Funeral Director - Code of Practice: consultation analysis

Analysis of the consultation carried out between June and September 2019 on the proposed Funeral Director: Code of Practice.

3. Qualifications: Questions 6-9 and 11

Question 6

Do you agree that all funeral director, funeral arranger/administrator and funeral service operative/assistant/driver/bearer training and qualifications should be accredited by an official accreditation body, such as the Scottish Qualifications Authority, or another official UK accreditation body?

Eighty of the 86 total consultation respondents answered Question 6. Sixty-four respondents expressed agreement (either 'strongly agreed' or 'agreed') that all funeral director, etc. training and qualifications should be accredited by an official accreditation body, such as the Scottish Qualifications Authority, or another official UK accreditation body. While the majority of support came from non-funeral director respondents, support also came from funeral industry trade body respondents. Eleven of the 13 respondents that expressed disagreement ('disagreed' or 'strongly disagreed') were funeral director organisations or individual funeral directors.

Table 8: Responses to Question 6.
Answer Number
Strongly agree 33
Agree 31
Disagree 10
Strongly disagree 3
Don't know 3
Total 80

Respondents' comments often went beyond a strict focus on accreditation, to discuss issues related to training and qualifications more generally, and often using the terms interchangeably. It was evident from the responses that there was varied understandings, and possibly some confusion, about the meaning, of the term 'accreditation'. This is addressed in section 9.

Nonetheless, most comments were generally supportive of accreditation. Others focused on the potential outcomes of implementing accreditation, such as building public trust; improving service delivery standards; simplifying training; and improving standards of care of the deceased.

Funeral industry trade bodies, which, at the time of the consultation, offer a variety of non-accredited training and qualifications, all highlighted how critical qualifications were to the future of funeral directing. One funeral director organisation stated that mandatory qualification(s) were required for funeral directing to become a "recognised profession" and another commented that a concerted effort was needed for changes to education and training to take place.

"Education and training is crucial to the funeral directing trade, this will provide a strong foundation for all members, it will give them confidence in their job and will help give the public faith and knowledge in the people who have been entrusted with their loved one know exactly what they are doing. The B.I.F.D., N.A.F.D. & S.A.I.F. already have training, exams and certificates of competence, wither using an outside company enhances this is very doubtful, where do the external examiners obtain their training if not through one of the above?"(Funeral industry trade body)

"The need to improve this area isn't news for the sector and has been deflected by the profession for 20 years. If we aren't forced to improve then nothing will happen." (Funeral director organisation)

Three respondents called for the Scottish Government to create qualifications, or to be involved in their creation. However another four respondents noted that training and qualifications should be kept 'in-house'.

Despite the general support expressed for accreditation, some comments indicated there should be flexibility around any proposed statutory qualification(s) in the future. For example, some respondents specifically stated that qualifications should not be required for all roles or wanted the Scottish Government to consider exemptions or alternatives for experienced practitioners ("grandfathering"). For example:

"Although I do agree that there should be more regulation and training - I think it would be a grave error to impose official training on all funeral related jobs, particularly on the lower skilled jobs, as long as training is provided by the employer. Official training of all staff would make it very difficult for small companies to prosper and exist." (Funeral director organisation)

"Training should be offered by an independent body and adequate training for funeral staff should be available for those requiring it. Existing practitioners in the funeral sector should not be required to undertake training if they can demonstrate competence acquired through experience."(Other organisation)

In contrast to those supporting accreditation, a minority of respondents warned against any future qualification(s) requirement. Objections included that costs could be passed to families or that strict qualification requirements for all roles may affect organisations that rely on volunteers.

"[The] [c]urrent situation is entirely adequate. Training costs would be passed on to families and would increase the cost of a funeral which I'm sure the Scottish Government do not want to be responsible for." (Funeral director organisation)

Question 7

Question 7 comprised three sub-questions: 7.1, 7.2 and 7.3. These sub-questions asked respondents about the 'appropriateness' of levels on the Scottish Qualifications and Credit Framework (SCQF) with respect to different roles within the funeral industry. Respondents were provided with a description of each SCQF level and a link to more information about SCQF within the consultation. Funeral industry roles are not currently associated with the SCQF, and this question sought to assess whether SCQF levels were appropriate for certain key roles.

Question 7.1: Is Level 6 an appropriate level on the SCQF for a funeral director qualification to be registered at?

Question 7.2: Is Level 5 an appropriate level on the SCQF for a funeral arranger/administrator (FA) qualification to be registered at?

Question 7.3: Is Level 4 an appropriate level on the SCQF for a funeral service operator/assistant/driver/bearer (FS) to be registered at?

Seventy-five of the 86 total consultation respondents answered Questions 7.1, 7.2 and 7.3. The frequencies of responses are presented in the tables below.

Table 9: Responses to Question 7.1
Answer Number
Yes 39
No 10
Don't know 26
Total 75
Table 10: Responses to Question 7.2
Answer Number
Yes 38
No 11
Don't Know 26
Total 75
Table 11: Responses to Question 7.3
Answer Number
Yes 34
No 14
Don't know 27
Total 75

For all three sub-questions, the most frequently selected option was 'yes', indicating that majority of those who responded agreed with the SCQF levels proposed. A relatively high number of respondents also selected 'don't know', indicating uncertainty if the levels were appropriate or not.

In general, the majority of support for the proposed levels and qualifications came from non-funeral director respondents. However, 10 funeral director organisations, two individual funeral directors three funeral industry trade bodies agreed with all of the proposed levels. The open-ended comments also indicated that most respondents were generally supportive of the proposed SCQF levels. Some respondents indicated that although it would require some investment, funeral directors will ultimately benefit from achieving standardised, accredited qualifications (despite potential costs).

"… [The levels] are the minimum standards that the public would expect of such a profession. The levels are right when compared to the responsibilities and job descriptions of those roles. It may take some considerable time to achieve this but it is right to set it as a level." (Funeral director organisation)

"I think there has to be some formal training at an appropriate level to ensure the deceased are treated properly and this would be an appropriate level." (Individual)

"It may cost Funeral Directors to become qualified but well worth it…" (Faith/religion based organisation)

Other correspondents expressed disagreement with the proposal, suggesting, for example, that training "can be carried out in house" (Funeral director organisation). One respondent felt the delivery of accredited qualifications by the funeral industry trade bodies may limit consumer options.

"… Training for training sake is not appropriate and would only further line the pockets of those organisations that make money from such training. I am happy to be scrutinised and if I am found wanting then apply conditions. However, I work with families to help create personal appropriate ceremonies and wish to continue to do so outside of a one-size-fits-all framework applied by a trade organisation. Accreditation may stop people being able to choose more individual approaches to funerals." (Funeral director individual)

The final set of respondents, those that selected 'don't know' (26), were comprised of funeral director organisations and individual funeral directors. Most provided no further explanation for their selection, however those that did seemed to be generally unsupportive of either the proposed levels or of training/qualifications in general.

The comments highlighted some further considerations. First, a small number of respondents suggested amending the proposed levels. For example, one funeral industry trade body expressed that funeral service operators, etc. should be trained to Level 2 on the SCQF, instead of to the proposed Level 4. Additionally, it was noted that an accredited training programme, as opposed to a qualification, was more appropriate for people in these roles to undertake. A couple of comments actually suggested higher levels for some, depending on role and client contact rate:

"Funeral arranger / administration - we believe that this should be set at level 6 (Higher) rather than a first level Modern Apprenticeship, due to the customer contact and sensitivity." (Local government)

"I would suggest the proposed levels 6 & 5 are each a level too low, and that a level 7 and 6 for funeral director / funeral arranger would be more appropriate, presuming that the funeral arranger is restricted to an administrative role?"
(Other organisation)

Second, a number of comments highlighted that FS roles were often discharged on a casual basis and that set training/qualification requirements may discourage potential applicants, precluding vacancies from being easily filled.

Finally, some comments suggested the nomenclature used to describe the roles in questions 7.1, 7.2 and 7.3 demonstrated an inherent bias in the Code towards one model of funeral directing over others. For example:

"I'm concerned to see that this code has been written with the conductor/arranger/bearer/driver model at its core. That would indicate that trade associations have heavily influenced the writing of this code and that it is geared towards corporate models of funeral directing." (Funeral director organisation)

Question 8

Do you agree that funeral directors, funeral arrangers/administrators and funeral service operatives/assistants/drivers/bearers should undertake training and receive qualifications that are primarily vocational in nature, with a focus on gaining practical skills over more classroom-based learning?

Eighty of the 86 total consultation respondents answered Question 8. Overall, a majority (n=58) of those who responded to Question 8 agreed or strongly agreed that funeral directors, FA, and FS should undertake training and receive qualifications that are primarily vocational in nature, with a focus on gaining practical skills over more classroom-based learning. Like Question 7, the majority of support for this proposal came from non-funeral director respondents.

Table 12: Responses to Question 8.
Answer Number
Strongly agree 21
Agree 37
Disagree 10
Strongly disagree 4
Don't know 8
Total 80

However, many comments (across those who replied 'agree' or 'disagree') highlighted the need to incorporate both vocational and classroom-based content. All of the funeral industry trade bodies appeared to support this kind of 'blended' learning in their comments

"There is a requirement for theoretical knowledge as well as practical skills." (Health body)

"We feel that Vocational Training should be mixed with Classroom Learning. There are pros and cons with both styles of training therefore to have a mix would definitely be the way forward." (Funeral industry trade body)

Some respondents suggested that the balance between vocational and classroom-based learning would vary depending on the job description. A minority of comments expressed that any future training and qualifications should be almost entirely, or exclusively vocational, in particular for the roles of FS. For example:

"I would agree for some of these job descriptions only. For operatives, driver/bearers, and administrators it should very much be vocational and practical, whereas for funeral directors/arrangers this should include significant classroom learning and understanding of things like; legal concerns, statuary paperwork, grief, health and safety law, risk assessments etc." (Individual Funeral Director)

"Practical experience is far more important than classroom based learning; particularly for Operatives level and below. Classroom based learning does not work for many." (Funeral director organisation)

Additional issues raised were the need for flexibility in future qualifications requirements, for example the provision of distance or online learning; and inclusion of broader skills such as counselling or coaching. Some commented that accredited training should be optional rather than compulsory.

A minority of comments from respondents who disagreed with the proposal in Question 8 seemed to generally disagree with the training/qualifications concept rather than on any particular point pertaining to the content of any future qualifications:

"Formal qualifications are not the answer to the dubious practices of the funeral industry." (Funeral director organisation)

"No outside training required." (Funeral director organisation)

Question 9

Do you believe that accredited training and qualifications should be available to those wishing to undertake embalming courses in the future?

As context to this question, it is noted that there are currently no restrictions in who can carry out embalming, nor are there any accredited qualifications. An embalmer may be employed by a funeral directors' business or may set themselves up as an independent trader who works on a contractual basis for one or more businesses.

Seventy-four of the 86 consultation respondents answered Question 9. Overall, 70 of those who responded to Question 9 selected 'yes', suggesting they agreed that accredited training and qualifications should be available to those wanting to undertake embalming courses in the future. Most open-ended comments also seemed to support this view.

Table 13: Responses to Question 9.
Answer Number
Yes 70
No 3
Don't know 1
Total 74

Additionally, a number of comments also mentioned the training already available from the British Institute of Embalmers (BIE), and noted this body should either run or otherwise be involved in any accredited training for embalmers. For example:

"[Name redacted] believes that accredited training and qualification should be available to those wishing to undertake embalming courses as it provides peace of mind to the bereaved when their loved one will undergo embalming. At present, some embalming training exists in the industry and [name redacted] would welcome efforts to accredit this training and identify where there may be gaps that should be filled with new schemes. [Name redacted] notes that there is an existing professional body (the Institute of Embalmers), who should have a key role in defining how the training and qualifications in place are accredited and can be strengthened." (Funeral industry organisation)

Only three respondents selected 'no' in response to Question 9 and only one open-ended comment was submitted in relation to this, which was about this respondent's objection to embalming generally.

"I would prefer that we stopped allowing embalming. I believe it is toxic to the body and environment and it should be unnecessary to stop the natural process of decay." (Other organisation)

Two other key issues were raised in the comments. The first was that the currently available training/qualification(s) needed improvement. Concerns included the high cost of training, a lack of available funding for training, inappropriate duration (comments suggested they were both too long and too short) and limited training locations.

Secondly, one respondent noted that the draft Code could be improved by more clearly explaining certain processes:

"The code also fails to clearly explain 'first offices' or 'invasive procedures' and shows no understanding of how nuanced this work can be - sometimes procedures need to be carried out but the family do not want to know as they would find it damaging, both emotionally and psychologically." (Funeral director organisation)

Two further comments were received elsewhere in the consultation but which relate to embalming and are noted here. These provide suggestions for how the draft Code of Practice could be further developed in relation to this topic:

"…the decision as to how accessible the body is to relatives is ultimately the [funeral director]'s. As such, we feel that the sections in the Code of Practice referring to 'viewing' and 'embalming' should also include paragraphs which emphasise the [funeral director]s responsibilities in this regard, clearly indicating that any decision not to allow viewing/embalming is ultimately their professional decision based upon all information provided to them, and not simply the decision of medical personnel/pathologists who may have cared for the deceased prior to the involvement of the [funeral director]." (Health body)

There is no guidance on what constitutes 'circumstances where it may prove necessary for the funeral director to perform an emergency invasive procedure'… I don't not see that these 'emergency invasive procedures' have any justification whatsoever… Why would you document that embalming must be authorised and not done routinely and then add a section to legitimise 'emergency invasive procedures', with only reasonable attempts to gain the client's authorisation? It seems that it voids the whole exercise!!" (Funeral director organisation)

Question 11

How many hours of Continuous Professional Development (CPD) per year do you think (11.1) funeral directors (FD); (11.2) funeral arrangers/administrators (FA) and (11.3) funeral service operatives/assistants/drivers/bearers (FS) respectively should need to complete in order to stay up to date on industry best practices in the funeral industry?

Question 11 was comprised of three sub-questions: 11.1, 11.2 and 11.3. Of the 86 total consultation respondents, 78, 74 and 72 respondents answered Questions 11.1, 11.2 and 11.3 respectively. The majority of those that did not answer these questions were faith/religion based organisations.

Table 14. Responses to Question 11.1
Answer Number
0 Hours 7
Between 1 and 15 hours 39
Between 16 and 30 hours 28
More than 30 hours 4
Total 78
Table 15. Responses to Question 11.2
Answer Number
0 Hours 8
Between 1 and 15 hours 49
Between 16 and 30 hours 14
More than 30 hours 3
Total 74
Table 16. Responses to Question 11.3
Answer Number
0 Hours 9
Between 1 and 15 hours 55
Between 16 and 30 hours 7
More than 30 hours 1
Total 72

Overall, the most frequently selected response to each sub-question was that between 1 and 15 hours of CPD per year were needed in order to stay up to date on industry best practices.

From the open-ended comments, most respondents appeared to be generally supportive of the need for CPD. Many comments indicated it was important to regularly allocate time to stay up to date with changes in the funeral industry. Others, while supportive, provided additional contextual considerations:

"It is essential to continue professional development and this requires time. The biggest issue is that as a service industry providing 24/7 service 365 days a year when we can be called at any time to attend a death, to schedule and honour training/education sessions is difficult especially for smaller operators. E-learning would help with this but hands-on practical training and joint events/courses are very useful too, hence trying to go for an answer that is reasonable but also achievable is essential." (Individual funeral director)

Others cited recent or forthcoming legislative changes to the funeral industry in Scotland as a reason for selecting annual CPD hours at the higher end of the proposed range:

"With the large amount of new legislation, regulations, etc. coming into force in the funeral sector in Scotland, currently and in the foreseeable future, it is certainly crucial that the funeral director as the guide to families on legal and technical matters is fully abreast of these issues." (Funeral director organisation

The funeral industry trade bodies provided differing opinions on how many hours each role should undertake, however, all supported a minimum of annual CPD hours be required for each of the roles.

Some respondents provided comments suggesting that the 'less advanced' roles should be required to complete as many and in some cases more, CPD hours per year, than 'advanced' roles. Others stated that the minimum proposed requirement was more suitable for such roles:

"Funeral arrangers are the people who mostly deal with bereaved clients and have the emotional connection with them. They are the people who need the most training and development. 'Funeral operatives' are often responsible for collecting the person who has died from home, which is a difficult and sensitive time and needs to be done with extreme care. The importance of this role has been downplayed and undervalued." (Funeral director organisation)

"Whilst it is tempting to answer '0' hours, these individuals [funeral service operatives/assistants/drivers/bearers] have a vital interaction with the [bereaved] public." (Health body)

"I feel a maximum of 15 [hours] is required, the role of the funeral operatives are changing in a modern funeral directors. Therefore, personal development is essential to their overall training." (Individual funeral director)

A further set of open-ended comments (22) appeared generally unsupportive of CPD or raised particular concerns. The most common concern related to funeral staff finding the time to satisfy CPD requirements. There also seemed to be scepticism that certain segments of the industry would participate in even the minimum proposed requirement. Others suggested that proposing a minimum requirement was unnecessary or counterproductive, and that they would resist the imposition of this requirement.

"[G]ood luck with asking freelance bearers to attend CPD courses. you will lose an important element of the industry." (Individual funeral director)

"There is absolutely no point in making this mandatory as it will be counter-productive. A good funeral director should naturally strive to stay up to date on industry practices. This practice should be encouraged and facilitated but not imposed or it will become a tick-box exercise." (Funeral director organisation)

"Who decides what best practice is? My business has been conducting funerals since 1890. My funeral directors have 150 Years of experience I think we can decide what best practice is." (Funeral director organisation)

Similar to comments received for previous questions in this consultation, four respondents suggested that annual CPD requirements may disproportionally affect SMEs/rural funeral directors, citing a lack of time and/or resources.

"Most decent funeral directors spend their time looking at important developments and funeral rites and emotional needs as part of their day to day job - Having to take time out away from work and/or families to tick more boxes may well not be the best use of time or money for a small business." (Individual)

"As a small business with ever rising costs I simply could not survive if required to pay for regular CPD courses." (Funeral director individual)

Finally, clarity about the definition of CPD was requested:

"We would welcome clarity on the definition of CPD from the Scottish Government's perspective, and what it is envisaged this will include. In our view, CPD should be concise and focus on covering information on changing policies and practices, such as the introduction of the new Code of Practice, changes to health and safety legislation and new industry best practice. Going forward, it may also cover issues such as money laundering and GDPR." (Funeral director organisation)



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