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Violation#202: Disposed or caused disposal of HW at an unauthorized point. Observation: When asked by Denise Farias, Shift Leader, how the facility's tono batteries (used in equipment to test for eye glaucoma) are disposed of, Gabby Holdsworth, Registered Veterinary Technician, stated she disposes of the batteries into the trash like she does at home. According to the Banfield Pet Hospital Waste Management Plan, all batteries are to be managed as universal waste. Banfield Response:As required by Banfield's Waste Management Plan, all batteries are to be managed as universal waste, in a container labeled "Waste Batteries." At the time of the inspection,the hospital did not have any waste batteries onsite and the tono batteries are replaced on very limited basis as they last for several years.The hospital does not currently have waste batteries; however, universal waste management was reviewed with the current hospital manager and the requirement has been reviewed with all hospital personnel (Attachment C). It is noted that the current hospital manager is not aware of any batteries being disposed of in the regular trash. Violation#403: Failed to keep hazardous waste containers closed except when adding or removing hazardous waste. Observation:An open cardboard box, marked with the words "Expired Drugs," and storing expired pharmaceuticals, according to Denise, was observed near the facility entrance door, on a high shelf, and directly on top of the white container labeled as Hazardous Waste Expired Rx Waste. Denise retrieved the cardboard box from the shelf for further observation. According to the Banfield Pet Hospital Waste Management Plan, expired non-controlled pharmaceuticals, and hazardous expired controlled pharmaceuticals (included on the list in Appendix A), are to be managed as hazardous waste. Banfield Response:As required by Banfield's Waste Management Plan, expired non-controlled pharmaceuticals must be placed in a closed hazardous waste container.The hospital was provided containers with tight fitting lids for all hazardous waste streams with instructions provided in the Waste Management Plan for segregation of the wastes. Expired non-controlled pharmaceuticals must be stored in closed black 5-gallon buckets and waste hazardous controlled pharmaceuticals are placed in labelled sealable plastic bags and placed in a closed lockbox. Hazardous waste containers and storage procedures have been reviewed with the current hospital manager and the requirements have been reviewed with all hospital personnel (Attachment Q. Photos of the storage containers are in Attachment B. Violation#404: Failed to inspect hazardous waste storage areas at least weekly. Observation: According to the Waste Management Plan, missing or incomplete hazardous waste labels are to be corrected immediately and containers with missing or open lids are to be replaced immediately, during the weekly hazardous waste storage inspections. Numerous hazardous waste containers, one of which was found open,were observed with incomplete labeling. According to the Waste Management Plan, completed weekly hazardous waste storage inspection forms are to be maintained in the Waste Management Binder for minimum of three years. Completed weekly Hazardous Waste Storage Inspection forms could not be found at the time of inspection. Banfield Response:As provided in Banfield's Waste Management Plan, Banfield hospitals are required to conduct weekly hazardous waste inspections.The procedure was discussed with the hospital during the recent call with the current hospital manager and staff safety meeting(Attachment C) and copies of recent weekly inspections are included in Attachment E. Additionally, all containers are closed and are properly labeled with all required information (Attachment B). Violation#405: Failed to manage incompatible wastes in containers properly. Observation:The Banfield Pet Hospital Waste Management Plan does not include instructions for employees to segregate wastes based on incompatibility or hazard, although the plan indicates that expired non-controlled pharmaceuticals, hazardous expired controlled pharmaceuticals, and waste pharmaceuticals may exhibit various hazardous waste properties. It is unknown if the hazardous wastes found in the following containers are potentially incompatible and should be segregated in order to prevent a reaction.