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Violation#404: Failed to inspect hazardous waste storage areas at least weekly. Observation:The most recent hazardous waste storage weekly inspection was completed on 11/15/2019 by Banfield Representative, Elizabeth Diaz Benitez, as seen on the hazardous waste storage inspection forms observed in the Banfield Pet Hospital Waste Management Binder 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 D) and copies of recent weekly inspections are included in Attachment F. Violation#601: Stored hazardous waste onsite greater than 180 days. Observation: Hazardous waste containers were found on-site with an accumulation start date of greater than 180 days or no accumulation start date. Banfield Response: In accordance with California's Health and Safety Code Section 25123.3(b), the accumulation period does not begin until the facility has accumulated greater than 220 pounds(100 kilograms).As indicated by the 2019 manifests which indicate the largest accumulation was 100 pounds, Hospital #1164 never accumulated more than 220 pounds of hazardous waste on-site;therefore,the 180-day limit for storage was not exceeded. Additionally, as provided in Banfield's Waste Management Plan, Banfield has scheduled quarterly pickups of hazardous waste with the waste disposal vendor. The current hospital manager has been reminded that hazardous waste labels must be replaced after every pick-up and the accumulation start date indicated on the label when waste is first placed into the container. Photographs of the labels are provided Attachment C, Photos 2 through 6.All wastes were removed on 12/5/2019 and the signed manifest (000861764WAS) is included in Attachment E. Violation#605: Failed to completely label containers or portable tanks of hazardous waste. Observation: Hazardous waste containers were observed on-site with incomplete labeling. Banfield Response: Banfield's Waste Management Plan requires hospitals to properly label all hazardous waste containers. Hospital#1164 has properly labelled all containers with the required information. Proper labelling was discussed with the current hospital manager and reviewed the requirements with all hospital personnel (Attachment D). Photos of hazardous waste container labelling are included in Attachment C. Overall Inspection Comments Bullet#3:According to the Banfield Pet Hospital Waste Management Plan, Banfield disposes of all non-controlled pharmaceutical waste, and only the controlled pharmaceutical waste listed on Appendix A of the plan, as hazardous waste. Any other controlled pharmaceutical waste, not listed on Appendix A, are managed in accordance with Banfield's Returning and Expired Drugs policy. Please submit a statement to the EHD explaining if Banfield has made a determination as to which pharmaceutical wastes are RCRA vs non-RCRA, for both the non- controlled and the controlled pharmaceutical wastes. Banfield Response: Banfield has evaluated its formulary to determine if pharmaceuticals are RCRA or non-RCRA wastes, when expired, spilled, or otherwise unusable. However, as a matter of policy and as specified in the Waste Management Plan (Section 3.3.3), Banfield disposes of all expired and waste non-controlled pharmaceuticals as hazardous waste. Expired and waste controlled pharmaceuticals that are RCRA hazardous wastes (Appendix A of the Waste Management Plan) are managed in accordance with both DEA and hazardous waste requirements through the hazardous waste vendor. Expired and waste controlled pharmaceuticals that are non-RCRA wastes are managed in accordance with California's Medical Waste Management Act and DEA requirements by sending to a reverse distributor. Banfield appreciates your review of this Response. If you have any questions, please contact me via email at Jamie.Trotter@banfield.com, or phone at(360) 784-5806.