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*DAMERbN HOSPITAL ASSOCIATION <br />525 WEST ACACIA STREET <br />STOCKTON. CALIFORNIA <br />95102 <br />June 28, 1985 <br />Department of Health Services <br />Licensing and Certification <br />Mr. Jack Drury, District Administrator <br />2422 Arden Way <br />Building B., Suite 35 <br />Sacramento, CA 95825 <br />RE: Infectious Waste Regulations: Title 22, Chapter 30, <br />Article 13, Section: 66840f <br />"Infectious waste, except for sharps capable of puncturing <br />or cutting, shall be contained in double disposable plastic bags <br />which are impervious to moisture and have a strength ---- <br />We respectfully request program flexibility from the <br />requirement for double plastic bags. Our request is based on <br />the Center for Disease Control publication "Guidelines for <br />Isolations in Hospitals 1983 (attached), which states "--- <br />a single bag is probably adequate if the bag is impervious and <br />sturdy and if the article can be placed in the bag without <br />contaminating the outside of the bag, otherwise double bags <br />should be used." <br />Our plan to use single bags is as follows: <br />1. The bag is certified by the manufactures to be impervious <br />and to pass the dropped dart test as specified in section <br />66840f. <br />2. The bag will be held open by suspending it from a frame - <br />type hamper (illustration attached). This enables personnel <br />to place wastes in the bag without contaminating the <br />outside. <br />3. The bags will be tied off and removed by specially <br />trained members of the housekeeping staff. These employees <br />will be gowned and gloved. <br />4. Infectious waste will be picked up separately from all <br />other waste, transported in a specially designated cart <br />used only for that purpose, and taken directly to the <br />appropriate receptacle outside the hospital. The cart <br />will then be cleaned. <br />5. All personnel will receive instructions to use extreme <br />caution when placing infectious waste into these bags. <br />We feel that this technique will be a considerable cost savings <br />to the hospital with no added infectious risk to personnel, patients <br />or the environment. <br />J L : j s <br />enclosure <br />Yours truly, <br />-- — <br />JoAnne Lamm, RN <br />Infection Control Nurse <br />