department of Labor, limiting OSHA’s ability to fully comprehend the extent of robot-related incidents.

Adam predicts that OSHA may move towards citing facilities for lacking risk assessments, similar to how they cite for incomplete DHAs (Design Hazard Analysis). OSHA’s regulations require adherence to national consensus standards relevant to the industry, which allows them to enforce compliance using the general duty clause, known as 5A1.

Robotic systems, compared to other industries, have unique complexities due to factors like automation, extensive programming, and diverse international components. This complexity often raises questions about responsibility and compliance with specific standards, depending on the system’s design and components.

Adam noted that while standards like NFPA 652, 61, and R1506 require risk assessments, they may have slightly different parameters. However, the overall goal remains to evaluate and mitigate risk effectively. He typically collaborates with operators and maintenance personnel when conducting risk assessments, as they possess valuable insights into the equipment’s operation and potential hazards.

While the standards for robotics and combustible materials differ significantly, Adam finds some similarities, such as the importance of risk assessment in both cases. Despite the differences in hazards, the use of ANSI B11 standard for risk evaluation is applicable to both types of systems. In summary, Adam recognizes that robotic systems present unique challenges and opportunities for enhancing safety, and his work involves educating and collaborating with various stakeholders to achieve compliance and minimize risks effectively.

Conclusion

“I always emphasize to people that ignorance is not bliss, especially when it comes to safety,” Adam says. “Doing a risk assessment is crucial, and not knowing you need one doesn’t exempt you from doing it. In every risk assessment I conduct, I make it a point to recommend training for all employees, including operators and maintenance staff who work with the robots. Many employees are curious and want to witness the installation of new robots in their facility. By providing comprehensive training on robot functions, safety issues, and hazards, along with the measures taken to protect them, we can mitigate risks because untrained and unqualified individuals pose significant dangers…. This approach ensures that safety considerations are integrated from the earliest stages of the project, resulting in a safer and more compliant robotic system.”

If you would like to discuss further, leave your thoughts in the comments section below. You can also reach Adam Haroz directly:

Website: https://www.conversiontechnology.com/
LinkedIn: https://www.linkedin.com/in/adam-haroz-eit-1a902727/
Email: [email protected]

If you have questions about the contents of this or any other podcast episode, you can go to our ‘Questions from the Community’ page and submit a text message or video recording. We will then bring someone on to answer these questions in a future episode.