March 2017

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Page A18 MARCH 2017 FUNERAL HOME & CEMETERY NEWS S ec t i on A
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938
March Specials
8” Gold/Silver Crucifix
Original Price: $15.75
Sale Price: $13.40
Johnstown Hearse Rental and
Funeral Supply
Serving the funeral industry since 1954
800-452-2249
Personal Urn Cover
Available in Blue, Green,
Burgundy
Original Price: $8.25
Sale Price: $6.00
By Jim Starks, CFuE, CCrE
Jim Starks, CFuE, CCrE, is President of J. Starks Consulting in Lutz,
FL, and a nationally-recognized trainer on funeral home and crema-
tory risk management.
He used his experience in both funeral home and crematory oper-
ations and risk management, combined with his involvement with
funeral homes of all sizes and geographies, to become an author-
ity at controlling risk and loss in the death care industry, providing
lectures and presentations to private firms, as well as regional, state
and national associations. He also conducts private audits and risk
assessments to independent funeral homes and crematories in the
US and Canada, often identifying ways to save or generate thou-
sands of dollars of profit.
Jim is a Michigan and Indiana Licensed Funeral Director and
Embalmer and ICCFA- and CANA-certified crematory operator, as
well as Dean of ICCFA University’s College of Cremation Services. He
is a graduate of the University of Wyoming, the Mid-America School
of Mortuary Science, and the ICCFA University. For more information
on risk management in the death care industry, visit jstarksconsulting.
com. Contact Jim at (813) 765-9844 or
Initial Steps to
Reduce Cross-Contamination
The death care profession has changed significantly in the
past 40 years. But the concept of universal precautions when
dealing with cross-contamination is frequently overlooked.
This is important because – when ignored – the entire fa-
cility may be contaminated, creating long-term effects that
spill over to the facility’s staff and the community it serves.
The cross-contamination discussion begins with the
stretchers used to make removals. The stretchers are taken
into morgues and hospitals, long-term care facilities, and
residences to transport deceased. They are then placed in
removal vehicles, which often have carpeted flooring, be-
fore the stretcher arrives in the embalming room or an-
other area to transfer the deceased onto an embalming or
dressing table or refrigeration tray.
Addressing the cross-contamination from transportation
begins with the stretcher wheels, which must be disinfected;
they are likely the home of unknown pathogens. Next is the
Protecting
Your Families
and Business
cations must analyze their facility and develop policies
and procedures to reduce the level of possible cross-
contamination, including what areas and equipment
must be disinfected with an appropriate chemical or
treatment on a regular basis. This process must be doc-
umented when completed to maintain accountability
in the work environment.
floor in the removal vehicle. Many funeral homes use
their removal vehicle for general purposes as well. The-
oretically, anything placed in the back of the van could
be contaminated with unknown pathogens. Even the
route the stretcher is taken through in the facility must
be disinfected to prevent cross-contamination.
Continuing with the stretcher, the mattress should
be sprayed with disinfectant after each deceased is
transferred. And even as important, the stretcher
cover and the metal tubing the stretcher is made of
must be considered. Disposable gloves should always
be used when making the transfer from the place of
death, but during the transfer the stretcher is adjust-
ed with the gloves on, which can transfer pathogens
from the deceased to the frame.
This creates more problems: Many times the stretch-
er is moved without the protection of disposable
gloves, and the person does not wash his or her hands
immediately. Worse yet, he or she moves the stretcher
then handles paperwork for the deceased – paperwork
that is then taken to the office for processing.
Another opportunity for cross-contamination is
shoes worn by staff. A majority of embalmers em-
balm in their everyday shoes without any protective
covering. When they complete their work they re-
move their personal protective equipment, hopefully
wash their hands, and proceed into the general pub-
lic area with those shoes. Now the facility may be
cross-contaminated.
Because this list of opportunities for cross-contam-
ination is not nearly exhaustive, it shows only a few
ways that cross-contamination tends to happen. Lo-
ciation (NFDA) designed to increase compliance with the
Funeral Rule. All the homes found in violation during the
past two years have chosen to enter the FROP rather than
subject themselves to the possibility of an enforcement law-
suit seeking civil penalties of up to $40,654 per violation.
The FROP provides participants with a legal review of the
price disclosures required by the Rule, and on-going train-
ing, testing and monitoring for compliance. Funeral homes
that participate in the program make a voluntary payment
to the U.S. Treasury in place of a civil penalty, and pay an-
nual administrative fees to the NFDA.
The results of the FTC 2015-2016 undercover inspections
for price list disclosures by region are as follows:
• In Bakersfield, California, none of the 10 funeral homes
inspected in 2016 failed to make a price list disclosure;
• In Atlanta, Smyrna and Marietta, Georgia, one of the 10
funeral homes inspected in 2015 failed to make a price list
disclosure;
• In Detroit, Warren and Ann Arbor, Michigan, 10 of the
15 funeral homes inspected in 2015 failed to make a price
list disclosure;
• In St. Louis, Missouri, three of the 16 funeral homes in-
spected in 2015 failed to make a price list disclosure;
• In Alamogordo and Roswell, New Mexico, nine of the 14
funeral homes inspected in 2016 failed to make a price list
disclosure;
• In Bismarck, North Dakota, none of the six funeral homes
inspected in 2016 failed to make a price list disclosure;
• In Oklahoma City, Oklahoma, four of the 34 funeral
homes inspected in 2015 failed to make a price list dis-
closure;
• In Fairfax, Loudoun and Prince William Counties in Vir-
ginia, two of the 17 funeral homes inspected in 2016
failed to make a price list disclosure; and
• In Tacoma, Washington, two of the 11 funeral homes in-
spected in 2015 failed to make a price list disclosure.
Since the FROP began in 1996, the FTC has inspected
more than 3,000 funeral homes and found 530 homes
with violations. In addition, the FTC identified a num-
ber of homes, within the nine states, with only minor
compliance deficiencies. In such cases, the FTC requires
the funeral home to provide evidence that it has corrected
the problems.
The FTC educates consumers in English and Spanish
about their rights under the Funeral Rule, and provides
guidance to businesses in how to comply. For more infor-
mation, read Shopping for Funeral Services, Paying Final
Respects, Your Rights When Buying Funeral Goods and
Services, and Complying with the Funeral Rule.
The Federal Trade Commission works to promote competi-
tion, and protect and educate consumers. You can learn more
about consumer topics and file a consumer complaint online
or by calling 1-877-FTC-HELP (382-4357). Like the FTC
on Facebook, follow us on Twitter, read our blogs and sub-
scribe to press releases for the latest FTC news and resources.
FTC Undercover Inspections of Funeral Homes in
Nine States Prompt Compliance with Funeral Rule
Disclosure Requirements
WASHINGTON,DC— Federal Trade Commission investi-
gators working undercover in nine states found failures to
disclose pricing information to consumers, as required by
the FTC’s Funeral Rule, in 31 of the 133 funeral homes
they visited during 2015 and 2016.
The FTC conducts undercover inspections to ensure
that funeral homes comply with the Funeral Rule. Issued
in 1984, the Rule gives consumers important rights when
making funeral arrangements. Key provisions require fu-
neral homes to provide consumers with an itemized general
price list at the start of an in-person discussion of funeral
arrangements, a casket price
list before consumers view
any caskets, and an outer
burial container price list
before they view grave liners
or vaults. The Rule also pro-
hibits funeral homes from
requiring consumers to buy
any item, such as a casket,
as a condition of obtain-
ing any other funeral good
or service. By requiring the
provision of itemized pric-
es, the Funeral Rule enables
consumers to compare pric-
es and buy only the goods
and services they want.
Funeral homes that vio-
late the price list disclosure
requirements for the first
time can enter the Funer-
al Rule Offender’s Program
(FROP), a training pro-
gram run by the Nation-
al Funeral Directors Asso-
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