Quality comes first

words: Joseph Murren & Paul Allcock, SAIF
Quality Assurance

SAIF members are at the heart of our communities, providing unwavering support in times of need. For a quarter of a century, SAIF’s Quality Assurance (QA) programme has provided the benchmark. To keep up with changing legislation and standards, a complete review has resulted in a new QA programme. We discuss the revised programme, explain the requirements for SAIF members and how it will continue to develop

SAIF has been operating its Quality Assurance (QA) programme for more than 25 years. It was introduced to ensure members were complying with SAIF’s Code of Practice and providing a quality standard of facility and service to meet the requirements for SAIF membership.

Over the years it has developed and improved to reflect changes in legislation and standards relating to the funeral profession. However, it has also been criticised for not being robust enough, especially as it did not address the principal role of the funeral director – caring for the deceased.

The last few years have seen considerable attention focused on the profession, resulting in changes affecting the way we operate our businesses and the introduction of new style low-cost offerings to the bereaved. We could debate for many hours the reasons behind this. However, the fact remains, we now have a profession that bears little resemblance to that operated by our forefathers.

Much of this attention has been of our own making. An unregulated industry with a reluctance by many to embrace and comply with self-regulation, and a profession that is inward looking. A fragmented industry with many operators still believing they are untouchable, and that poor and hidden practices, high prices and lack of customer focused innovation will go unnoticed.

In Scotland, the Scottish Government passed the Burial and Cremation (Scotland) Act 2016 which gave them powers to introduce a Government Code of Practice and a registration scheme for all funeral businesses. This is now close to implementation and, although it will be introduced having consulted the profession, it could have been applied unilaterally with serious consequences for independent funeral directors.

Following the Competition and Markets Authority (CMA) investigation of the UK funeral profession, it issued its Statutory Order putting transparency and disclosure requirements on all funeral companies and required them to offer to customers a standard funeral whose content it prescribed, despite advice from SAIF. It has also stated it will consider a further investigation with a view to controlling prices.

A fragmented profession is a benefit to consumers. However, a fragmented representation of the industry is damaging, not only to the profession, but also the consumer, as inappropriate legislation can be imposed by those who lack industry knowledge, and new players whose sole interest is profit are allowed to take advantage of a vulnerable consumer.

The CMA recommended legislation for industry regulation and was happy to allow Scotland to continue with its plans. For the rest of the UK, it asked the Ministry of Justice (MoJ) to acquire ownership of this and decide how to regulate for the protection of the consumer. The MoJ, in its wisdom, gave this over to the two trade associations and requested that one code was adopted. SAIF believed the code, adopted by the National Association of Funeral Directors (NAFD), was not aligned

with what was happening in Scotland and would put our Scottish members in a difficult position having to obey a government legislative code which was not aligned with the code being applied for members elsewhere in the UK. Apart from the confusion it would cause for those members who operate cross border, it could also result in a reduction of association membership.

An approach to the NAFD by SAIF to make changes which would align the codes was refused outright and SAIF was left with no option but to develop its own code. Having discussed this situation with the MoJ, they agreed for SAIF to proceed and agreed the code should include prescriptive rules for back of house areas.

Our new code was adopted by members at our AGM in March 2022 and became operative three months later in June.

The code is outcome-based with mandatory rules which, when followed, will ensure the outcome is achieved. It also has good practice advice which, if adopted, will add to consumer confidence in the member’s service. There are some additional sections, such as care of the deceased, mortuary security and inclusions required by the CMA. Most of the mandatory rules are concise, however, there are some subjective areas which we have tried to keep to a minimum.

This new code demanded a complete review of the QA programme resulting in a new programme in both content and approach. This now requires the assessor to not only ask if something is being carried out but also how it is being carried out. The member may have to provide evidence to support this such as training records or qualifications to show staff have been trained and are competent in performing their duties. There will also be areas of compliance demanded by the CMA such as transparency and clearly displayed price lists.

There are new requirements for preparation rooms and embalming theatres, such as security and access to refrigeration. To distance SAIF members from the unacceptable practices by the online disposal companies, preparing and dressing the deceased is now the default position for all deceased unless instructed otherwise by the client. SAIF has now adopted a minimum standard for this preparation which can be provided by the assessor.

SAIF has also prepared sample forms and examples of policies to assist members in compliance and these are being made available on the members area of the SAIF website.

Areas of your business that will be assessed are:

  • To ensure the owner or operator is of good character and has the appropriate knowledge and skills to legally manage the business and provide a respectable and sensitive supply of funeral services to the community they serve.
  • To ensure suitable staff are employed and they can demonstrate the skills and knowledge to perform their duties legally and to the satisfaction of the client.
  • To ensure the premises and equipment is sufficient for the intended purpose of the supply of funeral services in the community served.
  • Engagement of the funeral director To ensure that the funeral director is transparent about goods and services they offer, and that all relevant information is recorded and retained.
  • Transfer of the deceased into the funeral director’s care To ensure that the procedure is dignified and respectful, the equipment is suitable, the deceased has identification, and you have the correct authority to perform the transfer.
  • Care of deceased and mortuary facilities To ensure your facilities for the purpose of performing the preparation or embalming of a deceased are clean, in good condition and that the client has been fully informed and given their permission.
  • Care services, first offices and viewing This is to ensure all deceased are cared for to a minimum standard as defined by SAIF or instructed by the client
  • Estimates, accounts and confirmations This is to ensure the client fully understands and agrees to the costs involved in what they have requested. That they have written details of the arrangements on the day of the funeral and that any outside associated services fully understand what is required of them.
  • Cremated remains (ashes) To ensure cremated remains are treated with the same care and respect as the deceased before cremation. That they are retained in a secure location and are delivered or disposed of in accordance with the instructions given.
  • Complaints To ensure clients are aware of the procedures to make a complaint should they be dissatisfied with any aspect of the service provided.
  • Health and safety and business continuity This is to ensure members are fully compliant with their legal responsibility under the Health and Safety at Work Act, that clinical waste is disposed of legally and they can demonstrate good practice in providing a safe working environment. To have in place a continuity procedure should an unforeseen event disrupt the provision of services.

The areas are assessed as either fully compliant, partial compliant, or non-compliant. If partial or non-compliant the assessor will discuss with the member ways and timescales to become fully compliant. The member will also be asked to sign to indicate their acceptance of the assessment and agreement to any changes that may be required. If a member disagrees with an assessment, they have the right of appeal and to be assessed by a different assessor who will have no information from the first assessment.

There are areas of assessment that are not specific to the code which have always been included in the QA programme. These relate to normal operational areas of a business and which owners or operators should be aware of without having to be instructed in a trade association’s code of practice. Such areas as employment regulations, the Health and Safety at Work Act, the CMA Order, the Companies Act, the Health and Safety Executive guidelines on mortuaries, the Equal Opportunities Act, Fire Safety Acts, the Disability Act and more.

It is the owner or operator’s responsibility to comply with these Acts and regulations immaterial of an association’s code. The QA programme helps you do this, but it does not assume your responsibility for compliance.

Following the QA review and the new programme of assessment, it was decided to apply for independent verification to demonstrate its excellence and worth as a quality standard. We applied to the British Assessment Bureau, an independent assessor accredited by UKAS, the Government appointed and internationally recognised accreditation service. The SAIF QA programme achieved ISO9001 in June 2022.

This mark of excellence demonstrates the member is providing a standard of quality in premises and service by meeting the requirement of a quality programme, which has been independently assessed as robust and demanding in its application.

The events which demanded change are still active. The Scottish Government code and licensing are still being worked on. The CMA is monitoring compliance and has left the door open for further investigation. The Ministry of Justice is waiting to see if we can finally self-regulate. The Human Tissues Act, that regulates public and hospital mortuaries, is revising legislation which will include access for collection of the deceased. Last, but by no means least, we have the ongoing enquiry into the dreadful activities of David Fuller which will include funeral directors’ mortuaries in part two, due to complete in summer of 2023.

So, now is not the time to relax. The code and the QA programme are a work in progress and will continue to evolve as we respond to the changes and future demands that will affect us all. If we are to avoid industry regulation and inspection by Government then we must show we can self-regulate. We ask all members to examine your own facilities and procedures in the light of our new code and QA programme to ensure you meet the high standards expected by SAIF.

SAIF guidance: handling complaints

Tips for developing a customer complaint policy:

  • Ensure your complaints procedure is clear and simple for clients to follow
  • Decide which staff have the authority to resolve a complaint, and make sure they know what to do. Bringing in someone specifically to handle the complaint will indicate to the client you are taking the matter seriously.
  • Set a time frame to respond to a complaint. Taking too long may result in the problem escalating.
  • Give one person responsibility for managing the complaint from beginning to end, so the customer does not have to repeat their complaint to different staff
  • Involve your staff in creating your policy
  • Ensure staff know your policy and how to treat complaints fairly. Poor complaint handling, for example blaming the customer for the problem, or marginalising them by saying no one else has complained, will only worsen the problem.

Review your policy regularly and make changes as necessary A complaint handling policy can:

  • State why your business welcomes complaints, listing the benefits to customers, staff and the business
  • State who the policy covers and who is authorised to resolve complaints
  • Define a complaint
  • Commit to quick, fair and confidential complaint handling
  • State who is responsible for taking, recording, resolving, analysing and reporting on complaints
  • Explain how to log complaints
  • Explain the complaint procedure and what to do about complaints
  • Set timelines for complaint handling and keeping customers informed
  • List acceptable ways to resolve complaints
  • Explain what will happen to the complaint if it cannot be resolved
  • Be reviewed regularly for effectiveness and updated
  • State where people can get further help
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