1910.146 is pretty clear as to when “entry” has taken place, and 1926.1202 even expands the definition to make it clear that even UNINTENTIONAL breaking of the plane is an “entry. But why did OSHA say “any part of the body” and not “the head” since the majority of accidents are atmospheric related? I have written about this and point anyone interested to read the 1910.146 Preamble for a clear picture of their reasoning – it is VERY SOUND reasoning. But in this posting, I wanted to share with you how workers can die inside confined spaces even when they only PARTIALLY enter these spaces…
1910.146(b)
“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.
1926.1202
Entry means the action by which any part of 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, whether or not such action is intentional or any work activities are actually performed in the space.
In 2012 at a German brewery, there were two (2) separate confined space fatalities in two (2) separate accidents at the SAME brewery involving the SAME atmospheric hazard. BOTH workers, one was the owner, had PARTIALLY entered a vessel and were OVERCOME by carbon dioxide (CO2).
In the first incident, the owner was found dead with his head and torso in a beer-mixing tank. It is thought that, after bottling and subsequent cleaning, the owner had leaned in to check the container and was overcome by the hazardous atmosphere (e.g., CO2).
Ten (10) months later, a worker was found dead partially in a pressure tank used to recirculate wheat beer. He had probably forgotten to fit a yeast plug and had leaned into the tank – which was already pressurized with CO2 – to fit one. He was found up to his hips in the container and had been poisoned due to the high concentration of CO2.
Both of these incidents were INTENTIONAL PARTIAL ENTRIES without the proper precautions taken, and the results were two fatalities. They should be stark reminders as to why OSHA defines the entry as having occurred once any part of the entrant’s body breaks the plane of an opening into the space.
