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Information on Robotics, Presence Sensing Devices, Ergonomics, and Hand Speed Criteria

Summary An OSHA office summarized material for agency recommendations on machine guarding, robotics, and ergonomics. It said a presence-sensing device could be considered under a de minimis enforcement policy where a machine met the safety intent of the standard, and identified a 63-inch-per-second hand-speed constant in 29 CFR 1910.217. OSHA labels the memo archival, and its referenced attachments are not reproduced on the page.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-03-20
Date issued
March 20, 1991
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Machine Guarding Robotics Ergonomics
Source
View the official document

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

March 20, 1991

MEMORANDUM FOR: JAMES F. FOSTER, DIRECTOR
OFFICE OF INFORMATION AND
CONSUMER AFFAIRS

FROM: RAYMOND E. DONNELLY, DIRECTOR
OFFICE OF GENERAL INDUSTRY
COMPLIANCE ASSISTANCE

SUBJECT: Information on Robotics, Presence Sensing Devices, Ergonomics, and Hand Speed Criteria

Attached are documents with highlighted information that may be used in order to implement recommendations 4 and 5, made to you in my letter of January 28.

The information on presence sensing devices and hand speed criteria is part of the Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.217. However, if an employer complies with the clear intent of the standard but deviates from its particular requirements in a manner that has no direct or immediate relationship to employee safety or health, the presence sensing devices and hand speed criteria may be used on any machine per the attached OSHA Instruction CPL 2.45B CH-1 on de minimis violations. The OSHA standard 29 CFR 1910.217 uses 63 inches per second as a hand speed constant.

The information on ergonomics is contained in an Ergofacts report released in 1991 by OSHA, and it applies to punch press operations. This problem could occur on any machine requiring similar movements by a person during production and machine guarding operations.

The information on robotics is derived from a draft copy (still not released) of chapter 20 of the OSHA Technical Manual.

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