Hazard Communication Standard Guide

The purpose of this guide is to provide enforcement guidance for compliance inspections of chemical manufacturers, importers and distributors regarding their classification of hazardous chemicals and their development of safety data sheets (SDS) and labels for chemical mixtures prepared for end-user employers, such as NFDA members.

Describes OSHA’s enforcement position on the Hazard Communication Standard as of the effective date of June 1, 2015, and addresses situations in which chemical manufacturers, due to circumstances beyond their control, have not received classifications and safety data sheet information from their upstream suppliers of raw materials. In addition, this enforcement guidance addresses the circumstances under which manufacturers and importers must develop compliant safety data sheets and labels after receiving upstream supplier safety data sheets. Additionally, the Guide answers questions related to the extension of the effective date to produce compliant safety data sheets and labels and also states that OSHA will not issue a citation against an end-user employer who has not received updated safety data sheets or labels from suppliers.

This enforcement guide clearly indicates the importance of the new provisions in the revised OSHA Hazard Communication Standard. NFDA members should confirm, with their suppliers, that they have received the most current, revised Safety Data Sheets, review each revised sheet with employees as they are received, and ensure that they are kept readily available for review and reference as required by the Hazard Communication Standard.

Whistleblower Provisions

Whistleblower provisions protect employees who report violations of various laws including workplace safety, health, environmental and consumer protection laws, among others, all of which impact funeral service.

While OSHA sees fewer overall deaths in the workplace today, the leading cause of worker fatalities continues to be motor vehicle crashes. Texting while driving dramatically increases the risk of motor vehicle crashes and is the leading cause of worker fatalities. Distracted driving crashes killed more than 5,400 people and injured nearly 500,000 in 2009.

Safe Patient Handling

OSHA’s brochure entitled “Safe Patient Handling: Preventing Musculoskeletal Disorders” focuses on safe patient handling for nursing home and residential care workers. While it does not specifically apply to funeral homes, it does provide important information for funeral professionals because musculoskeletal injuries could occur while lifting, moving or positioning human remains.

Musculoskeletal injuries can be reduced or prevented through the implementation of a safe patient handling program. In order to implement such a program, management must be committed to its execution, and it must involve hazard assessment, technology, equipment to control hazards, and training of front line workers.

While there is no specific OSHA ergonomics rule, citations for ergonomic hazards can be issued under the General Duty Clause. Therefore, funeral homes should be aware of hazards and seek to mitigate them in order to avoid being cited during an OSHA inspection.

Safer Workplace Chemicals

OSHA offers a toolkit to help identify safer chemicals that can be used in place of hazardous ones. The toolkit is designed to walk employers and workers, step-by-step, through information, methods, tools, and guidance to either eliminate hazardous chemicals or to make informed substitutions by finding a safer chemical, material, product or process. While no specific chemicals are named, the website does provide steps and advice for transitioning to safer chemicals.

The toolkit can be used by all types of businesses, including funeral homes and crematories. According to OSHA, using safer workplace chemicals provides a number of important benefits, including cost savings, promoting efficiency, establishing industry leadership and advancing corporate stewardship.

Ebola Guidance

Background information on the Ebola virus and EHF, hazard recognition, medical information, standards for protecting workers from Ebola virus, control and prevention of EHF, and provides a listing of additional resources.

Lung Dysfunction

The two guidance documents focus on the use of spirometry – a pulmonary function test that measures how well a person moves air in and out of the lungs – to detect significant changes in a worker’s lung function due to the inhalation of dust, gases or other air contaminates that, over time, can result in lung damage. Spirometry testing should be part of any physical examination, whether or not required by OSHA, for employees who, as part of their employment duties, are exposed to hazardous and toxic chemicals or inhale dust, gasses or other air contaminates. Spirometry testing can also indicate lung dysfunction caused by non-workplace conditions such as cigarette smoke and other non-workplace causes.

Employer Document – Explains the need for spirometry testing and how a screening program can be implemented.

Worker Document – Stresses the need for spirometry testing for those who are required to perform tasks that are physically demanding, require a respirator or cause exposure to possible breathing hazards.

Note: These documents are currently not available through OSHA.

Indoor Air Quality

A free educational booklet, “Indoor Air Quality in Commercial and Institutional Businesses,” addresses concerns about poor indoor air quality and the impact it has on the health of office workers and other building occupants. It provides building owners, managers, employers and workers with recommendations to prevent or minimize indoor air quality problems in commercial and institutional buildings. Funeral professionals can find specific recommendations related to air quality in the prep room in NFDA’s Formaldehyde Best Management Practices and ventilation study.

Brochure: Indoor Air Quality in Commercial and Institutional Businesses

Additional indoor air quality resources 

Funeral professionals can find specific recommendations related to air quality in the prep room in NFDA’s Formaldehyde Best Management Practices and ventilation study.

Respiratory Protection Training Videos

This series of videos (some in Spanish) educates workers about the proper use of respirators on the job and cover the following topics:

• Respiratory Protection in General Industry
• Respiratory Protection in Construction
• Respirator Types
• Respirator Fit Testing
• Maintenance and Care of Respirators
• Medical Evaluations for Workers Who Use Respirators
• Respiratory Protection Training Requirements
• Voluntary Use of Respirators
• Counterfeit and Altered Respirators: The Importance of NIOSH Certification

Read more about the Respirator Protection Standard.
Respiratory Protection Training Videos