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Page 1 of 3 <br /> Alfonso Arambula [EH] <br /> From: Alfonso Arambula [EH] <br /> Sent: Monday, May 05, 2014 8:58 AM <br /> To: 'Deniz Garrett' <br /> Subject: RE: EHD Request for Document for Synergy Health PLC audit <br /> Attachments: MWMAfinal20l3.pdf <br /> Good Morning Deniz, <br /> After review of Synergy Health's medical waste reports the following Health and Safety Code section in the <br /> medical waste management act(MWMA) 118280(d)(1)(A) requires Syngery Health have medical waste removed <br /> once every seven days. <br /> 118280(d) <br /> (1) Except as provided in paragraph(5), a person generating biohazardous waste shall comply <br /> with the following requirements: <br /> (A) If the person generates 20 or more pounds of biohazardous waste per month,the <br /> person shall not contain or store biohazardous or sharps waste above 0 degrees Centigrade (32 <br /> degrees Fahrenheit) at any onsite location for more than seven days without obtaining prior <br /> written approval of the enforcement agency. <br /> The Health and Safety code (H&SC) section 117635 (d) in the MWMA defines fluid blood as <br /> biohazardous waste. I understand Synergy Health does a treatment on fluid blood prior to discharging to <br /> sanitary sewer but medical waste may only be treated as specified in the MWMA H&SC section 118215 <br /> (a). A facility that discharges medical waste to a public sewage system without treatment must comply <br /> with H&SC section 118215 (b) in the MWMA. Please see all corresponding code sections below: <br /> 117635(d) Waste, which at the point of transport from the generator's site, at the point of disposal, or <br /> thereafter, contains recognizable fluid blood, fluid blood products, containers or equipment containing <br /> blood that is fluid, or blood from animals known to be infected with diseases which are highly <br /> communicable to humans. <br /> 118215 -Methods <br /> (a) Except as provided in subdivisions (b) and(c), a person generating or treating medical waste shall <br /> ensure that the medical waste is treated by one of the following methods, thereby rendering it solid <br /> waste, as defined in Section 40191 of the Public Resources Code, prior to disposal: <br /> (1) <br /> (A) Incineration at a permitted medical waste treatment facility in a controlled-air, multi- <br /> chamber incinerator, or other method of incineration approved by the department which provides <br /> complete combustion of the waste into carbonized or mineralized ash. <br /> (B) Treatment with an alternative technology approved pursuant to paragraph(3), which, <br /> due to the extremely high temperatures of treatment in excess of 1300 degrees Fahrenheit, has <br /> received express approval from the department. <br /> (2) Steam sterilization at a permitted medical waste treatment facility or by other sterilization, in <br /> accordance with all of the following operating procedures for steam sterilizers or other sterilization: <br /> (A) Standard written operating procedures shall be established for biological indicators, <br /> or for other indicators of adequate sterilization approved by the department, for each steam <br /> sterilizer, including time,temperature, pressure, type of waste, type of container, closure on <br /> container, pattern of loading, water content, and maximum load quantity. <br /> (B)Recording or indicating thermometers shall be checked during each complete cycle to <br /> ensure the attainment of 121* Centigrade (250* Fahrenheit) for at least one-half hour, depending <br /> 5/7/2014 <br />