Quick Tips #280
The
Occupational Safety and Heath Administration (OSHA) has no standard
specific to funeral homes. There are several regulations, however,
within OSHA's Industry Standards Code of Federal Regulations (CFR) Title
29 Part 1910 that apply to funeral homes. This document reviews the
standards funeral home operators must follow to maintain a safe work
environment.
As of 2013, there are
19,486 funeral homes in the United States. As with any workplace,
funeral homes present a variety of occupational hazards.
Funeral-affiliated employers must address these hazards to ensure their
employees have a safe work environment. The OSHA act states that each
employer shall furnish to each of his employees a place of employment
which is free from recognized hazards that are causing, or are likely to
cause death or serious physical harm. It also requires that employers
comply with occupational safety and health standards promulgated under
OSHA.
Who's Covered By OSHA?
Any
employer with one or more employees is covered, and can be cited under
the OSHA Act of 1970. In addition, employers with 11 or more employees
are required to comply with OSHAs Recording and Reporting Occupational
Injuries and Illness (29 CFR 1904) requirements. Under 29 CFR 1904,
employers are required to maintain occupational injury and illness
records. The purpose of maintaining these records is to:
- Provide injury and illness information which is used by OSHA to measure and direct the agency's efforts
- Enable employees and employers to identify types and causes of injuries and illnesses at each establishment
- Make employers and employees more safety conscious
- Encourage employee and employer cooperation
(For more information on OSHA's recordkeeping requirements, refer to Quick Tips #183, OSHA Reporting Requirements.)
Funeral Homes and OSHA's General Industry Standards
A
number of occupational activities performed in funeral homes fall under
OSHA's General Industry Standards. These general industry standards are
discussed in this document. Funeral home operators must be aware of the
following regulations in order to stay compliant.
The Right-To-Know Law
The
Right-To-Know Law, officially known as The Hazard Communication
Standard 29 CFR 1910.1200 was enacted November 25,1983, by OSHA. Its
purpose is to ensure that chemical hazards in the workplace are
identified and evaluated, and that the information concerning these
hazards is communicated to both employers and employees. This transfer
of information is to be accomplished by means of a comprehensive hazard
communication program that includes container labeling and other forms
of warning including Safety Data Sheets (SDSs) and employee training.
(Refer to Quick Tips #150 for detailed information on the Hazard Communication Standard and Quick Tips #374 on Globally Harmonized System (GHS).)
OSHAs Bloodborne Pathogens (BBP) Regulation (29 CFR 1910.1030)
This
regulation applies to all individuals who may reasonably anticipate
contact with blood or other potentially infectious bodily fluids in the
course of their employment. This includes contact with skin, eyes,
mucous membranes or contact from piercing the skin. The focus of the
regulation is the creation of a written Exposure Control Plan that
describes how the employer will protect employees from exposure (See Quick Tips #105 for additional information on the BBP Standard.).
Personal Protective Equipment (PPE) Standards
A
key component of the PPE Standard is the hazard assessment of the work
area as required under the General Requirements. According to OSHA,
under 1910.132(d) Hazard Assessment and Equipment Selection states that
the employer shall assess the workplace to determine if hazards are
present, or are likely to be present, which necessitate the use of
personal protective equipment. If the assessment determines that hazards
are present, or likely to be present, the employer shall:
- Select and have each affected employee use PPE that will protect from the identified hazards
- Inform each affected employee of the selection decision
- Select PPE that properly fits each affected employee
- Document
that the hazard assessment has been performed through a written
certification that identifies the workplace evaluated; the person
certifying that the evaluation has been performed; the date(s) of the
hazard assessment
In addition, the employer is also required to train the affected employees on the proper use of the selected PPE (For more information on PPE Standard request Quick Tips #240.).
Respiratory Protection Program
This
program ensures that all employees are properly protected from
respiratory hazards. According to 29 CFR 1910.134, creating and
maintaining an individualized written respiratory protection program is
the responsibility of all employers who provide respirators to their
employees. The program must be administered by a suitably trained
program administrator.
When
establishing a Respiratory Protection Program, the funeral home operator
must first identify what airborne contaminants are present. The SDS
required under the Hazard Communication Standard contains this important
information. Once the contaminants are identified, the operator will
need to conduct air monitoring to determine whether employee exposures
exceed OSHA's permissible exposure limit (PEL) for the identified
contaminant(s). The established PEL(s) are also printed on the SDS.
If,
after conducting the air monitoring, the employer determines
contaminant concentrations are above the PEL, the employer must
implement engineering controls (ventilation systems) or administrative
controls (job rotations) to reduce the employee exposure. If neither of
these options are feasible, the employer must then provide appropriate
respiratory protection to the employee. Assigned respiratory protection
must be approved by National Institute of Occupational Safety and
Health (NIOSH) for the contaminant(s) present (For more information on establishing a Respiratory Program refer to Quick Tips #195.).
Formaldehyde and Glutaraldehyde Regulations
Formaldehyde
and glutaraldehyde are two common hazardous materials used in funeral
homes. Formaldehyde use is regulated under a specific OSHA standard, 29
CFR 1910.1048 and was established to protect workers from occupational
exposures to formaldehyde. It defines an Action Level, a PEL and a
Short-Term Exposure Limit (STEL) for formaldehyde exposure in the
workplace. The following are the established airborne concentrations for
each of these levels:
- Action level: Airborne
concentration of 0.5 parts per million (ppm) formaldehyde. If this level
is exceeded, the employer must perform periodic air monitoring until
the levels can be reduced below this point (29 CFR 1910.1048 (b))
- PEL: Airborne concentrations of 0.75ppm formaldehyde as an 8 hour time weighted average (29 CFR 1910.1048 (C)(1))
- STEL: Airborne concentration of 2ppm formaldehyde over a 15 minute time interval (29 CFR 1910.1048 (C)(2))
All
employers who have any form of formaldehyde in the workplace must
monitor employee exposure unless they can objectively document that the
presence of airborne formaldehyde will not exceed the action level or
STEL under foreseeable conditions (29 CFR 1910.1048 (d) (1)). If this
cannot be done, the employer must begin monitoring.
Initial
monitoring is accomplished by identifying all employees who potentially
have an exposure at or above the action level or STEL. Each potentially
exposed employee may be monitored, or a representative sampling plan
implemented for each job classification and work shift. Monitoring must
occur each time a change in equipment, process, production, personnel,
or control measures is instituted (29 CFR 1910.1048 (d) (2)). If
formaldehyde concentrations are revealed at or in excess of the action
level, monitoring must be repeated every 6 months. If the monitoring
shows levels at or above the STEL, annual monitoring is required (29 CFR
1910.1048 (d) (3)).
Monitoring can be
discontinued if after two consecutive sampling periods (taken at least
seven days apart) airborne concentrations are below both the action
level and STEL (29 CFR 1910.1048 (d) (4)).
Glutaraldehyde,
which is not covered under a specific OSHA standard, is still a
hazardous material with established exposure limits. NIOSHs
recommended exposure limit (REL) for glutaraldehyde is a ceiling limit
of 0.2 ppm. This exposure level should not be exceeded at any time.
Another organization that establishes chemical exposure limits is the
American Conference of Governmental Industrial Hygienists (ACGIH). The
ACGIH has reduced their ceiling limit to a more conservative level of
0.05 ppm (Additional information on glutaraldehyde awareness is available on Quick Tips #174.).
Eye/Face and Wash/Shower Requirements
When
it comes to emergency eye/face wash and shower requirements, OSHA has
two different types of regulations, general and specific. Funeral homes
fall under the general requirements that are located in OSHA's First Aid
Standard under 29 CFR 1910.151(c). This standard states where the eyes
or body of any person may be exposed to injurious corrosive materials,
suitable facilities for quick drenching or flushing of the eyes and
body shall be provided within the area for immediate emergency use.
The
performance guideline for emergency drenching equipment that OSHA
recognizes is the American National Standards Institute's (ANSI)
Z358.1-1998. This Emergency Eye Shower and Wash Equipment standard aids
employers in selecting and installing emergency equipment to meet OSHA
requirements (For more information on this ANSI standard see Quick Tips #120.).
Medical and First Aid Regulations
In
1998, OSHA revised its Medical Services and First Aid regulation, 29
CFR 1910.151. The revision states; In the absence of an infirmary,
clinic, or hospital in near proximity to the workplace which is used for
the treatment of all injured employees, a person or persons shall be
adequately trained to render first aid. Adequate first aid supplies
shall be readily available. Included in the revision was Appendix A, a
non-mandatory guideline that contains examples of minimal contents for
first aid kits.
This appendix is taken
from the ANSI Z308.1-1978, Minimum Requirements for Industrial
Unit-Type First Aid Kits; it identifies the fill content that should be
adequate for small worksites. The employer is responsible for
determining the need for additional first-aid kits, quantities and the
types of supplies at the worksite for large/larger worksites (Quick Tips #208 has more information on first aid kits.).
Chemical Compatibility Concerns in Storage
Chemicals
play an important role in many workplace applications. The inherent
hazards of chemicals can be reduced by minimizing the quantity of
chemicals on hand. However, when chemicals must be in-house, proper
storage and handling can reduce or eliminate the associated risks.
Proper storage information can usually be found on the chemical's SDS. The SDS will answer questions such as:
- Is the chemical a flammable or combustible?
- Is the chemical a corrosive?
- Does the chemical need to be stored at a temperature other than ambient?
- Is the chemical an oxidizer or reducer?
- Is the chemical light sensitive?
- Does the chemical require any special handling procedures?
Proper
segregation of chemicals is necessary to prevent incompatible materials
from inadvertently coming into contact with each other. If incompatible
materials come into contact, a fire, explosion, violent reaction or the
creation of toxic gases can result.
When
segregating chemicals, acids should not be stored with bases and
oxidizers should not be stored with reducing agents or organic
materials. A physical barrier and/or distance is effective for proper
segregation.
If cabinets are used to
segregate chemicals, consider the compatibility of the chemicals with
the cabinet itself. For example, corrosives like strong acids and
caustics will corrode most metal cabinets. Non-metallic or epoxy-painted
cabinets are available and will provide a better service life with
these corrosive materials.
Safety
cabinets are specifically made to maintain flammable and combustible
materials. It's important to be aware of maximum allowable container
size and maximum quantities for storage in cabinets based on the class
of the flammable. The class of a flammable or combustible is determined
by its flash point and boiling point (For more information on flammable and combustible liquids, see Quick Tips #179 and Quick Tips #180.).
Disposal of Hazardous Waste
The
disposal of hazardous waste varies from State to State and even between
municipalities within the State. To validate that you are in compliance
within your local requirements, you may want to contact your
waste-water treatment plant.
While
this document identifies the OSHA standards that apply to funeral homes,
additional guidance may be necessary in interpreting how these
standards apply to a specific situation. Your state OSHA Consultation
Project (see Quick Tips #185)
and the National Funeral Directors Association (NFDA) are resources for
this information. The NFDA has an OSHA Support Line that's available to
its members.
For information on NFDA membership, you can access their website at http://nfda.org/about-nfda-/membership-information.html or call 1-800-228-6332.
Sources
(Rev. 6/2014)
