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When Safety Targets Cause More Misses Than Hits

Posted by Gary Finch on June 1, 2017

  I don’t even recall what it was in 1989 that led OSHA to promulgate the Formaldehyde Standard. It seems so long ago. I just recall that it was a crisis and it had reached the point that the government felt a need to intervene. Intervene they did. Within a few months, quick drench showers and emergency eye wash stations were in most preparation rooms. There were also signs on the entry door declaring the preparation room as a “regulated area.” That was a big mistake.

  Thirty years later, how many lives has the standard saved? Does anyone have an estimate of how much formaldehyde injury rates have dropped? Of course not. OSHA does not want that kind of information published. The standard has had virtually no effect on reducing injuries in our industry. If I may speak frankly, the standard is mostly a bunch of hooey. But we have it. And as a result, every year we train all exposed employees in formaldehyde safety.

  Ditto for the Hazard Communications Standard. That is a written program and it informs all exposed workers about toxins and other hazards. Mostly, this is about teaching employees how to read a Safety Data Sheet. In some states, annual training is required. Others require training anytime a new hazard is introduced into the workplace. I would not categorize this standard as “hooey,” but it certainly qualifies as “overkill.”

  Of all the standards that indirectly target the death care industry, I am most on-board with the Bloodborne Pathogen Standard and Needlestick Safety Standard. Annual training is repetitious but the hazards in blood are very real to embalmers and preparation room attendants. I would love to change the training requirement to every three years. This is because there is fatigue in annual training. The audience tends to tune it out. I think this is a case where less would be more.

  As I see it, every year funeral homes set aside time for annual training. They cover the basics as previously mentioned, then a few hours later, it’s time to sign off on the training certificates and we will visit this again in a year. Is this training going to help reduce injuries? Not as much as it is helping the employer as an obligatory CYA.

  If it does not help, then what would? Now that gets into real safety training. How many funeral directors age fifty and over have bad backs? When I ask that question to my safety class audience, about twenty percent of those attending raise their hands. Note to OSHA and funeral home employers, most first call attendants do not follow safe lifting procedures. Most have never been taught safe lifting techniques. That’s why we have a pandemic of back injuries and hernias being ignored while we focus endlessly on formaldehyde and other very mild workplace hazards. It is what happens when we focus on compliance and exclude everyday safety issues.

  There are other areas that should be covered. Most accidents in the funeral home workplace fit into a category known as “slip, trip and fall” safety. This can be a ten-minute PowerPoint from your OSHA advisor. Instead, the focus is on OSHA required training topics. This is counter-productive to real safety. I wish everyone would look at other areas too. If they did, it would reduce employee accidents.


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