Phase I at a Funeral Home
    Topic posted April 19, 2011 by ESG66Member, last edited January 19, 2012 
    4129 Views, 26 Comments
    Phase I at a Funeral Home

    I might be doing a Ph I for a former funeral home.  Not having done a funeral home before, what type of concerns should I be looking for?  Just looking for some insight.





    • jessedphillips

      Good question....I haven't done one of these either.  Can whoever responds to this throw in any concerns about a cemetery too?  I've always been curious.  I'd assume for the funeral home that there are all sorts of nasty chemicals that, in the early days, could have been spilled or disposed of using nefarious methods.  I'd also assume that the cemeteries could have such issues, but that both are regulated today by Departments of Occupational Regulation or somesuch. 

      Might be offbase though.  Good topic!

    • Emily B

      Oh wow, this is a great topic!  I have no experience with funeral homes, but I imagine that you would be right to wonder about some sort of chemical waste stream (formaldehyde or something? no idea), as well as possibly biowaste, but depending on years of operation, that might not have been strongly regulated.  I would imagine they would have some vehicles (hearses) on hand, but that you wouldn't need to worry about fueling or maintenance issues, and that any vehicle issues would likely be de minimis.

      This should be a very educational and interesting discussion!

    • azebell

      We recently worked on a funeral home and one of the primary concerns we identified was the disposal of the various embalming chemicals used at funeral homes.  Our particular site was connected to the municipal sanitary sewer system so everything got processed through the wastewater treatment plant.  All the information we got said that was standard practice.  Just send it down the drain, it all goes to the city to worry about (assuming your site does not use a septic system).

      We still sampled near any floor drains just in case.  Formaldehyde was one of the big concerns.  There are also some chemicals used by funeral homes that contain benzene and toluene.  A review of MSDS sheets would tell you exactly what they are using.

    • kevin

      Funeral homes have purchased embalming fluid on an as needed basis since the 1960s.  That isn't to say one or two larger companies doesn't stored the stuff in bulk - anything is possible.  Treat the job as if you are assessing a science lab.  Most have POTW discharge permits and some have water treatment separators similar to car washes.        

    • rbeebe

      Arsenic was commonly used from the 1860's to about 1912 for embalming; several pounds per cadaver.

    • DClement

      We did a Phase I at a funeral home a while back.  The concerns we had included the caretaker residence on the property.  The residence used fuel oil for heat, and there was a former UST (and a newer AST) which held the fuel oil. The property owner was unable to provide us with any decommissioning/sampling report for the UST closure and the ventline was still there going into the ground.

      The funeral home itself had an embalming room which was not currently in use, but historically was used.  There was a floor drain in the room that connected to the city sanitary sewer system, and when the room was used for embalming "minor" amounts of wastes would drain to the system. 

      This funeral home was multi-story so there was an elevator - in this case electric.

    • Donald

      A few things: lead and mercury have been found to be problems at cemeteries and funeral homes.  Embalming is associated with acids, alkalis, and a number of other metals (antimony, arsenic, barium, cadmium, chromium, cobalt nickel, zinc).

      As always, if you read the Phase I ESA standard, if you are not experienced with this type of property, you should NOT be doing the assessment, but you should go with a person who is experienced.  If you admit to a lack of experience, and anything goes wrong down the road (lawsuit), you will get hammered by the opposing counsel.

      Thanks …

      • McCarthy

        I realize this post is more than a year old, but was querying it as I'm approaching a Phase I at a Funeral Home.  I think your second paragraph represents a very narrow interpretation of the Phase I ESA standard, or by logic no one would ever perform a Phase I on any type of property that they hadn't done before, or completed it under another EPs tutelage (which isn't a reasonable expectation).   Please elaborate....others welcome to chime in...thanks

    • JenW

      I did a Phase I for a funeral home several years ago.  It was for a previous employer, so I can't pull up the report.  I recall the critical issue being weather the home ever had a septic system or not.  I suppose our conservative clients would like to know the integrity of the drains in the embalming room, regardless whether they go to the sanitary sewer or a septic field.  @azebell - did you find anything when you sampled near the floor drain?

      Never did a Phase I on a cemetery, but I recall an article indicating they would most definitely be a REC.  Arsenic would be a contaminant of concern.  Found this article doing a Google search:


      • azebell

        We definitely found visual impact (pink soil that perfectly matched the color of one of the chemicals).  However, lab results did not identify any contaminants of concern. 

    • bkea

      Years ago we did a Phase I on property that surrounded a mortuary on three sides.   It had been in operation for years,  was downtown and was on city sewer.    We called it a REC and did a Phase II.  We found a low concentration of formalehyde the groundwater sample that the state didn't care about.   Even if the facility is on community sewer, the sewer lines may be in less than good condition. 

    • ECI

      I have not conducted a Phase I ESA 1527-05 with AAI at a funeral home.  However, I have a comment on cemeteries. With the exception of non-Jewish cemeteries, prior to 1915-16, bodies were embalmed with arsenic.  They did not use the thick walled concrete vaults or metal caskets, so as the bodies decomposed and the caskets deterriorated the organic reverted back to the organic, so to speak, and what was left was arsenic, and plenty of it.  In Macomb County Michigan there was a big problem when an upscale condominium was constructed nea,r and partially on,  an old cemetery site. They were originally going to have well water as opposed to municipal water service.  However, it was soon discovered that the groundwater was hugely impacted by arsenic and was unfit for drinking. By the way, the reason I excluded non-Jewish cemeteries is due to my understanding that Jewish people do not embalm their deceased at all, which is why they are typically interred within 24 hours of death. 

      • ECI

        Excuse my error above. I meant to exclude Jewish cemeteries and I meant to say "...with the exception of Jewish cemeteries.."  not non-Jewish cemeteries.  Jewish cemeteries do not pose the problem of contaminating the ground with chemicals.

      • jessedphillips

        I believe that's right, regarding Jewish burials.  And, contrary to popular belief, you don't HAVE to be embalmed; not in Virginia anyway.  Certain cemeteries have requirements that everyone must be embalmed, but others will allow a "natural" burial.  I believe it's the state that requires burial within 24 hours if there is no preservation.  It's a sanitation thing.  There's something weird about pumping a corpse full of chemicals to me.  I'll be in the ground pretty quick. 

    • Tom Speight


      If they're on a septic and have disposed of bodily fluids via it, there could be some water quality impairment issues if they or their neighbors are on a private well-- maybe not so much an OHM issue as odor, dissolved oxygen, etc.

      • jessedphillips

        So long as they don't migrate "into structures on the property or into the ground, ground water, or surface water of the property," you should be fine, although it's a business environmental risk in any case.  I'd recommend the installation of fencing along any surface waters and around wells, and recommend the stocking of chainsaws or other implements meant to deter the migration of such zombies on the property. 

        • Emily B

          Excellent engineered control ideas.  Zombies don't seem like a very coordinated bunch.

          There's also the potential for haunting.  Would a ghost (or "shadow people" as seen on all of those ghost hunting shows) be considered a VEC? 

          • Tom Speight

            IIRC, didn't the EPA v. Venkman, Spengler, Stanz et al decision (dramatized as the movie 'Ghostbusters') settle that back in the 80s?  The court held that ghosts cannot be classified as a hazardous waste because as insubstantial phenomena (i.e. not solid) they do not first constitute a solid waste, and are thefore not subject to RCRA.  The decision didn't speak to zombies though.

            (all in good fun)

    • crims

      According to the EPA -

      Because many funeral homes employ an on-site sanitary system for disposal of embalming wastewater, EPA regulates these as Class V industrial process water and waste disposal wells. EPA has found that wastewater includes external corporeal wash water, internal body fluids, as well as residual arterial embalming chemicals. These chemicals typically include formaldehyde, phenol, and methanol. A funeral home disposing of embalming fluids in an on-site sanitary system, has three options: 1.Connect to the sewer, if access is available, 2.Containerize embalming waste and haul it off site, or 3.Apply for a UIC permit, and operate under a UIC permit if granted.

      I'll likely be doing a Phase I on a mortuary in the next month or so, so I've been researching it as well. The site had several removed USTs and has been a mortuary since the 1930s.

    • crims

      Another source of information from the National Funeral Directors Association on the use of septic systems in funeral homes is below.

      "The study, conducted by two leading environmental scientists, found that funeral home septic systems are capable of treating formaldehyde and phenol, the key ingredients of funeral home embalming products, to low levels that will not jeopardize the safety of drinking-water sources or the public health."  The study doesn't mention the use of other potential chemicals of concern that may have been used historically by funeral homes though.

    • crims

      Yet another EPA article on funeral homes, cesspools and groundwater impacts at

      Funeral homes in Region 2 were found to be injecting embalming waste fluids into Underground Injection Control (UIC) wells, which are regulated by the Safe Drinking Water Act.  Formaldehyde and phenol are principal constituents of embalming chemicals, which present human health risks, if ingested in drinking water.  Bloodborne pathogens and pharmaceuticals can also be present in embalming waste fluids. 

      Region 2 developed a Funeral Home Initiative with four goals: 1) improve environmental compliance with UIC regulations at funeral homes over Underground Sources of Drinking Water (USDW); 2) prioritize environmental compliance as part of funeral homes’ normal operations; 3) ensure compliance of the entire business sector, not only facilities that are inspected; and 4) ensure continued compliance through permanent changes.  Region 2 implemented this initiative with local and state agencies, and the New York State Funeral Directors Association.    

      To date, 58 EPA UIC inspections identified 26 facilities practicing on-site embalming waste fluid injection.  Twenty-five of these funeral homes voluntarily ceased injection into their UIC wells, prior to inspection.  They are remediating contaminant residuals from former injection of waste embalming fluids.  Waste fluid generation from embalming is reduced from at least 120 gallons to only 5 gallons.  About 288,000 gallons of tap water per year for the 25 facilities, are being saved.  Wastes from waterless aspiration are now managed as medical wastes.

      Twelve of the EPA inspected funeral homes operated Large Capacity Cesspools (LCP) for disposal of embalming waste fluids and sanitary wastes.  LCP’s were banned by EPA on April 5, 2005.  Funeral homes operating the banned LCP’s were issued Non-Penalty Orders for Compliance, requiring them to cease injection to LCP’s and remediate any residual contamination.  Rapid compliance is being achieved.

      As a result of this initiative, there is now increased regulatory compliance and pollution reductions among funeral homes; implementation of innovative technology to eliminate embalming fluid injection, while concurrently reducing water consumption; and lowered risk from former injection of embalming fluids to USDW’s.  Results indicate enhanced knowledge of and compliance with regulatory requirements; prevention or mitigation of risks to USDW’s; and conservation of potable water.  In addition, approximately 20 cubic yards of contaminated material, per facility UIC well, are being addressed. 

    • David Bachman

      All very excellent comments (except maybe the zombie ones).  One thing that has not been noted is the taking of pictures.  It is unethical, improper, and I think illegal to take pictures of dead people in funeral homes.  I have taken pictures of the viewing room just before it was to opened for business, but made sure any pictures that included the casket were at an angle that didn't show what was inside.  And I was prevented by the funeral director from taking any pictures in the embalming room because two bodies were in the middle of preparation.

      • Emily B

        That's a really good point; I had been thinking of a scenario where the building is no longer in active use.  In sensitive situations, it's important to work with your client and site contact to protect everyone's interests.

        Once upon a time I did a Phase I at a laboratory, where certain areas were off limits for photos or visual access based on the nature of the research being conducted and proprietary aspects of it.  I added that into the report as a limiting condition, and was able to get what I needed regarding typical materials use, storage, and disposal through interviews.  In a similar case, I worked with the site contact to have him send me a photo of the floor drain I was interested in, taken at a time when the room was out of use.