OSHA Compliance Newsletter
May 2007
OSHA Regulatory Changes
There have been no federal OSHA regulatory changes affecting funeral home operations in the past 30 days.
OSHA Inspection Activity
Indiana - Complaint - Violations/Penalties Not Stated - April 9, 2007
Topic of the Month
Respiratory Protection
 
Most funeral homes have respirators available for workers to use when warranted.  However, when is that exactly?  Respiratory protection is required by law in two primary instances:  1) excessive embalming chemical exposures, and 2) tuberculosis (TB) protection. 

Typical embalming procedures rarely result in worker overexposure to formaldehyde and other related embalming chemicals.  However, it is recommended that workers wear respirators to clean up spills of embalming fluid.  Respirators are also required when handling or embalming the deceased who have had active TB infection at time of death.  Respiratory protection from formaldehyde and other embalming chemicals requires the use of either a formaldehyde or organic vapor cartridge and respiratory protection from TB requires a particulate cartridge such as the HEPA series.

Respirators are most commonly used by funeral home personnel for removal of "odor cases", whereby the deceased has begun to decompose.  Formaldehyde or organic vapor respirator cartridges work very well in adsorbing the organic-based volatiles coming from decomposing bodies.  Without question, this is the most common use of respirators within the funeral home industry.

Over the years, we have seen a number of trade organizations, as well as, OSHA consultants neglecting this very important area of the funeral home's overall health and safety compliance program.  We're not sure if it's because of a lack of knowledge about the need for respiratory protection or a lack of general knowledge about the technical aspects of respiratory protection.  But, nonetheless, it is an important compliance issue.  The bottom line is....if you have respirators on site for employees to wear regardless of need, you have a legal obligation to ensure you have a compliant and viable respiratory protection program in place which includes worker medical approval for program participation, annual respirator fit testing, respirator inspections, and annual training.  We will elaborate more on the aspects of a proper program in future newsletters.

Questions & Answers
QUESTION:  Do I really need to test my emergency shower and eye wash weekly? 

ANSWER:  Yes.  It is required by OSHA by inference to the American National Standards Institute (ANSI) for proper care and maintenance of the equipment.

QUESTION:  Am I required to ask new embalmers to sign the hepatitis B vaccination Acceptance/Declination document and keep it on file in their confidential medical file?

ANSWER:  Yes.  All employees are to be offered the hepatitis B vaccination series free of charge within 10 days of starting work.  If they accept the funeral home's offer for the vaccine, then they must sign the "acceptance" portion of the document.  If they refuse, they must sign the "declination" portion of the document.  Either way, they must sign the document.  Once they accept, it is up to the funeral home management to follow up and ensure the employee receives the vaccination series on a timely basis.  If a new employee has previously had the hepatitis B vaccination series at a previous place of employment, you still need to have them sign the "declination" portion of the document and they need to provide you verification of their successful completion of the hepatitis B vaccination series via copies of report from physician etc.

QUESTION:  Is it true that OSHA inspectors will look inside sharps containers to see if they see capped needles?

ANSWER:  Yes.  This is not uncommon.  If they see capped needles/syringes inside the sharps container, you are subject to being fined for the practice. 

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