by Marjori Todd
American Funeral Director, December, 2008

Concern for the safety of our embalmers, our staff and our family is a recurring theme that has been echoes by our clients over the 15 years Duncan Stuart Todd, Ltd. has been designing and outfitting preparation rooms in funeral homes.

Perhaps Santos Moreno in Lubbock, Texas, said it best after completion of his Lake Ridge Chapel and Memorial Designers: “The level of care we have provided for our embalmers’ well being says, ‘I support you because I respect you.’”

For Moreno, as well as our many other clients across the country, we provide guidance concerning regulatory requirements and compliance standards as part of our approach to design. The preparation room, being an area that contains hazardous materials, is subject to the Occupational Safety and Health Act of 1970. OSHA was enacted to ensure that workers are provided with safe and healthful working conditions.

OSHA has adopted several regulations that refer to the use of emergency equipment. The primary regulation is contained in 29 CFR 1910.151, which states:

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.

The OSHA regulation regarding emergency equipment does not set specifications for emergency eyewash and shower equipment. In order to provide additional guidance to employers, the American National Standards Institute developed Standard Z358.1. This standard, its most recent version adopted in 2004, is a widely accepted guideline for the proper selection, installation and maintenance of emergency equipment such as showers, eyewashes, drench hoses, etc. As clarified in a letter to Jennifer Shishido of the Hawaii Occupational Safety and Health Division on Nov. 1, 2002, “OSHA has often referred employers to ANSI Z358.1 as a recognized source of guidance for protecting employees who are exposed to injurious corrosive materials.” Since OSHA has not adopted the standard, it does not enforce the ANSI requirements. However, in a letter dated Feb. 27, 2007, to Robin Bolte of Allied Universal Corp., OSHA states, “We agree that equipment that complies with ANSI requirements would usually meet the intent of the OSHA standard.” Given these clarifications, we suggest that ANSI requirements be considered when outfitting the preparation room.

We recommend that our clients install both an emergency shower and eyewash in their preparation rooms. We consider this a best practice.

Consider these three major components of safety devices.

1. Emergency showers, eyewashes and other safety equipment needs to be easily accessible and located within 10 seconds travel time of the potential hazard.

2. Emergency equipment flushing fluid must be tepid.

3. All emergency equipment needs to be connected to a supply that will allow for a minimum of 15 minutes of operation.

The delivery of tepid water for a minimum 15 minutes of operation to emergency equipment may raise complicated engineering issues. At a minimum, it generally involves providing both hot and cold water to the general vicinity of the emergency equipment, and then installing a blending valve to mix the water to the desired temperature.

Is your preparation room equipped to respond to an emergency?

Ask yourself these questions:

1. Is the proper emergency equipment installed in your prep room? At minimum, we recommend installation of an emergency shower and eyewash. Please refer to the diagrams on these pages for additional information.

2. Does the emergency equipment work when activated? Equipment should be in good working order and meet performance specifications.

3. Is the emergency equipment tested on a regular basis? To conform to ANSI Z358.1 requirements, equipment should be tested weekly and inspected annually.

4. Is the emergency equipment properly identified? Equipment should be identified with highly visible signage.

5. Is there proper lighting near the emergency equipment? The area should be well lighted and highly visible.

6. Are your employees familiar with the operation of emergency equipment? Employees who may be exposed to hazardous materials must be instructed in the location and proper use of the emergency equipment.

In the event of an accident, the emergency eyewash and shower unit are the primary first aid equipment in the preparation room to minimize injury. However, they are not a substitute for personal protective equipment, including eye and face protection and protective clothing, or for safe procedures for handling hazardous materials. These regulations, outlined in the Occupational Exposure to Bloodborne Pathogens Standard 1910.1030, are for preventing injury.

Furthermore, funeral directors should develop a response plan to be used should an accident occur. The focus of the response plan should be to provide assistance to the injured worker as quickly as possible.

We at Duncan Stuart Todd, Ltd. trust that these performance requirements and quick tips help clarify some of the criteria for emergency equipment and provide guidelines for keeping your staff safe in case of an accident in the embalming room.

Marjori Todd and Duncan Todd may be reached at 720-583-1886 or, or visit

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