Robotic Inspection SOP Template for PSM Facilities: Integrating Boston Dynamics Spot into OSHA 1910.119 Mechanical Integrity Programs

SOP TemplatePublished April 2026·11 min read·Actel Robotics Editorial Team · Sugar Land, TX
Legal notice: This template provides a framework for integrating autonomous robotic inspection into PSM mechanical integrity programs. It is not a substitute for review by qualified EHS counsel, process safety engineers, or your facility's PSM coordinator. Compliance with OSHA 1910.119 is site-specific and requires facility-specific assessment. Actel Robotics provides this template as operational guidance for customers deploying Boston Dynamics Spot through our implementation service.

1. Scope and Applicability

This Standard Operating Procedure (SOP) governs the use of Boston Dynamics Spot autonomous inspection robots as part of the Mechanical Integrity (MI) program at OSHA Process Safety Management (PSM) covered facilities. It applies to: scheduled autonomous inspection missions on PSM-covered equipment, data collection and archiving for MI documentation, anomaly reporting and escalation to the MI program database, and interface with the facility CMMS.

This SOP does not apply to: initial robot commissioning (covered by Actel Robotics deployment procedures), emergency response activities using the robot, or construction and maintenance activities conducted during robot-assisted inspection. It applies to all facility personnel who interact with or manage the robotic inspection program.

Covered facilities: This template is applicable to OSHA 1910.119 PSM-covered processes, which include highly hazardous chemicals above threshold quantities. For facilities in the Greater Houston corridor — refineries in Baytown, chemical plants in Deer Park and La Porte, and facilities along the Ship Channel — PSM compliance is typically administered by a dedicated PSM coordinator who should be involved in implementing this SOP.

2. Definitions

  • Autonomous Inspection Mission (AIM): A programmed Spot inspection route executed without continuous human operator input
  • Inspection Point: A specific equipment item, gauge, or structural location included in a programmed inspection mission
  • Baseline Reading: The established normal operating condition for a specific inspection point, used for anomaly detection comparison
  • Anomaly: A reading that deviates from baseline by more than the configured threshold
  • Mission Data Package: The complete data output from a single AIM including route log, sensor readings, images, and anomaly flags
  • CMMS: Computerized Maintenance Management System (IBM Maximo, SAP PM, or equivalent)

3. Mission Operations Procedure

3.1 Pre-Mission Requirements

  • Verify robot battery charge is above 30% before mission start (system will not launch below 20%)
  • Confirm no scheduled maintenance or process upsets on the mission route — check with area operator before launch
  • Verify robot network connectivity in management platform — confirm RSOC can see robot status
  • Log mission start in site inspection log (date, time, mission ID, inspector name)

3.2 Mission Execution

Autonomous missions are launched from the Orbit or Boston Dynamics management platform. The robot follows the programmed route, collecting sensor data at each inspection point. Personnel on the route should allow normal 6-foot clearance as with any mobile equipment. The robot will pause and reroute if it detects a stationary obstruction — do not attempt to manually redirect the robot during an autonomous mission without explicit instruction from the Actel Robotics support team.

3.3 Post-Mission Procedure

  • Review Mission Data Package in Orbit within 2 hours of mission completion (or at shift change if mission runs at shift end)
  • Verify all inspection points were successfully collected — flag any missed points for follow-up
  • Review all flagged anomalies — classify per Section 5 matrix
  • Archive Mission Data Package in CMMS per Section 6 procedure
  • Log mission completion in site inspection log

4. Documentation Requirements

OSHA 1910.119(j)(4) requires that MI inspection records include the date of the inspection, the name and employee ID of the inspector, identification of the inspection result, and a description of any corrective action taken. Spot's Mission Data Package satisfies all of these requirements when properly archived:

  • Date and time: Auto-timestamped at mission start and at each inspection point
  • Inspector identification: Mission ID linked to the operator who launched the mission in Orbit — document operator name and employee ID in the mission launch log
  • Inspection results: Sensor readings, thermal images, and anomaly flags archived in Mission Data Package
  • Corrective actions: Anomaly escalation workflow (Section 5) produces CMMS work orders that satisfy corrective action documentation requirements
PSM audit tip: Print or export the Mission Data Package index at each quarterly PSM audit review. The timestamped archive demonstrates inspection frequency and data quality that exceeds what manual round documentation typically provides. Texas OSHA (DOSH) auditors have reviewed robotic inspection documentation at several Gulf Coast facilities — the data archive consistently satisfies inspection record requirements.

5. Anomaly Classification and Escalation Matrix

All anomalies flagged by the robotic inspection system are classified by severity and escalated according to this matrix:

SeverityThresholdAction RequiredTimeframe
LowThermal delta <5°C above baseline; visual condition change notedLog in CMMS, schedule follow-up inspection within 30 daysNext scheduled maintenance window
MediumThermal delta 5–15°C above baseline; visible corrosion or damage; pressure instrument deviationNotify shift supervisor within 4 hours; open CMMS work order; schedule engineering evaluation within 7 daysWithin 7 days
HighThermal delta >15°C above baseline; active leak indication; structural concernImmediate notification to process engineer and shift superintendent; initiate PSM equipment evaluation per facility MOC processImmediate
CriticalThermal delta >30°C; active failure indicators; safety system anomalyImmediate process engineer notification; consider process shutdown per emergency procedures; do not enter area without authorizationImmediate — emergency protocol

6. CMMS Integration Procedure

The Orbit-to-CMMS integration configuration is completed during the Actel Robotics deployment. After go-live, each Mission Data Package is automatically archived in the CMMS with the equipment tag, reading values, and anomaly flags. Work orders generated from anomaly escalation are created by the reviewing engineer in the CMMS, linked to the specific Orbit mission ID and reading that triggered the escalation.

7. Personnel Qualification Requirements

Mission operators (personnel who launch missions and review Mission Data Packages): Completion of Actel Robotics robot operator training (4 hours). Annual refresher with current software version familiarization.

Anomaly reviewers (engineers who classify anomalies and initiate escalation): Completion of Actel Robotics anomaly interpretation training (2 hours). Basic thermal imaging interpretation competency. Familiarity with CMMS work order creation for their facility.

PSM coordinator (oversees integration with MI program): Review this SOP and the facility's MI program procedures. Participate in initial Actel Robotics implementation training. Responsible for SOP annual review and update.

8. Audit and Record Retention

Mission Data Packages: retained for minimum 5 years (consistent with PSM MI record retention requirements). CMMS work orders generated from anomaly escalation: retained per existing CMMS retention policy. Mission launch logs (paper or electronic): retained for minimum 5 years. Annual SOP review: PSM coordinator reviews and updates this SOP annually, or following any significant change in robot configuration or process equipment covered.

For questions about implementing this SOP at your facility, or to discuss how it integrates with your specific PSM program documentation structure, contact Actel Robotics. We serve oil and gas and energy and utilities facilities across Greater Houston, Louisiana, and Oklahoma.

Frequently Asked Questions

Yes, when properly documented. OSHA 1910.119(j)(4) requires inspection records to include date, inspector identification, results, and corrective actions. Boston Dynamics Spot's Mission Data Package, when archived per this SOP, satisfies all four requirements. Texas OSHA (DOSH) auditors have reviewed robotic inspection documentation at Gulf Coast PSM facilities — the data archive consistently satisfies inspection record requirements. Always involve your PSM coordinator and legal/EHS counsel in implementing the program.
Spot can inspect any equipment that requires periodic visual, thermal, acoustic, or dimensional inspection — including pressure vessels, heat exchangers, rotating equipment, electrical systems, instrumentation, and piping. The robot cannot perform destructive testing, ultrasonic thickness measurement, or other intrusive inspection methods that require physical contact. Those intrusive inspections continue to require qualified human inspectors.
High and Critical anomalies that may require process changes, equipment isolation, or shutdown are escalated to the process engineer, who initiates the facility's Management of Change process as appropriate. The robotic inspection system flags the anomaly and generates the CMMS work order — the engineering team applies facility-specific MOC judgment. The SOP is designed to feed into, not replace, existing MOC and emergency response procedures.
The general framework applies to EPA RMP facilities (40 CFR Part 68) and RCRA facilities with equipment inspection requirements. Specific documentation requirements differ between programs, and this SOP should be reviewed by your environmental compliance team before implementation at facilities covered by multiple regulatory frameworks. Actel Robotics can connect you with EHS consultants familiar with Gulf Coast regulatory requirements for facilities subject to multiple overlapping programs.
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