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Introduction

The Health Protection (Coronavirus Restrictions) (No.5) (Wales) Regulations 2020 impose restrictions on individuals, businesses and others social activities. This has been done to control the spread of coronavirus in Wales and to help protect the public from the spread of severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2).

Death of a family member or friend is a very distressing event which is why the Regulations recognise the need to attend funerals in certain circumstances.   Funeral services should continue, and funeral providers should consider how they can facilitate this.

Funerals with physical attendance of mourners should continue as long as those attending adhere to the Regulations as interpreted by this guidance, which sets out how the risk of transmission can be reduced.

However, although members of the public may attend a funeral, they should be respectful of the fact that there are restrictions that have been imposed as a result of a public health emergency. The overarching advice, therefore, is that people should only attend the funeral of their closest family and friends, and can only do so if they have been invited by the person responsible for arranging the funeral.

Celebrating the life of a deceased person/a wake is permissible if held in regulated premises (such as public houses or community centres) and if directly associated with a funeral. These gatherings, which are limited to a cap of 15 people, must take place in compliance with the duties on organisers created by Regulation 6 and Part 6 of the Regulations (minimising risk of exposure to Coronavirus) and the guidance set out in this document.  

To ensure that organisations managing funerals are able to cope with an increased number of deaths it is important that funerals are not delayed.

Legal requirements

The Regulations make provisions that apply both to those responsible for a crematorium, place of worship or cemetery at which a funeral or burial is held, and to members of the public who may wish to attend a funeral or burial. They also make provisions which regulate the conduct of associated social gatherings.

Places of worship, cemeteries and crematoria, funeral directors, hospitality businesses and community centres which may be used to hold ‘wakes’ all fall within the definition of regulated premises, which are permitted to be open. The Regulations require those responsible for those premises to take reasonable measures which must be taken by all workplaces and premises open to the public to minimise the risk of exposure to coronavirus.  

Part 2 of the Regulations imposes limits on meeting other people, with Regulation 5 addressing extended households, and Regulation 6 focussing on gatherings in public places. The general rule for gatherings in public places is that they are limited to 4 people, not including children under 11.         

The restriction on gatherings in regulation 6 applies, subject to having a reasonable excuse for gathering. Examples of such reasonable excuses are to attend a funeral or and a gathering to celebrate the life of a deceased person. Please note that in order to attend a funeral as a mourner a person must be the person arranging it, have been invited or be the carer of someone lawfully attending it. 

The number of people who may attend a funeral is determined by how many people the venue can safely accommodate whilst complying with the physical distancing requirements, following a risk assessment by the person responsible for the venue.                     

For celebrations of a deceased person’s life (a wake), the maximum number of people who may attend is 15 (not including children under the age of 11) and the celebration must be held in regulated premises, not in private dwellings.

This guidance offers advice on the practical implementation of these legal requirements. A simplified version aimed at members of the public can be found in the Annex.

Taking all reasonable measures to minimise risk of exposure to coronavirus

A key aspect of the Welsh Government’s response to the public health emergency is to place restrictions on people gathering. Attending a funeral or an associated social gathering, is an exception to the restrictions on gatherings in public places, under which the general rule is that gatherings in public places must be limited to 4 people.

The number of people able to attend a funeral is limited by the capacity of the venue whilst ensuring the physical distancing requirements are applied. Unfortunately this necessitates changes to traditional customs and practices at funerals in so far as this involves interaction between people from different households.

A person responsible for a venue where a funeral is to be held, will be subject to a duty to:

Take all reasonable measures to ensure 2 metres distance is kept between persons waiting to enter and when inside premises;

Take other reasonable measures to minimise risk of exposure to coronavirus, for example by avoiding face to face interaction and maintaining good hand washing and respiratory hygiene; and

Provide information to people who enter or are working in the premises on how to minimise that risk.

In most circumstances people are expected to practice physical distancing measures. This means maintaining a distance of 2 metres wherever practical. This does not include between members of the same household, or a carer and the person assisted by the carer. Separate guidance makes it clear that it is not expected that children under 11 maintain physical distancing. However, as young children can still transmit the virus, parents/carers of young children should still exercise their good judgement and take care especially to encourage their children to follow hand hygiene measures and keep close contact to a minimum wherever possible.

New guidance has been issued providing advice and guidance on taking reasonable measures to minimise the risk of exposure to coronavirus in workplaces and premises open to the public. This should be taken into account alongside the advice provided in this document.

Guidance for faith and belief practices that involve close contact with the deceased

Those handling the deceased should be aware that there is likely to be a continuing risk of infection from body fluids and tissues in cases where coronavirus infection has been identified or is suspected.

For those, for whom care of the deceased is part of their faith, rituals such as viewing, keeping watch and hygienic preparations such as washing are an important part of the mourning process. We strongly advise that any rituals or practices that bring people into close contact with the deceased with suspected or confirmed COVID-19 should be undertaken using appropriate PPE under the supervision of somebody trained in its use.

Personal care of deceased people

Given the increased risk of severe illness for extremely vulnerable people from COVID-19, it is strongly advised that they have no contact at all with the deceased and do not participate in any activities such as washing, preparing or dressing the deceased.

Mourners are advised not to take part in rituals or practices that bring them into close contact with the deceased. Where there are aspects of faith which include close contact with the deceased that contact should be restricted to those who are wearing Personal Protective Equipment (PPE) under the supervision of someone who is trained in appropriate use of PPE. Detailed guidance on care of the deceased is available and should be followed, regardless of the setting in which personal care of the deceased is provided.

Given the very significant risk for people at increased risk and extremely vulnerable people who come into contact with coronavirus (COVID-19), it is strongly advised that they have no contact with the body of the deceased. This includes washing, preparing or dressing the body.

The maximum number who can attend a funeral

The most obvious means of taking all reasonable measures to maintain a 2 metre distance between persons present at a funeral (be that a cremation or burial), is to limit the number who may attend. This number will depend on whether the funeral involves a burial in a cemetery (including the interment of ashes), a cremation in a crematorium or a service in a place of worship.

In so far as a crematorium or place of worship is concerned, the appropriate limit will depend on the size and layout of the building. The legal requirement is that all reasonable measures are taken to ensure a distance of 2 metres is kept between those attending. This means a distance of 2 metres between members of different households, rather than between each individual person in the same household. In practice, however, it will generally not be practicable to assess in advance how many people from the same households will be sitting together at any particular funeral. A figure should be calculated for each crematorium or place of worship, based on the number that could reasonably be accommodated if every person sat 2 metres apart. This should, however, only be a guide and a degree of flexibility can be exercised on the assumption that a significant proportion of those attending will be sitting together with members of their household (which could enable more people to attend).

Different considerations apply to practising physical distancing in a cemetery, or burial ground or garden of remembrance in a crematorium, as the most important aspect will be limiting the extent to which members of different households congregate, most obviously around the grave. Grounds surrounding a crematorium are also not required to close, this includes any burial grounds or gardens of remembrance which should remain open to visitors. 

Requirement for those attending to be invited

Regulation 6 provides that attendance at a funeral as a mourner is limited to those responsible for arranging the funeral, those specifically invited by the organiser of the funeral, and the carer of anyone attending. Those who are officiating/working at the venue are not included in the number of attendees.

This should be implemented by informing those who are organising funerals that they must expressly invite those they wish to attend (though this does not require any formality such as sending an invitation in writing). In view of the risk of people attending uninvited (as of course is the normal practice), those organising should also be encouraged to limit information about the location of the funeral in death notices and make clear that attendance at the funeral is by invitation only.

Outdoor funerals are subject to the same restrictions, with the number of attendees based on the risk assessment of the owner of the venue, and the ability of mourners to socially distance in a safe manner.

Requirement for those attending to wear face coverings

Those attending a funeral are required to wear face coverings throughout the duration of the ceremony with the exemption of individuals with a reasonable excuse, such as:

  • they are not able to put on or wear a face covering because of a physical or mental illness, or because of a disability or impairment; or
  • they are accompanying somebody who relies on lip reading where they need to communicate.

Travelling to and from a funeral

Those attending from the same household should travel together and should not travel with others from different households. Where a vehicle is used to provide a service of carriage for passengers, all reasonable measures must be taken to minimise the risk of exposure to coronavirus. Read the guidance for the public on travelling safely.

You should travel to the venue in a car by yourself or with people from your household, especially if you are at increased risk or extremely vulnerable. If this is not possible, you are advised to:

  • share your transport with the same people each time
  • open windows for ventilation
  • travel side by side or behind other people, rather than facing them, where seating arrangements allow
  • face away from each other
  • consider seating arrangements to maximise distance between people in the vehicle
  • ensure the car is cleaned between journeys using standard cleaning products, particularly door handles and other areas that people may touch
  • wear a face covering. You are required by law to wear a face covering on public transport, in taxis and private hire vehicles unless you are exempt for health, disability or other reasons. Passengers who are not exempt are legally required to wear a face covering when travelling in a funeral director’s vehicle or hearse. A face covering is also strongly recommended for drivers.

People resident in other UK nations

No one living in a tier 3 area of England, in a level 3 or 4 area of Scotland or in Northern Ireland (referred to below as “restricted areas”) may enter or remain in Wales unless they have a reasonable excuse to do so. However, if you live in the restricted areas the Regulations provide that you have a reasonable excuse to attend a funeral in Wales if you are the person responsible for arranging it, if you have been invited to attend by the person arranging it or if you are the carer of a person attending. Residents of England and Scotland who do not live in the restricted areas do not need a reasonable excuse to enter Wales. As a matter of Welsh law, residents of Wales wishing to attend a funeral in the restricted areas would have a reasonable excuse to leave Wales to do so but would need to check whether this is permitted under the English, Scottish or Northern Irish regulations.

However, the exemption permitting travel into Wales for a person living in the restricted areas does not extend to attending a wake or celebration of the life of a deceased person and you would need to comply with all other restrictions applying in Wales.  People living outside Wales would also need to comply with all applicable regulations applying in the place where they live, but the Welsh Government cannot advise you on those.

International travel restrictions affecting mourners

Mourners returning to Wales from abroad, who have travelled from countries that are not exempt from the requirement to self-isolate (within the last 14 days) are required to self-isolate for 14 days from the day they were last in a non-exempt country. However, Regulation 10(4)(k) of the Health Protection (Coronavirus, International Travel) (Wales) Regulations 2020 provides an exception from the requirement to self-isolate, in limited circumstances, in order to attend the funeral of a family member or close friend.

The mourner can only leave their place of self-isolation when attending the funeral, and is otherwise expected to self-isolate for the remainder of the 10-day period unless another exemption applies. Please note that the list of exempt countries is updated regularly and people travelling must check the self-isolation requirements for the day they arrive and act accordingly.

Restrictions and Regulations for mourners seeking to attend a funeral

People who are symptomatic should not attend

Anyone who has symptoms of COVID-19 (a new continuous cough, a high temperature or a loss of, or change in, your normal sense of taste or smell), should not attend a funeral (although please see below in relation to funerals of family members or close friends). You should immediately self-isolate, follow the latest guidance, and request a test online, or by contacting NHS 119 via telephone if you do not have internet access.

People who are required to self-isolate

If you have been instructed by Wales NHS Test, Trace, Protect to self-isolate because you have tested positive for COVID-19, or you are the close contact of someone who has tested positive for COVID-19, you should not attend a funeral.

It is a legal offence for a person who is required to self-isolate to attend a funeral unless it is to attend the funeral of a family member or close friend.

If you are legally required to self-isolate you may only leave self-isolation if attending the funeral of a family member or close friend and otherwise must continue to self-isolate. People with a legal duty to self-isolate are:

  • anyone who is notified by Test, Trace, Protect that they have tested positive for COVID-19. They must self-isolate (stay at home) for the period ending 10 days after they first developed symptoms, or if they did not have symptoms, 10 days after the date of the test
  • anyone who is notified by Test, Trace, Protect that another member of their household or support bubble has tested positive. They must stay at home for the period ending 10 days after that household or support bubble member’s symptoms began, or if they did not have symptoms, 10 days after the date of the test
  • anyone who is instructed by Test, Trace, Protect to self-isolate because of close recent contact with a person outside their household or support bubble who has tested positive for COVID-19. They must stay at home for the period instructed by NHS Wales Test, Trace, Protect (which will end 10 days after the point of most recent contact with the person who has tested positive)

Even if you are the person arranging the funeral, a family member or close friend of the deceased, we strongly recommend that you attend remotely if possible, to reduce the risk of COVID-19 spread to other mourners. However, if after careful consideration of the considerable risks you present to others, you choose to attend in person, and this is acceptable to the person arranging the funeral, it is essential that you take all of the following precautions:

  • advise the funeral organiser and other mourners that you are in your self-isolation period, and ensure that you do not attend at the same time as another mourner who may be at increased risk or extremely vulnerable.
  • ensure those facilitating the venue of the funeral are made aware of your intention to attend. It is a legal requirement for a venue manager to complete a risk assessment and take all reasonable measures to limit the risk of transmission of COVID-19. These measure could include additional ventilation, and/or the use of screens or other barriers.
  • sit apart from others, and maintain a social distance of at least 2 metres between yourself and others at all times. Other mourners need to be aware of this prior to attending,
  • practise strict hand and respiratory hygiene by:
    • wearing a surgical-grade Type IIR face mask or higher grade, properly fitting, to minimise any risk of viral transmission from yourself to others. If a respirator mask is used (for example N95), this should be non-valved
    • washing your hands more often than usual with soap and water for at least 20 seconds, or using a hand sanitiser
    • avoiding touching your eyes, nose and mouth
    • covering your coughs or sneezes

Those responsible for places of worship, crematoriums and funeral directors premises must take all reasonable measures for the purposes of minimising the risk of exposure to coronavirus at those premises, or the spread of coronavirus by those who have been at those premises. If the operator of the place of worship or a crematorium becomes aware that someone who is required to quarantine or self-isolate or someone who is symptomatic or has tested Covid-positive plans to attend a funeral, the operator may insist on that person wearing an appropriate standard of protective equipment and taking other appropriate precautions to minimise the risks to others attending. If that person declines or is unable to comply with those conditions, the operator may refuse to admit them.

Any mourner who comes into close contact with you during the ceremony (for example, to console or otherwise support you) will then be required to self-isolate. Other mourners need to be aware of this prior to attending.

Guidance for households with possible or confirmed coronavirus infection is available.

Safety precautions for mourners

All mourners should practise careful hand and respiratory hygiene:

  • wash their hands more often - with soap and hot water for at least 20 seconds or using a hand sanitiser
  • avoid touching their eyes, nose, and mouth
  • covering their cough or sneeze with a tissue, then throwing the tissue in a bin
  • use their own transport where possible.

Mourners who are extremely vulnerable (formerly shielding) should be facilitated to attend, with processes put in place to minimise the risk of transmission. They should be advised to minimise their contact with others for their personal protection, especially if someone permitted to leave self-isolation is also attending.

If a person is attending who would otherwise be self-isolating, it is essential that every measure is taken to ensure those who are at increased risk or who are extremely vulnerable are kept as far removed as possible from the person that would ordinarily be self-isolating.

Mourners who are extremely vulnerable should follow the general physical distancing advice and should maintain a distance of 2 metres away from others as a minimum.

Actions to reduce the risk of infection for all attendees by the person arranging the funeral should include:

  • advising mourners who are self-isolating either because they have symptoms or as a part of the same household/extended household as someone with symptoms, or if they have been advised by Test Trace Protect to self-isolate not to attend
  • the person responsible for arranging the funeral should advise other attendees if there is an extremely vulnerable person attending, and reiterate the need to stay at home if they are unwell, in order to be respectful of the vulnerable person’s need to avoid close contact at any point
  • the person responsible for arranging the funeral should ensure that all those attending the funeral; mourners, and those facilitating the service, are made aware if one of the mourners is Covid-19 positive

Actions to reduce the risk of infection for all attendees by those responsible for premises where funerals are conducted must include:

  • provision of information to those entering or working at the premises about how to minimise the risk of exposure to coronavirus. This could include:
    • changing the layout of premises including the location of furniture and workstations
    • controlling use of entrances, passageways, stairs and lifts
    • controlling use of shared facilities such as toilets and kitchens
    • otherwise controlling the use of, or access to, any other part of the premises
    • installing barriers or screens
    • providing or requiring use of personal protective equipment
    • advising the mourner to travel to the venue via the safest route possible, preferably in a car by themselves, or with someone from their household
    • considering the additional risk involved if attending the funeral requires travelling by public transport

Mourners who are at increased risk or extremely vulnerable should adhere to rigorous hand and respiratory hygiene at all times but particularly whilst out of the home environment. Hand sanitiser or sanitising wipes should be used regularly whilst outside of the home

During the funeral

Arrangements should be put in place to ensure that upon arrival at a crematorium, place of worship or cemetery, those attending can be kept apart and are not required to congregate in confined spaces. This is particularly important while waiting to go into a crematorium or place of worship.

Those attending should then be shown to their seats in accordance with arrangements put in place in advance that ensure that all can maintain a 2 metre distance.

Those attending should be advised not to touch, kiss or come into contact with the coffin. This includes bearers who may accompany the coffin at appropriate distances but should not carry the coffin on their shoulders. Rather the coffin should be moved using wheeled biers and lifted as required by the funeral director.

Processes should be put in place to allow a suitable time to clean and disinfect the area in which a service has taken place both before and after each service, paying attention to frequently touched objects and surfaces, using regular cleaning products. They should also ensure that handwashing facilities are available and clearly signposted. Hymn books should be removed making use of bespoke order of service pamphlets for all purposes instead.

Collections should be arranged online rather than at the crematorium or place of worship.

It is important also to limit the extent that people from different households congregate after a funeral. That may be outside a crematorium or place of worship, or at a graveside. Arrangements should be put in place to ensure that those attending can pay tribute to the deceased with dignity, and to greet family and friends as appropriate, while ensuring physical distance is maintained.

Singing, chanting and the use of musical instruments

We recognise the importance of music, singing and chanting in worship, religious and belief ceremonies. However, there are significant risks associated with playing wind instruments and with singing or chanting. The risks are associated with the increased spread of droplets or aerosol which rise alongside volume. For this reason activities such as congregational singing, chanting, or shouting should be specifically avoided indoors, particularly if those in attendance are Covid-19 positive.

It is possible for an organised group or groups of musicians or singers to play a part in the funeral service, but a specific risk assessment and mitigating actions should be put in place to provide a Covid-19 safe environment. Therefore, anyone who has symptoms of COVID-19 (a new continuous cough, a high temperature or a loss of, or change in, your normal sense of taste or smell), or has been instructed by Wales NHS Test, Trace, Protect to self-isolate because they have tested positive for COVID-19, or they are the close contact of someone who has tested positive for COVID-19, should not attend the funeral. Singing or playing in groups should be limited in line with the capacity of the space given appropriate physical distancing requirements.

Wind instruments should not be played indoors. The decision whether to play an organ that requires air to be pushed through the mechanism should be based on a risk assessment and adherence with physical distancing, hand hygiene and cleaning guidance.

It is advised that you use alternative instruments such as a piano, electronic instruments or recordings.

If singing or the playing of music is to happen it should be accompanied by clear messages that those not in an organised group of musicians or singers should not join in.

Specific risk assessments for organised groups who are singing or playing musical instruments should consider:

  • Physical distancing between individuals
  • Physical distancing between fixed groups
  • Physical distancing between performers and congregations
  • The size and layout of the space
  • The ventilation available to prevent the accumulation of aerosol.
  • The use of screens or other barriers between individuals and fixed groups
  • The positioning of singers and instrumentalists to favour back to back or side to side and reduce face to face performance.
  • Performing outdoors 
  • Reference should be made to the guidance on performing arts, which deals with safe performance for singers, musicians and other performers.

Congregational singing should not occur indoors. If appropriate worshippers can read hymns, songs, prayers or other texts in a lowered voice. Spoken responses should also be made quietly. 

Singing and playing music outdoors is permissible for an outdoor service, although as an organised activity it is subject to a risk assessment and the organiser must take reasonable measures to minimise the risk of exposure to coronavirus. Such gatherings should maintain physical distancing between households and volumes kept low wherever possible.

Ringing of bells, or similar, may take place. However, people attending to peal bells should be included in the risk assessment process and subsequent protocols for attendance at the event. Specific provisions should be made where circumstances allow, such as separate entrances, and physical distancing measures between bell ringers and hand hygiene while pealing the bells and between them and the other attendees.

Broadcasting, online condolence and memorial at a later date

The restrictions imposed on funerals may be upsetting to those close to the deceased at a very distressing time. Attending funerals, often in great numbers, is an important part of Welsh culture. Those closest to the deceased take consolation from friends and family attending the funeral of their loved one. This will not be possible during the public health emergency, but solace may be achieved in other ways.

It is possible for funerals to be broadcast online (if broadcasting requires a technician or someone to manage the filming that the number should be the absolute minimum and considered in the calculation of how many can attend), and those who wish to do this should be helped to do so. Similarly those organising a funeral should be encouraged to open books of condolence and collections online, or to facilitate tributes to be paid by electronic communications or on social media. Alternatively, or in addition, there could also be a memorial service or celebration of life for the deceased after the public health emergency has come to an end.

Celebrating the life of the deceased or ‘wakes’

Annex

Guidance to members of the public on the impact of coronavirus restrictions on funerals

Funerals can be a distressing experience, and the impact of coronavirus is making it even more difficult to make practical arrangements. This guidance has been prepared to help people at this very difficult time.

The Welsh Government has put in place restrictions to control the spread of coronavirus in Wales and to protect people’s health. This includes temporary restrictions on gatherings of people in Wales.

These have an impact on how funerals are organised but they do enable funerals to go ahead because we recognise it is important for people to say goodbye to a loved one. Funeral directors have been given specific advice about how to organise funerals during the pandemic. They will be able to guide you through the process and help you make arrangements, making sure that you receive the advice and support you need.

The following information will help you to understand some of the main restrictions that are in place.

People can attend a funeral if:

  • you are the person organising the funeral,
  • you have been invited to the funeral by the person responsible for arranging the funeral, or
  • you are the carer of a person who is attending the funeral (either because they are the organiser or they have been invited).

Everyone attending a funeral – whether at a crematorium, place of worship or cemetery – should take all reasonable measures to stay 2m away from someone they don’t live with or care for. This will help to reduce the spread of coronavirus. Those responsible for running the crematorium, place of worship or cemetery will make arrangements to maintain this distance between people and any other reasonable precautions they feel are necessary to reduce the risks of people contracting coronavirus. 

This will mean there are limits on the maximum number of people who can physically attend a funeral, dependent on the size of the venue and ability to comply with the physical distancing requirements. This will be clearly communicated to you before the funeral takes place. To help protect against the spread of coronavirus, funerals must be by invitation only.

The death of anyone close to you is a very distressing and sad event. But at this time, we ask you to only attend funerals of your closest family and friends and only if you have been invited by the person responsible for arranging the funeral.

If you have symptoms of coronavirus – a high temperature, a new, persistent cough, or loss of taste or smell – you should not attend but self-isolate and apply for a test. If you are self-isolating due to a possible case of coronavirus in your household, or as advised by Wales NHS Test, Trace, Protect, you should not attend, unless the deceased is a family member or close friend.

If you are the person responsible for arranging the funeral, and/or a close family member of the deceased, and you are in self-isolation we strongly recommend that you attend remotely. However, if after careful consideration of the risk, you choose to attend in person, it is essential that you make others aware of your condition before the funeral service due to the high risk you present to them, particularly those who are extremely vulnerable.

You should also advise the funeral director, and venue manager in advance that you are in self-isolation as additional safeguards will need to be in place to facilitate your attendance.

Mourners coming into Wales who have travelled to Wales from countries that are not exempt from the requirement to self-isolate can leave their place of self-isolation in limited circumstances including on compassionate grounds. This includes attending a funeral but they are expected to self-isolate for the remainder of the specified 14-day period unless another exemption applies.

No one living in a tier 3 area of England, in a tier 3 or 4 area of Scotland or in Northern Ireland (referred to below as “restricted areas”), may enter or remain in Wales unless they have a reasonable excuse to do so. However, if you live in a restricted area you can enter Wales to attend a funeral if:

  • you are the person organising the funeral,
  • you have been invited to the funeral by the person responsible for arranging the funeral, or
  • you are the carer of a person who is attending the funeral (either because they are the organiser or they have been invited).

Funerals can be broadcast and livestreamed so people who cannot be physically present can attend the ceremony virtually. In addition, books of condolence can be opened online and other tributes paid through electronic communications or social media.

Family and friends may also want to consider holding a memorial service or celebration of life once the coronavirus pandemic is over.

It is important that you do not delay the funeral of your loved one. We understand how difficult this will be for their families and friends, however the current guidance will be in place for the foreseeable future for the safety of the public and to ensure that funeral directors, crematoriums and burial grounds can continue to offer as normal a service as possible.

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