Laserfiche WebLink
SAN JOAQUIN <br />CC LJ N T Y ------- <br />Environmental Health Department <br />RCRA Large Quantity Hazardous Waste Generator Inspection Report <br />Facility Name: <br />Facility Address: <br />1 <br />Date: <br />AMAZON.COM SERVICES INC (SJC7) <br />188 S INTERNATIONAL PKWY, TRACY <br />March 03, 2020 <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />Item # <br />Remarks <br />102 <br />CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br />OBSERVATIONS: <br />-Metal fines are being generated in the maintenance area and are recycled as scrap metal without first making a <br />hazardous waste determination. <br />-Incomplete hazardous waste determinations were made for Bissell Pro Oxy Spot & Stain and OxyClean Color <br />Boost. Gregory Guitierrez (EHS Specialist) demonstrated how a hazardous waste determination was made for <br />OxyClean Color Boost and Bissell Pro Oxy Spot & Stain. <br />-OxyClean Color Boost was observed in a hazardous waste container labeled as oxidizer, corrosive and had waste <br />code D001 (ignitability). Per Gregory Gutierrez (EHS Specialist) only sections 2, 3, 8 & 9 of the SDS are used to <br />make a hazardous waste determination. In reference to the SDS, Gregory Gutierrez (EHS Specialist) said that the <br />OxyClean Color Boost is an oxidizer because it contains hydrogen peroxide (1-5%) and the OxyClean Color Boost <br />was corrosive because of the pictogram that was included in the SDS. The pH of OxyClean Color Boost was listed <br />in section 9 as 5.5-6.5. The flash point of OxyClean Color Boost was listed in section 9 as "Not Available". <br />-Bissell Pro Oxy Spot & Stain was observed in a hazardous waste container labeled as non RCRA hazardous waste <br />liquid & solid (latex paint, soap). No hazardous properties were included on the container. The SDS for Bissell Pro <br />Oxy Spot & Stain said that it contains 3% or less of hydrogen peroxide, but it was not labeled as an oxidizer. Per <br />Gregory Gutierrez it did not have the corrosive pictogram so it was not put in the same container as the OxyClean <br />Color Boost. <br />REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste <br />as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous <br />wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive <br />or ignitable. Metal particles 100 microns or smaller in size must be handled and disposed of as hazardous waste if <br />the metal is determined to be a hazardous waste. Metal particles larger than 100 microns in size can be recycled as <br />scrap metal. <br />CORRECTIVE ACTION: Immediately stop recycling metal fines, make a hazardous waste determination for each <br />waste and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling and test results or <br />other knowledge to make your hazardous waste determination. Waste testing must be done using methods <br />specified in Title 22 CCR including Title 22 CCR sections 66261.20-24. <br />Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current <br />storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes <br />determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your <br />hazardous waste generator status. <br />This is a Class II violation. <br />FA0023764 PR0541451 SCO01 03/03/2020 <br />EHD 22-03 Rev. 9/20/2019 Page 5 of 10 RCRA Large Quantity Hazardous Waste Generator OIR <br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com <br />