Funeral Home OSHA Safety Requirements

by Mark Harrison March 27, 2021

Funeral homes can be risky places. Between helping families grieve, running a business, and ensuring you are keeping up with the latest trends, finding time for safety and funeral home OSHA compliance can be difficult. An unsafe workplace can lead to many challenges and OSHA fines. It is critical to ensure your funeral home and funeral home employees address the workplace hazards to ensure your business runs smoothly and you can continue to help your customers in their time of need.

We interviewed more than 100 funeral homes in the U.S. and found that less than half of them are in annual compliance with OSHA.

What follows is a concise overview of the core funeral home OSHA requirements. Certified Safety Training is here to answer your questions, provide you with plans, resources, and training, to ensure that safety remains a top priority for you without detracting from servicing your customers and business. You can purchase a Full Funeral Home Self-Guided OSHA Compliance Program here. What follows is an outline of everything OSHA requires of funeral homes.

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The Federal Occupational Safety and Health Administration or OSHA operates within the United States Department of Labor. OSHA’s mission is “to ensure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance.” Several states have their own OSHA standards and/or occupational safety and health programs. All states, regardless of whether or not they have their own state OSHA program, must adhere to regulations as strict or more strict than federal OSHA.

Several activities in funeral homes fall under OSHA’s General Industry Standards. The most relevant funeral home worker safety is control of infection and working with hazardous chemicals, such as embalming fluids containing formaldehyde or formalin, and many other hazardous chemicals that are often present in the workplace.

OSHA and Funeral Homes

Funeral homes must follow applicable OSHA regulation to remain in compliance with OSHA. The Occupational Safety and Health Act of 1970 empowers OSHA with full authority to issue citations and penalties to covered employers with one or more employees if they are found to be in violation. The average OSHA fine for a funeral home was more than $4,000 in 2019. Here is a summary to help you stay in compliance with OSHA.

OSHA Hazard Communication Standard for Funeral Homes

The Hazard Communication Standard (29 CFR 1910.1200) was created to ensure that chemical hazards in the workplace are identified and evaluated, and that the information concerning those hazards is communicated to both employers and employees. Here are the general requirements of OSHA’s Hazard Communication Standard:

Provide a written Hazard Communication Program specific to your facility. The written program does not have to be long and technical, but it must be in writing.
Provide a master list of all hazardous chemicals used at your facility.
Ensure that containers of hazardous chemicals are properly labeled.
Obtain a Safety Data Sheet (SDS) for each hazardous chemical covered by the standard and used at the facility.
Train all affected employees about the hazardous chemicals with which they work.

Meet all of the OSHA Hazard Communication Standard (29 CFR 1910.1200) requirements including a Hazard Communication Written Plan, Hazardous Communication List and Chemicals, Material Safety Data Sheets, and Online Training with Certificates, by purchasing Certified Safety Training’s OSHA Hazard Communication Program.

OSHA Bloodborne Pathogens Standard for Funeral Homes

The Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to all workplaces in which employees may have contact with blood or other potentially infectious materials. The purpose of the BBP Standard is to reduce exposure and transmission of blood and body fluids to employees to prevent the contraction of diseases that can have severe consequences. One primary focus of the standard is the creation of a written BBP Exposure Control Plan. Here are the general requirements of OSHA’s Bloodborne Pathogens Standard:

Here are the general requirements of OSHA’s Bloodborne Pathogens Standard:

Each funeral home that conducts embalming must develop a written BBP Exposure Control Plan designed to minimize or eliminate employees’ exposure to bloodborne pathogens.
Hepatitis B vaccinations must be offered to all employees who are potentially exposed, unless the employee has previously received the complete hepatitis B vaccination series, antibody testing has revealed that the employee is immune or the vaccine is contraindicated for medical reasons.
The employer must document annually the consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure. Obtaining input from affected non-managerial staff members is also required documentation.
Documented annual review and update of the Exposure Control Plan is required.
A post-exposure evaluation and follow-up procedure must be in place in the event of an employee’s exposure to blood or OPIM (Other Potentially Infectious Material), such as a puncture wound from a suturing needle.
Employees must use at least Universal Precautions, as defined by OSHA, with all procedures that entail the possibility of exposure to blood or OPIM. Universal Precautions assumes that all human blood and certain body fluids are treated as if known to be infectious.
Drinking and eating are not allowed in the embalming room and other work areas where there is a reasonable likelihood of exposure to blood or OPIM.
The facility must have a written housekeeping schedule for those areas that may be contaminated with blood or OPIM.
Only disinfectants or sterilants that are EPA registered or FDA cleared may be used to decontaminate surfaces or instruments that have been contaminated with blood or OPIM.
Tongs, forceps or other appropriate engineering controls must be used to reach into cleaning containers to pick up reusable sharps.
Scrub sponges and other potentially contaminated instrument cleaning tools must be properly disinfected and stored.
A biohazard warning label must be attached to containers of potentially infectious material.
Waste cans used for containment of biohazards must be lined with biohazard bags. The regulated waste must be placed in a container that is closable.
Sharps containers must be easily accessible to personnel and located as close as feasible to the immediate area where sharps are used.
Employees with occupational exposure to bloodborne pathogens must be trained on the safety procedures related to blood or OPIM.
A sharps injury log is used to record injuries resulting from sharps.

Meet all of OSHA’s Bloodborne Pathogen (29 CFR 1910.1030) requirements including a Bloodborne Pathogen Written Plan, Exposure Determination, Personal Protective Equipment (PPE), Personal Protective Equipment (PPE) Disposal, Housekeeping and Laundry Plans, Decontaminants, and Online Training with Certificates, by purchasing Certified Safety Training’s OSHA Bloodborne Pathogen Program.

OSHA Personal Protective Equipment Standard for Funeral Homes

The Personal Protective Equipment (PPE) Standard (29 CFR 1910.132 Subpart I) requires that personal protective equipment be utilized for many tasks performed in funeral service settings, such as preparation rooms. Coveralls, shoe covers, gloves, chemical goggles, face shields, head covers, surgical masks and respirators all have application in funeral service settings. Coveralls, aprons or gowns need to have full sleeve coverage and be impervious to blood, formaldehyde and other chemical agents. Here are the general requirements of OSHA’s Personal Protective Equipment Standard:

The employer must perform a job hazard assessment for the tasks conducted at the funeral home to determine what PPE is needed. A written certification of this assessment is required.
Employees required to wear personal protective equipment must be trained in the proper use of that equipment. Again, a written certification that workers have received and understood this training is required.
Gloves and eye protection designed for protection against the hazards found in the embalming room are required.

Meet all of OSHA’s Personal Protective Equipment Standard (29 CFR 1910.132 Subpart I) requirements including a job hazard assessment and Online Training with Certificates, by purchasing Certified Safety Training’s OSHA Personal Protective Equipment Standard Program.

OSHA Respiratory Protection Standard for Funeral Homes

Whenever respirators are required in the workplace, the requirements of the Respiratory Protection Standard (29 CFR 1910.134) are triggered. There are two basic classes of respiratory hazards encountered in funeral home settings. Hazards may be in the form of particulates, such as flu viruses, droplets containing tuberculosis bacteria, etc., or they may be in the form of organic vapors, such as formaldehyde.

Generally speaking, a respirator that is suitable for most biological particulates (respirators such as N95s or Powered Air Purifying Respirators) provides no effective protection for organic vapors and vice versa. There are very expensive respirators on the market that are capable of providing protection against both of these types of hazards, but such respirators are not generally encountered in funeral homes. Here are the general requirements of the Respiratory Protection Standard:

A written Respiratory Protection Program and a qualified administrator are required.
All employees required to wear a respirator must be medically evaluated to ensure that the respirator does not place an undue physiological burden on an employee’s health.
If the use of respirators is required because the permissible exposure limit for formaldehyde has been exceeded, then it is a requirement of the Formaldehyde Standard that the affected worker must receive not just a medical evaluation but rather a medical examination annually.
The Formaldehyde Standard also requires that the cartridge for a respirator used for protection from formaldehyde must be changed after at least every three hours of use.
Employees must be fit-tested with the same make, model, style and size of respirator that will be used. Fit testing must be repeated at least annually, and records must be kept.
Training in respirator use must be provided annually, and records of the training must be kept.
For situations where a respirator is not required but an employee chooses to wear one on a voluntary basis, the employee must still be provided with the information included in Appendix D of the standard, and the employer must ensure that the employee is medically evaluated and cleared to use the respirator.

Meet all of OSHA’s Personal Protective Equipment Standard (29 CFR 1910.132 Subpart I) requirements including a job hazard assessment and Online Training with Certificates, by purchasing Certified Safety Training’s OSHA Respiratory Protection Program.

OSHA Formaldehyde Standard for Funeral Homes

Formaldehyde/formalin is a common hazardous chemical used for embalming. This chemical is specifically regulated by OSHA and has its own OSHA standard (29 CFR 1910.1048) that sets maximum exposure levels and monitoring requirements, and requires engineering controls designed to protect workers from the negative effects of formaldehyde exposure. Here are the general requirements of OSHA’s Formaldehyde Standard:

Measurements of the level of exposure to formaldehyde during embalming must be taken. Two measurements are required: a Time-weighted Average (TWA) and a Short-term Exposure Limit (STEL). TWA and STEL measurements are done by wearing a dosimeter badge and are different from measurements taken with a detector tube. Detector tubes provide measurements on the spot, but they are not the same thing as Time-weighted Average or Short-term Exposure Limit measurements required by the standard. TWA and STEL measurements are made over a period of time and are not spot measurements. They require mailing the personal dosimeter to a laboratory for analysis.
Affected employees must be notified of the monitoring results.
Engineering controls, such as an effective ventilation system, must be utilized, along with work practice controls to minimize exposure to formaldehyde so that exposure is below the Action Level of the standard.
Annual formaldehyde safety training must be provided.
Protective clothing and personal protective equipment must be provided.
A change room must be provided.
A medical surveillance program is required if exposure at the Action Level or Short-term Exposure Limit occurs or whenever employees show signs or symptoms of overexposure to formaldehyde no matter the level of measurement.
An emergency eyewash and drench shower in the embalming room must be provided.
Although not specifically mandated, work facilities using other chemicals, such as glutaraldehyde, will also benefit from exposure monitoring to determine level of exposure.

Meet all of OSHA’s Formaldehyde Standard (29 CFR 1910.1048) requirements including a Time-weighted Average (TWA) and a Short-term Exposure Limit (STEL) and Online Training with Certificates, by purchasing Certified Safety Training’s OSHA Formaldehyde Program.

OSHA Fire Extinguisher Training Standard

OSHA does not strictly require portable fire extinguishers in most general-duty workplaces. However, not having a fire extinguisher presents a serious safety risk. If portable fire extinguishers are present in a workplace, then several OSHA requirements (29 CFR 1910.157) become active. If portable fire extinguishers are present, they must:

Be properly mounted.
Be properly identified.
Have a current annual inspection tag in place.
Be of the appropriate rating type, usually Type ABC for most funeral service settings.
Have a SDS (Safety Data Sheet) available if the fire extinguisher itself is pressurized or contains any hazardous chemicals.

Fire extinguishers must be inspected monthly by the employer, and it is a best practice to record those monthly inspections. The biggest requirement for portable fire extinguisher use, however, is that annual training must be provided by the employer for all employees who are expected to use portable fire extinguishers.

Medical Services and First Aid Regulation in Funeral Homes

The simplest of all OSHA standards; the federal version (29 CFR 1910.151) has just four sentences. However, there is a lot of information covered in those four sentences. Here is an overview of each:

The first topic covered is medical services or first aid. The standard requires that if there is not an infirmary, clinic or hospital in near proximity, then an employee is required to be adequately trained to render first aid. In addition, adequate first aid supplies must be readily available.

How does OSHA define “near proximity”? The general rule is that if an injured worker requiring first aid cannot receive it within three minutes, a person is required to be trained to provide such first aid in the workplace.

You can make sure that a person is adequately trained to render first aid in your facility by having him or her take a short course provided by such organizations as the Red Cross, local community colleges, etc. Here is a full list of what OSHA deems adequate for first aid supplies for a small organization:

1. Gauze pads (at least 4 x 4 inches).

2. Two large gauze pads (at least 8 x 10 inches).

3. Box adhesive bandages (band-aids).

4. One package gauze roller bandage at least 2 inches wide.

5. Two triangular bandages.

6. Wound cleaning agent such as sealed moistened towelettes.

7. Scissors.

8. At least one blanket.

9. Tweezers.

10. Adhesive tape.

11. Latex gloves.

12. Resuscitation equipment such as resuscitation bag, airway, or

pocket mask.

13. Two elastic wraps.

14. Splint.

15. Directions for requesting emergency assistance.

The second topic of the federal standard that deals with eyewashes and drench showers is even shorter, just a single sentence. To properly explain all of the things that should be incorporated into an eyewash and drench shower would require a separate article. The best management practice, therefore, is to make sure that your eyewash and drench shower comply with the current ANSI standard Z358.1. Although this ANSI standard has not been formally incorporated by reference into the federal OSHA Standard, some state OSHA plans have formally incorporated various editions of the ANSI standard over the years. But whether your workplace is in a state that has formally adopted the ANSI standard or not, the best management practice is to comply with ANSI requirements. Doing so will ensure that you go beyond OSHA’s minimal requirements.

OSHA Walking and Working Surface Safety Standard for Funeral Homes

Tens of thousands of workers are injured each year in slips, trips and falls. This is the number one injury reported by OSHA year after year. The Walking and Working Surfaces Standard (29 CFR 1910.21 Subpart D) are fairly intuitive, however, during stressful times, people often forget basic safety protocols. General requirements of the Walking and Working Surfaces Standard include:

Ensuring that walkways are well lit, have non-slip surfaces and are free from obstructions.
Cleaning up spills immediately and displaying warning signs, when appropriate.
Ensuring that staff members avoid steps, stairs and uneven surfaces when carrying or moving loads.
Making sure that any floor openings and holes are properly covered or repaired.