The article - entitled 'Transsexuals should cut it out' - was removed from the paper's website by editor John Mulholland after numerous complaints and resulted in transgender rights protesters picketing The Guardian Media Group's offices in North London.
According to The Guardian, although the PCC does not usually act on third party complaints or those relating to stories without specific individual targets, they decided to open an investigation after receiving over 800 objections to Burchill's piece.
It is likely that the language Burchill used to describe the transgender community - including "a bunch of dicks in chicks' clothing" - falls under the commission's definition of "misleading or distorted terminology".
Her phrasing would also be called into question by the editors' code of practice, where a clause about discrimination states that writers "must avoid prejudicial or pejorative reference to an individual's race, colour, religion, gender, sexual orientation or to any physical or mental illness or disability".
The Observer's readers' editor Stephen Pritchard is currently conducting his own internal inquiry into how the column came to be published. The results of his investigation are due to be published in this weekend's Observer.