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Page 3 of 4 <br /> http;//kpnet.kp.org/­­`ehs/`­ <br /> NOTICE TO RECIPIENT: If you are not the intended recipient of this e-mail,you are prohibited from sharing,copying,or otherwise using or disclosing its contents. If <br /> you have received this e-mail in error,please notify the sender immediately by reply e-mail and permanently delete this e-mail and any attachments without reading, <br /> forwarding or saving them. Thank you. <br /> From: Matthew J Huray/MD/KAIPERM <br /> To: alison.dabney@cdph.ca.gov <br /> Date: 07/24/2014 12:42 PM <br /> Subject: Follow-up to our call last week regarding local inspectors interpretation of MWMA <br /> Hi Alison- <br /> Thanks for talking with me on the phone last week, I've got all of the facts. <br /> We are requesting CDHP's guidance regarding our current practice and to determine if we are out of compliance with the <br /> MWMA, before trying to work with the local inspector to allow our current practice to continue or seek additional support from <br /> CDPH. <br /> Our current practice is to manage waste test tubes(plastic and glass)with fluid blood as sharps waste for incineration. The <br /> test tubes are collected in a Stericycle reusable sharps container for commingled medical waste,The practice of collecting the <br /> test tubes as medical waste for incineration in a sharps container has been in place for a few years,there were no citations for <br /> this practice in previous inspections. <br /> We would like to continue the practice of collecting our waste test tubes in a sharps container, is this something we can <br /> continue to do? <br /> Also,we are in the process of working with the local compliance officer to consider changing the treatment technology from <br /> incineration to steam sterilization. <br /> This is the information I got from our local EH&S folks.... <br /> The inspector,did not agree/identify that the test tube with fluid blood was a sharp and as such stated, must be treated like <br /> fluid blood aka "bio-haz"waste.As such, he is states that the blood test tubes must be disposed of in a red biohazardous <br /> bag with the appropriate signage/labels.And specifically cited us on the following: H&S Code 118275(b) Biohazardous <br /> waste,except biohazardous waste as defined in subdivision (g)of Section 117635, shall be placed in a red biohazard bag <br /> conspicuously labeled with the words—Biohazardous Waste or with the international biohazard symbol and the word <br /> —BIOHAZARD. <br /> 8/25/2014 <br />