Reduced-speed in collaborative mode

Lets say we have a collaborative application where the robot stands free. We have eliminated the risk of getting hit by the head, but we are able to get in the way of the robot with other parts of the body.
We have taken into account the Pressure and Force from Annex M.

Are we allowed to run more than 250mm/s when there are no other guards or safety functions?

I ask because the new EN ISO 10218-2:2025 states in 5.5.6.1 about “reduced-speed” that “This is a safety function where the speed of accessible moving parts shall be no greater than 250mm/s…”

As I read it, the robot in the collaborative application has accessible moving parts. And therefore this would mean that it is not allowed to run more than 250mm/s in a collaborative application?

I would appreciate some input about this.

You’re allowed to do whatever you want if you perform your own risk assessment. The standard is defining for you what “reduced speed” means. Maybe your risk assessment has deemed that the application is not dangerous at speeds above that. But in order to use “reduced mode” as a mitigation technique for identified risks, you would have to keep the robot under 250mm/s

we have done many collaborative applications with no guarding and speed upwards for 650-700mm/s. I haven’t seen the new 2025 version of the standard yet but up until this point, our safety engineer has always reviewed each application based on forces from a collision and potential danger of the tool. we did a palletizing application with a shmalz area gripper (with nice padding around it) and were able to achieve 650mm/s safely. the safety engineer came in and purposely faulted the robot with his force gauge on any of the more dangerous looking positions and took a reading. as long as that value was within the standard we were good. Proper signage and operator training and PPE are also ways to increase that speed.