|OSHA requirements are set by
statute, standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular circumstances, but they
cannot create additional employer obligations. This letter constitutes
OSHA's interpretation of the requirements discussed. Note that our
enforcement guidance may be affected by changes to OSHA rules. Also, from
time to time we update our guidance in response to new information. To
keep apprised of such developments, you can consult OSHA's website at
March 20, 1991
||JAMES F. FOSTER, DIRECTOR|
OFFICE OF INFORMATION AND
||RAYMOND E. DONNELLY, DIRECTOR|
OFFICE OF GENERAL INDUSTRY
||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.