One of the topics we have debated about 1910.146 is whether (c)(5) and (c)(7) entry methods could be used simultaneously on the same space. I was a resounding “No” but since we could never get an official answer from OSHA, there were many in our profession who felt it was acceptable to use (c)(5) and (c)(7) entry methods simultaneously on the same space. Then in 2015, OSHA published their 1926 Subpart AA Confined Spaces in Construction in which they made it appear that they were allowing both entry methods could be used simultaneously on the same space. Then in 2016, they issued an LOI which lends more evidence that they intended this to be the case:
