OSHA's standard on permit-required confined spaces (PRCS) says entry occurs as soon as any part of the entrant's body breaks the plane of the opening into the permit space. As clarified in an OSHA Letter of Interpretation (LOI) dated October 18, 1995, "When any part of the body of an entrant breaks the plane of the opening of a PRCS large enough to allow full entry, entry is considered to have occurred and a permit is required, regardless of whether there is an intent to fully enter the space."

An OSHA LOI clarifies that there are situations where a partial entry would be hazardous: "Examples of situations where entry by only part of the body into a PRCS can expose an entrant to the possibility of injury or illness are as follows:

  1. An entrant can possibly suffer a burn while reaching into a PRCS, which is so classified because it contains a thermal hazard.
  2. An entrant can possibly fall into a below grade PRCS while standing on a vertical ladder in the opening of the space, which is so classified because it contains an oxygen deficient atmosphere.
  3. An entrant can possibly become unconscious as result of his head accidentally entering a PRCS while they are reaching into a PRCS, which is so classified because it contains an oxygen deficient atmosphere."

OSHA says examples of situations where entry by only part of the body into a PRCS would not expose an entrant to the possibility of injury or illness are as follows:

  1. An entrant reaches through the opening of a horizontal PRCS, which is so classified only because it contains exposed live electrical parts ten feet from the opening.
  2. An entrant put his head through the opening of an overhead PRCS, which is so classified only because it contains unguarded rotating parts ten feet from the opening.

Also consider a situation such as a worker reaching through a small grate to take a sample from a permit space. The LOI further states, "If a part of the body were placed in an opening through which the worker could not pass into the permit-required confined space, no PRCS entry will have occurred." Keep in mind, however, that the employee would still need protection from any hazards involved in the task, but a permit would not be needed.

Confined Spaces on KOL
KellerOnline can help to answer all of your confined space questions by providing access to OSHA regulations and letters of interpretation. Within the Confined Spaces topic in the Topic Index, you'll find a definition of exactly what OSHA considered to be a permit-required confined space, and also OSHA's training and entry requirements for those spaces.

KOL can provide citations to the regulations and guidance documents that may apply to your operations. For instance, you can reclassify a permit space as a non-permit confined space if there are no actual or potential atmospheric hazards and if all other hazards within the space are eliminated without entry into the space, under Paragraph (c)(7)(i) of the final rule. The reclassification would be valid as long as the non-atmospheric hazards remain eliminated.

When it comes to training, employers must train affected employees before initial assignment, before a change in duties, whenever changes in permit space operations present hazards on which an employee has not been trained, or whenever the employer has reason to believe either that there are deviations from the permit space entry procedures required or that the employee's knowledge of these procedures is inadequate. Employee rescue service personnel must make practice rescues at least once every 12 months. KOL's Training Center provides a variety of training materials, including classroom training, online training, and archived webcasts.