Before a robot technician works on a US customer site: COI, contractor licensing, union sites and safety orientation

Short answer: a robot technician can't just fly in and start work on a US customer site. Before the first visit, larger customers (warehouses, hospitals, malls, plants) usually want a set of documents from purchasing, EHS or property management: a certificate of insurance (COI) with the additional insured endorsement, workers' compensation evidence, vendor set-up and a tax form (W-8BEN-E for a foreign company), and site safety orientation with a lockout/tagout handover. If the job involves wiring, anchoring or building work, a state contractor or electrical licence may apply. On a unionized site, ask first which tasks site staff must do. Miss any one of these and the technician can be turned away at the door.

This guide is for robot makers with robots in the US who need to send someone on site for repair or deployment, whether their own engineers or a field service partner. It summarizes the ACORD form, OSHA rules, IRS instructions and the California, Washington and Texas statutes and agency pages as checked on November 11, 2026; "our reading" marks interpretation. It is not legal, insurance or tax advice. For the insurance programme itself, see robot product liability insurance in North America; for ways to cover the US without your own team, see nationwide service network or dedicated field service partner.

The checklist: 8 things a US site may ask for

Who asks for what varies by customer; their written vendor or contractor requirements decide. Our advice: when you close your first US customer, have sales request those requirements and go through this list then, not when the first service call comes in.

1. The COI: one page, issued to the customer's requirements

A US COI is usually an ACORD 25 Certificate of Liability Insurance. It lists the producer (broker), the insured, the insurers with NAIC numbers, and each policy's number, dates and limits. Coverage rows: commercial general liability (including the PRODUCTS - COMP/OP AGG limit), automobile liability, umbrella/excess, and workers' compensation and employers' liability. Each row has two boxes, ADDL INSD and SUBR WVD. At the bottom are the DESCRIPTION OF OPERATIONS / LOCATIONS / VEHICLES box (ACORD 101 can be attached) and the CERTIFICATE HOLDER.

The form itself carries two warnings worth reading:

• "This certificate is issued as a matter of information only and confers no rights upon the certificate holder." It does not amend, extend or alter the policies and is not a contract.
• "If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must have ADDITIONAL INSURED provisions or be endorsed." The same goes for a waiver of subrogation. "A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s)."

So when a customer says "add us as additional insured", they need an endorsement from the insurer. Common ISO forms: CG 20 10 (ongoing operations), CG 20 37 (completed operations, for example a robot that fails weeks after a repair) and CG 20 26 (designated person or organization). Use whatever form number the contract names.

Details to get right:

1. Certificate holder = the customer's legal entity and address, not the store name. If the property owner and the operator are different companies, ask whether both need one.
2. Describe the work, e.g. "on-site diagnosis, repair and maintenance of robotic equipment"; some customers also want the site address.
3. Match the limits to the contract. $1M per occurrence / $2M aggregate CGL is common, sometimes with an umbrella; the contract decides (see the insurance guide, "Four contract requirements").
4. Check the policy covers US work. For a Canadian firm, the policy territory is a more common blocker than the COI itself.
5. Reissue before renewal. Many vendor systems suspend site access automatically when a COI expires.

2. Workers' compensation for a Canadian technician in the US

The last row of the COI is workers' compensation and employers' liability, and US customers often ask when it is blank.

For a BC employer, WorkSafeBC says it may cover medical and wage-loss costs when a BC worker is injured working in another province or country, if all four conditions hold: the employer is located in BC; the worker's residence and usual place of employment are in BC; the job requires working both in and out of the province; and the worker is still with the same BC employer and returns to BC in less than six months. It also says employers are responsible for contacting the jurisdiction where they will operate to make sure they comply. Whether the US state's workers' compensation law also applies, and whether a customer will accept WorkSafeBC evidence, is not something we found a single answer to: ask your broker and check the state's rules. Some customers ask for separate employer's liability cover for US work.

The same question applies if engineers fly in from China: whose insurance pays if they are hurt, and what proof will the customer want? Settle it with a broker before anyone travels.

3. Vendor set-up and tax forms

Accounts payable will want a tax form before paying. A foreign company (a Chinese parent or a Canadian firm) gives the payer a W-8BEN-E, which the IRS describes as used "by foreign entities to document their status"; US persons use a W-9. Decide first who invoices the end customer. A common setup: the manufacturer (or its US subsidiary) stays responsible to the customer, and the field service provider invoices the manufacturer, so the customer only sets up one vendor.

Some large customers also require contractors to register on a third-party prequalification platform and upload insurance, safety records and training before they can be scheduled. These platforms usually charge an annual fee, so ask early whether the customer uses one and who registers.

4. Contractor and electrical licensing: three states only

There is no national contractor licence in the US; rules differ by state and often by city. We only cover the three states whose texts we read. What they have in common: licensing turns on the nature of the work, not on whether it is a robot. Does the work make equipment part of the building (hard-wiring, anchoring, structural changes)? Is it electrical work? Plug-in, free-standing robots and repairs inside the robot's own enclosure have the strongest case for no licence. New branch circuits, conduit or disconnects for a robot need a licensed electrical contractor in all three.

Three practical steps:

1. Split your models in two: plug-in or battery-powered and free-standing, versus hard-wired, anchored or fenced. For the second group, hire local licensed electricians and contractors for the electrical and fixing work; the field technician does the robot itself.
2. Put the authorization in writing: a letter appointing the service partner as your authorized service representative for named models. In Texas it maps to 1305.003(a)(7); elsewhere it at least shows customers and inspectors who the technician is. See building an authorized service provider network.
3. Check every other state separately. Don't extend these three to the whole US. For each new state or city, read the state contractor and electrical regulators' own texts and ask local counsel if needed.

Note: the official California statute site blocked our requests, so we read the California sections on california.public.law (marked as verified against the official text on November 11, 2026). The Texas section was read on texas.public.law and later amendments could not be confirmed. Check the official text before relying on it.

5. Entry: who can go to the US site

Insurance and licences decide whether the work can be done; immigration decides who can go. Two official texts, both narrower than many assume:

• Canadian citizens: the USMCA after-sales service category in 8 CFR 214.2(b)(4)(i)(F) covers installers, repair and maintenance personnel working under a warranty or service contract incidental to the sale of commercial or industrial equipment purchased from an enterprise outside the US, during the life of that agreement.
• Visa nationals, including engineers from China: 9 FAM 402.2-5(E)(1) allows a B-1 visa to install, service or repair commercial or industrial equipment bought from a company outside the US, if the sales contract requires the seller to provide the service, the person has specialized knowledge, and they receive no US-source pay. It excludes building or construction work, on site or in a plant.

Both exclude construction-type work such as wiring, anchoring or building a robot cell, which lines up with the licensing point above: that part goes to local licensed trades. A situation-by-situation table is in robot field service in Seattle and the Pacific Northwest. The border officer or consul decides.

6. Site safety: orientation, lockout/tagout and who is responsible

Orientation. Most warehouses, hospitals and plants run a site safety orientation for outside workers (PPE, forklift aisles, muster points, hot work and height permits), sometimes by booking and on weekday hours only. OSHA 10- and 30-hour cards come up often, but OSHA says the Outreach Training Program "is a voluntary program and does not meet the training requirements for any OSHA standards", and that none of the courses is a certification. Some states and employers require them anyway: Nevada requires construction workers to get an OSHA-10 card within 15 days of hire (OSHA-30 for supervisors), and New York requires at least 10 hours of OSHA construction safety training on state and municipal public work contracts of $250,000 or more. Ordinary robot repair usually falls outside these, but a customer's contractor rules may still require a card, so ask.

Lockout/tagout. OSHA 29 CFR 1910.147 covers servicing and maintenance of machines where unexpected energization, start-up or release of stored energy could cause injury, which normally includes robot repair. Paragraph (f)(2) says that when outside servicing personnel do this work, "the on-site employer and the outside employer shall inform each other of their respective lockout or tagout procedures". So the service provider needs a written, model-specific energy isolation procedure: main power, battery, pneumatics, gravity and spring energy, arm brakes. The maker should write it per model in English and give it to its service partner. For cobot cells, see cobot and robot arm installation in Canada and the US; for IT and network approvals, see robot IT security requirements.

Who is responsible. OSHA's multi-employer citation policy (CPL 02-00-124) classifies employers on a site as creating, exposing, correcting or controlling, and more than one can be cited. Our reading: a service provider can't rely on "it's the customer's site"; it answers for its own people and the hazards it creates.

7. Union sites: ask about work rules first

Some US warehouses, plants, hospitals and venues have collective agreements or site rules that reserve tasks such as moving, connecting or dismantling equipment for site staff or specific trades. We found no general rule that covers every private site, so ask each time: before the visit, ask the site contact whether an agreement or site rule limits what outside workers may do, who will assist, and whether that is charged. Separately, large federal construction projects ($35 million and up) require project labor agreements under FAR 22.503; that applies to construction contracts, not ordinary equipment repair.

8. Seven things the robot maker should prepare

1. Get the customer's site requirements at contract signature, as part of the service handover.
2. Fix the contract chain: who is responsible to the customer, who invoices, whose subcontractor the field provider is. Both the USMCA after-sales category and B-1 depend on service obligations in the sales contract; write them in with the SLA.
3. Arrange insurance early: your product liability cover plus your service partner's CGL, workers' compensation and auto, with endorsement forms matching the customer contract.
4. Write English lockout/tagout and work instructions per model, with tools and PPE; the partner follows them and the customer's EHS can review them.
5. Mark which work needs a licence: separate plug-in, free-standing models from hard-wired or anchored ones and line up local licensed trades for the latter.
6. Keep a site-entry pack: COI, endorsements, workers' compensation evidence, W-8BEN-E or W-9, safety procedures, technician training records and SDS (e.g. batteries) in one folder for each new customer.
7. Keep a record per robot: tickets, parts swapped, photos (see robot warranty and RMA in North America).

What KeepRobots can do

We are a robot field service company in Vancouver. We don't give legal, insurance or tax advice, and we don't replace licensed electricians or building contractors. Within that, we can:

• prepare site-entry documents to your and your customer's requirements, attend site safety orientation and work to written lockout/tagout procedures
• diagnose, repair, maintain and commission robots on US and Canadian customer sites, coordinating local licensed trades for wiring or anchoring
• turn Chinese work instructions and energy isolation steps into English field versions
• work in English and Chinese, read Chinese technical documents and overlap with China working hours

Rates before tax: diagnostic US$200 in the US or C$200 in Canada, per robot, per visit, credited against an approved repair; C$100 call-out in core Greater Vancouver; labour US$150 or C$150 per hour; US projects and travel outside the core area quoted per project. How we cover US cities is on robot repair and field service in the USA; other US providers are listed in robot field service companies in the USA. Or email partners@keeprobots.com.

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FAQ

What is a COI, and is it enough to get on site?

A certificate of insurance, usually an ACORD 25, lists the broker, the insured, the insurers, and each policy's number, dates and limits. The form says it is for information only and confers no rights; if the holder is to be an additional insured, the policy must provide for it or be endorsed. Customers therefore usually want the COI plus a copy of the endorsement (often ISO CG 20 10 or CG 20 37), and may also ask for workers' compensation evidence, tax forms and safety training records.

Does a robot technician need a contractor licence on a US site?

It depends on the state and the work. California exempts installing finished products that do not become a fixed part of the structure (B&P 7045); its minor-work exemption needs a total under $1,000 and no employees (7048). Washington requires contractor registration for work on improvements attached to real estate (RCW 18.27). Texas has no statewide general contractor licence. Plug-in, free-standing robots are the least likely to need one; hard-wiring, anchoring or building work goes to local licensed trades. Check other states separately.

Is robot repair electrical work?

New circuits, conduit and disconnects are electrical work needing a licence in all three states. In Washington, repairing internal parts of hard-wired equipment falls under specialty 07E equipment repair, with a licensed electrical contractor. Texas Occupations Code 1305.003(a)(7) exempts commissioning, troubleshooting, same-ampacity repair and in-enclosure maintenance by an authorized employee or authorized representative of the equipment manufacturer, limited to its products.

Is an OSHA 10 card required?

Not by federal OSHA: the Outreach program is voluntary and is not a certification. Nevada requires OSHA-10 for construction workers within 15 days of hire, and New York requires 10 hours on state and municipal public work of $250,000 or more. Ordinary robot repair usually falls outside these, but customers' contractor rules may require a card.

What does lockout/tagout require of an outside technician?

Under 29 CFR 1910.147(f)(2), when outside servicing personnel do work covered by the standard, the on-site employer and the outside employer must inform each other of their lockout or tagout procedures. Bring a written, model-specific energy isolation procedure covering power, batteries, pneumatics, stored mechanical energy and arm brakes.

Does WorkSafeBC cover a BC technician working in the US?

It may, if the employer is in BC, the worker lives and usually works in BC, the job requires work in and out of BC, and the worker returns within six months. WorkSafeBC also tells employers to check compliance with the jurisdiction where they work. Whether US state workers' compensation rules also apply is a question for your broker and that state.

Can KeepRobots work on US customer sites, and what does it cost?

Yes, per project from Vancouver, with Greater Vancouver as our home base in Canada. We prepare site-entry documents, attend orientation, work to written lockout/tagout procedures and coordinate local licensed trades for wiring or anchoring. We don't make legal, insurance or tax calls. Before tax: diagnostic US$200 or C$200 per robot, per visit, credited against an approved repair; labour US$150 or C$150 per hour; C$100 Greater Vancouver call-out; US travel quoted per project.

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Sources

• ACORD 25 Certificate of Liability Insurance (2025/12), as published by the New York DFS: dfs.ny.gov
• Sonoma County, additional insured endorsements (CG 20 10, CG 20 37, CG 20 26): sonomacounty.gov
• IRMI, history of ISO additional insured endorsements: irmi.com
• WorkSafeBC, out of province: worksafebc.com
• IRS, About Form W-8BEN-E and instructions: irs.gov, irs.gov
• California B&P Code 7045 and 7048 (mirror): 7045, 7048
• CSLB bulletin, AB 2622 minor work exemption raised to $1,000: cslb.ca.gov
• CSLB, C-10 electrical classification: cslb.ca.gov
• Washington RCW 18.27.090, RCW 19.28.095, WAC 296-46B-920: 18.27.090, 19.28.095, 296-46B-920
• Texas Governor's Office, Basics of Business Licensing transcript (TDLR: no statewide general contractor licence): gov.texas.gov
• TDLR electricians FAQ: tdlr.texas.gov; Texas Occupations Code 1305.003 (mirror): texas.public.law
• OSHA 29 CFR 1910.147: osha.gov; Outreach Training Program: osha.gov; CPL 02-00-124: osha.gov
• Nevada NRS 618.983 (mirror): nevada.public.law; New York Labor Law §220-h: nysenate.gov
• FAR 22.503, project labor agreements: acquisition.gov
• 8 CFR 214.2(b)(4), USMCA business visitors, (i)(F) after-sales services: ecfr.gov; 9 FAM 402.2: fam.state.gov

A summary of public documents checked on November 11, 2026; "our reading" marks interpretation. Not legal, insurance or tax advice: confirm with the state regulators' own texts and with US counsel, your broker and your tax adviser. KeepRobots rates are current published rates, before tax, and may change.

中文版：去美国客户现场修机器人之前：COI 保险证明、州承包商执照、工会场地和安全培训清单