What Happens to Your Risk Assessment When AGVs and Robotics Arrive?

Have you considered implementing more automation at your facility? AGVs and other automated machinery are becoming increasingly popular at sites we visit. And there's a reasonable assumption that comes with that: automation makes a site safer. In some respects it does. Removing a human driver from a vehicle eliminates a category of human error entirely, and that changes the accident profile on many sites.

The problem is that assumption can become a reason not to revisit the paperwork. The risk hasn't disappeared; it's changed shape. And a risk assessment written for a human-driven warehouse often has significant gaps when autonomous vehicles enter the picture.

We know how much pressure there is to get new systems operational. But according to legislation in Britain, introducing AGVs or robotic machinery is a material change to your risk profile, and it triggers specific legal obligations.

In this article, we'll walk through exactly what the law requires, where most safety plans fall short when automation arrives, and what practical steps you need to take to stay compliant and safe.

Contents

1. What Does the Law Say When You Introduce New Work Equipment?
2. What Changes on the Ground When AGVs Are Introduced?
3. What Are the Specific Gaps Most Risk Assessments Miss?
4. How Does Your Pedestrian Segregation Strategy Need to Adapt?
5. What Should a Reviewed Risk Assessment Cover?
6. Where Do We Fit In?

What Does the Law Say When You Introduce New Work Equipment?

The starting point is Regulation 3 of the Management of Health and Safety at Work Regulations 1999. It requires employers to carry out a suitable and sufficient risk assessment, and critically, to review that assessment whenever there's reason to believe it's no longer valid, or when there's a significant change in the matters to which it relates.

Introducing AGVs is a significant change. Full stop.

Alongside this, the Provision and Use of Work Equipment Regulations 1998 (PUWER) apply directly to AGVs and robotic systems. PUWER requires that all work equipment is suitable for its intended use, maintained in safe condition, and that risks from its use are controlled. Where equipment is mobile, which AGVs are, additional duties around stability, visibility, and lighting apply.

Regulation 25 specifically addresses self-propelled work equipment, setting out requirements for preventing unauthorised start-up, minimising consequences of collision, and providing braking and speed control. This means your documentation needs to cover not just where AGVs operate, but how they're controlled, how emergency stops work, and how workers are protected when normal safeguards may be suspended during maintenance.

The Workplace (Health, Safety and Welfare) Regulations 1992 also remain in play. Regulation 17 specifically covers traffic routes: they must be suitable for the people and vehicles likely to use them, sufficient in number, wide enough, and properly organised to separate pedestrians from vehicles where necessary.

A risk assessment written before automation arrived is unlikely to satisfy these requirements without revision. HSE inspectors are increasingly familiar with automated facilities, and the documentation expectations have risen accordingly. 

What Changes on the Ground When AGVs Are Introduced?

The instinct is to treat AGVs as equivalent to FLTs, just without a driver. In practice, the risk profile is different.

AGVs typically travel fixed, pre-programmed routes. That predictability is beneficial, but it creates a specific hazard that doesn't exist with human-operated vehicles: workers learn the routes and start to trust them. Over time, they stop looking before crossing a travel lane. Near-misses become normalised. The risk isn't so much the vehicle but the complacency that predictable movement can encourage.

There are also physical differences to account for. Many AGVs operate at lower ground clearance than a counterbalance FLT, which affects whether existing barriers, specified to PAS 13 for standard forklift impacts, will perform as intended. Some AGVs are significantly heavier than they appear. Others move faster than a typical warehouse pedestrian expects.

And then there's the operating hours dimension. AGVs often run overnight, during shift changes, or in low-light conditions. A pedestrian segregation system designed around a single-shift, fully-staffed operation may not be adequate when the building is also running autonomously at 2am.

What Are the Specific Gaps Most Risk Assessments Miss?

Based on what we see during site assessments, the most common omissions when automation arrives fall into three areas.

Pedestrian crossing points

The original layout may have crossing points that were adequate for low-frequency FLT movement. When an AGV is running that route every four minutes, the risk calculation changes entirely. Crossing points need reviewing for frequency, sight lines, and physical control measures.

Visual warning systems

Traditional floor markings (painted lines, floor tape, etc.) were designed for environments where the vehicle operator shares responsibility for the interaction. In an AGV environment, the vehicle cannot adapt to a poorly marked crossing point. The warning system needs to work harder, be more visible, and in many cases be dynamic rather than static.

LED projected floor markings are increasingly used in automated facilities precisely because they don't degrade from AGV traffic passing over them, can be sensor-triggered to activate when a vehicle approaches, and don't require the vehicle to 'read' a line.

Our LED projected floor marking systems can be configured to integrate with AGV movement, projecting active warnings at crossing zones when a vehicle is inbound.

Barrier specification and placement

Barriers specified for FLT impact profiles may not perform identically against an AGV with a different weight, speed, or bumper height. This isn't necessarily a problem, but it needs to be assessed rather than assumed. The placement logic also needs revisiting: barriers positioned to guide human drivers may be in the wrong location to provide meaningful protection from an autonomous vehicle following a fixed path.

How Does Your Pedestrian Segregation Strategy Need to Adapt?

HSG136 (the HSE's guidance on workplace transport safety) sets out the principle that physical segregation is the most reliable form of pedestrian protection. That principle doesn't change with automation; if anything, it becomes more important.

The difference with AGV environments is that segregation needs to be more consistent. With human-operated vehicles, a driver can stop for a pedestrian who wanders into a vehicle zone. An AGV will stop too, but only if its sensors detect the person, and only within its programmed stopping distance. The consequence of a pedestrian being in the wrong place is the same regardless of whether there's a human in the cab.

Modular polymer barrier systems work well in AGV facilities because they can be reconfigured as travel paths are adjusted without extensive remedial work to floors. Our polymer safety barriers are installed without hot works and can be repositioned during planned maintenance windows, which matters when AGV routes change as operations evolve.

If you're at the planning stage, consider designing pedestrian routes that don't cross AGV lanes at all where possible. Physical separation is always preferable to managed crossing points. 

What Should a Reviewed Risk Assessment Cover?

When you sit down to update your risk assessment for an automated facility, the documentation should address the following as a minimum:

• A description of each AGV or robotic system, its travel routes, speeds, and operating hours
• The interface points between AGV movement and pedestrian activity, including shift change periods and maintenance windows
• How crossing points are controlled, marked, and physically managed
• What barriers are in place, their specification relative to AGV impact characteristics, and confirmation they remain fit for purpose
• Emergency stop procedures and how these are communicated to all workers on site
• Evidence that the assessment has been reviewed following the introduction of each new automated system

The last point matters. If you add a second type of AGV, extend routes, or change operating hours, the review obligation is triggered again. Automation tends to evolve incrementally, and the risk assessment needs to keep pace.

Where Do We Fit In?

We're not automation consultants, and we'll always say so. But the physical safety infrastructure that separates people from AGVs, marks hazard zones, and keeps pedestrians protected is very much what we do.

We conduct on-site assessments that look at your existing segregation, barrier specification, and floor marking strategy against how your facility actually operates now, including automated systems. We're honest about what's adequate, what needs updating, and what isn't relevant to your specific setup.