In 1987, OSHA was set to release a new standard on formaldehyde. There was a fair amount of confusion among funeral homes on what would be required. Mortuary suppliers and manufacturers were subject to the standard as well and they too were confused. Despite this, funeral homes were quick to take any and all advice they could from their suppliers.

  Nearly every supplier was providing their funeral home customers with signs to post on the front door of their preparation room.

DANGER

FORMALDEHYDE

IRRITANT AND POTENTIAL

CANCER HAZARD

AUTHORIZED PERSONNEL ONLY

  They never told you that once the notice was in place, no one could legally enter the room without a respirator. Or that the person would need a physical to first determine if they were certifiably safe and fit to don a respirator. Or that they had to first undergo respirator training and fit testing. But in one sense the suppliers were successful. They managed to get notices put on over 90 percent of the funeral homes either before or within a few months of the standard taking effect.

  Ten years later, almost a third of those signs were still in place. Today, I still see them from time to time. I also find respirators that were purchased in 1987 because the funeral home was told they were required. Over time, they have become an odor screening device.

  They are also a compliance hazard that gets tagged during OSHA inspections. If they had them, they were not subjecting employees to the required physical, doing the required fit testing or the required training. If they did not have them, they were not distributing “Appendix D” to employees that might want to don a respirator.

  Note: Providing respirators is not required if the employer has monitored their employee exposure to formaldehyde and the results were within the established threshold, and the employer has distributed “Appendix D” to the employees. Many firms do not own or provide respirators. However, they do the things that are necessary to opt out of the red tape that comes with having company owned respirators.

  So why am I writing about things that happened 25 years ago? Because formaldehyde is no longer a “potential cancer causing agent.” Now it is classified as a “carcinogen or known cancer causing agent.” By June 1, 2016, you must have new signage that reflects that. The signage covers contaminated clothing and equipment for most everyone. It covers entrances for establishments that are over the threshold limits.

  So 2016 is looking like 1987, and as much as the industry fumbled this issue then, I see a strong chance that it could happen again. It gets worse. Every funeral home employer that has not reworked their written programs and/or their employee training in the last year is now obsolete on formaldehyde, hazard communications, and the Needlestick Safety Act, which is part of the bloodborne pathogen standard.

  That is three out of three. You need to get to work on updating your programs or you need to get help. It’s important for everyone to stay on top of these changes so you don’t have 1987 déjà vu. Most of you did compliance the hard way then. Hopefully, most of you will go the easy route this time.