OSHA defines entry as:
“Entry” means the action by which a person passes through an opening into a permit-required confined space. Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.
Here is a tragic reminder as to why they consider the space as being enter as soon as any part of the entrant’s body breaks the plane of the spac.
At 5:00 a.m. on September 27, 2018, the employee was unloading and washing a truck tanker with water that had contained poultry blood. The employee was found unresponsive on top of the tanker with his head over the tanker opening. The employee was killed from exposure to ammonia and hydrogen sulfide vapors from the tanker truck.
Keep in mind that atmospheric hazards can be present at the opening, especially depending on where the opening is located and/or how the space is being ventilated. OSHA did NOT issue any PRCS citations as they had no evidence the worker broke the plane of the space.
Source: https://www.osha.gov/pls/imis/establishment.inspection_detail?id=1349549.015
