While providing remediation project oversight for an excavation and stream-channel restoration project at a former manufactured gas plant (MGP) site, Apex had to deal with a utility vault approximately 4 feet deep and accessed by removing a cover for an approximately 3 foot by 3 foot opening.
Questions were raised as to various scenarios of entering the vault, versus remaining outside the vault entirely and as to what activities would consist of "breaking the plane" for the purpose of working on utilities within and/or collecting air sample measurements within the vault.
Our Corporate Health and Safety Manager clarified that ANY body part entering such a space is considered "breaking the plane." However, rather than treating the activity as a full-fledged permit-required confined space, it was determined that a most appropriate and cost-effective approach for activities within this shallow vault would be to provide air ventilation, continuous air monitoring and a means of egress (ladder), such that the space might be reclassified as non-permit required and documented appropriately.
Make sure to encourage your staff to initiate a dialogue from the field for appropriate evaluation of potential confined space areas at your sites. Resolution can be achieved quickly with good identification and communication.