Week 12: FTC Compliance, Cremation Containers

​FTC Compliance

•  Requirements When Offering Cremation Services

  • Transparent Pricing
    The General Price List (GPL) must clearly describe all services and containers included in the cremation offering.

  • Purchaser-Provided Container
    The GPL must list a price for direct cremation when the purchaser supplies their own container.

  • Funeral Home-Provided Container
    The GPL must also include pricing for direct cremation using an alternative container provided by the funeral home.

​FTC Compliance

• Third Required Disclosure: Use of Alternative Containers for Direct Cremation

  The Funeral Rule requires that you inform consumers they have the option to use an alternative container for direct cremation. This disclosure must appear directly next to the price listing for direct cremation on your General Price List (GPL).

​FTC Compliance

• The required language is:

  "If you want to arrange a direct cremation, you can use an alternative container. Alternative containers encase the body and may be made of materials like fiberboard or composition materials (with or without an outside covering). The containers we provide are (specify containers)."

​FTC Compliance

• You must include a description of the specific containers your funeral home offers at the end of the statement.

  Note: If your facility does not offer direct cremation, this disclosure is not required on your GPL.

  Refer to Complying with the Funeral Rule for full details and examples.

​FTC Compliance

• Required Disclosures (3rd Disclosure)

  Use of Alternative Containers:
  The third required disclosure informs consumers that they may choose to use an alternative container for direct cremation.

  No Tying Arrangements:
  Funeral providers may not require consumers to purchase specific goods in order to receive certain services.

  Example:
  If a family chooses direct cremation, they cannot be required to purchase a casket.

​FTC Compliance

• Misrepresentations to Avoid

  Casket for Direct Cremation:
  It is a violation to suggest that a casket is required for direct cremation. A casket is not necessary for this service.

  Embalming Requirements:
  Funeral providers must not falsely state that embalming is legally required. Embalming is not required by law, but may be necessary if certain services, such as a public viewing, are selected.

Cremation

• Safety Recommendations for Crematory Operators

  Inspect Cremation Containers Carefully:
  Always identify and remove any potentially hazardous materials before the cremation process begins.

Cremation

• Avoid the Following Materials:

  • Metal Containers:
    Not suitable for cremation. They do not combust and may release zinc byproducts that can damage the cremator and harm the environment.

  • Plastics and Fiberglass:
    Also unsuitable. These materials release toxic byproducts into the atmosphere during combustion.

Cremation

• Cremation Scheduling Guidelines
  Recommended Order for Daily Cremations

  • Larger Individuals:
    Begin the day with the largest body and proceed in descending order by size. This approach helps manage heat retention and equipment efficiency.

  • Infants and Small Remains:
    Should be scheduled last in the cremation day due to their size and sensitivity of processing.

Cremation

• • Wood Caskets (Ornamental/Burial-Style):
    If cremating a traditional wood casket intended for burial, remove all hardware before the process to prevent damage and safety risks.

  • Alternative Containers:
    These can be cremated at any point in the schedule, but ensure they are free of any restricted or hazardous materials.

Cremation

• Proper temperature range, 1400-1800 degrees Fahrenheit

• Knowledge of equipment and emissions (Opacity)

OSHA Compliance

•  Compliance with OSHA requirements

Cremation Containers

•  Casket Types and Cremation Suitability

  • Burial Caskets:
    Typically not recommended for cremation. If used, all hardware must be removed beforehand.
    Metal caskets are never suitable for cremation.

  • Cremation Caskets:
    Specifically designed for cremation. These are fully combustible and constructed entirely of wood or other approved materials.

Cremation Containers

• • Rental/Ceremonial Caskets:
    Used for viewing or services prior to cremation.
    Must include a disclosure that the casket is for temporary use only and not intended for cremation.

Cremation Containers

• Alternative Containers for Cremation

  Alternative containers are designed to be combustible, non-metal, and suitable for cremation. Common types include:

  • Corrugated Fiberboard

  • Wood (unfinished or minimal construction)

  • Particle Board or Plywood

Cremation Containers

• • Cardboard (often used for green or eco-friendly cremations)

  • Pouch (for minimal or direct cremation cases)

  • Rental Casket Insert (used inside ceremonial rental caskets)

  These options offer a range of choices based on budget, environmental concerns, and service needs.