T.R.S. ENTERPRISES

The training program will include and explain the following: Explanation of OSHA Inspections Citations Required Records Hazard Communication Program Exposure Control Plan Emergency Evacuation Plan Procedures in Case of Spills The Hazards of the Preparation Room Personal Protective Clothing/Equipment Formaldehyde PEL/STEL Monitoring MSDS's/Chemical List Housekeeping/Sanitation

The purpose of the "OSHA" is to protect all employees from job-related accidents that may cause serious illness or death. The OSHA (administration) was created under the Department of Labor to enforce and bring forth any standards or regulations that will help in the effort to protect employees. OSHA will conduct "without notice" inspections to insure the standards and regulations that are pertinent to the funeral business are being implemented. If, by any chance, citations for violations occur, there may be a fine imposed. The fines that may be imposed can be up to $7,000.00. These fines can be reduced up to 95% depending on the severity.

According to OSHA standards and regulations (1904.2, 1904.21, 1910.20), employers must keep records on training, respirator fit-testing, formaldehyde monitoring, hepatitis B vaccine approval/disapproval and any injury that is reported. Injuries should be logged in on the OSHA 101 and OSHA 200 forms. Some records are to be maintained anywhere from 5 to 30 years. Training Record - Employees will sign on their individual training record indicating they have been trained. This will be done once a year. Respirator Fit-Test Record - The employees who are assigned a respirator will fill out and sign the respirator fit-test record. This will indicate the employee has tried the respirator on, adjusted it and made sure it had a tight seal. Formaldehyde Monitoring Record - This record will be filled out and signed by the employees who have exposure to hazardous chemicals. This will indicate the PEL and STEL tests were conducted. The lab results will be attached to the records when returned from the lab. Hepatitis B Vaccine Declination - This record will be filled out by the employees who are considered at risk employees. This record will be signed by the employee indicating he/she does not want to receive the vaccine and filed in the employee's medical file. If the employee wishes to receive the vaccine, the proper record of the shots will be filed in the employee's medical file. OSHA 101/200 Form - If an employee reports an injury, the available OSHA 101 and 200 forms will have to be filled out. The OSHA 101 form will be filed in the employee's medical file.

The Hazard Communication Program explains the responsibilities of employees who have been assigned certain duties within the funeral home. The Hazard Communication Program includes the employees who will be responsible for the hazardous waste and labeling of fluids, the MSDS and chemical list, the hazardous non-routine tasks, the contractor escort, the training program policy and location of the "OSHA Compliance and MSDS Program". An exposure control plan has been developed in a accordance with Title 29 Code of Federal Regulations 1910.1030, an exposure control plan must be established to determine the employees who are exposed and who are not exposed. This will help reduce the exposure to employees whose job duties don't call for it.

The employees who have the risk of exposure will be supplied with the proper personal protective equipment to help reduce the chance of exposure by skin contact or inhalation. The following is a list of personal protective equipment that will be provided to the employees: Head and Foot Coverings Face Masks Eye Protectant Fluid Retardant Gowns Gloves Respirators Employees who start on a job that has risk of exposure will be required to wear the above mentioned personal protective equipment. The respirator will be voluntary. Two emergency respirators will be available in case of emergency. The respirators will be kept outside the prep room in a designated place, clearly labeled.

An Emergency Evacuation Plan has been established to handle an emergency in an organized manner. In case of an emergency, exits have been designated for each area in the funeral home that might be occupied if ever an emergency might occur. Employees have been assigned duties in event of an emergency and are aware of these duties. (Discuss Emergency Evacuation Plan.)

If a spill ever occurs that involved a hazardous chemical, the following steps will be taken: 1. For small spills, absorb the liquid and dispose of the materials used in a properly labeled container. Place container in a well?ventilated area. 2. For a large spill, neutralize the spill with sodium hydroxide or sodium sulfite if available. You may also use other neutralizing agents if you have them available. Place materials used in clean-up in properly labeled containers.

The preparation room contains hazardous chemicals and may contain at one time or another: blood, bloodborne pathogens, airborne pathogens or other infectious bodily secretions. Universal precautions will be observed when working in the preparation room. The entrance to the preparation will be clearly marked with "Danger - Formaldehyde - Irritant and Potential Cancer Hazard - Authorized Personnel Only". Inside the preparation room an eyewash will be available in case of an emergency. The eyewash is hands free and with the push of a lever will operate hands free for at least 15 to 20 minutes. A quick drench shower will be made available. If not in the preparation room, it will be located adjacent to the preparation room.

Formaldehyde is considered a carcinogen, therefore, it is important to know about this chemical. The precise hazards associated with exposure to formaldehyde depend both on the form (solid, liquid, gas) of the material and the concentration of formaldehyde present. Exposure to the skins or eyes with 37-50% solution of formaldehyde present a greater hazard than solutions containing less than 1% formaldehyde. Materials containing formaldehyde must be moderately heated before ignition will occur. Water can be used to extinguish the fire because formaldehyde can be cooled below its flash point. Formaldehyde reacts with hydrochloric acid to form the potent carcinogen, bischloromethyl ether. A violent reaction can occur when formaldehyde is mixed with strong oxidizers. Oxygen in the air can oxidize formaldehyde to formic acid, especially when heated; formic acid is corrosive. * Exposure to formaldehyde by ingestion of 10-40% can cause severe irritation and inflammation of the mouth, throat and stomach. Severe stomach pain usually follows with possible loss of consciousness and death. * Exposure to formaldehyde by inhalation can irritate the eyes, nose and throat. Symptoms would include tearing of the eyes, burning of the eyes, difficulty in breathing and coughing. * Exposure to formaldehyde by skin contact can cause white discoloration, drying, cracking or scaling. Prolonged exposure to skin can cause numbness and darkening of skin. * Exposure to formaldehyde by eye contact can cause discomfort to permanent corneal clouding and loss of vision. In case of an eye splash with formaldehyde immediately flush the eyes for 15 - 20 minutes with cold water. If irritation and discomfort continue, contact a licensed physician.

The warning signals that can alert an employee to formaldehyde become less sensitive as exposure to formaldehyde continues. Relying on these warning signals can lead to overexposure. Each employee who is exposed to formaldehyde must have their exposure monitored. The monitoring of the concentration of formaldehyde employees are being exposed to is a critical tool in decreasing the chance of overexposure. The monitoring is done by an employee whose job classification requires exposure to formaldehyde. The monitoring will determine the Permissible Exposure Limit (PEL) which is not to exceed .75 ppm over an 8-hour period. The monitoring will also determine the Short Term Exposure Limit (STEL) which is not to exceed 2 ppm's over a 15-minute period. The monitoring will be done in two parts. There will be two tests conducted on the initial monitoring day chosen, and at least seven days later the final two tests will be conducted. Before the initial monitoring, it shall be determined who will have exposure to formaldehyde. The monitoring shall be done so that the concentration of formaldehyde will be the same (not underestimated) for all employees. If this will not be possible, then each employee must monitor their exposure to formaldehyde separately. Monitoring shall be done periodically to determine exposure to formaldehyde. If the results of the STEL or PEL exceed their maximum ppm, testing shall be done every six months until the ppm's are at or below the maximum STEL or PEL allowed. Monitoring shall be accurate to within plus or minus 25% for airborne concentrations of formaldehyde at the STEL or PEL and within plus or minus 35% at the action level. If any employee develops any signs or symptoms relating to overexposure to hazardous chemicals, the employee is to report this to the employer immediately. The employee will fill out the medical disease questionnaire which is located in the "OSHA Compliance and MSDS Program". This medical disease questionnaire will need to accompany the employee if he/she sees a physician.

A Material Safety Data Sheet section is located in the "OSHA Compliance and MSDS Program". The MSDS contains all the vital information on hazardous chemical on the premises. If there is ever a question on the effects of a hazardous chemical by an employee, he/she will have access to the MSDS for review. Along with the MSDS there will be a corresponding hazardous chemical list. The list will contain the chemical name, manufacturer name and MSDS corresponding reference number. This will give any employee looking for information regarding a hazardous chemical easy and immediate access to the MSDS of choice.

It will be required to maintain the premises in a sanitary condition. The funeral home will be kept clean and without hazards due to obstructed hallways or work areas at all times. Contaminated waste will be disposed of properly and by trained personnel. Contaminated laundry will be placed in the proper container and handled accordingly. If laundry is done on premises, it will be handled by trained personnel and gloves will be worn. If laundry is contracted out, there will not be an overabundance in the prep room at any time.

The purpose of the training program for this facility is to help reduce any job-related accidents that may cause serious illness or death. This training program shall be taken seriously and all requirements implemented.