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Robot lockout/tagout and teach mode safety: OSHA rules and guidance

Servicing a robot and programming it with a teach pendant are two of the riskiest moments for workers. This page explains what OSHA's lockout/tagout standard requires and what the OSHA Technical Manual recommends for teach mode.

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Answers are written by a language model solely from this base's documents, with numbered sources. They can be wrong and aren't legal, medical or financial advice: check the sources before any important decision.

When lockout/tagout applies to robots

29 CFR 1910.147 covers servicing and maintenance where unexpected energization, start-up or release of stored energy could injure workers. Normal production operations are not covered. Servicing or maintenance during normal production is covered only when a worker must remove or bypass a guard or safety device, or place part of their body in the point of operation or an associated danger zone.

Minor tool changes, adjustments and other minor servicing during normal production are excluded if they are routine, repetitive and integral to production, and if alternative measures provide effective protection.

The employer's energy control program

Employers must set up a program of energy control procedures, employee training and periodic inspections. If an energy isolating device can be locked out, lockout must be used, unless the employer can show that tagout gives full employee protection.

Procedures must include steps for placing, removing and transferring lockout or tagout devices, and for testing the machine to verify the measures work. The procedures must be inspected at least annually.

Teach mode and enabling devices

Robots are often programmed with a teach pendant in manual mode, sometimes called T1 mode, with the programmer possibly inside the restricted space. The OSHA Technical Manual states that robot speed during teaching should not exceed 10 inches (250 mm) per second.

The enabling device is typically a 3-position device: the worker must hold it in the center-ON position or the robot's motion is inhibited. If it is interconnected with other equipment in the cell, that equipment is inhibited too.

Frequently asked questions

Is there a specific OSHA standard for industrial robots?

No. OSHA states that there are currently no specific OSHA standards for the robotics industry. It points instead to general industry standards, including machine guarding in Subpart O and lockout/tagout in 1910.147.

What are common causes of robot accidents according to OSHA?

The OSHA Technical Manual lists human errors of integration or programming, control errors, unauthorized access, mechanical failures and environmental sources. It notes that the most common problem is over-familiarity with the application, which leads workers to put themselves in hazardous positions.

What happens when a worker enters a guarded robot area during automatic operation?

In most cases, the robot application automatically reaches a safe state when a worker enters the safeguarded space. Separation in automatic mode relies on guards, interlocked guards and presence-sensing devices.

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