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Environmental Health Department <br />AMENDED <br />4/8/2020 <br />RCRA Large Quantity Hazardous Waste Generator Inspection Report <br />Date: <br />March 10, 2020 <br /> Facility Address: <br /> 1777 W YOSEMITE AVE, MANTECA <br /> Facility Name: <br /> KAISER FOUNDATION - MANTECA <br />SUMMARY OF VIOLATIONS <br />(CLASS I, CLASS II, or MINOR - Notice to Comply) <br />RemarksItem # <br /> 102 CCR 66262.11 Failed to determine if a waste is a hazardous waste. <br />OBSERVATIONS: <br />1. According to Deanne Smith, Sterile Processing Manager, 3M steam indicator tape, which she is told is lead-free, <br />is used in steam autoclaves. However, Tonia Shaw, Safety Operations Leader, provided the SDS for the 3M <br />Comply Steam Indicator Tape, which states the tape contains lead carbonate hydroxide. It is unclear how this tape <br />is managed after it has been used. <br />REGULATION GUIDANCE: Any person who generates a waste shall determine if the waste is a hazardous waste <br />as specified in Title 22 California Code of Regulations (CCR). There are wastes that are listed as hazardous <br />wastes. There are wastes that exhibit one or more of the hazardous waste characteristics: toxic, corrosive, reactive <br />or ignitable. <br />CORRECTIVE ACTION: Immediately make a hazardous waste determination for the tape containing lead <br />carbonate hydroxide, and manage it according to Title 22 CCR. Use Safety Data Sheets (SDS), waste sampling <br />and test results or other knowledge to support your hazardous waste determination. Waste testing must be done <br />using methods specified in Title 22 CCR including sections 66261.20-24. <br />Submit a statement and supporting documentation with your hazardous waste determination. Demonstrate current <br />storage and labeling for wastes determined to be hazardous wastes. Provide disposal records for wastes <br />determined to be hazardous wastes and stored longer than the number of days specified in Title 22 CCR for your <br />hazardous waste generator status. <br />This is a repeat violation, Class II. <br />FA0003978 PR0543628 SC001 03/10/2020 <br />EHD 22-03 Rev. 9/20/2019 RCRA Large Quantity Hazardous Waste Generator OIRPage 5 of 10 <br />1868 E. Hazelton Avenue | Stockton, California 95205 | T 209 468-3420 | F 209 464-0138 | www.sjcehd.com