Is a permit required to reach into a space with a tool?

If it is a permit space, OSHA considers entry to take place as soon as any part of the body breaks the plane of the opening into the space. This even includes hands and arms to reach into a permit space to use a tool or do air monitoring tests. If, for example, the space has a flammable atmosphere and using the tool causes a spark that ignites combustible dusts or flammable gases, the person at the entry could easily be injured in a fire or explosion. In other situations, the person could touch exposed energized parts near the opening or come into contact with hazardous chemicals. Of course if the person puts his or her head into the permit space, a hazardous atmosphere can cause asphyxiation very quickly.

An October 18, 1995 OSHA Letter of Interpretation (LOI) says that a partial entry without a permit, such as reaching into a permit space, would be a de minimis violation if the entrant isn’t exposed to any possibility for injury or illness. For example, a de minimis citation would be issued if the worker reached into a space that is only a permit space because it has exposed live electrical parts or unguarded rotating parts that are 10 feet away from the opening. The entrant could not contact anything hazardous by reaching in with just his arm.

If the person is reaching into a space that is too small to bodily enter, then the space does not meet the definition of “confined space,” so the standard on permit spaces does not apply. But, an employer still must provide appropriate protections for whatever hazards are in the space.