The Association of Independent Funeral Homes of Virginia (IFHV) supports the intent of the proposed regulation as it provides clarification for the funeral service license and complies with the profession's standards of care.  We do have some concern with the suggested mandate of maintaining a "log" in that it imposes an additional administrative burden and may represent an additional separate potential regulatory violation (failure to maintain the log.)  In lieu of a mandatory log, the Board may wish to consider something similar to the concept that a notation in the deceased records (relating to refrigeration) shall be considered by the Board as evidence of compliance.  However, noting the proposed regulations track the Board's current guidelines, and proposal following accepted standards of the profession, IFHV concurs with the intent and supports this issue moving forward in the regulatory process.