Programme Directors: SAFPA Secretary General- Mr Monageng Legae and the Training & Skills Development Coordinator- Ms Nape Masenamela

The President of SAFPA: Dr Nomfundo Mcoyi-Zondo

Former Presidents of SAFPA in the room

Members of the NEC, NGC and all leaders of SAFPA present

Representatives from the Funeral Parlours and Undertaking Sector,

Distinguished Guests, partners, delegates, Ladies and Gentlemen,

Good day to you all

It is my privilege to address you today as we focus on strengthening compliance with labour laws, particularly occupational health and safety standards within the funeral parlour industry.

This industry serves families at their most vulnerable and do it with compassion, dignity, and professionalism.

I want to begin by honouring the men and women of this sector who showed extraordinary bravery during the COVID-19 pandemic. At the height of uncertainty and fear, the funeral service industry stood on the frontline, handling infected mortal remains on a daily basis. They supported families who mourned in isolation and ensured that every deceased individual was treated with dignity despite severe restrictions on gatherings and rituals. Your courage, selflessness, and sacrifice must remain etched in our national memory. Some of your team members became infected, and some never made it home. Today, we pause to recognise your heroism.

This pandemic revealed that funeral services are not just a business but a critically essential service and a pillar of public health and social stability.

Our constitution, Section 24 (a), guarantees everyone the right to an environment that is not harmful to their health or wellbeing. This right extends fully to all workplaces, including funeral parlours and mortuaries. As one of the Member States of the International Labour Organization, South Africa also affirms that a safe and healthy working environment is a fundamental human right and a core labour principle that is recognised globally.

The Occupational Health and Safety Act 85 of 1993 places an obligation on employers to provide working environments that are safe and without risk. In the funeral sector, this responsibility is significant due to the combination of biological, chemical, ergonomic, psychosocial, and environmental hazards workers encounter.

Biological hazards include exposure to infectious diseases such as tuberculosis, Hepatitis B and C, HIV, and emerging pathogens. Embalming activities can generate aerosols, increasing the risk of airborne transmission. Chemical exposure, particularly to formaldehyde and embalming agents, can lead to respiratory illnesses, skin irritation, and long-term health complications. Ergonomic risks arise from lifting bodies, transferring human remains, and working in physically demanding and awkward positions. Psychosocial pressures stem from constant exposure to trauma, grief, and emotionally charged environments.

Another critical hazard that requires special attention is exposure to cold environments due to the storage of bodies in refrigerated and cold rooms. Workers often enter cold chambers set between 0°C and 5°C to store, retrieve, or prepare human remains. Prolonged exposure can cause cold stress, reduced manual dexterity, numbness, and increased risk of injury. Handling bodies in such cold conditions is physically demanding, as cold stiffening  increases  the  force  required  during  lifting  and

movement. To address these cold-environment risks, the Environmental Regulations for Workplaces of 1987 provide essential requirements. These regulations emphasise that workplaces must maintain reasonable temperatures to ensure worker wellbeing. Where low temperatures are unavoidable as is the case with body refrigeration, employers must implement specific measures including:

• Providing suitable protective clothing to prevent cold stress.
• Limiting the duration and frequency of exposure inside cold rooms.
• Ensuring   that   cold   storage   areas   are                 designed   with insulation to prevent excessive cold leakage.
• Implementing safe entry and exit procedures, including emergency release mechanisms.
• Maintaining clear lighting, non-slip flooring, and adequate ventilation within refrigeration units.
• Ensuring that cold environments do not compromise worker safety or increase ergonomic strain.

In addition, emergency preparedness is critical. Refrigerated storage units must be supported by reliable backup power systems such as generators or uninterrupted power supply (UPS) units to ensure continuous operation.

A failure in refrigeration does not only compromise the dignity and preservation of mortal remains; it also creates health risks for workers, including the release of decomposition gases, odours, and potential exposure to biological hazards.

For this reason, employers must ensure:

• Backup power capable of handling the full refrigeration load.
• Regular testing and maintenance of generators and UPS systems.
• Emergency procedures for safe body handling during power interruptions.
• Alarm    systems    that    alert    staff             immediately        when temperatures rise above safe thresholds.

Proper refrigeration management supported by strong emergency preparedness is essential not only for the preservation and dignity of the deceased but also for ensuring safe and healthy working conditions for employees. Furthermore, strong emergency preparedness measures support business continuity, which is vital in this industry where reputation, trust, and reliability are critical. A single failure can damage public confidence, disrupt operations, and negatively impact grieving families who depend on these services during their most vulnerable moments.

Compliance with the Hazardous Biological Agents Regulations of 2022, the Hazardous Chemical Agents Regulations of 2021, the Ergonomics Regulations, the Environmental Regulations for Workplaces of 1987 and other applicable regulations ensures that every aspect of the funeral environment is addressed holistically. These regulations guide employers on risk assessments, engineering controls, appropriate PPE, safe operating procedures, and adequate workplace conditions. Since some hazards cannot be eliminated entirely, medical surveillance is an essential safeguard. Through baseline and periodic medical examinations, immunisation programmes, lung function assessments, and biological monitoring, we ensure that workers' health is continuously monitored and protected.

The Department's Inspectorate remains committed to supporting this sector. Inspectors conduct advocacy campaigns, host workshops, and provide advisory visits to guide employers before formal inspections. They offer assistance with compliance, infection control strategies, chemical safety management, ergonomic improvements, and the safe operation of cold storage facilities. Through collaboration with industry, both the formal and informal funeral parlours benefit from best practices and national guidelines.

These measures contribute to cultivating a culture of prevention, where safety becomes part of everyday practice, supported by leadership commitment, worker participation, continuous skills development, and strong health and safety committees. Compliance is not merely regulatory, it is an investment in the wellbeing of workers, the dignity of the deceased, and the reputation and sustainability of the entire sector.

Ladies and Gentlemen,

Data from the inspectorate in this sector shows that the sector constitutes a high-risk environment due to exposure to biological agents, chemicals, electrical hazards, and heavy physical handling. In addition, many funeral homes are family-owned enterprises which, while formally registered, continue to operate informally, without standardized HR, payroll, or OHS management systems. Inspections were conducted to test compliance with the Basic Conditions of Employment Act (BCEA); Occupational Health and Safety Act (OHSA); Unemployment Insurance Act (UIA/); and Compensation for Occupational Injuries and Diseases Act (COIDA)

Key areas of non-compliance BCEA & NMWA:

• Failure to provide employment contracts
  
  No employee records
  
  Non issuance or incorrect payslips
  
  Unlawful deductions
  
  Payment below the National Minimum Wage

OHSA:

• Unsafe electrical installations
  
  Poor ventilation in mortuaries
  
  Lack of PPE
  
  Unhygienic ablution facilities
• No risk assessments or OHS appointments
  
  Weak control of biological agents
• Non compliance with Ergonomic and Chemical agents regulations,

UIF:

• Non-registration of employees
  
  failure to declare employees,
• None payment of contributions
•  

COIDA:

• Failure to register or submit Return On Earnings
  
  No assessment payments

Root causes of non-compliance

• Family-owned and informally run businesses lacking HR/OHS systems
• No standardised payroll or OHS file
• Reluctance   to   spend   on   compliance                    (no PPE,    no UIF/COIDA registration)
• Limited knowledge of legislation

Impact on workers

Workers face:

• Exposure to infectious biological agents
  
  Chemical hazards
  
  Electrical shock and fire risks
  
  Poor hygiene and ventilation
  
  Wage exploitation and unfair deductions
  
  No UIF or COIDA protection

This results in a vulnerable workforce, especially in rural funeral establishments.

Impact on businesses

Businesses face:

• Legal penalties and forced closures
• Back-pay obligations (R1.3 million was discovered as a result of underpayments and R2.6 Million worth of fines imposed)
• Doubling of fines increases enforcement pressure
• Loss of community trust
• Operational inefficiencies due to informal systems

CCMA

• The Commission for Conciliation, Mediation and Arbitration (CCMA), was established as an independent dispute resolution body in terms of the Labour Relations Act (LRA).
• The CCMA's processes aim to promote fair labour practices and resolve labour disputes in the workplace.
• The CCMA further seeks to ensure that disputes are dealt with in an expeditious, effective and fair manner.
• It plays an integral role in providing a framework within which parties can collectively bargain to determine wages and conditions of employment and other matters of mutual interest, promoting orderly collective bargaining and giving effect to the right of workers and employers to organise and bargain collectively.

• The CCMA, in terms of section 150 of the Labour Relations Act, may also offer to resolve a dispute through conciliation in public interest matters.
• The CCMA is responsible for the management and control of applications for the accreditation and subsidies of bargaining councils and private agencies.
• The CCMA may also provide procedural advice, training and dispute prevention initiatives as a means of transforming workplace relations and promoting best practices.
• It is mandated to promote social justice and fairness in the workplace by delivering ethical, qualitative, innovative and cost-effective dispute resolution services, institution building services, education, training and development and efficient administration

The sector shows persistent and systemic non-compliance across Labour legislation. These include underpayment of workers. Workers remain at risk of injury, exploitation, and inadequate social protection. On the other hand, employers face escalating financial, legal, and reputational consequences. The sector requires ongoing enforcement, capacity-building, and engagement to strengthen compliance and transition businesses from informal operation to structured, compliant enterprises.

Government is obliged to ensure that those who carry the burden of this sacred responsibility in the sector are protected, respected, and supported.

Let us renew our collective commitment to strengthening occupational health and safety, enhancing preventive measures, investing in medical surveillance, and deepening collaboration between the Department and industry stakeholders.

Together, we must ensure that every worker in this essential industry enjoys the constitutional and international right to decent work, and that the dignity they give to others is reflected in how we protect them.

I thank you.​

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