Roco RescueTalk™

Confined Space Entry vs Bodily Enter More Than Semantics

Written by Roco Rescue | Sep 3, 2024 4:09:04 PM

Perhaps the most commonly confused topic in confined space entry that I hear out in the wild is the difference between the terms entry and bodily enter. And it makes sense because, at face value, these two things sound incredibly similar. However, when we dig a little deeper and put into context, we’ll find out that they have two entirely different meanings and applications. So, let’s dive in!

To set the stage, let’s do a quick overview of the three characteristics that define a confined space. OSHA says that a confined space is a space that:

  • Has limited means of access and egress, and
  • Is not designed for continuous human occupancy, and
  • Is large enough to bodily enter and perform work.

Remember that the space must contain all three characteristics for it to be considered a confined space. Notice the 3rd bullet point – large enough to bodily enter and perform work. We must be able to physically fit our body into the space and perform the assigned task. Now, the use of the term bodily enter stops with the definition.

Next, let’s look at what defines an entry. OSHA says an entry has occurred when any part of the entrant’s body breaks the plane of an opening into a confined space. Notice that making entry into a confined space does not necessarily mean entering with the whole body. In fact, only reaching your arm into the opening of the confined space constitutes an entry.

"So, here’s the difference. The ability to bodily enter is one of the three characteristics that define a confined space, whereas the term entry is the action of breaking the plane with any part of the body – not necessarily the whole body."

At this point, you may be thinking this is nothing more than semantics; however, this is an incredibly important differentiation.

When we understand that making entry into a confined space does not have to involve entering with our entire body, we may realize that workers in our area may have been making a lot more confined space entries than we realized. I’ve heard on numerous occasions and even seen it firsthand, where a worker sticks their arm in to turn valves or pokes their head in for a quick peek at something without going through the permit-required confined space entry procedure. After all, it’ll only take a second!

The reason this is important, and why it’s more than just semantics, is that even though a worker may be only just sticking their arm or head into a space, they could still be exposed to the hazards inside of that space. In some cases, that could have some serious consequences! For example, there may be exposed and activated rotating equipment inside of the space; so, sticking your arm or hand in may result in you being less handy around the worksite than you used to be! Alternatively, atmospheric hazards don’t just magically stop becoming hazardous right at the plane of the opening. The immediate area around the opening of the space could likely contain hazardous atmospheres as well. Sticking your head in for a quick look could be a fatal mistake.

"The time you save isn’t worth your life."

Understanding the difference between the two terms is critical for ensuring the safety of workers in and around confined spaces. The difference between the two carries significant weight, not only in definition but also in practical application. Knowing that crossing the opening of a confined space, even with just a limb, constitutes an entry and potential exposure to serious safety and health hazards is a basic fundamental concept that all workers should be well informed. So, the next time you think – I’ll just reach in and turn that valve or take a quick look – slow down and think! The time you save isn’t worth your life.

ONLINE REFERENCES:

OSHA 1910.146 PRCS

Chris McGlynn, M.S., CSP is a Certified Safety Professional and Nationally Registered Paramedic who serves as the Director of Safety and VPP Coordinator for Roco Rescue. He currently serves as Director-at-Large on the VPPPA Region VI Board of Directors and is past President of the American Society of Safety Professionals Greater Baton Rouge Chapter. Chris also represents ASSP on the ANSI Z117 Confined Space and Z390 Hydrogen Sulfide Training Standard Development Committees. He is also an active OSHA Special Government Employee within the Voluntary Protection Program.