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Virginia Regulatory Town Hall
Department of Health Professions
Guidance Document Change: Education and coursework for licensure as a funeral director
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3/8/21  8:11 am
Commenter: Dianne Rencsok

Guidance Document 65-7

There is no need for a pathology course to be a funeral director, just for an embalmer.  The Board of Funeral Directors & Embalmers has created Guidance document 65-7 in an attempt to clarify this requirement.  However, it does not provide sufficient clarity in guidance on how an applicant for Funeral Director could meet the requirement for a course in Pathology.  As an Emergency document, this is subject to change.  It is suggested that the pathology course requirement should be removed. 


A search for the term “pathology”  from Virginia colleges evidences the problem with this requirement.  Provided here are some examples of possible options that resulted with that search.

                     New River Community College: “Forensic Science” targeting police/crime investigation

                     Virginia Western Community College: “oral pathology” for dental hygienists         

                     Virginia Tech: 4 separate courses on Plant Pathology described as “the study of diseases, plant

                                            pathogens and their management”

                     Several institutions have Medical Technician or Medical Technologist programs.  When these are

                                           included in an internet search, one sees American Society for Clinical Pathology,                                                   (ASCP)the certifying organization. 

                     Five of Virginia’s community colleges offer: “Introduction to Human Pathology”.  This 

                                          Introduces the basic concepts, terminology, etiology, and characteristics of

                                          pathological processes” and is  part of the Allied Health Diagnostic, Intervention,                                                  and Treatment Professions, Other program.


                      Tidewater Community College has a Funeral Service degree program:  “Pathology for Funeral Service” . Its description “Introduces the general processes of disease, stressing their importance to the scientific embalmer and funeral director as health guardians.  Studies diseases of specific organs and organ systems with emphasis on the significant structural changes involved and the embalming problems they present.”   This description seems to have no relation to the needs of a funeral director not involved with embalming.


  If the purpose of creating a separate Funeral Director position is to attract someone to this profession who was not interested in the aspects of “scientific embalmer”, a requirement to take this course could negate that purpose.  With the exception of the Tidewater Funeral Service course, which focus is embalming (a separate licensure), the pathology courses on offer serve to create understanding of disease processes in order to care for and heal individuals.  Thus, delaying their need for a Funeral Director.             


                If the purpose of including pathology for licensure of the profession of Funeral Director is to assure that an individual is aware of possible health hazards to themselves and their area of responsibility, the training mandated by the Occupational Safety and Health Administration (OSHA) should meet that need.   Although it is doubtful that plant pathologists would be required to take the OSHA training on Bloodborne Pathogens and Occupational Exposure, the other professions cited would certainly be required to do so.  If there is concern that a Funeral Director might not be aware of the potential hazards for an Embalmer, this OSHA standard is cited:       1910.1030(c)(1)(v) An employer who is required to establish an Exposure Control Plan shall solicit input from non-managerial employees responsible for direct patient care who are potentially exposed … and shall document the solicitation in the Exposure Control Plan”.


The guidance document accepts “a course in pathology that is approved by the Board for licensure”.   More complete guidance is needed to identify such a course and its purpose.   Either this requirement should be removed as necessary for licensure, or the Board needs to provide more specific information on the purpose of the requirement and on resources available for successfully meeting it.

CommentID: 97290