Quote:
R22 BUMPERS must be located entirely within the BUMPER ZONE, which is the volume contained
between two virtual horizontal planes, 4 in. above the floor and 12 in. above the floor, in reference
to the ROBOT standing normally on a flat floor. BUMPERS do not have to be parallel to the floor.
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Emphasis is mine, the bumpers don't even have to be parallel to the floor, they just have to exist, in the correct construction per the other bumper rules, between 4 and 12 inches from the ground.