The following questions and answers are meant to serve as guidelines and best practices based on the recommendation of others. All answers are recommendations and suggestions and based on the information available at the time of posting. PLEASE make sure you consult any state or local references or authority as many issues are being monitored and decided on the state and local level.
Additionally, as we learn more, some of these answers may need updates, so please share with us any other information as well as questions that you think will be valuable to all of our members. We know this is a difficult and confusing time – the goal of these questions are to help all deathcare professionals answer their specific questions as they are happening.
April 23, 2020
Question: Are deathcare professionals (funeral homes, cemeteries and crematories) exempt under the newly created paid sick leave and expanded family and medical leave under the Families First Coronavirus Response Act (“FFCRA”)?
Answer: Recently, under the Families First Coronavirus Response Act (FFCRA), the right to Emergency Paid Sick Leave was widely expanded for American workers during the pandemic. Although the provisions of FFCRA apply to any employer with UNDER 500 employees automatically, the expanded FFCRA also allows employers with under 50 employees the chance to opt out of FFCRA upon applying for a waiver to the Department of Labor (DOL).
ICCFA has been working with the DOL in an effort to clarify that deathcare workers and supporting industries are included as exempt. As of the time of this writing, the DOL, as well as other deathcare associations, have agreed verbally that those in the deathcare profession would be part of the ‘emergency responder’ classification outlined by the DOL.
This is based on the interpretation that due to the essential role deathcare professionals play, they are emergency responders for purposes of new paid sick and expanded family leave benefits created by the Families First Coronavirus Response Act (FFCRA). This interpretation is based on DOL guidance on FFCRA, where the DOL describes ‘emergency responders’ as anyone that transports COVID-19 patients and also provide specific care in a declared emergency. The deathcare profession continues to transport and handle bodies affected by COVID-19 and, under U.S. Department of Homeland Security, through its Cybersecurity and Infrastructure Security Agency (CISA), deathcare professionals are recognized as health care workers under critical infrastructure guidance to states.
Through this interpretation, deathcare professionals, funeral homes, cemeteries, as well as crematories, would be classified as exempt, allowing access to all of their resources, including man and woman power, to handle COVID-19 victims and other decedents. While this interpretation has not been put in writing from the DOL, ICCFA continues to work with the DOL on the issue.
April 13, 2020
Question: Am I at risk if I go to a funeral or visitation service for someone who died of COVID-19?
Answer: There is currently no known risk associated with being in the same room at a funeral or visitation service with the body of someone who died of COVID-19.
We encourage the remains to be embalmed and disinfected, reducing risks to the general public and family exposure. Embalming is an effective measure of disinfection and has unofficially proven to reduce the virus’s sustainability in a dead host. It is still recommended that PPE be worn when handling an embalmed COVID-19 case (suspected or confirmed) as data is inconclusive if the virus remains volatile in an embalmed body.
Some funeral homes are offering gloves and masks to family so they may come in contact with the embalmed remains while they say their good-byes.
April 13, 2020
Question: Can a case that died of COVID-19 be open casket for the viewing for family members?
Answer: Absolutely, and many in our profession are already doing this. The WHO and CDC both state that remains can be viewed, just not touched.
Is there a way that death educators can help funeral homes if/when they get inundated with people needing their services?
April 1, 2020
Question: Is there a way that death educators (not a funeral home staff member) can help funeral homes if/when they get inundated with people needing their services?
Answer: We anticipate that certain states which have high impact zones – or hotspots – will be posting certain needs and ways people can be of service to essential businesses like deathcare. This could possibly become a licensing issue, and for that reason each state will handle things differently. ICCFA is following these updates and posting them on the State Orders section of our COVID-19 resource pages. We anticipate that many states will be updating filing requirements, as well as other operational aspects that are state regulated. We recommend that you follow your state licensing agency, and please forward any such notices to ICCFA (email@example.com) so we can keep all of our members updated. If you are an ICCFA member in need of help, or if you want to offer your services, please submit it in our COVID-19 Q&A portal and we will start a running list to try and connect those in need.
April 1, 2020
Question: Has the deadline for pre-need renewal been extended? My report is not done and my account is closing for 2 weeks to comply with the Stay at Home Order issued for Osceola and Orange counties in Florida.
Answer: Each state is handling licensing issues differently. ICCFA is following these updates and posting them on the State Orders section of our COVID-19 resource pages. We anticipate that many states will be updating filing requirements, as well as other operational aspects that are state regulated. We recommend that you follow your state licensing agency, and please forward any such notices to ICCFA (firstname.lastname@example.org) so we can keep all of our members updated.
Updated March 26, 2020
Question: We have zero N95 masks and there are none available. Do deathcare providers have a way of receiving them from authorities since retail is not helpful at this point? And what about other PPE, how do we get these needed supplies if we are essential?
Answer: Currently, all Personal Protective Equipment (PPE) is scarce and difficult to obtain. As deathcare providers continue to assist in this crisis, they, like other frontline providers, are having difficulties obtaining necessary PPE. While the Federal Government, thorough Homeland Security, has recommended that deathcare providers be labeled as essential, this is only a recommendation and ultimately each state and locality will make the classification in its orders. As of the time of this response, most states ARE identifying deathcare as essential functions. This does help because it will put deathcare in the position to receive PPE from local agencies.
Distribution works on a local level through your State Department of Health Services (DHS). DHS works through the Assistant Secretary for Preparedness and Response (ASPR) who in return release PPE from the Strategic National Stockpile (SNS) to the local DHS. Unfortunately, state DHS locations have been notified of the extremely limited supply of PPE that will be distributed. Typically, ASPR will provide DHS with 48-hours’ notice as to when supplies will arrive, so as an essential business you need to work with your local DHS to receive supplies. Please note that:
- The stockpile of PPE coming to states is severely limited. It consists of extremely small numbers of N95 respirators, surgical masks, face shields, gowns, coveralls, and gloves.
- Businesses that use PPE should be optimizing current inventories of PPE per the CDC guidance.
John Flowers, CEO of Bass-Mollett, shared his personal research with Connecting Directors on how to navigate the government’s process for PPE allocation. Here’s the process as it was explained to Flowers:
- All N95s in existing stock and those being manufactured now are sent to the Federal Emergency Management Agency (FEMA)
- FEMA allocates supplies to each state’s Emergency Operations Center (EOC) based on need
- Each EOC manages requests from entities within its respective state — including death care professionals
- To place a request for N95s, you’ll need to contact your state’s EOC.
CLICK HERE for complete contact information of Emergency Operations Centers for each state.
Please note, that while the above is the designated method of distribution based on Federal reserves, you still may be able to secure PPE from your current supplier. As of the time of this response, several suppliers have confirmed that they still have PPE available. While some items are running low, or in high demand, some deathcare suppliers are still fulfilling orders. However, in some cases, current orders are being based on previous orders in an effort to make sure that supplies remain consistent and avoid any hoarding of necessary supplies. You should contact your current supplier to see what may be available.
While not optimal, experts as well as the CDC have recommended that as a last resort, any healthcare workers who can’t get a N95 mask should make one. Listed below are a few suggestions from experts in the field:
- Disposable surgical face mask and 2 layers of facial tissue Surgical masks can get the job done. Place 2 layers of facial tissue between your face and the surgical mask.
- Create a makeshift mask If you don’t have a surgical mask you can make your own mask. You will need a thick fabric such as wool and rubber bands. You can also make a mask with the use of an old shirt and a pair of scissors. It doesn’t look very professional but works in a pinch.
- Last resort: Use a wet handkerchief or towel When you don’t have time to create your own mask, then the quickest way you can protect yourself is to get a wet cloth, preferably a handkerchief or a towel, and cover your mouth. This has been taught as a fire safety tip for a long time.
Lastly, ICCFA has prepared a letter that can be used by suppliers in deathcare to send to their distributors, as well as deathcare businesses to send to their suppliers, in hopes of making sure that they remain in the supply chain as this crisis continues. In this way, deathcare providers can continue to order and receive some PPE through their normal outlets, distributors, and providers. The letter – which can be accessed here – should be printed on your letterhead and sent directly to your various suppliers, distributors and supply chains. This does not guarantee continued receipt of PPE and other needed supplies, but it may help in making sure that deathcare providers are recognized as essential workers, and as supplies are distributed, receive priority access to needed supplies.
March 24, 2020
Question: Are personnel subject to quarantine if they conduct a removal from a contaminated environment such as a house or nursing facility that is under quarantine? Does wearing proper fitting personal protective equipment (PPE) serve as a barrier to protect the person doing the removal and negate the need for quarantine?
Answer: If the team doing the removal of a suspected or confirmed case of COVID-19 wears all the proper PPE equipment (see list below), then this should serve as a barrier and negate the need for the removal personnel to be quarantined.
Here is a suggested process of how to handle the removal of a quarantined death. PLEASE NOTE that local and state agencies may also require additional procedures. These suggestions serve as a guideline only:
- The family should be prepared by the funeral home that upon arrival of their staff at the place of death they will be donning their full protective equipment before entering the residence and that no family members should meet them outside upon arrival. We must ensure no family members who are present greet the staff outside or before they are “suited up” in their PPE.
- Upon entering the residence, best practice would be to request family to respect the “social distance” recommended of 6 feet (2 meters). The removal team should refrain from unnecessarily touching any surface inside the house. When dealing with the remains, make sure you spray the remains down with a strong disinfectant and cover the facial area with a cloth soaked in disinfectant before moving the remains. The remains must be placed inside a body pouch and upon closing the pouch the outside of the pouch must be sprayed with disinfectant. Once the remains are closed and, on the gurney, remove yourself and remains from the house.
- Once the remains are loaded into the removal vehicle and the family have returned to inside the residence, then the PPE may be removed following proper procedures of doffing equipment. The used PPE must be bagged in a bio-hazard bag, sealed and disposed of accordingly. Remember, when returning to the funeral home with the remains the gurney should not be touched until you have once again donned appropriate PPE. It is heavily suggested that the entire removal vehicle and gurney be disinfected before next use.
- Remember that the PPE we wear is to protect us and keep us from exposure and reduce risk of contamination. If PPE is properly worn, there is no reason for us to have to go into quarantine after making the removal of a quarantined death. If that were the case, every healthcare professional caring for the sick in this situation would have to stop working and self-quarantine.
Suggested list for proper PPE for a safe removal:
- Disinfectant spray (know your product and its effectiveness to work on COVID-19)
- Full Tyvek suit
- N95 mask or greater
- Facial shield or goggles
- Long cuffed gloves
- Shoe covers
- Bio-hazard bag (for disposal of PPE when completed)
- Hand sanitizer to disinfect hands prior to removal of N95 mask
Donning and doffing PPE by CDC standard – https://www.cdc.gov/HAI/pdfs/ppe/ppeposter148.pdf
March 24, 2020
Question: Does aspiration of a deceased create aerosolization of the COVID-19 virus and should this be handled in a different way?
Answer: Aspiration can very easily cause aerosolization depending on the equipment used and setup you have at your facility. Ideally you have a system that automatically “feeds the drain.” This means that the waste isn’t discarded into a commode/toilet or open sink, but instead the discharge tube feeds directly into the drain and out-of-sight, which is the ideal setup. I recommend running water into the closed drain while aspirating to prevent any back splashing that may occur from the drain.
If you do use a commode/toilet as your discharge point, then cover the area up with something that can be discarded or sanitized after each use. Another suggestion to reduce the risk of any aerosolization coming from the aspiration procedure is to place a cloth which has been soaked in a disinfectant around the aspiration point to reduce any splashing or spraying from the site.
Currently, there are several experts that are recommending to either delay aspiration or not aspirate at all. These suggested practices do offer some positive benefits, and you may want to consider them as they can help further limit aerosolization, as well potentially allowing the virus to die before potential exposure. In general, it is important to be extra smart and think of how you can prevent droplet or aerosolization throughout the aspiration and embalming procedure.
March 24, 2020
Question: We are a pet crematory and wondering how do we handle business if things go into a “full lockdown” situation due to COVID-19? Are we considered an essential business at that point?
Answer: There has been some information released on pets and COVID-19. Most experts are currently suggesting that pets can possibly spread the virus just as any other contaminated surface or object would. This means that if you touch them, and they have the virus on them, and you then touch your mouth, nose, or possibly eyes – then the virus could potentially be transmitted. However, experts also currently suggest that it is highly unlikely because pet hair is porous and especially fibrous, and absorbs and traps the virus, making it harder to contract through simple touch. Please see the following AVMA FAQ on this issue: (https://www.avma.org/sites/default/files/2020-03/covid-19-faq-pet-owners_031620.pdf)
It is suggested that pet deathcare professionals practice the same standards as other deathcare professionals when making removals. Removals should be made using PPE (Personal Protective Equipment) to reduce any potential risk and best practices should be followed concerning cleaning and disinfecting. COVID-19 is transmissible from person-to-person by droplet spray (sneezing and coughing) and close contact with someone who is infected. While pets may not be carriers, it is possible that your staff could be around people that are infected, so practice safe removals to limit potential infection.
- Use your PPE, which would include a N95 mask and gloves along with all other PPE. Consider clothing that can be removed and laundered and kept away from personal clothing.
- Actively disinfect your equipment after every use. We should do this to a higher level now and begin to disinfect the service vehicles after each use. We can do this with chlorine bleach diluted at a 1:10 ratio. An example of that would be 1.5 cups of chlorine bleach to 1 gallon of water. This ratio is also effective to use inside any rooms, to disinfect cupboards and tabletops, and mop the floor with.
- Properly train those that do removals on what is expected of them in controlling the spread of “any virus or transmissible disease.” I say that because it happens all too frequently that those doing removals are untrained retirees or new students entering the profession.
- Gloves MUST be worn during the transfer. I know many are worried about the “appearance” of wearing gloves, but we need stop this and act professionally for the health and safety of all. Gloves and appropriate PPE should always be worn. Disinfection using appropriate disinfecting sprays should always take place before and after moving the deceased. There is varying information on the length the COVID-19 virus lives on surfaces so we must err on the side of caution.
In regard to the “essential business” part of the question, this is an ongoing issue. From what we know currently, the Federal Government has issued a recommendation that all deathcare services be identified as essential businesses (https://www.cisa.gov/publication/guidance-essential-critical-infrastructure-workforce). Currently, the Federal recommendation is only a suggestion and we are seeing State and local orders being issued. Some are including the Federal recommendations; others are writing their own – so it will be dependent on each order.
Stating that, there are some states that have included vets as essential businesses, and also included deathcare; so, the argument is that you could be viewed as essential. Keep in mind each state will be different, and simply because you are not listed does not mean you are excluded. If you are listed as non-essential, then you would be excluded. But again, most states are broad in their descriptions to allow necessary businesses that they may not have directly thought of when drafting the order. If you choose to proceed, just make sure you follow all other parts of the order, such as safety, distancing, etc.
March 23, 2020
Question: Are cemeteries setting up tents and chairs during this time?
Answer: Cemeteries are beginning to limit not only equipment at the gravesite, but we are also seeing a limitation in services as a whole. This is the result of various CDC recommendations, as well as various state and local orders on what is currently allowed. The National Concrete Burial Vault Association has published graveside recommendations which provide further details on gravesite recommendations. You can view the information here: https://www.ncbva.org/resources/Documents/NCBVA_newsletter_3192020.pdf
March 23, 2020
Question: Are there any ideas for contingency plans for a funeral home/cemetery/crematory – should a staff member test positive for COVID-19?
Answer: A contingency plan for the situation in which a staff member tests positive for COVID-19 would be based on multiple variables. For example, the CDC recommends that a person sharing a dwelling with another person who tests positive for COVID-19 should follow the recommended self-quarantine guidelines. These guidelines are in place because it is assumed that the infected person is in close proximity with the non-infected person for extended periods of time.
With this in mind, many factors contribute to the contingency plan that would be enacted should a staff member test positive. Factors such as:
- Where does the infected staff member perform their duties regularly?
- Are they an embalmer who spends the majority of their time in the preparation facility and has limited contact with other staff?
- Are they a grounds crew member who performs the majority of their duties outdoors?
- Are they an administrator or other staff member who shares workspace in close proximity to other employees?
Essentially, one would have to conduct a risk assessment of the entire staff’s potential exposure and then develop a contingency plan accordingly. At the very least, while still protecting the confidentiality of the person involved, any team members deemed to be at high risk for exposure should be notified.
In addition to how to handle a possible case of an employee being tested positive for COVID-19, it is important to start doing everything you can as a business to reduce the risk of infection. In deathcare, the options of an at-home workforce may be limited, if not impossible. However, consider allowing any and all possible positions to work remotely if at all possible. The other suggested option is to create a schedule that keeps as many of your staff separated as possible. This can be done by limiting staff that report to work; rotating the schedule; and even segregating positions so that employees have little to no contact with others. Of course, the general suggestions of disinfecting; limiting contact and personal space should always be followed as well. These suggestions also follow recommended guidelines from the CDC: https://www.osha.gov/Publications/OSHA3990.pdf
IF YOU HAVE A QUESTION ABOUT COVID-19 AND HOW IT AFFECTS OUR PROFESSION, SUBMIT IT HERE!