OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

October 20, 1999

Michael Johnson
Oxy Vinyls, LP
Louisville Plant
Bells Lane, P.O. Box 34370
Louisville, KY 40232-4370

Dear Mr. Johnson:

Thank you for your September 28, 1999 letter to the Occupational Safety and Health Administration's (OSHA's) Office of General Industry Compliance Assistance (GICA). You have a question regarding the Permit-Required Confined Spaces standard, 29 CFR 1910.146. Your question is restated below for clarity.

Question. In terms of permit-required confined space entry, does "body" include all extremities (hands, feet, arms and legs) or does it indicate just the head and torso?

Reply. The term "body" refers to any part of the anatomy including all extremities.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. Please be aware that OSHA's enforcement guidance is subject to periodic review and clarification, amplification, or correction. Such guidance could also be affected by subsequent rulemaking. In the future, should you wish to verify that the guidance provided herein remains current, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850.


Richard E. Fairfax, Director
Directorate of Compliance Programs