Funeral Director Code of Practice

Care of the deceased and premises used by the funeral director

21. The funeral director should familiarise themselves with the Health and Safety Executive’s guidance on managing infection risks when handling the deceased. It covers the safe handling, storage and examination of bodies and pathological specimens in hospitals, mortuaries and post-mortem rooms. It also provides guidance for those involved in funeral services (including embalmers).

22. It is expected that funeral directors clearly and sensitively describe their services for care of the deceased to the client and must keep a record of having done so.

23. It is important that no client is pressured or exploited, and advice should be given to them by experienced and/or trained staff in a clear manner using plain language. The funeral director should always be mindful of the difficult circumstances the client is likely to be experiencing.

24. The client must be told the location(s) where the deceased will be cared for/kept.

25. Where the funeral director is using the services of another provider for any part of the care of the deceased a written Service Level Agreement (SLA) must be in place with that provider. Each SLA must be reviewed regularly and at least once per year. A SLA is not required for singular ad hoc arrangements (e.g. repatriation); in such a case a written agreement is sufficient.

26. Where aspects of care of the deceased are being carried out by a third party the funeral director must clearly and sensitively inform the client which aspects of the care of the deceased these are and keep a record of having done so.

27. All care of the deceased must take place in a location(s) specifically chosen for that purpose and the funeral director must ensure that their care facility or mortuary is fit for purpose. This requires that:

• the premises are lockable and accessible by authorised persons only.
• the premises are clean, well-maintained and regularly inspected to ensure high standards of cleanliness.
• the location of, and access to and from, the care facility or mortuary is suitable for the designated purpose.
• the funeral director has access to equipment that can accommodate all body types and care services offered by the funeral director and the equipment must be well maintained.

28. The funeral director must carry out regular visual checks of the condition of the deceased and a further check immediately before the coffin is closed or immediately prior to the funeral service if no coffin is being used.

29. The funeral director must retain a comprehensive record of all deceased persons who have been in their care. The record must be sufficiently detailed to record what actions have been carried out in relation to the deceased (e.g. first offices, washing, dressing – where, when and by whom, time of deceased’s arrival and departure at funeral director’s premises). The record must be stored in an accessible form, in secure conditions and is to be retained for a minimum of 5 years. Where a record contains data about any person who is still living, funeral directors are required to comply with all relevant legislation (e.g. UK General Data Protection Regulation, the Data Protection Act 2018 etc.).

Care practices

30. The funeral director must be able to demonstrate that they have assessed the activities undertaken by every staff member whose role includes duties relating to the care of the deceased. A record of each assessment, the outcome of the assessment and training requirements/training undertaken must be kept by the funeral director and made available to inspectors on request.

31. At all times during their care the dignity of the deceased must be maintained and appropriate shrouds, clothes and/or modesty covers used.

First offices

32. First offices is a process of caring for the deceased to assist with preservation and to make them presentable for viewing.

33. When requested the funeral director must describe their services for first offices in a way that is sensitive to the client to ensure that the client has an understanding of how the deceased will be cared for by the funeral director.

34. Where it is possible to do so first offices must take place in every case unless the client has specifically requested that first offices are not to take place. First offices must be carried out in a manner that maintains the dignity of the deceased, treats them with care (including moving the deceased in ways which avoid damage) and, at a minimum, includes cleaning and washing the body, dressing them, closing the eyes and mouth and arranging the hands.

35. Where first offices have not taken place the funeral director must keep a record of the reason/s for this.

Embalming

36. Embalming is defined as the preservation of a body from decay through injection of a chemical embalming fluid. The preservative solution (the embalming fluid) replaces the blood as well as treating the body cavity and organs.^[1]

37. Embalming is not a requirement for burial or cremation.

38. There is no requirement for the funeral director to offer embalming as a service.

39. The funeral director must provide clear information to the client about embalming in order that the client can make an informed decision about whether or not to instruct embalming.

40. The funeral director must obtain the client’s informed and written permission before embalming can take place.

41. It is the responsibility of the funeral director to ensure that those performing embalming on behalf of their business are adequately trained/qualified to do so and are meeting the necessary health and safety requirements.

Emergency invasive procedures

42. An invasive procedure is any procedure that involves the breaking of skin or the opening of bodily cavities.

43. In some circumstances it may be necessary for the funeral director to perform an emergency invasive procedure with the intent of preserving the deceased to a good standard.

44. In the event of these circumstances occurring the funeral director must make reasonable attempts to contact the client and explain the circumstances in advance of performing the procedure.

45. It is the responsibility of the funeral director to ensure that those performing emergency invasive procedures are adequately trained/qualified to do so and are meeting the necessary health and safety requirements.

46. In every case the funeral director must keep an accurate record of the circumstances and the procedure carried out. This record must be made available to inspectors on request.

Refrigeration

47. Refrigeration is a critical element of caring for a deceased person in a dignified, appropriate and respectful manner.

48. The funeral director must have on their premises, or have access to, clean and appropriate refrigeration facilities to store the deceased in their care. Where refrigeration is provided by a third party a SLA must be in place. Each SLA must be reviewed regularly and at least once per year. Where refrigeration is being carried out by a third party the funeral director must clearly and sensitively inform the client of that fact.

49. Refrigeration can be a purpose-built refrigeration unit or temperature controlled cold room. Refrigeration units and cold rooms must be kept between 4 – 7 degrees Celsius.

50. The required refrigeration capacity that a funeral director must have on their premises, or have access to through a SLA, should be sufficient to accommodate persons received into the funeral director’s care. A funeral director must review their refrigeration capacity at least once per year.

51. Each deceased person must be stored individually in separate compartments (e.g. a separate rack shelf or drawer) within the unit or cold room.

52. Refrigeration units must be in a locked and secure location. Cold rooms must be locked and in a secure location.

Viewing of the deceased

53. The funeral director must provide clear information to the client about whether they provide viewing of the deceased as standard. This will enable the client to make an informed decision about whether or not they would wish to view the deceased.

54. If viewing is not normally offered as part of a service, for example where the funeral director only offers direct cremation, the funeral director must make it clear to the client, before the client engages their services, that viewing is not included as standard. If the client subsequently requests to view the deceased the funeral director is to take steps to facilitate a viewing where possible, for example by agreement with another funeral director to use their viewing facilities. Any additional costs for facilitating viewing should be made clear to the client before that service is provided, in accordance with the Competition and Markets Authority (CMA) Funeral Markets Investigation Order 2021.

55. Viewing areas must be fit for purpose, private, clean, regularly inspected and well-maintained.

56. Prior to any viewing the funeral director must ensure that the identity of the deceased is checked to ensure that the correct deceased person is shown to the visitor and that regard is given to requests made by the client such as: make-up application, if the coffin is closed or left open, who can be permitted to view the deceased, etc.

57. The funeral director must ensure that bereaved persons are afforded privacy when viewing the deceased. The funeral director or another trained and competent member of their staff must remain near and ‘on hand’ to answer any questions or requests.

58. In some circumstances viewing the deceased may not be recommended by the funeral director or some restrictions may have to be put in place such as viewing behind glass.

59. In circumstances where the funeral director advises against viewing entirely the funeral director must provide the client with sensitively worded advice setting out their reasons and make every effort to support the wishes of the client in relation to that advice. The funeral director must keep a record of this advice.

60. Where the funeral director has advised against viewing but the client does not accept that advice the funeral director must keep a record of this.