OSHA furloughed ninety percent of its inspectors during the government shutdown. This has caused a significant backlog on inspection as well as complaint and accident investigations. Funeral homes were already an unlikely inspection target (except in North Carolina and Virginia). The backlog should keep our inspection rate low.

  Does this mean a funeral home can ignore OSHA requirements? It does not. While we are all but invisible as an OSHA target, there are other factors at work which make compliance essential.

1.      The workplace over OSHA’s 30 year history was largely made up of baby boomers. They saw gradual improvements in their workplace and were not likely to lodge complaints.

2.      That generation of employees feared OSHA as much as their employers did. They did not trust OSHA. They feared a complaint might result in them having to embalm in moon-gear.

3.      The next generation will not be as reticent about complaining. They don’t equate employee safety with moon-gear. Any employer that ignores safety regulations does so with peril. Any legitimate complaint lodged by an employee to OSHA will result in that employer being inspected.

4.      If an employer has written programs, policies, and training programs, it makes sense to keep them. Getting into compliance is a major expense for a small firm. Staying in compliance is not.

  I believe there are too many compliance solutions being marketed today. OSHA compliance in a box might sound like the perfect answer, but it is anything but that. When you are inspected and when you meet with OSHA for an informal conference, the box turns into a deaf mute. It does not advocate for you. It is conspicuously absent at the moment you are most vulnerable. Worst of all, it’s not a good platform to contest inspection citations.

  So while I forecast very little inspection activity over the next six months, stay compliant. Take this opportunity to improve worker safety. Employers should let employees know that safety really is a priority at your workplace. Employees should not be reticent to complain about safety issues, first to their employer. Then, if the issue is still not resolved, to OSHA.

  Most employers are OSHA compliant. It’s time to call out those who are not. The bloodborne pathogen standard is over 20 years old. The hazard communication and formaldehyde standards are even older. Whatever you might be waiting for does not wash with me and it should not wash with your employees. You need to get started yesterday.