By Jason Weir with Conner Patten

OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, applies to funeral home employees with occupational exposure. That means reasonably anticipated contact with blood or other potentially infectious materials. The standard requires a written exposure control plan, free hepatitis B vaccination, task-matched PPE, sharps controls, annual training, and confidential medical records. OSHA names human remains as a source individual, so an exposure incident in the preparation room triggers full post-exposure follow-up.

Jason Weir, Vice President of Hilton Funeral Supply, is a Michigan-licensed funeral director and embalmer and a Certified Funeral Service Practitioner (CFSP). He reviews the clinical and technical content of Hilton's guides. Conner Patten is Hilton's Customer Outreach and Product Specialist.

Quick Answer: What Does OSHA 1910.1030 Require of Funeral Homes?

OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, requires every funeral home with occupationally exposed employees to run a written bloodborne pathogens program. The funeral home must keep a written exposure control plan and review it at least annually. It must offer the hepatitis B vaccine at no cost within 10 working days of an exposed employee's initial assignment. It must provide appropriate PPE, sharps containers, and a written cleaning schedule. It must train exposed staff at assignment and at least annually. It must keep employee medical records for the length of employment plus 30 years and training records for 3 years.

What Are OSHA's Bloodborne Pathogens Requirements for Funeral Homes?

The table below summarizes the core duties in 29 CFR 1910.1030. Every row is a federal mandate, not a recommendation.

What Is the Hilton Exposure Control Standard?

The Hilton Exposure Control Standard is Hilton Funeral Supply's internal framework for evaluating a preparation room's bloodborne pathogens readiness on four criteria: Task Mapping, Barrier Fit, Containment, and Documentation.

The Hilton Exposure Control Standard is Hilton's own framework. It is not an OSHA standard, a state rule, or a professional standard, and it carries no regulatory force. Meeting the Hilton Exposure Control Standard does not establish compliance with 29 CFR 1910.1030.

Does OSHA's Bloodborne Pathogens Standard Apply to Funeral Homes?

Yes. 29 CFR 1910.1030 applies to all occupational exposure to blood or other potentially infectious materials. OSHA addressed funeral homes directly in a 1992 interpretation letter to the National Funeral Directors Association. OSHA stated that funeral homes are among the workplaces known to have such exposure. NFDA had acknowledged this during the rulemaking for the standard, which OSHA issued on December 6, 1991.

The Bloodborne Pathogens Standard defines a source individual as any individual, living or dead, and lists human remains as an example. OSHA's 1992 NFDA letter states that the inherent risk of exposure from human remains is similar to that from a living person. The standard's definition of other potentially infectious materials also includes unfixed human tissue or organs, other than intact skin, from the living or the dead.

Formaldehyde exposure falls under a separate rule, 29 CFR 1910.1048, covered in Hilton's OSHA Formaldehyde Standard guide. Reduced-exposure fluid options are covered in Hilton's Champion embalming fluid guide.

Which Funeral Home Employees Does the Bloodborne Pathogens Standard Cover?

The Bloodborne Pathogens Standard covers any employee whose duties create reasonably anticipated contact with blood or other potentially infectious materials. 29 CFR 1910.1030(c)(2) requires a written exposure determination in three parts:

• Job classifications in which all employees have occupational exposure.
• Job classifications in which only some employees have occupational exposure.
• The specific tasks and procedures that create exposure in those mixed classifications.

The exposure determination must be made without regard to PPE, so wearing a gown does not remove an embalmer from the list. Embalmers typically fall in the first category. A funeral director who also makes removals may fall in the second, by task. OSHA's 1992 guidance says employees designated as non-exposed should be trained to recognize exposure tasks and defer them to designated staff.

What Must a Funeral Home Exposure Control Plan Include?

A funeral home exposure control plan must contain three elements under 29 CFR 1910.1030(c)(1):

• The written exposure determination.
• The schedule and method for implementing the standard's methods of compliance, vaccination and post-exposure follow-up, hazard communication, and recordkeeping.
• The procedure for evaluating the circumstances of each exposure incident.

The exposure control plan must be accessible to employees and available to OSHA on request. It must be reviewed and updated at least annually. It must also be updated when tasks, procedures, or exposed positions change. Each annual review must document consideration and implementation of appropriate, commercially available safer medical devices.

What PPE Does OSHA Require for Embalming?

OSHA requires PPE that keeps blood and other potentially infectious materials off an employee's clothing, skin, eyes, mouth, and other mucous membranes. The PPE must perform under normal use for as long as it is worn. The requirement is performance-based, not a fixed kit. OSHA's 1992 letter to NFDA, quoting the standard's preamble, says employees need not wear a "moon suit" for every task. The employer selects PPE by the type and amount of exposure each task presents.

The Bloodborne Pathogens Standard cites autopsies and orthopaedic surgery as examples of gross contamination. The employer judges when a preparation room case presents comparable contamination.

What PPE Rules Apply to Every Preparation Room Task?

• The employer provides, cleans, launders, repairs, and disposes of required PPE at no cost to the employee.
• Hypoallergenic gloves, glove liners, or powderless gloves must be readily accessible to employees allergic to standard gloves.
• Disposable gloves are replaced when contaminated or torn and are never washed for reuse.
• Hands are washed immediately or as soon as feasible after gloves or other PPE come off.
• A garment penetrated by blood or other potentially infectious materials is removed immediately or as soon as feasible.
• All PPE comes off before the employee leaves the work area.

Hilton stocks Microflex Sensation Nitrile Gloves, a powder-free nitrile option, alongside latex options in its latex and nitrile glove category. Body protection includes Disposable Gowns, Disposable Aprons, and Disposable Shoe Covers. All three appear in Hilton's preparation room PPE category.

OSHA defines a handwashing facility as running potable water, soap, and single-use towels or air dryers. The facility must be readily accessible to employees. Hilton carries Champion Surgical Soap for the preparation room sink.

How Should Embalmers Handle Contaminated Sharps?

Contaminated sharps go immediately, or as soon as feasible, into closable, puncture-resistant containers that are leakproof on the sides and bottom and labeled or color-coded. 29 CFR 1910.1030 sets these handling rules:

• Contaminated needles are not bent, recapped, or removed unless no alternative is feasible.
• Any permitted recapping or removal uses a mechanical device or a one-handed technique.
• Shearing or breaking contaminated needles is prohibited.
• Sharps containers stay upright, close to the point of use, and are replaced before they overfill.
• Reusable sharps, such as trocars, go into puncture-resistant, leakproof, labeled containers until reprocessed.
• No employee reaches by hand into a container holding contaminated reusable sharps.

Routine preparation room sharps include suture needles, hypodermic needles, scalpel blades, and trocars. The standard's definition of contaminated sharps names scalpels. The same removal limits therefore apply to taking a contaminated blade off a reusable handle.

Hilton carries Disposable Scalpels with #21 blades, 10 per pack. A disposable scalpel goes into the sharps container whole, with no blade change. For reusable instruments, Hilton carries Scalpel Blades #22 and the Scalpel Handle #4, which fits blades 20 to 25. For reprocessing reusable instruments, Hilton carries Wavicide-01, a glutaraldehyde-based instrument solution. Follow the Wavicide-01 label for immersion time and reuse limits.

Is a Human Body Considered Regulated Waste Under OSHA?

No. OSHA's 1992 letter to NFDA states that a human body is not regulated waste under 29 CFR 1910.1030. The regulated waste and biohazard labeling rules do not apply to the body or its storage or transport container. The same letter says containment may still be needed in circumstances such as decay or trauma.

Regulated waste includes liquid or semi-liquid blood and items that would release blood if compressed. It also includes items caked with dried blood, contaminated sharps, and pathological waste. Regulated waste goes into closable, leakproof containers that are labeled or color-coded, such as red bags. Final disposal follows federal, state, and local rules.

For compromised remains, Hilton lists the Body Bag - Disaster Pouch at 36 by 90 inches. The Disaster Pouch uses 20 mil vinyl with a leak-resistant interior layer and six nylon-reinforced handles. Hilton's mortuary plastics, including Mortuary Plastics - Unionalls, are designed to protect garments. Unionalls come in white or clear, sizes S to XXL. Other containment options from Hilton's mortuary plastics and MOBI lines include:

• Body Bag - Standard: 40 by 90 inches, 6 mil heat-sealed vinyl, heavy-duty U-shape zipper, three ID tags.
• Body Bag - Medium Density: 40 by 90 inches, scrim-reinforced polyethylene, 1,000 lb capacity.
• MOBI Mortuary Cot Pouch with Zipper: waterproof interior, stain-resistant exterior, dual heavy-duty YKK zippers.
• MOBI Oversized Mortuary Cot Pouch with Zipper: the same features, sized for oversized cots of about 77.5 by 23.5 inches.

Under 29 CFR 1910.1030(d)(4)(ii), all equipment must be cleaned and decontaminated after contact with blood or other potentially infectious materials. That includes a reusable cot pouch.

How Often Must the Preparation Room Be Decontaminated?

Contaminated work surfaces must be decontaminated with an appropriate disinfectant after each procedure. Spills and overt contamination are decontaminated immediately or as soon as feasible. Surfaces contaminated since the last cleaning are also decontaminated at the end of the shift. 29 CFR 1910.1030(d)(4) also requires a written cleaning schedule and method based on location, surface, type of soil, and task.

• Protective coverings on equipment are replaced when overtly contaminated or at the end of the shift.
• Reusable bins and pails are inspected and decontaminated on a regular schedule.
• Broken glass is picked up with a brush and dustpan, tongs, or forceps, never by hand.
• Soiled linen is bagged where it was used, never sorted or rinsed there, and placed in leakproof bags when wet.
• Equipment sent for service or shipping is examined and decontaminated, or labeled to show which parts remain contaminated.

Aspirators draw blood and body fluids during cavity treatment, so they fall under the same equipment rule. Hilton carries Champion SLC, Champion's glutaraldehyde-based aspirator treatment. Read the safety data sheet before handling any glutaraldehyde product.

The equipment rule applies to an embalming table or mortuary cot sent out for repair. Hilton's guide to MOBI dressing and embalming tables covers table materials and cleaning. For hard surfaces, Hilton's listing describes Frigid Fluid Spray Guard as a disinfectant for instruments, tables, and countertops. Choose a disinfectant whose label covers the intended surface and use.

When Must a Funeral Home Offer the Hepatitis B Vaccine?

A funeral home must offer exposed employees the hepatitis B vaccine series at no cost. Under 29 CFR 1910.1030(f), the offer comes within 10 working days of initial assignment, after training on the vaccine.

• The vaccine is given by or under the supervision of a licensed physician or other licensed healthcare professional.
• Administration follows current U.S. Public Health Service recommendations.
• No offer is required if the employee completed the series, tests immune, or has a medical contraindication.
• Prescreening cannot be a condition of receiving the vaccine.
• Boosters must be offered if the U.S. Public Health Service recommends them.

What Should Happen After a Needlestick or Splash in the Preparation Room?

After a needlestick or splash, the employee washes or flushes the area, reports it, and gets a confidential medical evaluation. A suture needle through the glove while closing an autopsied case is a typical example. Under 29 CFR 1910.1030(d)(2)(vi), exposed skin is washed with soap and water immediately or as soon as feasible. Exposed eyes and other mucous membranes are flushed with water. The employer must then make a confidential medical evaluation immediately available, including:

• Documentation of the route of exposure and the circumstances.
• Identification and documentation of the source individual, unless infeasible or prohibited by state or local law.
• Testing of the source individual's blood, subject to the consent rules set by law.
• Collection and testing of the employee's blood after the employee consents.
• Post-exposure prophylaxis when medically indicated, counseling, and evaluation of reported illnesses.

In a preparation room exposure, the decedent is the source individual. The employer must give the employee a copy of the healthcare professional's written opinion within 15 days of the evaluation's completion.

What Bloodborne Pathogens Training and Records Does OSHA Require?

OSHA requires bloodborne pathogens training for every exposed employee at no cost and during working hours. Training occurs at initial assignment and within one year of the previous session. Additional training is required when new tasks or procedures change an employee's exposure. The trainer must know the subject as it applies to that workplace. 29 CFR 1910.1030(g)(2) lists 14 minimum elements, including:

• An accessible copy of the standard and an explanation of its contents.
• An explanation of the exposure control plan and how to obtain a copy.
• The use and limits of engineering controls, work practices, and PPE.
• Hepatitis B vaccine information, including that it is offered free of charge.
• The procedure to follow and report after an exposure incident.
• A chance for interactive questions and answers with the trainer.

OSHA's 1992 guidance allows employee medical records to be kept off-site, such as with the treating healthcare provider. The records must remain accessible to OSHA.

Do State OSHA Plans Change Funeral Home Bloodborne Pathogens Rules?

States that run OSHA-approved programs enforce their own standards. OSHA lists 22 State Plans that cover both private and public employers. Each State Plan must be at least as effective as federal OSHA. Michigan, for example, enforces MIOSHA Part 554, Bloodborne Infectious Diseases. State funeral service boards may also set their own preparation room and sanitation rules. Confirm current requirements with your state OSHA program and licensing board.

Which Hilton Products Support a Bloodborne Pathogens Program?

A viewing serves a family's need to acknowledge the reality of the death. Safe preparation is what makes that viewing possible. Hilton Funeral Supply stocks gloves, body protection, disinfectants, and containment products for the preparation room. Specifications below come from Hilton's product listings.

Each employer decides whether a product is appropriate for the exposure a task presents. Buying a product does not by itself establish compliance with 29 CFR 1910.1030. Hilton's full prep room and equipment catalog lists every preparation room product.

Frigid Fluid Spray Guard

Best for: Disinfecting tables, countertops, and instruments between procedures.

Why it works: Hilton's listing describes Frigid Fluid Spray Guard as a 16 oz disinfectant. The listing states it contains 60 to 70 percent isopropyl alcohol plus additional disinfectants. It also names pre-embalming surface treatment of the eyes, mouth, and nose.

Champion Surgical Soap

Best for: The preparation room handwashing sink, used after gloves come off and after skin contact with blood.

Why it works: 29 CFR 1910.1030(d)(2) requires soap and running water at a readily accessible handwashing facility. Champion describes Champion Surgical Soap as a neutral, buffered soap containing Irgasan, a broad-spectrum antimicrobial. Hilton carries it in 16 oz, 1-gallon, and 5-gallon sizes.

Champion SLC Aspirator Treatment

Best for: Electric aspirators and Hydro-Aspirators between cases.

Why it works: Champion describes Champion SLC as a fluid drawn in through the suction hose. SLC stays in the aspirator between uses. Champion states that SLC sanitizes with glutaraldehyde, cleans the hose and impeller, and lubricates seals.

MOBI Mortuary Cot Pouch with Zipper

Best for: Residential and facility removals where leakage from the remains is possible.

Why it works: The MOBI Mortuary Cot Pouch with Zipper has a waterproof interior, per Hilton's listing. It closes with dual heavy-duty YKK zippers and attaches to the cot with snap-on straps at each end. An oversized version fits oversized mortuary cots.

Champion DI-SAN

Best for: Arterial cases where the embalmer wants added germicidal action in the arterial solution.

Why it works: Champion states that DI-SAN increases the germicidal qualities of the arterial solution. Champion also states it reduces the possible infectious nature of remains. Champion's label directs up to 4 oz of DI-SAN per gallon of arterial solution as a co-injection fluid. Follow the label for other dilution rates. The label states DI-SAN is not for use as a general disinfectant or sterilant. The label requires nitrile gloves, chemical goggles, and face shields. DI-SAN does not change universal precautions or the PPE a task requires.

Hilton's full Champion prep supplies line includes sealers, compounds, and soaps for the preparation room.

Frequently Asked Questions About Bloodborne Pathogens in Funeral Homes

Does OSHA's bloodborne pathogens standard apply to a funeral home owner who works alone?

No, not while the owner has no employees. The Department of Labor states that the OSH Act does not cover self-employed persons. Coverage begins when the funeral home has an employee with occupational exposure, including a part-time embalmer or removal assistant. State licensing and sanitation rules still apply to a sole practitioner. Hilton recommends universal precautions for every case as a best practice, not an OSHA mandate.

Do funeral homes have to keep a sharps injury log?

Funeral homes classified under death care services generally do not, unless OSHA or the Bureau of Labor Statistics asks them to keep injury records. The sharps injury log applies only to employers that must keep OSHA injury logs under 29 CFR Part 1904. OSHA lists death care services, NAICS 8122, as partially exempt from those logs. Companies with no more than 10 employees at any time during the last calendar year are also partially exempt. State Plans may differ. Hilton recommends logging every needlestick internally as a best practice, not a federal requirement.

Can an embalmer decline the hepatitis B vaccine?

Yes. An exposed employee may decline the hepatitis B vaccine but must sign the declination statement in Appendix A of 29 CFR 1910.1030. OSHA sets the wording of that statement, and it is mandatory. If the employee later accepts the vaccine while still covered by the standard, the employer must make it available at that time. The vaccine remains free to the employee.

Does OSHA require an eyewash station in the preparation room?

The Bloodborne Pathogens Standard requires flushing exposed eyes with water but sets no minimum eyewash volume. OSHA's 2020 interpretation says enough water must be used and found 4-ounce bottles insufficient. That letter cites ANSI Z358.1, a voluntary standard, for a 15-minute flush. The Formaldehyde Standard is stricter. It requires eyewash facilities in the immediate work area when eyes may be splashed with 0.1 percent or greater formaldehyde.

Does the bloodborne pathogens standard cover coroner and medical examiner staff?

Coroner and medical examiner staff employed by state or local government are covered only in states with an OSHA-approved State Plan. Federal OSHA does not cover state and local government workers. OSHA lists 22 State Plans covering private and public employers and seven covering public employers only. Private funeral homes and removal services working for a coroner remain covered by federal OSHA or their State Plan.

Can funeral home staff take contaminated gowns or lab coats home to wash?

No. Under 29 CFR 1910.1030(d)(3), the employer must clean, launder, and dispose of required PPE at no cost to the employee. All PPE must be removed before the employee leaves the work area. A garment penetrated by blood or other potentially infectious materials must come off immediately or as soon as feasible. Contaminated laundry is bagged where it was used and transported in labeled or color-coded containers.

Does a decedent's medical history change the PPE an embalmer needs?

No. Under universal precautions, all human blood and certain body fluids are treated as if known to be infectious for HIV, hepatitis B, and other bloodborne pathogens. 29 CFR 1910.1030(d)(1) requires universal precautions to prevent contact with blood or other potentially infectious materials. A reported negative history does not lower the protection a task requires. PPE is selected by the splash and contact the task presents, not by the case file.