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975 S. Fairmont Avenue • P.O. Box 3004 • Lodi, California 95241 • 209/334-3411 • 209/368-3745 (fax) <br />January 19, 2000 <br />San Joaquin County Public Health Services <br />Environmental Health Division <br />304 East Weber Avenue, Third Floor <br />Stockton, CA 95202 <br />Attention: Kasey Foley, Lead Senior REHS <br />Re: PHS -EH Log #99-154 <br />Dear Ms. Foley: <br />At your request, this letter is a written report regarding our follow-up investigation of the matter we <br />reported to you on December 29, 1999 regarding a potential incident of improper disposal of a 2.5 ounce <br />container of Steris 20 Sterilant Concentrate ("Steris 20"). <br />Background <br />There are three (3) Steris System sterilizer units in the Lodi Memorial Hospital Surgery Unit. They are <br />used for sterilizing surgical instruments. To operate the unit, a trained employee places a 2.5 ounce can of <br />Steris 20 in the unit. The concentrate feeds automatically during unit operation. Unopened canisters are <br />rarely discarded. However, they are discarded when the product expiration date has passed, or the canister <br />fails a visual quality control check. <br />Steris 20 consists of 35% peroxyacetic acid, CAS 79-21-0. According to the product MSDS, the material <br />in use is non -hazardous and can be discharged to sanitary sewer. The manufacturer instructions <br />recommend disposal of partially empty cans of concentrate by submerging the open can in one foot of <br />water and then discharging the diluted solution to sewer. In response to our inquiry, the manufacturer <br />recommended using the same method for disposing of full cans of Steris 20. <br />On December 29, 1999, an employee of Lodi Memorial Hospital (Employee A) informed us that on <br />November 23, 1999, she observed a co-worker (Employee B) place one unopened, sealed 2.5 ounce <br />container of Steris 20 concentrate into a general trash receptacle in the Surgery Unit of the Hospital. <br />Employee A also informed us that she had made a similar report to the Department of Public Health on <br />December 28, 1999. During your routine survey of our medical waste management systems on December <br />29, 1999, we informed you that we had received Employee A's report that same day and that we would <br />investigate the report and inform you of the results of our investigation and any actions we are taking to <br />assure proper management of outdated Steris 20 containers. <br />Investigation of Employee Report <br />Hospital management interviewed both Employee A and Employee B. Employee A repeated her <br />observation that Employee B had deposited an unopened Steris 20 canister in the general trash receptacle <br />