I, COBOT

I, COBOT: The Rise of Industrial Robotics and the Need for Employee Safeguarding

In general, OSHA’s view on robot safety is that if the employer is meeting the requirements of ANSI/RIA R15.06, the manufacturer has no issues.

Tech executive and billionaire entrepreneur Elon Musk recently took to Twitter calling for the regulation of robots and Artificial Intelligence (AI), saying their potential, if left to develop unchecked, threatens human existence. Google, Facebook, Amazon, IBM, and Microsoft joined in with their own dire forecasts and have jointly set up the consortium “Partnership on AI to Benefit People and Society” to prevent a robotic future that looks not unlike the “Terminator” movie series. National media heightened panic by broadcasting a video released by a cybersecurity firm in which a hacked industrial robot suddenly begins laughing in an evil, maniacal way and uses a screwdriver to repeatedly stab a tomato. The video demonstrated how major security flaws make robots dangerous, if not deadly.

Is all this just media hyperbole, or are robots really that hazardous to our collective health? Are productivity-driven manufacturers unknowingly putting employees at risk by placing robots on the plant floor? What kind of safeguarding is required? Should robots be regulated, as Elon Musk believes?

‘Dumb’ Machines vs. Cobots
Until now, the robots used in manufacturing have mostly been “dumb” robots—that is, room-sized, programmed machinery engineered to perform repetitive tasks that are dirty, dangerous, or just plain dull. Typical applications would include welding, assembly, material handling, and packaging. Although these machines are very large and certainly have enough power to cause injuries, the instances of employees actually being injured by robots is relatively rare. In fact, during the past three decades, robots have accounted for only 33 workplace deaths and injuries in the United States, according to data from the Occupational Safety and Health Administration (OSHA).

So, you might ask, why the sudden uproar when there are already 1.6 million industrial robots in use worldwide? Most of the clamor behind calls for regulation stems from a new generation of robots called “cobots” (collaborative robots) that are revolutionizing the way people work. Unlike standard industrial robots, which generally work in cages, cobots have much more autonomy and freedom to move on their own, featuring near “human” capabilities and traits such as sensing, dexterity, memory, and trainability.

The trouble is, in order for cobots to work productively, they must escape from their cages and work side by side with people. This introduces the potential for far more injuries. In the past, most injuries or deaths happened when humans who were maintaining the robots made an error or violated the safety barriers, such as by entering a cage. Many safety experts fear that since the cage has been all but eliminated with cobots, employee injuries are certain to rise.

Because cobots work alongside people, their manufacturers have added basic safety protections in order to prevent accidents. For instance, some cobots feature sensors so that when a person is nearby, the cobot will slow down or stop whatever function it is performing. Others have a display screen that cues those who are nearby about what the cobot is focusing on and planning to do next. Are these an adequate substitute for proven safeguarding equipment? Only time will tell.

There is another, more perilous problem with robots in general: Robots are basically computers equipped with arms, legs, or wheels. As such, robots are susceptible to being hacked. But unlike with a desktop computer, when a robot is hacked it has the ability to move around. For instance, a disgruntled ex-employee could hack into a robot and re-program it to harm people and destroy property. The more functionality, intelligence, and power a robot has, the bigger its potential threat.

Types of Injuries
OSHA lists four types of accidents resulting from robot use in the Technical Manual “Industrial Robots and Robot System Safety” (Section IV: Chapter 4).
1. Impact or collision accidents. Unpredicted movements, component malfunctions, or unpredicted program changes related to the robot’s arm or peripheral equipment could result in contact accidents.
2. Crushing and trapping accidents. A worker’s limb or other body part can be trapped between a robot’s arm and other peripheral equipment, or the individual may be physically driven into and crushed by other peripheral equipment.
3. Mechanical part accidents. The breakdown of the robot’s drive components, tooling or end-effector, peripheral equipment, or its power source is a mechanical accident. The release of parts, failure of gripper mechanism, or the failure of end-effector power tools (e.g., grinding wheels, buffing wheels, deburring tools, power screwdrivers, and nut runners) are a few types of mechanical failures.
4. Other accidents. Other accidents can result from working with robots. Equipment that supplies robot power and control represents potential electrical and pressurized fluid hazards. Ruptured hydraulic lines could create dangerous high-pressure cutting streams or whipping hose hazards. Environmental accidents from arc flash, metal spatter, dust, electromagnetic, or radio-frequency interference also can occur. In addition, equipment and power cables on the floor present tripping hazards.

Robot Safety Regulations
Robots in the workplace are generally associated with machine tools or process equipment. Robots are machines, and as such, must be safeguarded in ways similar to those presented for any hazardous remotely controlled machine, falling under the OSHA General Duty Clause (5)(a)(1), which requires employers provide a safe and healthful workplace free from recognized hazards likely to cause death or serious physical harm. Also applicable are OSHA 1910.212 (a)(1) “Types of Guarding” and 1910.212 (a)(3)(ii) “The point of operation of machines whose operation exposes an employee to injury shall be guarded.”

Various techniques are available to prevent employee exposure to the hazards that can be imposed by robots. The most common technique is through the installation of perimeter guarding with interlocked gates. A critical parameter relates to the manner in which the interlocks function. Of major concern is whether the computer program, control circuit, or the primary power circuit is interrupted when an interlock is activated. The various industry standards should be investigated for guidance; however, it is generally accepted that the primary motor power to the robot should be interrupted by the interlock.

In general, OSHA’s view on robot safety is that if the employer is meeting the requirements of ANSI/RIA R15.06, Industrial Robots and Robot Systems—Safety Requirements, then the manufacturer has no issues. For guidance on how to select and integrate safeguarding into robot systems, refer to the Robotic Industries Association’s Technical Report: RIA TR R15.06-2014 for Industrial Robots and Robot Systems—Safety
Requirements and Safeguarding.

Published by the American National Standards Institute (ANSI) and Robotic Industries Association (RIA), ANSI/RIA R15.06 is a consensus standard to provide guidance on the proper use of the safety features embedded into robots, as well as how to safely integrate robots into factories and work areas. The latest revision of the standard, ANSI/RIA R15.06-2012, references for the first time ISO 10218-1 & 2 to make it compliant with international standards already in place in Europe. Part 1 of ISO 10218 details the robot itself; Part 2 addresses the responsibilities of the integrator.

There are also new requirements in ANSI/RIA R15.06-2012 for collaborative robots; in this case, ISO 10218 and the ISO/TS 15066 Technical Specification. This standard clarifies the four types of collaboration: Safety Monitored Stop, Hand Guiding, Speed & Separation Monitoring, and Power & Force Limiting. ISO/TS 15066 holds key information, including guidance on maximum allowable speeds and minimum protective distances, along with a formula for establishing the protective separation distance and data to verify threshold limit values for power and force limiting to prevent pain or discomfort on the part of the operator.

The requirement for risk assessments is one of the biggest changes in the new RIA standard. The integrator, or the end user if they are performing the job of an integrator, now must conduct a risk assessment of each robotic system and summarize ways to mitigate against these risks. This may involve procedures and training, incorporating required machine safeguarding, and basic safety management. Risk assessments calculate the potential severity of an injury, the operator’s exposure to the hazard, and the difficulty in avoiding the hazard to arrive at a specific risk level ranging from negligible to very high.

In the future, as cobot use rapidly expands throughout industry, regulation of this technology will grow more focused and specific. Consider this: Although cobots currently represent only 3 percent of all industrial robots sold, they are projected to account for 34 percent of the industrial robots sold by 2025, a market that itself is set to triple in size and dollar volume over that period.

Conclusion
The next 10 years will be pivotal for American manufacturing, and success largely depends on companies’ ability to navigate the transition from traditional manufacturing to Industry 4.0-style automation and the widespread use of robots. While few people have as dire a view as Elon Musk on the subject, it is critical that employee safety is not lost in the excitement as we shepherd robots out of their cages to work hand in hand with humans.

Lack of Machine Guarding Again Named to OSHA’S Top 10 Most Cited Violations List

Every year around this time, the awards season kicks off with the Emmys, Golden Globes and the grand daddy of them all, the Oscars, eagerly announcing their lists of nominations. At the same time — and on a far more somber note — another roll call is issued, this one from the Occupational Safety & Health Administration (OSHA). Unlike Hollywood’s awards celebrations, however, no one wants to be nominated for OSHA’s Top Ten Most Cited Violations list, let alone take home the top prize.

OSHA revealed its 2017 Top 10 list at the National Safety Congress & Expo in the Indiana Convention Center. The top ten are:

1. Fall Protection – (1926.501): 6,072 violations
2. Hazard Communication (1910.1200): 4,176 violations
3. Scaffolding (1926.451): 3,288 violations
4. Respiratory Protection (1910.134): 3,097 violations
5. Lockout/Tagout (1910.147): 2,877 violations
6. Ladders (1926.1053): 2,241 violations
7. Powered Industrial Trucks (1910.178): 2,162 violations
8. Machine Guarding (1910.212): 1,933 violations
9. Fall Protection – Training Requirements: 1,523 violations
10. Electrical – Wiring Methods (1910.305): 1,405 violations

While reviewing the list, it is important to remain aware that the Federal Occupational Safety & Health Administration (OSHA) is a small agency. When tallied up to include its state partners, OSHA only has 2,100 inspectors who responsible for the health and safety of 130 million American workers, employed at more than 8 million work sites. This translates to about one compliance officer for every 59,000 workers. As a result, some serious injuries are not reported and thousands of potential violations go without citation or fines. In fact, numerous studies have shown that government counts of occupational injury are underestimated by as much as 50 percent. Employers are required to record all injuries meeting the OSHA’s ‘recordable injury’ criteria (except minor first-aid cases) on the OSHA 300 Log, and those meeting the ‘reportable’ criteria (e.g., hospitalizations or deaths), are to be reported to OSHA immediately, or within 24 hours of occurrence, as per the criteria defined in 29 CFR 1904. But it doesn’t mean all of them do.

MACHINE (UN)SAFEGUARDING IN TOP 10 MOST CITED VIOLATIONS
The absence of required machine safeguarding remains a perennial member of OSHA’s Top 10 Most Cited Violations, and 2017 was no exception. It was named number eight on the list with a total of 1,933 violations. These violations refer to OSHA 1910.212 for failing to have machines and equipment adequately guarded. Any machine part, function, or process that might cause injury should be safeguarded. When the operation of a machine may result in a contact injury to the operator or others in the area, the hazard should be removed or controlled.

A lack of machine safeguarding also held the dubious distinction of making the list of OSHA’s ten largest monetary penalties for the year — not once but four times. In fact, the largest proposed monetary penalty, a staggering $2.6 million (USD), arose from an incident where a worker was crushed to death while clearing a sensor fault in a robotic conveyor belt. OSHA alleges that the company failed to use energy control procedures to prevent robotic machinery from starting during maintenance. The manufacturer also was cited for exposing employees to crushing and amputation hazards as a result of improper machine guarding, plus failing to provide safety locks to isolate hazardous energy.

Despite these headline fines, the repercussions for employers putting workers in harm’s way remain small under the 1970 Occupational Safety and Health Act. The average federal fine for a serious workplace safety violation was $2,402 in fiscal year 2016, according to the most recent report by the AFL-CIO. And the median penalty for killing a worker was $6,500.

According to the most recent Bureau of Labor Statistics data, manufacturing plants reported approximately 2,000 accidents that led to workers suffering crushed fingers or hands, or had a limb amputated in machine-related accidents. The rate of amputations in manufacturing was more than twice as much (1.7 per 10,000 full-time employees) as that of all private industry (0.7). The bulk of these accidents occurred while removing jammed objects from a machine, cleaning or repairing the machine, or performing basic maintenance. These injuries were all largely preventable by following basic machine safeguarding precautions. Rockford Systems is committed to helping organizations reduce injuries and fatalities due to a lack of or non-compliant machine safeguarding. By creating a culture of safety in the workplace, Rockford Systems can help plant managers significantly reduce the number of on-the-job injuries and fatalities that occur annually, plus guard against hefty fines, lost production and increased insurance premiums.

Which leads to the question… “Where do we begin?”

TRAINING AND EDUCATION

Ignorantia juris non excusat (“ignorance of the law excuses not”). Recognizing that education is key to safety, Rockford Systems has offered its Machine Safeguarding Seminars for more than two decades. Thousands of safety professionals have attended the seminars from industries as diverse as aerospace and metal fabrication, to government and insurance.

Held ten times a year at our Rockford, Illinois headquarters, the 2.5 day seminars address key topics in safeguarding with a focus on OSHA 29 CFR and ANSI B-11 standards as they relate to specific machine applications and production requirements. Safeguarding equipment, both old and new, is not only explained in depth in the classroom, but demonstrated under power on the shop floor. Most of these machines are equipped with more than one type of safeguarding product so that attendees can see how different guards and devices can be applied.

Roger Harrison, Director of Training for Rockford Systems and an industrial safeguarding expert with over 25,000 hours of training experience, conducts the Machine Safeguarding Seminar.

>Another valuable educational resource is OSHA-10 General Industry and OSHA-30 General Industry training courses, both of which cover machine guarding. All of our training can be provided at your site, if preferred. To learn more about the Rockford Systems training curriculum, please visit https://www.rockfordsystems.com/seminars/

Rockford Systems also provides a variety of FREE machine safeguarding resources for your organization. Please visit our RESOURCES page to find videos, blogs, quick reference sheets, and more or visit our YouTube channel to download past webinar recordings.

ASSESSMENTS
If your organization is interested in safeguarding solutions, consider a Machine Risk Assessment or Machine Safeguarding Assessment as the critical first step in any machine guarding process as outlined in ANSI B11. Most assessments, but not all, follow the basic steps outlined below.

Step 1 – Provide Machine List
To get started, please provide Rockford Systems a list of all machines (manufacturer, model number, and machine description of each machine) to be assessed. This machine list is needed to determine the estimated resource requirement for the onsite audit. Upon receipt of your machine list, an Assessment Proposal will be provided, generally within 24 hours of receipt. Please email your machine list and any machine photos (optional) to sheryl.broers@rockfordsystems.com.

Step 2 – Schedule Onsite Visit
During the assessment, a machine safeguarding specialist will visit your site and conduct a complete audit of all machines identified on the list and evaluate their compliance in five guarding areas (Safeguards, Controls, Disconnects, Starters, and Covers). The assessment is based on OSHA 1910.212 General Requirements (a)(1), ANSI B11 Safety Standards for Metalworking, ANSI/RIA R15.06-2012 Safety Standards for Industrial Robots, and NFPA 79. If Rockford Systems, LLC has additional specific safeguarding requirements above and beyond OSHA 1910.212 and ANSI B11, please provide them before the site visit and we will incorporate them into the assessment.

Also, during the assessment, we may request copies of electrical, pneumatic and/or hydraulic schematics and operator manuals for specific machines. This information is needed for our Engineering Department to review the control circuit for electrical compatibility of equipment being offered, to verify control reliability of the control circuit, to determine interfacing requirements of suggested equipment. If requested, this information would be needed before advancing to Step 3 below.

Step 3 – Receive Compliance Report and Safeguarding Project Proposal
Upon completion of the assessment, a Compliance Report and Safeguarding Project Proposal will be provided to that identifies where each machine is in, or not in, compliance with the above stated regulations and standards. Where not in compliance, we will suggest guarding solutions to bring the machines into compliance, along with associated costs and timeframes.

We look forward to assisting your organization with its safeguarding needs. A team member will call you within 24 hours to further discuss your needs and applications. We are here to help businesses large and small address machine safety challenges and to remove the burden of managing the growing legal complexity of OSHA, ANSI and NFPA requirements from simple turnkey solutions to build-to-spec customized solutions.

Please contact sheryl.broers@rockfordsystems.com or call 1-815-874-3648 (direct) to get started on an assessment today.

PRODUCTS
If you are looking for Machine Safeguarding Products, please visit our PRODUCTS page that offers over 10,000 safeguarding solutions for drill presses, grinders, lathes, milling machines, press brakes, power presses, radial arm drills, riveters and welders, robots, sanders, saws and more.

RETURN ON INVESTMENT
Not sure if the investment in machine safeguarding provides a return on the investment (ROI), it absolutely does and we can help you calculate it. Please read our detailed blog post on this topic.

For more information on how avoid machine injuries and fatalities, please visit www.rockfordsystems.com.