CREMATION ON THE RADAR
It is indeed a good time for funeral directors to follow NFDA’s Environmental Best Practices because funeral homes no longer fly under the “environmental radar,” any firm that fails to follow these best practices risks sanction and increased expense. Thus it is critically important for funeral directors and cremation services to observe and implement them in their firm’s day-to-day operations. This article will alert you to the dangers that can result from ignoring NFDA’s nvironmental Best Practices.
NFDA’S ENVIRONMENTAL BEST PRACTICES
If you are not already familiar with NFDA’s Environmental Best Practices we want you to be. The best practices appeared in conjunction with the initial publication of NFDA’s “funeral home Wastertream Audit” in 1995 and NFDA has been fine tuning them ever since as we conduct studies and gain more information about the environmental issues funeral directors face. NFDA’s Best Practices have served as the model for state funeral service associations such as New Jersey and New York and regulators are now aware of the best practices as they find them prominently displayed in the “Environmental Protection Agency.” In fact we know of several instances when regulators visited funeral homes and brought with them their own copies of NFDA’s Best Practices. The best practices remind us that funeral directors are trained to protect the health and safety of the public, the environment in the community in which they live and their employees, families and themselves. The best practices are designed to help funeral directors meet the high standards of the funeral profession, and enable funeral directors to be the good environmental citizens that we say they are in front of congress and regulatory bodies. NFDA’s Best Practices are just that-practices that NFDA recommends our members follow-and provide guidance in five key areas of funeral home operation:
1.COMPLIANCE
A central tenet of NFDA’s Environmental Best Practices is to be aware of and follow the environmental laws that apply to funeral homes although the rules that any funeral director must observe vary somewhat from place to place. Each of the three levels of government-federal, state and local might have separate and somewhat different rules and funeral homes, like all businesses are subject to all three sets. It is each funeral director’s obligation to find out what rules apply to their funeral home and to observe them.
2. PRODUCT SELECTION’
A funeral home is regulated environmentally primarily because of the products that it uses and the way in which it deals with the waste produced. Therefore a funeral director should make wise choices about product selection, understanding not only how the product performs but also what is in the product and how various product components affect handling and disposal options and requirements. Product selection means that products should be reevaluated periodically and environmentally friendly products substituted when they become available.
3. WASTEWATER HANDLING
Funeral homes generate wastewater that might be discharged into a community treatment works or to an onsite wastewater system. Sometimes hauling wastewater offsite is required and this imposes special requirements and cautions. No matter what method of wastewater handling your funeral home uses, make sure that the system employed is properly sized, properly operating, regularly maintained and meets regulatory requirements. This includes pumping you funeral home’s septic tank no less than every three years.
4. WASTE HANDLING
Funeral homes produce a variety of wastes, including hazardous waste, medical waste, and solid waste and each type is subject to different storage and disposal requirements. Wastes of different types should never be commingled! Commingling is illegal under some laws and commingling violations subject the least toxic waste to the most onerous and most expensive requirements applicable to the most toxic waste. Therefore it is not only good practice but also incumbent that every funeral director be able to recognize the kind of waste his or her funeral home produces and to ensure that the waste is disposed of properly. This means staying informed about waste-disposal considerations, using licensed and reputable disposal firms and documenting that waste was taken to a facility-itself free of violations and in compliance-that is appropriate in keeping with the nature of the waste.
5. SPECIAL REQUIREMENTS FOR CERTAIN INGREDIENTS
Certain products historically have contained compounds such as chlorinated solvents that present a heightened risk during disposal. Such ingredients deserve special attention and it is important that products containing these ingredients should be used typically (if at all) and disposed of with special care. Being familiar with the following NFDA’s Environmental Best Practices sends an important signal that a funeral director and his or her firm take seriously their responsibilities to the community the environment and those that visit the funeral home. If regulators now know about these best practices surely a funeral director cannot say that he or she is familiar with and follows them yet raise serious questions about his or her commitment to compliance and environmental protection. Ignoring these best practices can imperil your funeral home’s livelihood and the image it presents to regulators, the public and the families it serves.
BEWARE: YOU FACE GREATER SCRUTINY
Today states and local regulators are more actively examining funeral homes and funeral home wastewater than ever before because the focus has shifted away from Federal Environmental Protection Agency (EPA) oversight and even away from oversight by the 10 individual U.S. EPA regional offices, to the communities where funeral directors live and work. This shift is due to a number of factors. First the Bush administration has caused the federal EPA to impose more on states and make them take on more environmental responsibility because of a federal budget shortfall affecting the federal EPA. Several years ago U.S. EPA region 2 in New York made funeral homes a special priority and communicated its approach widely to states throughout the country. (Regulators from different parts of the country meet throughout the
year and share stories and exchange information and funeral homes were subject to some of these discussions.) Second medical waste issues have gained heightened attention. While medical waste is generally regulated by states which have enacted their own laws its storage and transportation are regulated by the Occupational Safety and Health Administration and the U.S. Department of Transportation. Some states are considering changes to their medical waste rules in an effort to bring funeral homes within their domain. Third wastewater is inherently a local issue and tied to how much money a community has to spend on wastewater treatment and facility improvement. State and local regulators however facing their own budget reductions have increased their efforts to restrict and control discharges to groundwater in an effort to protect precious groundwater resources.
The consequence of these several factors is a shift in regulatory attention to the local area, and a corollary increase in the attention given to funeral homes. Not unexpectedly a funeral home now faces far greater scrutiny due to this smaller, local, community focus than the prior national oversight. Several recent examples from various parts of the country make this clear. For instance a municipal official in a small town in Georgia prohibited a funeral home from discharged wastewater into the town’s sewers even though the funeral home had discharged wastewater without incident for the prior 50 years. The town claimed that the content of the funeral home’s wastewater caused the town to violate its own wastewater discharge permit. This town lacked necessary funds to update and expand its treatment works, however and in the face of increased wastewater volume from the local hospital and substantial residential growth decided to prohibit the funeral home’s discharge even though the town lacked documentation that the firm caused the wastewater problems it faced! NFDA assisted this funeral home in warding off the town’s unjustified claims by helping the community recognize that this firm was a good environmental citizen and that there was no reason to restrict the funeral home’s wastewater discharge. Another example involves local regulators that refused to allow funeral homes to discharge embalming wastewater to a septic system in parts of Arkansas, New York and West Virginia. In each situation each state’s regulatory policies resulted from a lack of funding to construct the needed wastewater treatment works and regulator concern about protecting groundwater resources. In every case funeral directors were required to become familiar with waste-handling requirements and to devise alternative waste-disposal strategies to deal with these situations. One final example involves a West Virginia funeral director and NFDA’s recent efforts to help him obtain a permit for the discharge of sanitary wastewater created by his new funeral home. The permit application required the submission of 18 pages of detailed, technical information! Following the permit review, West Virginia published the draft permit in a local newspaper requesting public comment on its terms and issuance. The funeral director conducted himself admirably under the most difficult of situations causing the West Virginia regulator to recognize the funeral director as a good environmental citizen. The terms of the permit which are standard for all industrial discharges in West Virginia are far more onerous than any other permit we have examined to date.
Remember, Cremation Options here to help you all day, every day with your funeral and cremation needs. We’re open 24 hours a day, 7 days a week. To contact us, simply call 1-877-989-9090. At any time of day or night, you will be able to speak with one of our trained, sympathetic and understanding representatives.