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provide training PRIOR to initial exposure, which means before an employee starts working in a situation where they may be exposed to blood or other potentially infectious materials. This would include all embalmers, crematory operators, removal technicians, as well as others at the funeral home involved in the handling and care of the dead human bodies. Training MUST then be provided AT LEAST yearly after the initial training. The training must provide specific details related to the exposure control plan and the post-exposure evaluation and follow-up. Each potentially exposed employee at the funeral home should have a training record containing the following: dates of training sessions, the contents or a summary of the training sessions, the names and qualifications of the persons conducting the training, and the names and job titles of all persons attending the training sessions. These training records must be maintained for AT LEAST three years from the date of the training. It is critical to be sure these trainings include ALL elements required by OSHA as specified in the Bloodborne Pathogens Standard.155 Although NOT REQUIRED by OSHA for funeral homes, a log to document sharps related injuries is highly recommended.156 If a funeral home is to keep a log, the log must include the type and brand of device involved in the incident, the department or work area where the exposure incident occurred, and an explanation of how the incident occurred.157 Personal Protective Equipment Standard OSHA has established a Personal Protective Equipment Standard (29 CFR 1910.132). Personal protective equipment is specialized clothing or equipment worn by an employee for protection against a hazard.158 Examples of this might include gloves, masks, gowns, and face shields. Personal protective equipment is only considered to be suitable and appropriate if it prevents blood or other potentially infectious substances from passing through, or otherwise reaching, the employee’s work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of time and use.159 Employers are required to provide appropriate personal protective equipment suitable for the job being done. All employers are required to make an assessment of the hazards in their workplaces, and for any hazards identified, the employer must certify that the personal protective equipment which has been selected is that which is most appropriate for the hazard and that employees have been properly trained to use the personal protective equipment.160 There are specific requirements of this standard for funeral homes. Funeral homes should consult the safety data sheets (SDS) of all chemicals used to determine proper personal protective equipment for them. If air sampling indicates that exposure to formaldehyde during embalming exceeds the limits permitted by OSHA, then a respirator that protects against formaldehyde must be worn.161 Personal protective equipment should literally cover the funeral service professional from head to toe, with absolutely no exposed skin.162 Gloves for use during Exam Question 10. Per OSHA’s Personal Protective Equipment Standard, are required to provide appropriate personal protective equipment suitable for the job being done. a. Clients b. Employees c. Employers d. None of the above 150 OSHA Compliance Guidance for Funeral Homes, 13 151-152 OSHA Bloodborne Pathogens Standard 153 OSHA Compliance Guidance for Funeral Homes, 13 154 OSHA Bloodborne Pathogens Standard 155 OSHA Compliance Guidance for Funeral Homes, 14 156 OSHA Bloodborne Pathogens Standard 157 OSHA Compliance Guidance for Funeral Homes, 14 158 Mayer, 695 159 Mayer, 54 160 OSHA Personal Protective Equipment Standard 161 OSHA Compliance Guidance for Funeral Homes, 17 12 | Funeral Service Academy COMMUNICABLE DISEASE AND FUNERAL PROFESSIONALS embalming should be of sufficient thickness to provide protection; 13 mil thickness or greater latex or nitrile gloves should be utilized.163 Also during an embalming, embalmers should wear a surgical cap, hood, or other suitable head covering with all hair being tucked up underneath the head covering.164 The embalmer’s mouth, nose, and chin should be covered by a tuberculosis rated surgical mask, as well as the embalmer’s forehead, cheeks, and neck being protected by a splash barrier such as safety glasses, goggles, or a combination face-eye shield.165 The arms, torso, and legs should be protected by a garment or combination of garments that provide suitable coverage.166 The feet should be covered by a suitable water-resistant, nonslip foot wear or water-resistant, nonslip shoe coverings.167 In addition, employers must make accommodations to clean, launder, or otherwise dispose of contaminated personal protective equipment, as well as the repair or replacement of damaged personal protective equipment.168 The personal protective equipment must be removed immediately upon leaving the work area and placed into a designated area or container for storage, washing, decontamination, or disposal.169 The five action items that go with the Personal Protective Equipment Standard are discussed below: Funeral homes must assess the tasks conducted at the funeral
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