It is among the first questions I ask a prospective client.

  How many funeral homes do you operate? (Let’s just say four in this example.)

  Do you make invasive procedures at all four? “No, we only embalm at the primary location.”

  I want you to notice that the answer given was not the answer to the question that was asked.

  Are you comfortable with only having a program for the primary location? This is why I’m asking. Let’s assume you have a funeral scheduled for the second branch location. It is three hours before the funeral and you are ready to transfer the remains from the reposing room to the main chapel.

  One of your observant embalmers notices what appears to be moisture in the left lateral corner of the mouth. He gently presses on the stomach of the deceased. He now notices a trickle purge from the mouth. He determines that the remains need to be re-aspirated.

  My question to you is, “Where does this aspiration take place?”

  The prospective client attempts to brush this aside. “That rarely happens. I’ve always been told that you only had to have OSHA programs in a funeral home where you embalm. How likely is an OSHA inspector going to ask me that question?”

  Nine out of ten times, the inspector won’t ask that in their interview with you, however; the inspector is required to interview your employees. The better question is “How will your employees answer that same question on invasive procedures?”

  You may get away with not having a program in your branch locations where you do not embalm but it’s never my advice to put your employees in a position where they have to cover or lie for you. Fees for branch locations are substantially less than fees for primary locations. If you re-aspirate at a branch location, my advice is to install a secondary OSHA program for that location.