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SAKJOANIN COUNTY -- Environmental Health Department SLI -C 11/26/2019 RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: 1 Date: Banfield Pet Hospital #1188 10520 Trinity Pkwy. Stockton November 20, 2019 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 118 CCR 66265.16 Failed to maintain complete hazardous waste training records. OBSERVATION: (A) The business operator could not produce complete documentation during the inspection that demonstrates employees have complete hazardous waste training as specified in this section. 1. According to the Banfield Pet Hospital Waste Management Plan (Version 2.0, December 2018) in the Banfield Pet Hospital Waste Management Binder, hazardous waste training documentation for all facility personnel is to be maintained in Tab 5 of the Waste Management Binder. At the time of inspection, the employee training records found in the Waste Management Binder, stated the names of employees who completed the California Waste Management (2019) and California Waste Management (2017-2018) learning items/training (see photos IMG 9610-2). The following items were missing from the hazardous waste training records: (1) the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; (2) a written job description for each position listed under paragraph (1) of this section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but shall include the requisite skill, education, or other qualifications, and duties of employees assigned to each position; and (3) a written description, including a syllabus and/or outline, of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (1) of this section. (B) At the time of inspection, it could not be demonstrated that employees who handle hazardous waste were properly trained, based on the following observations: 1. When asked by Denise Farias, Shift Leader, how the facility's tono batteries (used in equipment to test for eye glaucoma) are disposed of, Gabby Holdsworth, Registered Veterinary Technician, stated she disposes of the batteries into the trash like she does at home. According to the Banfield Pet Hospital Waste Management Plan, all batteries are to be managed as universal .waste (IMG 9552, 9577). 2. When asked how the facility's expired pharmaceuticals are managed, Denise stated she did not know, since the protocol for managing expired pharmaceuticals recently changed. Denise stated that prior to the change in protocol, expired pharmaceuticals were sent to PS Industries, Inc. via UPS. Denise retrieved a cardboard box from a high shelf near the entrance door. The cardboard box was open, marked with the words "Expired Drugs," storing expired pharmaceutical pills, and was being stored on top of a white container labeled as Hazardous Waste Expired Rx Waste (IMG 9531-5). The white container was storing a bag of loose pills. Denise stated she was holding on to the expired pharmaceuticals in the cardboard box because she did not know how they were supposed to be managed. Denise Called Devina Taylor, the overseeing Practice Manager, to find out how expired pharmaceuticals are to be managed. After speaking to Devina, Denise stated that expired pharmaceuticals are to be placed in a black container and managed as hazardous waste. When asked how long ago the protocol for managing expired pharmaceuticals changed, Denise stated she found out about the protocol change in April of 2019 via an online training. According to the Waste Management Plan, hazardous waste generated by the facility includes, but is not limited to, expired non -controlled pharmaceuticals and hazardous expired controlled substances listed on Appendix A (IMG 9548-86). FA0024355 PR0542389 SCO01 11/20/2019 EHD 22-03 Rev. 9/20/2019 Page 8 of 19 RCRA Large Quantity Hazardous Waste Generator OIR 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com