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0 - V* ttATE'OF CALIFORNIA—HEALTH AND WELFA DEPARTMENT OF HEALTH SERVICES 714/744 P STREET P.O. BOX 942"2 SACRAMENTO, CA 94234-7320 (916) 327-6901 March 12, 1996 Rob Wangler Safety/Security Coordinator Lodi Memorial Hospital 975 South Fairmont Avenue P.O. Box 3004 Lodi, CA 95241-1908 Dear Mr. Wangler: 71111 1 ;a on 5*010 4,TY TV'ifi5i �4 PETE WILSON, Gownwr I am writing to you in response to your recent request for clarification of medical waste storage requirements as set forth in Section 118280 (old Section 25086) of the California Health and Safety (H&S) Code. In particular, I understand that you require an interpretation of the application of this section as it relates to questions of security and signage. We shall address signage first. The section's reference to "daylight hours" and "natural elements" would imply that outdoor storage was the major thrust of this section as considered by the drafters of the statute. Based on this reasoning, the Department has determined that the 1125 foot" legibility rule applies Dmly to outdoor signs. The issue of storage area security is not quite so free of misinterpretation. It is widely recognized among both State and local enforcement agencies that a storage area under constant supervision by nursing staff, say, close to a nursing station, - need not be secured. The presence of the staff is deemed sufficient security. On the other hand, it is also universally agreed that a storage area located at any great distance from continual supervision ("down the hall and around the corner") must be secured against unauthorized entry. However, it is difficult to mdraw the line," so to speak, beyond which locked security measures are necessary. The Department has determined that, in the intermediate case, the matter should be addressed in the Medical Waste Management Plan and that the facility's relative success in carrying out the conditions of the Plan should govern whether the facility is in compliance.