One has to be able to see it coming and going (if they bother to look) for it to count as OC. This is just my opinion. If it's just the grip showing but it's at 3:00 and visible to people in front of you it's OC.
Some claim that small of the back OWB is open carry. My argument is if the guy is carrying a desert eagle in that position for an hour and you don't notice a handgun until he walks away, well that's concealing to me.