Worry

NFDA’s environmental study concludes septic systems can safely treat funeral home wastewater

In June 2003, NFDA issued a report on its two-year-long septic study, “Investigation of the Removal of Formaldehyde and Phenol by Funeral Home Septic Systems” (LaKind and Bouwer). The study, conducted by two leading environmental scientists, found that funeral home septic systems 1 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.

NFDA has worked with the United States Environmental Protection Agency (EPA) since the mid-1990s to ensure that funeral home septic systems are properly regulated 2 . Aware of the priorities of EPA and state environmental agencies to protect drinking-water sources, NFDA began the septic study to provide concrete, scientific information confirming the effective treatment-capability of funeral home septic systems located throughout the United States.

Since the early 1990s, NFDA has taken a leadership role by sponsoring environmental research on funeral home wastewater. These studies provide the scientific foundation upon which funeral directors can build to serve their profession and their community as good environmental citizens. [ Editor's note: Please read the companion article, “Ten Things Every Funeral Director Needs to do to be a Good Environmental Citizen,” in next month's issue of The Director.] The septic study expands upon the “Funeral Home Wastestream Audit Report” (Killam Associates, 1995), NFDA's initial environmental study, which examined the composition and fate of funeral home wastewater, and determined that funeral home wastewater has little to no impact when discharged to municipal wastewater-treatment works. Until NFDA's study, there was no information available about the constituents of the wastewater, its volume or the ability of the treatment works to handle the wastewater.

NFDA's report on the first study included an extensive review of the products that funeral directors use by examining the Material Safety Data Sheets for those products and the composition of the wastewater produced by sampling the wastewater. The wastestream audit determined that funeral homes could safely discharge wastewater to a local treatment system because the volume of funeral home wastewater is inconsequential when compared to the volume of wastewater that the treatment works receives. Moreover, the study concluded that the primary chemical constituents of the wastewater, formaldehyde and phenol, can be expected to undergo extensive treatment by biodegradation in the sewers and treatment works.

Funeral homes located in small – particularly rural – communities often lack access to municipal wastewater-treatment systems. Instead, these funeral homes use onsite wastewater systems, typically septic systems, to treat the wastewater that the funeral homes produce. Funeral homes that discharge to septic systems are typically smaller in size than other funeral homes, when measured by the number of embalmings conducted. NFDA has determined that funeral homes using septic systems perform embalming approximately every seven to 35 days, amounting to between 10 and 52 embalmings annually, as compared to the average 135 embalmings conducted annually by funeral homes that discharge to treatment works. NFDA has estimated that somewhat more than 20 percent of the 22,000 funeral homes in the United States utilize septic systems.

A large group of products is available to funeral directors today to assure that embalming produces the desired results. Funeral directors are trained to employ the proper products in the proper amounts and to meet the high standards of the funeral profession for correct chemical handling and disposal. The wastestream audit documented that funeral home wastewater contains water, residues of the preservative products that funeral directors use in embalming (primarily formaldehyde and phenol), bodily fluids, and sanitary wastewater from other activities that take place at the funeral home and, possibly, from a private residence in the funeral home.

Virtually all embalming products contain formaldehyde, which continues to be the primary and most common preservative compound used in embalming. Phenol also is a preservative in embalming products, primarily in cavity formulations. It is widely used as a disinfectant and antiseptic, and is considered one of the most effective germicides. Phenol also is included in an array of household products commonly used at funeral homes, including cleansers and toilet disinfectants. The fate and transport of formaldehyde and phenol is the subject of the septic study because these preservative and disinfectant compounds were detected in the funeral home wastewater that was sampled.

With the exception of residues of formaldehyde and phenol, wastewater from a funeral home will be very similar to conventional sanitary wastewater. The volume of wastewater ordinarily discharged from a funeral home is small – on average, 632 gallons daily – with an average of 120 gallons of that wastewater produced when an embalming is performed.

Like residential wastewater, funeral home wastewater is likely to contain some amount of blood and bodily fluids. This should not pose a problem, however, as the Centers for Disease Control and Prevention (CDC) has determined that wastewater containing blood can be safely discharged to septic tanks, and that conventional on-site wastewater treatment will satisfactorily inactivate bloodborne pathogens. (See “Draft Guideline for Environmental Infection Control in Healthcare Facilities, 2001,” Centers for Disease Control and Prevention, Healthcare Infection Control Practices Advisory Committee, at 1, 99, 166, 167 and accompanying footnotes, updated November 8, 2002. This document can be accessed at www.cdc.gov/ncidod/hip/enviro/env_guide_draft.pdf.) CDC identified several factors that enhance the inactivation of bloodborne pathogens in wastewater disposal and treatment, including dilution of the discharged materials with water and inactivation of pathogens due to exposure to cleaning chemicals, disinfectants and other chemicals in the wastewater.

According to NFDA, the standard practice when an embalming is performed is to release the wastewater discharge only after bodily fluids have commingled with the embalming solution. This means that, as embalming proceeds, but before wastewater discharge, the preservative and disinfecting compounds will become mixed with the bodily fluids and will principally disinfect the bodily fluids, the blood and their microbial contents prior to discharge.

NFDA retained Dr. Judy LaKind, a leading health and environmental scientist, and Dr. Edward Bouwer, a professor of environmental engineering at Johns Hopkins University, to design and conduct the study of the efficacy of funeral home septic systems. Although septic systems have been extensively studied, LaKind and Bouwer reported that there are no studies in the published literature that examine the performance of funeral home septic systems, including the biodegradation of formaldehyde and phenol in such systems. Their report, which is contained in a comprehensive white paper and two extensive technical appendices, confirms, through a combination of modeling and field sampling, that septic systems are capable of treating wastewater from funeral homes by biodegradation and other processes at rates that will result in little or no impact to groundwater.

1. A model that explains the extent to which biodegradation in a septic system will remove formaldehyde and phenol from funeral home wastewater entering the system.

2. A field study that corroborates the model with actual data from a funeral home on a septic system. They designed the investigation so that its results are broadly applicable to funeral homes on septic systems throughout the United States, regardless of the size of the funeral home, its design or its location. The model indicates that extensive and, in some cases, complete biodegradation of formaldehyde and phenol will take place in the septic tank and that formaldehyde and phenol remaining when the wastewater enters the septic leach field after tank treatment will ordinarily be completely treated in the leach field.

A field study conducted at a funeral home on a septic system corroborated the conclusions of the “Funeral Home Septic Biodegradation Model.” The field study entailed sampling the funeral home's septic tank effluent to indicate the concentrations of formaldehyde and phenol exiting the tanks, and the groundwater upgradient and downgradient of the septic system to document the treatment provided by the septic system. The funeral home, which has been in operation since 1991, conducts approximately 50 to 60 embalmings annually. Both formaldehyde and phenol were detected in the effluent in the septic tank in the two sets of samples collected. Samples collected from locations that received the treated wastewater effluent from the septic tank showed reductions in concentrations of formaldehyde and phenol consistent with the model.

The EPA has recognized that onsite wastewater systems are “potentially viable, low-cost, long-term, decentralized approaches to wastewater treatment if they are planned, designed, installed, operated and maintained properly.” (US EPA, 1997) The septic study confirms the viability of onsite wastewater systems for funeral home wastewater, and should lay to rest any issues about the ability of funeral home septic systems throughout the United States to treat formaldehyde and phenol in funeral home wastewater.

1 Funeral home septic systems are regulated by the United States Environmental Protection Agency and the states as Class V wells under the “Underground Injection Control Program of the Safe Drinking Water Act.” A septic system typically includes a septic tank and a leach field. Large-capacity cesspools and motor vehicle wells also are Class V wells, but NFDA's study did not cover cesspools and motor vehicle wells. Under US EPA regulations, large capacity cesspools and motor vehicle wells are required to cease operation and shut down.

2 The United States Environmental Protection Agency issued new rules for Class V wells, including septic systems, in 1999. The EPA decided against issuing additional rules in 2000. NFDA was actively involved in the process leading up to the rules. NFDA President Dwayne Spence also served on the National Drinking Water Advisory Committee. NFDA participated in the Small Business Regulatory Enforcement Fairness Act process, articulating its concerns about the EPA's rulemaking plans because of their likely impact on funeral homes as small businesses. NFDA prepared written comments demonstrating that funeral homes were not the type of “high-risk” wells that required additional regulation. NFDA met on several occasions with high-level EPA officials, and NFDA's advocacy was successful and no additional requirements were imposed on funeral home wells.

Carol Lynn Green, Bethesda, Maryland, serves as NFDA's environmental-compliance counsel. For more information, contact Green at 301-941-8038 or John H. Fitch Jr., senior vice president of NFDA's Advocacy Division in Washington, D.C., at 202-547-0441, visit the advocacy section of NFDA's Website at www.nfda.org, or write to NFDA, 400 C Street, NE, Washington, DC 20002.

This article appears in the November 2003 issue of The Director.

Reprinted with the permission of the National Funeral Directors Association, The Director, NFDA Services, Inc., May 2008.