Texas Robotics Law

Updated Industrial Robot Standards Need Scope Checks

Published

Voluntary consensus standards; OSHA duties in effect. Law checked through October 18, 2026.

A Roman legion's standard told soldiers where to form; it did not tell them how to fight on ground they had never seen. Safety standards work the same way. They organize practice within a defined field and say little about what lies beyond it.

The international standards for industrial robots were rewritten in 2025. ISO 10218-1:2025 (the robot) and ISO 10218-2:2025 (the application and the robot cell) were published in early 2025, the first part on February 5. In September 2025, the American national standard ANSI/A3 R15.06-2025 adopted both. Together they are the reference points against which a robot integrator's risk assessment, guarding, and collaborative-operation choices will be judged.

OSHA has no standard written specifically for robots. Employers answer under the general duty clause of 29 U.S.C. § 654(a)(1) and under specific rules on machine guarding (29 C.F.R. § 1910.212) and hazardous energy control (§ 1910.147). Consensus standards matter because they help show what hazards an industry recognizes and what abatement is feasible. The OSHA Technical Manual's robotics chapter still cites older editions, so it cannot be used to show which edition is current.

The scope warning is the important one. ISO 10218 addresses industrial robots. A humanoid stocking shelves in a store, or a household robot, sits outside that scope, and calling it "compliant with ISO 10218" proves little. A dedicated standard for dynamically stable industrial mobile robots, ISO 25785-1, which reaches legged robots, remains in draft.

Limits

The standards are copyrighted and must be purchased; clause-level conclusions require the actual text. Conformity with a standard is evidence of care, not a legal safe harbor.

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