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Page 2 of 4 <br />From: Borsh-Estrada, Erin [mai Ito: EEstrada@STERICYCLE.com] <br />Sent: Wednesday, October 27, 2010 10:53 PM <br />To: Alfonso Arambula [EH] <br />Subject: Pharmaceutical Containers <br />Alfonso, <br />Thank you again for taking the time to speak with me today and your willingness to hear me out. I very much appreciate you <br />and your role. Casey Foley is held in high esteem and I consider her the expert in her field. You requested that I send you my <br />interpretation of the regulation. So here it is: <br />@So here iswhere I <br />would say,"Would <br />you like an Apple <br />or a <br />Banana?""Youcan <br />have a cookie OR a <br />brownie, not <br />both. So my <br />interpretation is <br />aslong as the <br />secondary <br />container is <br />labeled, that <br />hopefully would <br />besufficient. <br />I absolutely see where the regulation states: <br />g) Biohazardous waste, which meets the conditions specified in subdivision (g) of <br />OSection 117635, shall be segregated for storage and, when placed in a container Or <br />secondary container, that container shall be labeled with the words "INCINERATION <br />ONLY" or other label approved by the department on the lid and on the sides, so as to be <br />visible from any lateral direction, to ensure treatment of the biohazardous waste pursuant <br />to Section 118222. <br />I've also ran a report to show how many pharmaceutical containers get swapped or changed out on a <br />monthly basis. Qty is the actual containers and the volume is for a month. There are A LOT of <br />Pharmaceutical containers coming in and going out of a Hospital. For them to have to label on all four sides <br />and the lid with Incineration only stickers, will take time. Time that would be better spent changing the <br />containers out and cleaning the Hospital. Hospitals are running as lean as possible and to take someone <br />away from their job for 2-3 hours to label, might not seem like a lot but it does affect Patient Care. <br />Pharmaceutical Containers tend to fill up quickly. Which is funny since they get the longest time to be in the <br />Hospital. I do take pictures and reference Medical Act when I do Audits. I would be happy to share some <br />anonymous audits and show what I look for. With Pharmaceutical containers, I want to make sure they are <br />in a locked area or under Generator's control. They are labeled for Incineration waste. I want to make sure <br />they are not overfilled and that they are making not soup in the container (mixed chemicals which can <br />cause a reaction, some liquid is ok). I also look to make sure the RCRA drugs are not going into the <br />container, among other things. <br />Pharm <br />1:1 <br />12/1/2010 <br />