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I <br />Rob Wangler <br />Page 2 <br />March 12, 1996 <br />One component upon which the feasibility of the Plan might rely <br />would be the general site security program. In deferring to <br />security professionals those aspects of waste -stream control <br />which would derive from a well implemented security program, the <br />enforcement agency would be required only to judge whether the <br />security measures have been successful, not whether they are <br />likely to be. <br />The security plan would then become of necessity an integral part <br />of the medical waste management plan; the (agreed-upon) standards <br />for successful implementation, a criterion upon which an <br />evaluation could be based. Such a strategy lifts from the <br />enforcement agency the burden of "enforcement by conjecture" as <br />well as the potential liability which might attach to under - <br />enforcement. In exchange for a modicum of regulatory latitude, <br />the generator appropriately takes on the responsibility for <br />securing medical waste in accordance with the intent of the law. <br />We are confident that this interpretation will satisfy <br />enforcement agencies and generators alike. Should you have any <br />questions, I may be reached at the telephone number listed above. <br />c: Kasey Foley, R.E.H.S. <br />San Joaquin Co. EHD <br />Sincerely, <br />il�� —�_ Ccf,�— <br />Michael Schott, R.E.H.S., M.P.H. <br />Environmental Specialist III <br />