Deploying robots safely under HSWA: a guide for New Zealand workplaces

This article is general information for operations, facilities and health and safety managers. It is not legal advice. Confirm the specifics for your site with WorkSafe New Zealand or your own adviser.

Who carries the duty when a robot arrives on site?

Under HSWA, a person conducting a business or undertaking (PCBU) must ensure, so far as is reasonably practicable, the health and safety of its workers, and that other people are not put at risk by its work. WorkSafe calls this the primary duty of care. It includes providing and maintaining safe plant and safe systems of work, and giving people the information, training, instruction and supervision they need.

A cleaning, delivery or transport robot is plant. A PCBU that manages or controls plant at a workplace must ensure, so far as is reasonably practicable, that it is without risks to anyone’s health and safety. Separate upstream duties sit with the PCBUs that design, manufacture, import, supply, install or commission plant. WorkSafe notes they are well placed to design out risk before the robot reaches you.

Robots rarely involve a single business. In a shopping centre, the owner, the cleaning contractor and the equipment supplier may all have duties for the same scrubber. HSWA calls these overlapping duties: each PCBU must consult, co-operate and co-ordinate with the others, and none can contract its duty away. Agree in writing who does what, including who notifies WorkSafe if something goes wrong.

Software matters too. WorkSafe’s machinery guidance lists control errors among the hazards of robots, including software faults, electrical interference and programme corruption. Treat firmware updates, new maps and route changes as changes that need review.

What changes on 1 April 2027?

Parliament passed the Health and Safety at Work Amendment Bill in July 2026, and WorkSafe says the changes come into effect on 1 April 2027. Until then, the current Act applies in full. The main changes are:

• Critical risks. The Act will focus on risks linked to hazards listed in a new Schedule 1A, or any hazard likely to result in death, a notifiable injury, illness or incident, or a listed occupational disease if an incident occurs. The test is how serious the outcome would be, not how likely the event is.
• Small and large PCBUs. A PCBU with fewer than 20 workers for at least nine months of a financial year must manage critical risks ahead of other risks. Larger PCBUs must manage all risks and give critical risks the highest priority.
• Overlapping legislation. A business that complies with a requirement in another Act that manages the same risk, such as the Building Act 2004, will be treated as complying with HSWA for that risk.
• Officers. Officer duties are clarified to focus on governance.

For robots, the practical step is to work out which hazards on your site could meet the critical risk test, such as being struck or crushed by heavy mobile plant, and make sure they get priority. WorkSafe has said more guidance will be published before the changes start.

How should you run the risk assessment?

Use the usual process: identify hazards, assess the risks, eliminate them so far as is reasonably practicable or minimise them where you cannot, and review. WorkSafe warns that it is wrong to assume a robotic operation is safe just because workers rarely interact with it. With robots, the hazards depend heavily on the site:

Hazard	Where it shows up	Typical controls
Collision or impact	Busy corridors, blind corners, lift lobbies	Speed limits by zone, routes away from pinch points, visible and audible signals
Crushing or trapping	Docking stations, lift doors, narrow aisles, racking	Clearances around docks, lift integration rules, no-go zones
Slips and trips	Wet floors after scrubbing, parked robots, charging cables	Cleaning windows, drying time, signage, docks out of walkways
Mixed traffic	Distribution centres and yards with forklifts and pedestrians	Separated routes, defined crossings, a traffic management plan
Battery charging	Docks and charging rooms	Manufacturer charging instructions, docks away from exits and combustibles
Manual handling	Lifting robots, swapping batteries, emptying tanks	Task design, trolleys, training
Emergencies	Fire alarms and evacuations	Confirm robots stop or clear egress routes and never block exits or fire doors
Psychosocial	Work pace, job changes, cameras on robots	Engagement, clear information on data collection, workload review

Which standards are relevant?

Standards are generally not law on their own, but they are strong evidence of what is known about a hazard and how to control it. Ask your supplier which standards a platform was designed and tested to, and ask for the supporting documents. The main references are:

• ISO 13482:2014, Robots and robotic devices: Safety requirements for personal care robots. Covers mobile servant robots, physical assistant robots and person carriers. A revised edition, retitled Robotics: Safety requirements for service robots and extended to service robots in professional and commercial use, was at final draft (FDIS) ballot from September to November 2026. Check which edition a supplier is quoting.
• ISO 3691-4:2023, Industrial trucks: Safety requirements and verification, Part 4: Driverless industrial trucks and their systems. Applies to automated guided vehicles and autonomous mobile robots that carry, tow or lift loads, and divides a site into zones with different rules. The manufacturer covers the vehicle; the operating business owns the site application, including routes, zones and risk assessment.
• ISO 10218-1:2025 and ISO 10218-2:2025, Robotics: Safety requirements. Part 1 covers industrial robots and Part 2 covers robot applications and cells. Published in early 2025 to replace the 2011 editions, they incorporate the collaborative content previously published as ISO/TS 15066:2016.

WorkSafe’s Safe use of machinery guidance points to the AS/NZS 4024 series as the benchmark for safeguarding machinery. It includes a section on robotics and lists the parts of the series that cover industrial and collaborative robots. For newer categories such as humanoid platforms, standards are still being written, so your site risk assessment carries more of the weight.

How do you engage workers properly?

HSWA requires PCBUs, so far as is reasonably practicable, to engage with workers on health and safety matters that may directly affect them, and to have practices that let workers participate on an ongoing basis. WorkSafe lists when engagement is required, including when hazards are identified and assessed, when decisions are made about controls, when information and training are provided, and when changes are proposed that may affect health and safety. Engagement means sharing information, giving people time to consider it, taking their views into account and telling them the outcome.

In practice, bring cleaners, nurses, pickers, security officers, supervisors and your health and safety representatives into the mapping walk. They know where the blind corners, peak times and wet areas are. Explain what the robot’s cameras and sensors record and how the change affects their roles. Engage again when routes, tasks or software change.

What if the robot rides a lift?

Lifts are specified systems under the Building Act 2004. They appear on the building’s compliance schedule, are inspected by an independently qualified person (IQP), and are covered by the building warrant of fitness the owner supplies to the council each year. Council guidance states that adding, altering or removing a specified system must be done under a building consent.

Whether a robot interface counts as an alteration depends on how it connects to the lift. Involve the building owner, the lift maintenance contractor and the IQP before anything is fitted, and agree what the robot does when the lift is in fire service or out of service. Our article on robots and lifts covers the practical checks.

Cameras, sensors and the Privacy Act 2020

Many robots navigate with cameras, and some record or transmit images. Where people can be identified, that footage is personal information under the Privacy Act 2020 and its information privacy principles. The Privacy Commissioner’s CCTV guidance applies the same logic you should use for a robot: know your purpose, collect only what you need, switch off audio if it is not necessary, tell people with clear signage, control who can view footage, set a retention period, and be ready to respond when someone asks for footage of themselves.

If a privacy breach has caused, or is likely to cause, serious harm, you must notify the Privacy Commissioner and the affected people as soon as you are practically able. If a robot uses facial recognition or other automated biometric processing, the Biometric Processing Privacy Code 2025 applies. Its transition period for existing users ended on 3 August 2026.

Training, signage and traffic management

Train three groups. Operators need to start and pause routes, use the emergency stop, respond to assists, charge and clean sensors, and report faults. Other staff need to know how the robot behaves, who gives way, and not to ride, block or move it. Contractors and visitors need a short induction or clear signs.

Put signage at site entrances, docks, lift lobbies and zones where robots operate. In distribution centres, ports and yards, fold robots into the traffic management plan alongside forklifts and pedestrians. WorkSafe’s work site traffic guidance expects businesses sharing a site to manage traffic risks together and to engage workers when deciding how.

What happens when something goes wrong?

A notifiable event is a death, a notifiable injury or illness, or a notifiable incident. Notifiable incidents include unplanned events that expose people to a serious risk from, among other things, a fire or explosion, an electric shock, or plant or objects falling from height. The PCBU must make sure WorkSafe is notified as soon as possible, by the fastest means possible in the circumstances, even if emergency services attend. Only one notification is needed per event, so nominate which PCBU makes it.

The PCBU that manages or controls the workplace must preserve the site until an inspector authorises otherwise, with limited exceptions such as helping an injured person or making the area safe. Leave the robot where it is and keep its event logs. Record near misses, assists and unexpected stops internally, and review your controls after incidents, software updates and site changes.

Robotx can help you gather the supplier information and site details your health and safety review will need.