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RESPONSE TO DEFICIENCY # 78 <br /> As a result of the SJC Environmental Health Department inspection completed <br /> June 28, 2007, we have the following response to deficiency#78. We will <br /> education our staff regarding the Universal Waste Rules to simplify how we <br /> manage many common hazardous wastes. We will use the Department of Toxic <br /> Substances Control (DTSC) fact sheet to provide this information about these <br /> laws. And later this year we will add this information on our Healthstream <br /> interactive educational training site for SJMC employees. As well as update our <br /> 9.03 hazardous Material Communication Policy. (Attached) <br /> We will instruct our employees that Universal wastes are hazardous wastes that <br /> are more common and pose a lower risk to staff and the environment than other <br /> hazardous wastes. Federal and State regulations identify universal wastes and <br /> provide simple rules for handling, recycling, and disposing of them. <br /> The regulations, called the "Universal Waste Rule," are in the California Code of <br /> Regulations, title 22, division 4.5, chapter 23. All citations in this fact sheet refer <br /> to the California Code of Regulations, title 22, division 4.5, unless otherwise <br /> indicated. All universal wastes are hazardous wastes and, without the new rules, <br /> they would have to be managed under the same stringent standards as other <br /> hazardous wastes. Also, universal wastes are generated by a wide variety of <br /> people rather than by the industrial businesses that primarily generate other <br /> hazardous wastes. <br /> We will instruct staff on where we may send universal wastes. Many universal <br /> wastes must be recycled. We must send the universal wastes listed below <br /> directly to an authorized recycling facility or to a universal waste consolidator for <br /> shipment to an authorized recycling facility. <br /> Universal wastes that must be recycled: <br /> lamps <br /> mercury switches <br /> mercury thermometers <br /> mercury gauges <br /> dialators and weighted tubing <br /> gas flow regulators <br /> counterweights and dampers <br /> cathode ray tubes (TV and computer glass) <br /> If we do not recycle these wastes, then you must manage them as hazardous <br /> waste rather than as universal waste. This includes notifying DTSC, using a <br /> manifest and a registered hazardous waste hauler, complying with shorter <br /> accumulation times, and shipping only to an authorized destination facility. <br />