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on November 23, 1999.1 Employee B has no recollection of doing so. However, she did state that if she were to dispose of an unopened container of Steris 20, she would place it in a red biohazard bag, and she believes that she has done so 3 or 4 times during her 4-1/2 years of employment at the Hospital. We were not able to identify any other hospital personnel with personal knowledge of the incident reported by Employee A. Employee B is the primary user of the Steris equipment in the Surgery Unit. Our investigation did not reveal any other incidents of potentially inappropriate disposal of Steris 20 containers. In conclusion, we cannot confirm Employee A's report that one (1) unopened Steris 20 sterilant concentrate was deposited in a general trash receptacle. We believe, however, that Employee A may have deposited unopened cans of Steris 20 in red biohazard bags on 3 or 4 occasions in the last several years. Follow-up Actions Our education file for Employee B indicates that she has attended orientation and training on the Steris equipment and has current competency in the use of Steris equipment. Her most recent training on the Steris machines was on October 27, 1999. Hospital management has confirmed that Employee B understands the proper method of disposal of the Steris 20 concentrate, as recommended by the manufacturer. Hospital management has admonished her to follow the proper procedure, and she has confirmed that she will do so. We have inspected and confirmed that notices from the Steris operator manual are posted near each of the three Steris units in the Surgery Unit. We have instituted measures to assure that all employees using the Steris machines have been trained and are competent in the safe disposal of Steris 20 concentrate and cleaning solution and the use of personal protective equipment (PPE). Material Safety Data Sheets (MSDS) are available in the unit for Steris 20 concentrate. Finally, we have retained an independent consultant to assist us in developing operating procedures for the safe disposal of all solutions used in the cleaning and disinfecting of medical instruments at the Hospital. We trust this information is sufficient for your purposes. Should you require anything further, please do not hesitate to contact the undersigned. Very truly yours, Lodi Memorial Hospital Kenneth P. Wood, ARM, AIS, CPHQ Manager, Risk Management I We note that in the Notification of Hazardous Waste Discharge, PHS -EH Log # 99.154, you state that "apparently, product was disposed of into dumpster." However, Employee A reports that she observed Employee B deposit the unopened Steris 20 container into a general trash receptacle. Each receptacle holds trash in a white plastic bag, which is closed and sealed before subsequent deposition into a dumpster.