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• u 0 Environmental Health Inspection Program 2220, SM HW GEN <5 Tons/YR 303 1 CCR 66262.34(d)(2) • Premier Finishing Violations, Corrections, & WIP Class 11 Disposed or caused disposal of HW at an unauthorized point. Failed to maintain all communication or alarm systems, spill control, or decontamination equipment. Several eye wash stations throughout the facility were not maintained. The eye wash solution was expired. All facility communications or alarm systems, fire protection equipment, spill control equipment, and decontamination equipment, where required, shall be tested and maintained as necessary to assure its proper operation in time of emergency. Immediately begin this practice. Premier Finishing Correction, Process Improvement, and or Explanation (303): AUG O 5 2014 DEPARTMENT Inspection # Ref Codes/Regs: Type Violafion Descdpfion: 605 CCR 66262.34(f) Class It Failed to completely label containers or tanks of (repeat) hazardous waste. Failed to completely label containers or tanks of hazardous waste. A 55 -gallon container of waste acetone sludge located next to the acetone distilling unit did not have the hazardous properties listed on the label. All hazardous waste containers shall be marked with the following information: • The words "Hazardous Waste" • name and address of generator • hazardous properties • Physical State • composition (contents) • accumulation start date (Instructions) Immediately label these containers and ensure that all hazardous waste containers are marked with all the required information. The violation was corrected on site. This is a repeat violation (Class II). 1. Premier Finishing Correction, Process Improvement, and or Explanation (605): a. We had this labelled. We were missing one word (one thing). Corrected on the spot. b. An unfortunate failure to identify the fact the store-bought, provided label did not include all the information needed. c. We appreciate highlighting this problem to our management. We have, as noted, experienced this problem in the past. We suggest an aspect of the root cause is our efforts to use products that are made by vendors such as "Mesa Label Express"... which often times include either too much information, or not enough. d. In reference to long term resolution Premier is researching different labelling software and protective labels that can survive the rigorous environment where they are used. We will choose and implement one of these packages prior to November 2014. e. In addition Premier, is implementing a placard system to be displayed at each work -area where the labels are used, with copies in the inspection binder. Our plan is to seek approval from the SJEH Department for the placards and the checklist to ensure they are correct before implementation. IC