These are answers to questions received from bereavement sector licensees as part of the BAO Registrar’s COVID-19 Update, on April 1, 2020 — presented via webinar.  

Thank you to our licensees for their ongoing vigilance. Thanks to the OACFP for hosting this webinar.

Note: The BAO’s COVID-19 web section is updated several times a week – often daily – with the latest Registrar’s Directives, Notices and relevant information.  

Q1. Are funeral homes required to inform the cemetery of a COVID-19 death?

A1. Yes, of course. You must provide whatever information is available to ensure that cemetery staff can prepare and take precautions to ensure that their staff are kept safe, and any other relevant information.  Common sense prevails. There is no requirement to provide cause of death unless it could be detrimental to the operator and the staff.

Q2. Are cemetery offices required to be open?

A2. Cemeteries must be able to operate seven days a week. Whether you need your cemetery office open 24/7 is up to you.

Q3. Is there a duty for cemeteries to report on COVID-19 burials?

A3. It would be appropriate during this pandemic to keep suitable records.

Q4. Where can statistics related to the COVID-19 be found?

A4. Government of Canada website. Links to government and the World Health Organization are on the BAO’s COVID-19 web section.

Q5. Is Grass cutting and maintenance of a cemetery essential?

A5. Maintenance is essential if it would affect the safety and operation of the cemetery.

Q6. Number of people at funerals?

A6. (This was well covered in the presentation, Registrar’s Directives and the BAO web.) 10 is the max – for the entire funeral home (not counting funeral home staff). Try to have fewer. Follow the rules – Registrar’s Directives, laws, rules, personal protective equipment (PPE). You don’t want this in your funeral home, family, or community. Thank for your work during this pandemic.

Q7. Banning of visitors at cemeteries – can government mandate this?

A7. As the pandemic increases, the government can be expected to take additional measures to stop the spread of COVID-19. The cemetery is private property and so an operator can make appropriate restrictions. The Premier of Ontario’s order has restricted gathering in cemeteries to 10 individuals. Cemeteries can ban visitors, if they choose. The Province is in a State of emergency. As a licensee, you are well within your rights to manage your own establishment in compliance with all applicable laws.

Q8. Shrouding of a body – is it safe?

A8. It can be safe – but only if you are sure the deceased was not a COVID-19 victim. Respiratory droplets can be released from the deceased’s body. The COVID-19 virus stays alive for three to seven days.

Q9. Can cemeteries expect funeral homes to supply PPE to them?

A9. Negotiate if appropriate. The Chief Coroner (Ontario) is moving to inform families that they must identify where their deceased loved ones are to go for funerals. Families will have to choose a nearby funeral home immediately – this is a state of emergency.

Death certificates are under the Vital Statistics Act. Currently death certificates are not issued by funeral homes. This is being looked at by government and the Chief Coroner.

Q10. Can families touch the body of person who died from COVID-19.

A10. They should not. There is a danger to them in doing so. It is strongly recommended that families also maintain the two-metre rule when viewing their deceased family member. These are tough times for all.

Q11. Can cemetery operators refuse entombment if they don’t have PPE.

A11.  A cemetery operator can refuse to allow access to any one if they have a safety concern for themselves, their staff or the public.

Q12. Can we charge for more supplies and resources?

A12. You can cover your costs and must be able to justify the additional costs. Read the BAO’s April 30 Notice to the Profession.

Q13. Has the washing and dressing at a mosque etc., of COVID-1919 victims been addressed?

A13. Yes. Only licensed individuals, or those under a physician’s direction, have been recommended to do this. The BAO hasn’t yet had to suspend family-led death care. But, no one (or very few) is interested in doing this now. The Muslim community, for example, has received the BAO’s direction very well on this matter (as posted on the BAO’s COVID-19 web section).

Q14. Regarding disinfecting of a casket prior to graveside service, would it not make more sense for the Registrar to issue a directive to Funeral Homes to ensure caskets or cremation containers are disinfected prior to transportation for final disposition?

A14. The Registrar expects that both funeral establishment operators and cemetery/crematorium operators will use disinfectants on the casket prior to hand off from one to another. This is, and must be, routine practice.

Q15. Under normal circumstances we would take a family out to pick their lot. When a surge happens can we create a a section where burials would take place in sequence after another? And do we charge the same price?

A15. You may adapt your process for selling and issuing Interment Rights If, and only if, ordered to by the Premier of Ontario’s Order or Registrar’s order. The plan for this mass grave must be filed i.e. approved by the Registrar.

Q16. Is there still a need for a coroner’s certificate for cremation or to transport the body out of the province ?

A16. Yes, there is still a need for all required and proper documentation. The Chief Coroner of Ontario is working on an electronic death certificate to expedite this process. Coroner’s Cremation Certificates are already issued electronically.

Q17. As a cemetery operator, is it unreasonable for my cemetery to expect or demand that the funeral establishment provide pall bearers and appropriate personal protective equipment (PPE) to set casket on a lowering device?  

A17. Arrangements for burials and appropriate PPE must be negotiated at the time of scheduling the burials. Funeral establishment operators deliver the casket to the grave and have little or no contact with the cemetery staff. Once the funeral establishment staff and family leave then only will the cemetery staff approach and lower the casket. The casket can be disinfected before any contact. But please, work together to ensure maximum safety for all.

Q18. I understand that funeral homes are supposed to be up front about
COVID-19 with the crematoriums & cemeteries?

A18. Yes.

Q19. Are we supposed to ask the question for each of them, or are the funeral homes supposed to let us know that a COVID-19 deceased person is coming in?

A19. Yes. And yes.  Better to be safe than sorry.  Ask the question and note it.

Q20. Can the BAO post a list of directors that are available to help if needed? Or send an email for people to sign up.

A20. The list of Funeral Directors and all licensed establishments is available on our public website, on the Public Register page. Your professional association is also available for connections.

Q21. (Funeral and transfer services question) Can the requirement at the coroner’s office, and some hospitals, for two staff to attend transfers be suspended?

A21. Yes, but only if you can do this safely. As much as possible, please follow the rule of two staff when transferring decedents.

Q22. In the state of emergency is there some flexibility on getting signatures on contracts?  We have been using DocuSign, but for some elderly folks this is cumbersome. 

A22. At this time, it is even more important that informed authorizations and consents are received. They may only be disregarded if the Premier of Ontario, Coroner, the Registrar, or Courts issue an order to proceed without family/next-of-kin consents.

Q23. Can we have the link to the WHO guidance?

A23. The World Health Organization guidance is on our website, on the COVID-19 web section under Links, plus is available on the WHO’s website.

Q24. In cases of welfare funded services, there is generally a waiting period for approval before we can proceed. Any thoughts or plans to advise the agencies that we really cannot wait for approval?

A24. Contact your Ontario Works providers in advance. Note: If and when the pandemic increases to a stage when this is not possible, the Premier of Ontario, Coroner, the Registrar or Courts will issue relevant orders to proceed.

Q25. Can the EDITH program be put on hold at this time?

A25. There is no suspension of the Expected Death In The Home (EDITH) program at this time. However, remember it is your responsibility to ensure that the COVID-19 virus does not infect others because of your activities. EDITH is under the jurisdiction of the Ministry of Health. We will inform you if this program is suspended.

Q26. With the urgency placed on health care removals, could we possibly bill the coroner under the current fee structure?

A26. No. Ensure that before you touch a body that you have the authorization from the requester. This includes confirmation on who will pay for the removal/transfer.   

Q27. I understand that the BAO wants no delay in transfer, preparation, and disposition. Should we be delaying embalming/preparation to allow the virus to decay? (Mackinnon & Bowes cites 72 hours as an expected half-life.) We, as professionals, need to take our time and be cautious and careful.  

A27. At this time: : Do not transfer, delay preparation  or dispose of a body without the proper/correct authorizations and consents. Should the need for consents and authorizations be ordered waived – only then can you proceed with any of these activities

Q28. Is it necessary for cremated remains to be interred immediately? My understanding was that cremated remains were relatively “safe” & could wait for later to inter.

A28. The instruction is to proceed with as many full body interments and cremation interments and scatterings as soon as possible WITH the proper consents and authorizations. This includes interment of, and interment/disinterment of, cremated remains. This is to avoid any backlog. It must be done with the consent of the interment rights holders.

Q29. Can we deny a family to identify a deceased (who is a COVID-19 case) before cremation when the deceased is not embalmed?

A29. No, you cannot under normal circumstances deny a next-of-kin’s right to identify the deceased.  However, it might depend on the situation. You may, if the family was present and/or gave consent when the body was placed in the bag or placed in a cremation casket and there is suitable identification attached.

Q30. The electronic medical statements as mentioned on slide 7 – is this plan for COVID-19 decedents only, or for all deaths?

Q30. This not in place as yet. It will be for all decedents.

Q31. Is there a way to ensure transfer staff know the cause of death if there will be no hard copies of the death certificate?

A31. Ask the question/demand an answer.

Q32. With a state of emergency, many small-town funeral homes only have one director, would there be a consideration for pre-planners to take the pressure off our director and perform at-need meetings with the families. This would limit our director’s contact with families possibly carrying the virus.

A32. Funeral establishment operators are to ensure that licensed staff deal with consumers using price lists and contracts etc.  It may in the future come to be that pre-planners are used in case of extreme or justifiable situations.

Q33. If a staff member contracts COVID-19 does the funeral establishment have to close for two weeks? Or is it subject to discretion of each place?A33. Contact your local Medical Officer of Health for more information immediately, Infected staffers, and those in contact them, must be isolated.  Funeral Establishment MUST be totally disinfected and all staff may be required to be tested in order to be able to re-open. There is a risk to your establishment. 

Q34. Will the Registrar issue a directive to allow the Funeral Home to remove the body from the facility without the Electronic Medical Certificate of Death included Please?

A34. Not at this time.

Q35. What is the recommendation for pallbearers? Should they be wearing a mask and/or gloves?  Six-foot rule won’t work.

A35. They should wear PPE for sure!

Q36. At our cemetery, there are sections that typically present very challenging underground excavation conditions in the spring.  If we are not able to inter until a later date, are we authorized to choose a new lot in a section where conditions are known to be better underground in wet months?  

A36. With the families’ consent and if the ground conditions are safe for excavation you may use another previously planned and laid out area of the cemetery.  Ensure that proper records are referred to and maintained.

Q37. Regarding pre-planned arrangements and full-service visitations – will there be a reimbursement for the family and how should these credits or reimbursements be handled?

A37. Yes. Families are not expected to pay for services that are not provided. Reimbursements and credits will have to be made. Business losses may be addressed with the federal and provincial government agencies.

Q38. Can families still have an open casket funeral and visitation for decedents of COVID-19?

A38. Yes, but this is not recommended. Talk to the family about this in light of the State of Emergency and pandemic.  A spread of the COVID-19 virus in your funeral establishment might result in your establishment being closed down for a long period of time.

Q39. Can I have 10 people in one visitation room and another 10 in the chapel room?

A39. No. The 10 maximum directive means 10 people for the entire funeral home facility, not counting funeral home staff. This is a strict rule by necessity. Public and staff safety are paramount. Try to have fewer than 10 in your funeral home.
Remember, funeral homes are subject to the government’s law and risk of civil lawsuits if they are not complying fully with the 10-max directive and law of the land.

Consider what happened in Newfoundland, where 75 per cent of COVID-19 cases in the entire province have been traced to one funeral home. Now all funerals and visitations have been banned there.

Q40. Can people wait outside in their cars, or in a line six feet apart until 10 people leave the funeral home?

A40. No. That would enable potential spreading of COVID-19 in cars, or in lines. This is a tough directive. A necessary one. Please ensure strict compliance.  The financial and physical penalties apply even to the Directors of the Company. Thank you.

Q41. Do babies count as one person or half, toward the 10 maximum?

A41. Each baby or child counts as one person. Please aim for 10 or fewer in your funeral home. This is about minimizing the risk of spreading COVID-19. It spreads easily.

BAO COVID-19 Qs&As – for licensees

April 1, 2020
April 3, 2020
April 28, 2020

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