Most funeral homes have compliance programs of some sort. They don’t get a lot of wear and tear. For the most part, they sit on a shelf undisturbed. Dust them off and they still look new. Open them up and chances are every program in that book is obsolete. Every program is non-compliant with the latest standard, be it hazard communications, formaldehyde, bloodborne pathogens and the Needlestick Safety Act, etc.
    This is not necessarily caused by longtime neglect. If a Compliance Plus customer dropped off of our customer network in September of 2013, I can tell that former customer that every program in his Company Safety Plan manual is obsolete. Every single chapter has been replaced to reflect recent changes in the various standards.
    That is how compliance works. It can sit for years without any obsolescence. Then within a few months, it is no longer able to serve its purpose. Programs that address out of date standards never make the right kind of impression on an OSHA inspector. Out of date programs make even the best employers vulnerable to malicious employee retribution. Yes, that happens.
    The conglomerate firms have their own illness and accident prevention program specialist. A few thousand funeral homes use independent consultants like Compliance Plus. This article is not for them. This article is a gentle reminder to the 15,000 other funeral homes that your written safety programs and old training programs need to be replaced or at a minimum, updated.
    OSHA is transitioning away from Material Safety Data Sheets. It’s more than deleting Material from the name. The change to Safety Data Sheets and the Global Harmonized System of Chemical Classification is substantial.
    Now that the classification of formaldehyde has changed from suspected carcinogen to a known carcinogen, all the signage and training is obsolete. If you are with Compliance Plus and have a written formaldehyde safety program, that has to be changed as well.
    Sometimes the change comes without any changes to the standard. OSHA does not interpret the Needlestick Safety Act today the same way it did under President Bush. This Act was clearly intended for hospital workers. You can use a traditional scalpel with replaceable blades, but you had best have a study from non-management employees stating they prefer that type of device.
    To me, this is just red tape. It’s what we are trained to handle. To the uninformed, red tape is something people tend to trip over. Red tape is what made your OSHA written programs and training presentations obsolete. The first thing that triggers problem solving is when you learn that you have a problem. Now you know. Most of you have a problem.