I should preface this article by letting the reader know that this is an opinion piece. Whether funeral homes should have a respirator program or should not is open to argument. I decided many years ago that most should not. That it is even questionable is what causes most funeral homes to get it wrong. They use the logic, if there is any question at all, let’s go the extra mile. It is that extra mile that opens the funeral home up to the regulatory minefield.

  Respirators are covered under OSHA 29CFR 1910.134. We generally refer to it as the Respirator Standard. It ensures that all employees are properly protected from respiratory hazards. It is up to the employer to create and maintain an individualized written respiratory protection program. The program requires a suitably trained program administrator.

  That administrator has to oversee annual training and fit testing, recordkeeping and monitoring, and new employee training. It’s a tough gig that is more often met with failure than success. Sometimes, OSHA has requirements that funeral management has no option other than to meet them. In most cases (99 percent), funeral homes are not required to have one. It is rarely required. In over 1400 examples of monitoring formaldehyde at funeral homes, none of my customers has ever been required to develop a Respirator Program. Curiously, when I see articles claiming funeral homes are required to have respirators, they are invariably from someone or some company selling respirators.

  Funeral homes buy in because they are not confident over their exempt status. They do it because they think it is better to do it than to take a chance and not do it. They originally got respirators because suppliers thought they were required. To illustrate how rare it is for a funeral home to trigger the 1910.134 requirement, let’s examine what the standard says. Here are the steps that, when all are answered in the affirmative, should cause a funeral home to get respirators and institute a program.

·         Identify the airborne particulate. In our case, formaldehyde.

·         Conduct air monitoring to determine whether employee exposures exceed OSHA’s Permissible Exposure Limit (PEL), it would be on the SDS for a product containing formaldehyde or formalin. You should already have monitoring results as part of your formaldehyde monitoring. You may opt for a group sampling since all employee exposure are exposed from the same operation (embalming).

·         If, after management has conducted the monitoring, it is determined that the workplace concentrations are above the PEL, the employer is required to implement engineering controls. You probably already have this with your preparation room exhaust system. In some jobs, management may develop job rotations to decrease employee exposure. That does not normally work in our industry.

·         If you are still in excess of the PEL, then establish a temporary respirator program until you are able to bring exposure within the allowed PEL.

The above is what OSHA requires. Now let’s take a look at what I generally find when we install a professional compliance program at a funeral home.

·         While not required to have respirators since they are under the PEL, they have them because management purchased them (thinking it was required).

·         They have had respirators for 10 years or more and never used them, or used them only as an odor control device.

·         They do not have a respirator program.

·         They may have a program but they don’t have annual fit testing or training.

·         They also fail on cleanliness and storage of the devices.

·         They fail to train new employees that have exposure in a timely fashion.

·         Instead of viewing respirators as a temporary program that allows the funeral home time to get formaldehyde exposure under control, it is now viewed and has become a permanent program.

  Even though they were not required under the standard to institute a Respirator Program, they opted to provide respirators to exposed employees. This now subjects them to the full requirements of the standard.

  I submit they would be far better off doing their monitoring, and then after they were found to be under the PEL, forego the development of a Respirator Program. I did not come to this opinion lightly. I have installed over a thousand programs and had many inspections. I’ve never had anyone cited for a respirator standard or been required to have a funeral home institute one. There are usually better options. Every few years or so, I like to point that out.