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We continue to publish the very important observations from funeral directors in response to the invitation from the Funeral Service Consumer Standards Review to make contact, and have great pleasure in adding the contribution from Jo Williamson, of Albany Funerals.

Dear Mr Shand Smith,

It has come to my attention that on 22^nd August you issued a call to non-trade association affiliated funeral directors to share their views with the Funeral Service Consumer Standards Review you are currently conducting.

Sadly, as you have only allowed a very short timescale for busy funeral directors to respond (8 days – was this an afterthought?), I have missed the deadline but I would still like to take this opportunity to put forward my views.

We are independent funeral directors based in Kent, in our 10^th year of trading.  For the first 7 years we were members of SAIF but were left feeling largely unsupported and unchecked, and therefore made the decision to remain non-affiliated for a few years.  However, we have recently begun the process of joining the NAFD, mainly due to fierce local competition and we felt that we might be viewed as lacking ‘legitimacy’ if we were not members of an association, and there is no other real alternative. 

I cannot agree, however,  that I feel represented by these organisations ‘seated at the table’, as in my experience they do not always seem to be led by the interests of the bereaved person, or the person who has died, but more so in protecting their members, whose practices are sometimes questionable at the very least. 

Although I welcome any initiative to improve standards, I do feel confused that this is being run simultaneously with the Government CMA review, which is a completely independent review as opposed to an ‘industry initiative’ which yours claims to be, and I would also be curious as to how this will be implemented in conjunction with the findings and recommendations of the CMA report?

I have also looked at the Scottish Government Code of Practice Consultation in detail and was alarmed to see that the proposed regulations do not offer any real solution to prevent the exploitation of the vulnerability of bereaved people and the lack of transparency of the funeral industry, which are the two main areas of concern highlighted by the CMA. 

Moreover, some of the regulations proposed fall incredibly short, for example, although the Scottish Government ‘believes that the use of refrigeration is a critical element of caring for a deceased person in a dignified, appropriate and respectful manner’, they concur with SAIF’s recommendations that a mere ratio of 1:50 is acceptable (1 refrigerated space per 50 funerals)! 

This does not fill me with confidence going forward, particularly as your working groups are heavily represented by these trade associations and large corporations, that obviously benefit from such loose and misleading regulations.  It is very clear to me that any regulation of the industry should be entirely independent and not decided by stakeholders.  For a start an independent ombudsman should be reinstated so that when things do go wrong, consumers have somewhere to turn to.

My recommendation would be the following: to focus on the protecting the bereaved and their families/friends and not the funeral director. 

Instead of regulations, I believe it would be more productive and successful to produce an ethical code of conduct.  In 7 years, SAIF did not once inspect my mortuary or any of our funeral processes or procedures.  The inspection would consist of a cosy chat in the office and the advice to ensure that a ‘no smoking’ sign is displayed somewhere visible. 

Because of this lack of scrutiny, it has become easy for funeral directors to act to suit their own interests.  These are a few examples of things that happen ROUTINELY in many businesses, that we see and hear about on a DAILY basis:

• families given funeral dates 4/5 weeks after death to suit the diaries of the funeral directors
• routine embalming (often without permission) to avoid having to use refrigeration
• moving bodies about without permission from families to off-site storage units or for viewing purposes
• inadequate or no refrigeration at premises
• embalming taking place with inadequate facilities (bodies on the floor)
• overselling of funeral products
• huge mark ups on products
• funeral directors giving funeral quotes based on the type of car the consumer has
• tacit agreements with care homes/hospices to provide services for free in return for referrals
• limited time set for funeral arrangements (sometimes 40 mins)
• rewards/penalties for funeral plan or memorial selling
• clothes intended to dress the person who has died placed in the coffin still in the bag presented by the family
• THE LIST COULD GO ON…..

I can only hope that as you are independent as chair of this committee, that my letter might lead you explore some of these concerns and take them seriously.

Thank you for your time,

Kind regards,

Jo Williamson

Today we have the pleasure of publishing a letter from Jo Vassie, of Higher Ground Family Funerals, which was sent to the Competition and Markets Authority a few weeks ago.

We thought that the Funeral Service Consumer Standards Review might also find it interesting reading. 

Dear Sirs,

I’m am writing to express my thoughts and worries regarding the new legislation for Scotland and am concerned that similar will follow for the England.

I am 70 and still fully occupied with work along with my husband and son. We opened a natural burial ground 10 years ago, very soon individuals were securing their plots for eventually and very many asked me if I could deal with their funeral when the time came. The answer had to be no.

Once our son joined us in the business, this became a possibility and so we set to and converted a farm building into a beautiful facility, giving us a meeting room, visiting room, mortuary and garaging for our vehicle, which is not a hearse but an adapted people carrier ( work done by son)

This has been the most incredible experience; we have received very many emails and letters of thanks from our families. We have no qualifications, we just treat people as we would wish to be treated, this includes the family arranging the funeral and of course the person who has died.

Locally we have St Margaret’s Hospice, who last year caused quite a stir when they entered into the funeral world. Their start-up costs were ridiculous and so the venture has made a huge loss and it is thought that this has had a knock on effect that they are closing their inpatient beds in their Yeovil hospice.

I am very concerned that legislation will be brought in for training and qualifications – please tell me how this will ensure that everything is exemplary in funeral homes? 

I have no objections in my premises being inspected and chose to be a recommended funeral provider by The Good Funeral Guide, this just gives the public an independent opinion. But the best recommendation comes from families whom we have served.

If it becomes compulsory for training and belonging to SAIF or NAFD, it will increase set up costs for independent people like ourselves and will not prevent bad practice.

The net result is the public will be the losers.

Kind regards,

Joanna Vassie

Today’s offering from a person who wrote to the FSCSR in response to the invitation for unaffiliated funeral directors to contact the independent chair was sent by us on their behalf.

The author chose not to identify themselves in the letter because it had to be sent to the independent chair via the FSCSR Secretariat, which is run by the trade associations that this individual has elected not to belong to.

It struck the writer that this meant their letter would potentially be read by others, and they preferred that their name and location not be identified in such a way.

Obviously we know who the author is, but we are preserving their anonymity in publishing their letter without attribution.

(Postscript – the independent chair of the FSCSR has subsequently been in direct contact with the author and assured them of his independence.)

Dear Mr Shand-Smith

Re: Call to non-trade association affiliated funeral directors to share their views

I write to you in your capacity as Chair of the Funeral Service Consumer Standards Review to explain who I am and why I no longer belong to the NAFD, and also to highlight some of the failings within the Trade Associations.

I would also say that this call to us to respond is incredibly short notice and unlikely to be a great success given the time of year. I hope sincerely that that wasn’t your intention.

I am an independent funeral director who started up from scratch 11 years ago. I had only briefly worked in the funeral profession prior to opening, our facilities were very basic and we relied on a friend (and business partner) for help with staff, logistics and vehicles.

We did not join a Trade Association for a couple of years but we (myself and my wife) studied the Dip. FAA with the NAFD as soon as we started. As time went on we decided to give our business the added credibility of membership to the trade organisations SAIF and the NAFD. We are no longer members of the NAFD, reasons for which I shall outline later, but it was our decision. We are members of The Good Funeral Guide though, a consumer guide to good funeral practice.

We knew what we needed to do to succeed, and how to do it, and tighter regulation may have prevented us from opening but would that have been a good thing? We are now as big a business in our area as all the other firms and carry out as many, if not more funerals a year as anyone else in our area, because we fulfil a need and we do it well.

It is my belief that new businesses do not start up to rip off the unsuspecting consumer but because they have identified that consumers are currently being ripped off and they can offer a better service! This may not strictly be true in all cases but a lot of new businesses start up because the old family-run firm has been taken over and things are no longer done in the way they were, much to the embarrassment of the staff and disappointment of the customers.

In a report by Beyond.Life into Dignity Funeral Services and their share price they show that, and I quote:

“Between 2005 and 2016 (“the historical period”) the Company delivered:

Revenue growth from £143 to £314 million (7.4% cagr)

Operating profit growth from £42 to £98 million (8.1% cagr)

EPS growth from 22.4p to 119.8p (cagr 16.5%)

There have been two drivers of this historical performance:

a 53% increase in the number of branches (3.9% cagr); and

an 81% increase in pricing (6% cagr)

Branch expansion has mainly functioned to keep customers steady and offset a collapse in branch productivity

Dignity’s market share has been static at c.12% with customer numbers ranging from 62,300 to 73,500 as a function this static market share and a variable UK death rate

Branch productivity, in terms of funerals performed per location per year, has collapsed by more than 30% from 129/year in 2005 to 87/year at H1 2017.

Acquired locations typically provide around 150 funerals per year initially, offsetting customer losses elsewhere in the portfolio.

Pricing has been used to provide constant top-line growth

With customer numbers flat over the historical period, pricing has been used as a lever to provide revenue growth

Prices increased every year between 2005 and H1 2017 from £1,699 to £3,153 at a cagr of 5.6%, in line with the growth within the Funeral Services segment cagr of 6.1%

Effectively, management have driven top line growth through large price increases across the existing portfolio, whilst offsetting decreasing customer numbers in the existing portfolio by acquiring new locations. The net result is that Dignity serves roughly the same number of customers each year but charges each of them a higher price.” The full report is available here.

This, I believe is why new start-up businesses come about, and tighter regulation may prevent them from doing so, holding the public to ransom with high charges and lower standards offered by the big chains.

As an example of this, when our local branch of Dignity was taken over in 2006 they were carrying out the vast majority of funerals in the area (circa 600 per year), now they carry out about 250. You need to be asking why!

The Co-op has never really featured locally and Funeral Partners are not in the area so Dignity is our only point of reference for this.

It is my opinion that any investigation into the funeral profession should be aimed primarily at the big groups of funeral directors, to understand why they have lost half of their customers in the years after purchasing the business, why their charges are consistently higher than that of independents, despite them having all the economies of scale that the independents do not, and why they have a high turnover of staff, certainly a feature in our area, and I would plead with you not to let this whole investigation be led by the one group of people that need to be investigated but by proper, independent consumers.

Let it be led by those who may need our services, not by those who provide them. Would you let a second-hand car industry investigation be led by second hand car dealers? The trade associations exist purely to protect the interests of their members, NOT THE GENERAL PUBLIC.

There have also been TV programmes into malpractice in the funeral profession. Dispatches, on Channel 4 in 2012 uncovered various horror stories at the Co-op, as did the ITV report The British Way of Death with Funeral Partners. I’m sure that there are some unscrupulous independent funeral directors too but stories in the media would suggest that there are more complaints with the bigger firms.

After joining the NAFD I attended several of the local branch meetings but half of the room was filled with Co-op and Dignity members and no one seemed keen on bringing them to account for their high prices or shoddy practices. Their chief concern seemed to be who was next in line to receive the Chain of Office and who was buying the drinks!

On Radio 4 one Sunday in December 2018 there was an interview/ discussion about funeral costs featuring Abi Pattenden, then President of the NAFD and Louise Winter, a new and progressive funeral director in London.  Ms Pattenden’s arguments for defending the costs charged by some of her member firms were shocking and she was thoroughly shot down by Ms Winter on all counts. She was poorly prepared and, maybe because she actually works for an independent firm, didn’t really believe what she was saying. It was for this reason that I decided that the NAFD no longer represented my views. A belief I still hold.

In summary, I ask you to take a long hard look at our profession, but from the outside. There is absolutely no point in asking the membership of the largest trade organisations what they would like to see, when they obviously want to defend their members.

This needs to start from the other end, what do consumers want, where are they most likely to get that. Look at Beyond.life’s price comparison website, it’s not that great and I’ve had my disagreements with them but you can see a guide to funeral costs there. Ask probing questions to leaders of big companies and small. FIND THE TRUTH.

I do hope that you can take my points seriously and consider the view from the other side of the arrangements table. Please do feel free to contact me if I can be of any further assistance.

With kind regards

Here’s another submission that squeaked in before the deadline set by the self-appointed Funeral Service Consumer Standards Review group to hear the views from funeral directors who choose not to belong to a trade association – from the fabulous Jennifer Uzzell, occasional contributor to the blog and one of the directors of Saint & Forster Funeral Directors Ltd in Darlington:

“Dear Mr Shand-Smith

In response to your request for views from funeral directors who are not affiliated to the trade organisations and who would like to add their views to your consultation, please see below. 

I am one of the directors of Saint and Forster Funeral Directors Ltd. in Darlington in the North East of England. 

The company was set up by my partner Keith Munt and myself 8 years ago

We are not members of a trade organisation as it is our belief that these organisations exist in order to promote the interests of their client businesses and that, where a difference exists, they will promote the interests of their clients above those of the bereaved. They are, therefore, not in a position to represent the interests of the bereaved, or to administrate any form of regulation that may be introduced. 

I note with concern that the FSCSR appears to be presenting itself as the body that represents the funeral service in general and will, in fullness of time, be responsible for regulation. As far as I can see, the FSCSR has no remit or authority to do this, and it seems to a number of us that you are positioning yourself to defend the actions of the larger corporations, even when their performance is very poor; and to regulate against the interests of small independent and unaffiliated companies even where they are ethical. Our failure to join any of the associations is ethically motivated and is in no way because we have anything to hide, or because we do not feel we would meet the criteria.

I also question what your motivation was in allowing such a small window of opportunity for unaffiliated FDs to reply to your request for their views. Either you are deliberately trying to limit the number of responses you receive, or we are very much an afterthought. Neither possibility is particularly encouraging. 

Much that has been presented recently, in terms of the need for regulation, has been about the need to protect the public from ‘cowboy’ ‘unqualified’ practitioners who are setting up businesses across the country. I do not doubt that a small number of such businesses exist. However, as the evidence presented by my colleague Louise Winter (with whom I am in entire agreement, and whose letter to you I attach below in its entirety) suggests, the majority of instances of malpractice or poor quality service seem to be traceable to larger corporations rather than to smaller independent companies. 

You ask specifically for my views on regulation, which I give below. 

I welcome regulation of the funeral service, with the following provisos:

• Any regulation must be overseen by a body that can be shown to be truly independent. This should not be the trade organisations, the FSCSR, or any other body with a vested interest. 
• Complaints should be handled by an independent ombudsman as they once were
• Any system of regulation should not be limited to process (how bodies are stored, transported etc and how FDs are trained; important as these things are) but should also include an ethical element aimed at preventing the exploitation, financial or otherwise, of the bereaved. 
• FDs should not be required to have a qualification, particularly if it is devised, administered and awarded by the NAFD. This is, again, a vested interest and also, to my knowledge, contains training that would be at odds with my idea of good practice. There is a disturbing movement in the world in general at the moment towards the perception that academic qualification with increasingly low standards are a guarantee of quality. 
• With regards to the above, I would like to see FDs or businesses licensed according to what they can demonstrate that they can do in a system similar to the old NVQs, rather than requiring them to acquire an additional qualification. Again, this license must be administered by a truly independent body with no vested interests. 

Many companies, such as mine, have been set up by people with entirely adequate facilities. training and experience, but with a new vision of the quality, standards and emotional intelligence that the public should be entitled to expect from us. Any regulation must enable those companies to continue and to thrive and to provide a choice to the public. 

To conclude, I state again that I am entirely in agreement with Louise Winter of Poetic Endings, whose letter I attach in full here.  

Kind Regards, 

Jennifer Uzzell

Office Manager

Saint and Forster Funeral Directors Ltd

Letter to Lewis Shand Smith – 29th August 2019

After yesterday’s deadline for unaffiliated funeral directors to make contact with the FSCSR came and went, we thought we would share some of the thoughts from some of the people who managed to scrabble together a response to the request within the time frame offered.

Given that all responses were received by the FSCSR Secretariat, which is operated by the two funeral trade associations, these responses are hardly confidential, and all concerned are happy for their comments to now be in the public domain.

We begin today with the letter sent by Ru Callender, from The Green Funeral Company

Dear

My partner and I have been independent self taught undertakers and celebrants for the past twenty years. We run The Green Funeral Company.

We set up as a direct result of the dissatisfactory funerals I was subjected to throughout my childhood and twenties at the hands of the very corporate organisations which appear to be covertly represented here.

I discovered the work of The Natural Death Centre charity, which back then was a radical movement to empower the public and force funeral directors to show a little transparency.

It taught me, as you all know but I doubt much of the public do, that a family are not required by law to use a funeral director. They can do pretty much everything themselves, and we have indeed advised and supported many families to do exactly this, as well as providing a much more integrated and participatory service for the families who do chose us.

The reason this is possible is simple; dead bodies are not complicated, or as much of a health hazard as is generally perceived. You can disrespect them, but you cannot hurt them.

The real skill of funeral directing lies with how you treat the living.

 And no amount of spot checks or being part of a trade body will ensure that the living are treated well. This requires emotional intelligence, which is teachable to a degree, but is unlegislatable.

We believe regulation will destroy some of the best funeral directors in the country while appearing to ‘solve’ a problem in the eyes of the public, that doesn’t actually exist.

The problems that actually exists in the funeral industry are:

An emotional disconnect between individual funeral workers and the families they are serving, mainly in large corporate chains, and a lack of support for these workers when it comes to the complexities of the psychological stresses involved with the job.

A financial beholdenment to shareholders within the corporate sector above all else.

 The overmarketing of funeral plans as a tactic to secure future business by the large corporations forcing smaller funeral directors to follow suit in a manner which brings the moral tone of our work down in the eyes of the public through tasteless emotionally bullying adverts on daytime television.

 And most obviously, our crematoriums are with a few very notable exceptions no longer fit for purpose, environmentally, practically, spiritually or financially.

They have inappropriate outdated designs and short time slots and are mainly worked around the on time traffic of too many funerals per day.

These are the issues which are affecting the quality of funerals in the UK today.

Let me elaborate on my first point, about the emotional labour required to do this job properly.

By disconnect I mean that often with the larger chains, the people who pick up the body are not the same as the person who makes the arrangements, who is not the same as the person officiating on the day.

This lack of continuity reduces the dead person to a logistical problem, storing them in large central warehouses in identical coffins, and takes any emotional and narrative stake away from the people at the sharp end of the job.

They are as much a victim of the lack of joined up thinking as are families.

With no real training in the dynamics of shock, grief and bereavement and the impact these have on funeral workers, you have people on very low wages collecting bodies in the middle of the night walking into people’s houses in the middle of the night to collect their dead father asking “Where is it?” This happened to friends of mine.

We are not members of any trade organisation for many reasons, but largely because trade organisations in any industry largely exist to serve their members, while giving the public a veneer of accountability.

The funeral trade organisation offer cheaper insurance, a few quid off this and that, and are completely obsessed with selling pre paid funeral plans, most of which don’t significantly help the funeral director.

And the majority of the members of the largest trade body, the NAFD, are from the various Co-op’s who dominate the agenda to suit them, and use their enormous clout to produce endless press releases about changing trends in funeral music ignoring the bigger changes that have been created by small radical undertakers like ourselves,

When we make a mistake, as inevitably in the past twenty years we have, the buck stops with us. We are the complaints department as well as everything else. We are accountable, and own our mistakes and rectify them without the need for an intervening trade body. This is simple good and ethical business. People stand and fall on their reputation.

Don’t get me wrong, funeral directing is an extremely hard job, physically, psychologically and emotionally, and if you are doing it and it is not your vocation, then you will burn out.

Obviously we do not accept the widespread cultural belief that funeral directing is somehow exploitative, there are lots of fabulous undertakers, both independent and within some of the larger chains quietly and sincerely giving of themselves, but there are enormous corporate behemoths hiding behind a lot of good will and misunderstandings of the general public, and this regulation will only benefit them, while punishing the cutting edge creativity of many independents.

Forcing regulation on the industry will shut the door on ordinary members of the public participating in their own bereavement experience, and will close down the visionaries of this industry, all for the sake of convincing the public that they are protected, and has been tried by vested interests in the industry for over 100 years, with the same agenda; the shutting down of small independents.