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OSHA Issues Cemetery Hazards Letter to NFDA

Posted: November 30, 2009

The OSHA Atlanta-West Area Office has sent a letter to NFDA outlining various hazards that may exist in cemeteries which should be addressed for safety reasons. While this letter does not constitute an enforcement notice, it is a clear indication that at least for their jurisdiction, it could become an inspector enforcement priority. In addition, this does not appear to be a national effort but easily could be if other OSHA offices around the country decide to look into these hazards as well. The standards that they are using for these inspections would be the Trenching Standard (29CFR 1926, Subpart P, Excavations) and the OSHA General Duty Clause. Both come with significant fines and penalties for violations.

In essence, the letter indicated that hazards exist in a cemetery especially those involving digging and working in and around graves. The OSHA letter stated that "Employees are exposed to hazards such as falls, hazardous atmospheres (i.e. carbon monoxide, carbon dioxide, natural gas, methane from decomposing bodies and oxygen deficient atmospheres), equipment hazards, falling loads, collapses, and cave-ins that could be deadly if the proper precautions are not taken."

While NFDA does not necessarily agree with their findings and conclusions, or even the applications of the cited standards to today's cemetery operations, we will make sure our members who own or operate cemeteries are made aware of this information and take appropriate action. Click here to read the full text of the letter, and excerpts and diagrams from the Trenching Standard.

NFDA intends to send a letter to the OSHA Atlanta-West Area Office outlining its position that the application of these standards to cemeteries is incorrect and should be modified to accommodate today's cemetery operations.

If you have questions about complying with OSHA standards, call NFDA's FREE OSHA Hotline, 800-633-2674, answered by experts from Stericycle, NFDA's endorsed OSHA consultants.