AI & Technology

Practical Steps to Reduce Risk as AI Moves into the Physical World

By Chinh H. Pham and Andrew Cull, Greenberg Traurig, LLP

Artificial intelligence (AI) is moving beyond  abstraction and into large-scale deployment. The question for organizations is no longer whether to adopt AI, but how to embed it into products, operations, and services to create measurable value. This change is driving the rise of “Physical AI,” AI powered machines that can sense, understand, and interact with the physical world to achieve business objectives for these organizations.  

Unlike generative AI applications that exist in digital environments and produce text, images, or software code, Physical AI uses cameras, sensors, and other technologies to perceive and act within the physical world. From humanoid robots and autonomous vehicles to manufacturing equipment, drones, medical devices, and smart infrastructure, the adoption of Physical AI is increasingly influencing the way we work, interact in the real-world, and make decisions. It can increase productivity, enhance safety, optimize supply chains, and open the door to entirely new products and services. However, moving  towards the deployment of Physical AI can present a host of new operational, safety, and governance challenges. 

Physical systems can potentially introduce consequences that purely digital applications often do not. An inaccurate response from an AI chatbot may frustrate or misinform a user. However, an incorrect decision by an autonomous machine, industrial robot, or other AI-enabled device could result in equipment damage, operational disruption, or personal injury. 

These potential risks will require organizations to think ahead and consider how to deploy AI effectively, efficiently, and safely. 

Integrating Safety Features into Physical AI Systems 

Before deploying Physical AI systems, organizations should first consider how those systems are designed to operate safely in the real world. Risk mitigation begins with engineering. Technical safeguards can help Physical AI systems operate safely in dynamic, real-world environments. These measures may include physical emergency stop functions that allow operators to immediately disable a system, fail-safe mechanisms that pause operations if unexpected conditions are detected or a component fails, and operational limits that prevent systems from acting outside of their intended capabilities.  

Additional safeguards, such as continuously testing decisions made by AI against real-world conditions, maintaining human oversight, and encrypting or securing communications between connected devices, can further reduce the risk of unsafe outcomes.  

Building these protections into AI-enabled products from the outset can reduce the likelihood of accidents and mitigate legal risks. However, additional risk management considerations may be needed to further minimize legal exposures. 

Risk Management Should Begin Before Deployment 

As organizations evaluate Physical AI initiatives, risk management should become part of the development process, not an afterthought once products reach the market. While engineering safeguards provide an important first line of defense, they are only one aspect of a broader risk management strategy.  

Existing legal, operational, and governance frameworks were largely designed for conventional software and mechanical systems. AI introduces new variables, including evolving models, continuous learning, third-party components, and increasingly complex interactions between humans and machines. 

The following practical considerations can help organizations prepare for successful deployment of Physical AI systems. 

  1. Clearly Define Responsibility

One of the first questions executives should ask is, “Who is responsible when AI makes or contributes to a decision?” 

Physical AI systems often involve multiple participants, such as hardware manufacturers, software developers, AI model providers, systems integrators, distributors, and end users. Understanding the participants and how responsibilities can be  allocated along the product lifecycle will be important as systems grow more complex. 

Organizations should identify who designed the AI capabilities, who trained or supplied the underlying models, who is responsible for software updates, and who oversees ongoing monitoring and maintenance. Clearly identifying and defining these responsibilities early can help reduce uncertainty if problems arise after deployment. 

  1. Reevaluate Contracts and Risk Allocation

Many organizations developing AI-enabled products and systems rely on third-party technologies, including foundation models, vision systems, cloud platforms, or autonomous navigation software. Traditional vendor agreements may not adequately address AI-specific risks. Organizations should carefully review contractual provisions related to warranties, indemnification, limitations of liability, intellectual property ownership, cybersecurity responsibilities, and software updates. Clearly allocating responsibilities among technology providers, manufacturers, integrators, and customers helps reduce ambiguity while establishing appropriate expectations for all parties involved. 

  1. Review Insurance Coverage

Organizations should evaluate whether existing insurance programs appropriately address emerging AI risks. Traditional product liability, commercial general liability, cyber liability, and errors and omissions policies may provide some protection, but it is important to understand where gaps exist. Because AI systems often combine software, hardware, cloud services, and human interaction, working with experienced advisors can help determine whether additional coverage or policy modifications are appropriate for a particular use case. 

  1. Design for Transparency and Human Oversight

Trustworthy AI depends on a combination of reliable technical performance and transparency. It is crucial for users to understand what an AI-enabled system is designed to do, where its limitations exist, and when human intervention is appropriate. Clear operating instructions, user guidance, warnings, and documentation can help reduce misuse while improving user confidence. The National Institute of Standards and Technology’s AI Risk Management Framework emphasizes that organizations should build trustworthy AI systems that are valid, reliable, safe, secure, resilient, accountable, and transparent throughout their lifecycle. 

For many Physical AI applications, maintaining appropriate human oversight along with clear instructional guidance can provide  an important safeguard, particularly when AI recommendations influence high-impact operational flows and decisions. 

  1. Establish AI Governance Early

Organizations frequently establish cybersecurity, privacy, and compliance programs long before incidents occur. AI governance deserves similar attention. Effective governance begins with cross-functional collaboration among engineering, legal, compliance, cybersecurity, product management, and business leadership. Together, these teams can evaluate potential risks before products enter the marketplace. 

Governance programs may include testing and validation procedures, documentation standards, incident reporting protocols, model monitoring, change management processes, and periodic reviews as AI systems evolve over time. The OECD AI Principles similarly emphasize accountability, transparency, robustness, and responsible stewardship throughout the AI lifecycle. 

Responsible AI Can Become a Competitive Advantage 

Organizations that proactively address safety, governance, transparency, and accountability are often better positioned to build customer confidence, strengthen business relationships, manage risk, distinguish from competitors, and adapt to evolving regulatory expectations. 

Responsible AI should not be viewed as a compliance exercise. It should become an important component of long-term business strategy. 

Looking Ahead 

The next wave of AI innovation will increasingly occur in the physical world. Manufacturing, healthcare, transportation, logistics, infrastructure, agriculture, and consumer products are all poised to benefit from intelligent systems capable of interacting directly with people and their environments. 

With those opportunities comes greater responsibility. Organizations that identify risks early, establish thoughtful governance practices, clearly allocate responsibilities, review contractual protections, and prepare for emerging operational challenges will be better positioned to deploy Physical AI confidently. 

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