This would normally be a strange time to bring up OSHA inspections or penalties, knowing that federal and most state agencies are not inspecting retail service industries. However, we expect that to change in the next four or five months. That is when OSHA penalties will increase 80% across the board. We expect to see inspectors ring bells in every area as a way of letting people know that the sheriff has some new teeth. And these teeth bite a lot harder than the old teeth did.

  Errors, omissions and inconsistencies occur across the board, whether you have a professional or homemade compliance program. Time tends to lull the business to sleep. You have the same facility that you had twenty years ago. You do the same kind of work. Heck; you even have the same injection machine. The thing is, most of you do not have the same employees making those injections. Therein, you probably have a number of omissions.

  OSHA standards that apply to funeral homes require you to track a number of jobs in the written program. They require you to show who oversees that job and who actually does the job. For example, in the Compliance Plus “Company Safety Plan”, the Chief Safety Officer ensures that training is done, but Compliance Plus may do the actual training. They may also ensure that the hoses in the Preparation Room are periodically cleaned, but it is the Preparation Room Safety Officer that has this hands-on job.

  The tracking of responsibilities and jobs plays out in over fifty jobs in most plans. Who ensures there is protective equipment available? Who distributes it? Who trains or makes sure employees who need it know how to use it? Who is over housekeeping and who does the housekeeping work? Who buys the products required to do the housekeeping? If you track those things individually, when that key employee leaves, you probably have 30 or more changes to make in your written program.

  Professional programs use shortcuts. For example, Compliance Plus has four titles and all of these jobs can be traced back to one of the four: Chief Safety Officer, Assistant Chief, Preparation Room Safety Officer, and Housekeeping Safety Officer. Occasionally, we will add more titles to a program. The work saver here is if one of those key people should leave, we do not have to make 50 changes. Instead, we change one position on our list of Safety Officers. That new list is placed in front of the relevant chapter: Emergency Action, Formaldehyde, Hazard Communications, or Bloodborne Pathogen and Needlestick Safety.

  This is so much easier but for whatever reasons, just as many people forget to make changes in their program. I guess they have the same facility, the same preparation room, heck; they even have the same injection machine. What they don’t have is the same embalmer or Safety Officer and they have completely forgotten to make that change in their book. Now the not so good thing is that the inspector will make inspections to showcase the new penalties. Those $300 penalties will now be $500 apiece. If you forgot to designate that new employee for that former employee, there may be twenty or more jobs that are affected. Now we start to get into some real money. It often happens in multiple standards.

  How do you prevent making errors, omissions and inconsistencies? You have four months to review your program or get some help from a professional. If you don’t do it, maybe you will be lucky. I would not count on it. It’s not worth the worry. I would get it fixed now, before the penalty increase becomes effective.