When something goes wrong in a robot cell, the first question is always the same: whose fault is it? The integrator who built it? The manufacturer who made the robot? The plant that has run it for six years? The honest answer is that safety responsibility is not a single owner. It is a chain of duties that passes from the robot maker to the integrator to the end user, and the most dangerous gaps in West Michigan plants are the handoffs where one party assumed the next one had it covered.
The 2025 revision of the US robot safety standard finally makes that chain explicit. This is the engineer's guide to who owns what, what changed in 2025, and where the handoffs fail on real cells.
For nearly 15 years the governing US standard was ANSI/RIA R15.06-2012. In 2025 it was replaced by ANSI/A3 R15.06-2025, adopted from the newly published ISO 10218-1:2025 and ISO 10218-2:2025. The revision did more than update the text. It reorganized the standard around who is responsible, and added a section that never existed before.
That Part 3 is the important addition. Older versions of R15.06 defined the robot and the integration in detail but said comparatively little about the operating employer's ongoing duties after commissioning. In practice, that is exactly where most West Michigan compliance gaps live, and where OSHA citations land. For a fuller breakdown of how R15.06, ISO 10218, and OSHA 1910.147 interlock on a cell, see our companion piece on aligning the three governing standards.
The chain starts with the robot maker. Under Part 1, the manufacturer is responsible for the safety of the robot as a product: safety-rated stop functions, safety-rated monitored speed, position and axis limiting, and the integrity of the robot controller's safety functions. When you buy a current FANUC, ABB, KUKA, Yaskawa, or Universal Robots arm, it arrives certified to these requirements.
What the manufacturer is not responsible for is your application. A robot is a component, not a machine. It cannot be safe or unsafe until someone puts it in a cell, gives it a tool, surrounds it with guarding, and points it at a task. That is the integrator's job, and it is where the manufacturer's responsibility ends and the next link begins. The one thing the end user owes here is verification: confirm the robot you purchased actually meets the current revision, and keep the declaration of conformity on file.
The integrator turns a robot into a safe machine. Under Part 2, the integrator owns the engineering that makes a cell safe, and the documentation that proves it.
Here is the critical point most facilities miss: the integrator produces this documentation, but the end user has to receive it and keep it. A risk assessment that stays in the integrator's files does the operating plant no good during an OSHA inspection two years later. The handoff of documentation is where Part 2 responsibility meets Part 3 responsibility, and it is the single most common failure we find on audit.
Once the integrator drives away, the cell is yours. Part 3 of R15.06-2025 now defines the end user's ongoing duties, and they run in parallel with what OSHA has always required. This is the longest-lasting responsibility in the chain, because it covers the entire operating life of the cell.
Crucially, OSHA does not care who built the cell. Under 1910.147 and the General Duty Clause, OSHA cites the employer who controls the workplace. You can hire the best integrator in the Midwest and still receive a citation if your written procedures are generic, your training records stop in 2023, or you modified the cell without reassessing risk. Delegating the build never delegates the legal responsibility. That is what makes the documentation handoff so important, and it is the work behind our robot cell LOTO procedures and annual LOTO audit services.
Across the robot cell audits we run for West Michigan automotive suppliers, food processors, plastics, and packaging plants, the same three handoff failures appear again and again.
The integrator did a proper risk assessment and safety validation, but it lives on the integrator's server. The plant has a running cell and no risk assessment on file. When an OSHA officer or an insurer asks to see it, there is nothing to show, and the safeguarding choices cannot be defended. This is the most common gap, and it is entirely the end user's to close, by demanding the full documentation package at commissioning.
A LOTO procedure that names a robot family instead of the specific cell fails 1910.147(c)(4). Two cells with the same robot but different conveyors, fixtures, or pneumatic bleed points need different procedures. The integrator may supply a template, but tailoring it to each cell is the end user's responsibility.
The cell was safe on the day it was commissioned. Then a new end-of-arm tool went on, a conveyor was added, a guard was relocated to fit a new part. Nobody reassessed the risk. The cell is now operating outside the conditions its safety validation covered, and neither the integrator nor the manufacturer is responsible for a modification they never saw. Change management is a pure Part 3 duty, and it is where cells quietly drift out of compliance.
| Responsible party | R15.06-2025 | Owns | Ends when |
|---|---|---|---|
| Robot manufacturer | Part 1 | The robot as a certified component | The robot is integrated into a cell |
| Integrator | Part 2 | Cell design, safeguarding, validation, documentation | The documented, validated cell is handed over |
| End user | Part 3 + OSHA 1910.147 | Operation, LOTO, training, inspection, change management | The cell is decommissioned |
Read down that table and one thing is clear: the end user's responsibility is the longest and the one OSHA enforces. The manufacturer and integrator do their part and move on. The operating plant carries the duty for years, which is exactly why the handoff has to be clean and the documentation complete.
Most West Michigan manufacturers inherit cells with parts of the chain missing, usually the documentation transfer and the change-management discipline. The gaps are invisible until an inspector finds them or an incident exposes them. A no-obligation gap assessment walks the cells, checks what the integrator actually handed over, reviews the end-user documentation, and produces a prioritized closure plan. Our robotics gap analysis service exists to find exactly these handoff failures before OSHA does.
Both, at different stages. Under the 2025 revision of ANSI R15.06, the robot manufacturer is responsible for the robot itself (Part 1), the integrator is responsible for designing and building a safe cell and validating it (Part 2), and the end user is responsible for operating, maintaining, and controlling that cell over its life (Part 3). OSHA holds the employer, the end user, legally accountable for worker safety regardless of who built the cell.
Part 3 is a new US-originated section of the R15.06-2025 standard that addresses the end user's use of industrial robot cells. Earlier versions of R15.06 covered the robot (Part 1) and integration (Part 2) but left the operating employer's ongoing duties less defined. Part 3 fills that gap, covering how the end user operates, maintains, inspects, and manages change on a cell after the integrator leaves.
No. A good integrator reduces your risk, but OSHA cites the employer who controls the workplace, not the integrator who left months earlier. Under OSHA 1910.147 and the General Duty Clause, the end user owns the written LOTO procedures, training, periodic inspections, and safe operation. You can delegate the build. You cannot delegate the legal responsibility for worker safety.
Three places: documentation that never transfers (the risk assessment and safety validation stay with the integrator), procedures that are generic rather than cell-specific, and change management that never starts (the end user modifies the cell after commissioning without reassessing risk). Each gap is invisible until an OSHA inspection or an incident exposes it, and each is the end user's responsibility to close.
At minimum: the documented task-based risk assessment, the safety circuit design with ISO 13849 Performance Level or IEC 62061 SIL verification, the commissioning and safety-function validation report, the robot manufacturer declaration of conformity, and cell-specific operating and maintenance information. Without these, the end user cannot defend the safeguarding choices or build compliant LOTO procedures, and the cell is effectively undocumented.
The end user. OSHA 1910.147(c)(4) requires the employer to have machine-specific written energy control procedures, and that duty sits with the operating facility, not the integrator. The integrator should provide the energy-isolation information the procedure is built on, but writing, maintaining, training on, and annually inspecting the LOTO procedure is the end user's responsibility for the life of the cell.