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03/25/2011 FRI 8: 54 FAX 209 461 5046 Facilities NVP ®003/014 <br /> -.M.4 <br /> Administration <br /> St.Joseph's Medical Center Safety&Emergency Management <br /> n w�w6..,d'rruv 1800 North California Street <br /> P.O.Box 213008 <br /> Stockton,CA 95213-9008 <br /> 209 4615221 Telephone <br /> 209 4613299 Fax <br /> March 25, 2011 <br /> Garrett Backus <br /> San Joaquin County <br /> Environmental Health Department <br /> 600 E. Main Street <br /> Stockton, CA 95202-3029 <br /> RE: 2011 CUPA Inspection, violations and the return to compliance. <br /> On February 25, 2011, the San Joaquin County Environmental Health Department conducted an <br /> inspection of the hazardous material waste stream located at 1800 North California Street Stockton, CA, <br /> 95204. This letter addresses each violation as it appears on the inspection report. <br /> Item 7 <br /> Violation:Any person who generates a waste shall determine if the waste is a hazardous waste. In the <br /> Pharmacy Department, Patricia Sakai, supervising Pharmacist, was interviewed about waste <br /> pharmaceutical handling. The inspector showed a list of P and U listed RCRA Pharmaceutical to Patricia. <br /> Patricia stated that several of the pharmaceuticals are used in the hospital. These pharmaceuticals are <br /> Cytoxan, Daunomycin, Cyclophosphamide, Daunorubicin, Leukeran,and Warfarin (>0.3%). Patricia <br /> stated that if these pharmaceuticals are waste then they are placed in the blue container. The blue waste <br /> container is used to collect waste pharmaceuticals for incineration. <br /> Patricia stated that the pharmacy does not have a black waste container. The black containers are <br /> commonly used for RCRA hazardous waste accumulation. <br /> Listed RCRA pharmaceutical waste usually needs to be handled as RCRA waste. RCRA waste should <br /> be accumulated in a hazardous waste labeled container and removed from the facility by a registered <br /> hazardous waste hauler who generates a hazardous waste manifest. <br /> Make a hazardous waste determination for all of the waste pharmaceuticals. Determine which <br /> pharmaceuticals must be handled as RCRA hazardous waste and manage it according the Title 22 <br /> hazardous waste regulations. Submit a statement and supporting documentation explaining haw RCRA <br /> hazardous waste pharmaceuticals will be managed by March 25,2011_ <br /> Corrective Actions: In 2007-2008 an extensive pharmaceutical waste audit was performed by a third <br /> party vendor, Stericycle Inc. In collaboration with Stencycle a multi disciplinary team which consisted of <br /> the Infection Control Manager, Pharmacy Director, Safety Officer, Education Director, Support Services <br /> Director, and Facilities/Maintenance Director evaluate our pharmaceutical waste stream. <br />