Recently, one of our subscribers asked the following question:
We have numerous tanks on site (mostly <2,500 gallons) that are used in food manufacturing. They are round with a manhole access. We also receive deliveries of milk in tanker trucks. Employees are required to visually inspect the tanks and tankers for cleanliness after the cleaning and rinse cycles. They do not get in the space. They use an inspection light and their head may at times break the plane of the manhole cover (head may enter the tank/tanker). If an employee has to get in the tank/tanker, it is reclassified to a NPRCS. We have not had to reclassify a NPRCS to Confined Space. So - question: Does the employee need to conduct NPRCS to inspect the tank/tanker from outside of the space if their head may break the plane?
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Here’s how we answered:
In a case when the inspector’s head may at times break the plane of the manhole cover, you must follow your established procedures (NPRCS, PRCS, etc.) for entry to a confined space.
According to OSHA’s confined space rule at 29 CFR 1910.146(b), “entry… is considered to have occurred as soon as any part of the entrant’s body breaks the plane of an opening into the space.” In your case, that occurs when the person’s head breaks the plane of the manhole.
There is an OSHA letter of interpretation that reinforces the meaning of the term “part of entrant’s body.” Check it out here.