Case Study 2: Automotive Component Lubrication Robotics

Incorrect.  There would not be an exemption for this activity.

The employer still has an obligation to provide the servicing and/or maintenance employees protection if they are exposed to the unexpected energization, start-up, or release of stored energy, which could cause injury. Simply because it is impractical or difficult to effectively protect employees engaged in service and/or maintenance work, provides no exemption from the requirements of the standard. The robot could have been rewired to eliminate the problem of computer memory loss, or could be reprogrammed using a slave computer to transfer the necessary data and instructions to the robot's computer.

For more information: To better evaluate this specific case study, refer to the October 30, 1996, memorandum for Regional Administrators, and the 6^th Circuit Court decision in the Secretary of Labor vs. General Motors Corporation, Delco Chasis Division, OSHRC Docket numbers 91-2973, 91-3116, and 91-3117.

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