The Short Version
- ANSI R15.06 — U.S. national consensus standard for industrial robot and robot system safety. Cell design, safeguarding, interlock function, access control. Harmonized with ISO 10218-1 and 10218-2.
- OSHA 1910.147 — Federal regulation for the control of hazardous energy. Lockout tagout. Applies to any equipment with energy that could harm employees during service.
R15.06 is voluntary in the strict legal sense. OSHA 1910.147 is law. But OSHA cites R15.06 frequently as the recognized standard of practice for robot system safety, which means non-conformance with R15.06 can become a 1910.147 citation through the General Duty Clause.
What Each Standard Actually Covers
ANSI R15.06 covers:
- Robot system design and integration
- Safeguarding (perimeter fencing, light curtains, mats, scanners)
- Interlock function and validation
- Access control protocols
- Risk assessment methodology
- Operator and maintainer interface design
OSHA 1910.147 covers:
- Written, machine-specific energy control procedures
- Energy isolation device application
- Authorized employee training and authorization
- Periodic (annual) inspection of procedures
- Group lockout and shift change protocols
- Release from lockout sequence
Where the Two Converge
The interlock gated entry of a robot cell is the convergence point. R15.06 says the entry must be safeguarded with proper interlock function. 1910.147 says the energy control procedure must be at the point of use. The access control placard installed at the gate is the physical artifact that satisfies both standards simultaneously.
Cells without an access control placard at every gate fail R15.06 (safeguarded entry not properly identified) and 1910.147 (procedure not at the point of use) on the same walkthrough. It is the most common dual-citation pattern we see.
Where Compliance Programs Fail
Most compliance failures we see come from treating the two standards as independent.
- R15.06 work without 1910.147 follow-through. Integrator builds the cell to R15.06. Hands over a binder. Operations runs the cell for three years. No 1910.147 procedure ever gets written for the specific cell.
- 1910.147 work without R15.06 awareness. EHS team writes a generic LOTO procedure that addresses electrical isolation. Misses interlock gated entry as its own access protocol. Fails inspection at the gate.
- Tooling changes without updates to either. End-of-arm tooling changes shift the energy and hazard picture. R15.06 risk assessment never gets updated. 1910.147 procedure stays static. The two drift further apart with every modification.
What Compliance With Both Looks Like
- R15.06 risk assessment current for every cell
- Interlock function validated and documented
- 1910.147 cell-specific procedure on file
- Access control placard at every gated entry
- Authorized employees trained on both the access protocol and the energy isolation procedure
- Annual procedure review under 1910.147(c)(6) on file
- Documentation centralized so an inspector can see all of it without a scavenger hunt
Free Compliance Walkthrough
We walk every cell on your floor and map gaps to both R15.06 and 1910.147 in a single report. Half-day to full-day on-site, written report within a week, no commitment.
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