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Banfield Response:As required by Banfield's Waste Management Plan, all wastes are either in their original packaging <br /> or are placed in separate plastic bags, in order to segregate each pharmaceutical. Expired non-controlled <br /> pharmaceuticals and empty liquid pharmaceutical containers are to be placed in the black 'Expired RX' container in their <br /> original packaging, and waste pharmaceuticals are to be placed in sealable plastic bags and placed in the white 'Propofol <br /> Hazardous Waste' container. Hospitals are instructed to use a different plastic bag for each type of waste <br /> pharmaceutical generated.As such,there will be no comingling of hazardous wastes. <br /> Violation#605: Failed to completely label containers or portable tanks of hazardous waste. Observation: Hazardous <br /> waste containers were observed on-site with incomplete labeling. <br /> Banfield Response: Banfield's Waste Management Plan requires hospitals to properly label all hazardous waste <br /> containers. Hospital#1188 has properly labelled all containers with the required information. Proper labelling was <br /> discussed with the current hospital manager and reviewed the requirements with all hospital personnel (Attachment Q. <br /> Photos of hazardous waste container labelling are included in Attachment B. <br /> Overall Inspection Comments Bullet#3:According to the Banfield Pet Hospital Waste Management Plan, Banfield <br /> disposes of all non-controlled pharmaceutical waste, and only the controlled pharmaceutical waste listed on Appendix A <br /> of the plan, as hazardous waste. Any other controlled pharmaceutical waste, not listed on Appendix A, are managed in <br /> accordance with Banfield's Returning and Expired Drugs policy. Please submit a statement to the EHD explaining if <br /> Banfield has made a determination as to which pharmaceutical wastes are RCRA vs non-RCRA, for both the non- <br /> controlled and the controlled pharmaceutical wastes. <br /> Banfield Response: Banfield has evaluated its formulary to determine if pharmaceuticals are RCRA or non-RCRA wastes, <br /> when expired, spilled, or otherwise unusable. However, as a matter of policy and as specified in the Waste Management <br /> Plan (Section 3.3.3), Banfield disposes of all expired and waste non-controlled pharmaceuticals as hazardous waste. <br /> Expired and waste controlled pharmaceuticals that are RCRA hazardous wastes (Appendix A of the Waste Management <br /> Plan) are managed in accordance with both DEA and hazardous waste requirements through the hazardous waste <br /> vendor. Expired and waste controlled pharmaceuticals that are non-RCRA wastes are managed in accordance with <br /> California's Medical Waste Management Act and DEA requirements by sending to a reverse distributor. <br /> Banfield appreciates your review of this Response. If you have any questions, please contact me via email at <br /> Jamie.Trotter@banfield.com, or phone at(360) 784-5806. <br /> Sincerely, <br /> 6&4*D <br /> Jamie Trotter <br /> Sr. Manager, Regulatory Compliance <br /> Attachments: Attachment A—Signed Return to Compliance Certification Form <br /> Attachment B—Photographic Log <br /> Attachment C—Hazardous Waste Training Log <br /> Attachment D—Signed Hazardous Waste Manifests <br /> Attachment E—Weekly Inspection Checklists <br /> Cc: Lisa Bongiovanni, Bridge House Advisors <br />