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SAN JOAQUIN
<br />1W-1
<br />Environmental Health Department
<br />AMExDFM
<br />11/26/2019
<br />RCRA Large Quantity Hazardous Waste Generator Inspection Report
<br />Facility Name:
<br />Facility Address:Date:
<br />Banfield Pet Hospital #1188
<br />10520 Trinity Pkwy, Stockton
<br />November 20, 2019
<br />SUMMARY OF VIOLATIONS
<br />(CLASS I, CLASS II, or MINOR - Notice to Comply)
<br />Item #
<br />Remarks
<br />407
<br />CCR 66265.17(b), 66265.177 Failed to manage incompatible wastes in containers properly.
<br />OBSERVATION: The following incompatible wastes are stored in way that is not in compliance with these sections:
<br />1. A black container, about half filled with what appeared to be liquid pharmaceutical bottles and vaccine vials, was
<br />observed, on the floor next to a sink, with a blank Hazardous Waste label on top of the container lid and not affixed
<br />to the container (IMG 9521-23). According to Denise Farias, Shift Leader, the waste in this container is picked up
<br />by the hazardous waste hauler, Stericycle. According to the Banfield Pet Hospital Waste Management Plan,
<br />expired non -controlled pharmaceuticals & empty liquid pharmaceutical containers, including vaccine vials, are to be
<br />placed in one container and managed as hazardous waste (IMG 9548, 9551-6, 9567-9). The Waste Management
<br />Plan, states, "Expired non -controlled pharmaceuticals may exhibit hazardous waste characteristics of ignitability,
<br />corrosivity, and/or toxicity." The hazardous waste in the black container was not characterized or placed in separate
<br />containment based on hazard (i.e. ignitable, corrosive, or toxic).
<br />2. An open cardboard box, marked with the words "Expired Drugs," and storing expired pharmaceuticals,
<br />according to Denise, was observed near the facility entrance door, on a high shelf, and directly on top of the white
<br />container labeled as Hazardous Waste Expired Rx Waste. Denise retrieved the cardboard box from the shelf for
<br />further observation (IMG 9531). According to the Waste Management Plan, expired non -controlled
<br />pharmaceuticals and hazardous expired controlled pharmaceuticals (included on the list in Appendix A), are to be
<br />managed as hazardous waste (IMG 9567-70). The Waste Management Plan states, "Expired non -controlled
<br />pharmaceuticals may exhibit hazardous waste characteristics of ignitability, corrosivity, and/or toxicity" and
<br />hazardous expired controlled pharmaceuticals are to be labeled with "an indication of hazards associated with the
<br />waste." The hazardous waste in the cardboard box was not characterized or placed in separate containment based
<br />on hazard (i.e. ignitable, corrosive, or toxic).
<br />3. A white container, storing at least two plastic bags of used absorbent, was observed on a counter near the sink
<br />(IMG 9524-5). According to Denise and the Waste Management Plan, waste propofol and expired or waste liquid
<br />pharmaceuticals are poured into a plastic bag containing absorbent, to allow the liquid to absorb into the
<br />absorbent, which is then placed into the white container to be picked up by Stericycle (IMG 9570-1). The Waste
<br />Management Plan states, "Waste pharmaceuticals may have any of the hazardous characteristics of ignitability,
<br />corrosivity, and/or toxicity." The hazardous waste in the white container was not characterized or placed in separate
<br />containment based on hazard (i.e. ignitable, corrosive, or toxic).
<br />The Banfield Pet Hospital Waste Management Plan does not include instructions for employees to segregate
<br />wastes based on incompatibility or hazard. It is unknown if the pharmaceuticals observed in the containers, listed
<br />above, are potentially incompatible and should be segregated in order to prevent a reaction.
<br />REGULATION GUIDANCE:
<br />Incompatible wastes, or incompatible wastes and materials shall not be placed in the same container, unless
<br />section 66265.17(b) is complied with.
<br />(b) Hazardous waste shall not be placed in an unwashed container that previously held an incompatible waste or
<br />material.
<br />(c) A container holding a hazardous waste that is incompatible with any waste or other materials transferred or
<br />stored nearby in other containers, or open tanks, shall be separated from the other materials or protected from
<br />them by means of a dike, berm, wall, or other device.
<br />FA0024355 PR0542389 SC001 11/20/2019
<br />EHD 22-03 Rev. 9/20/2019 Page 15 of 19 RCRA Large Quantity Hazardous Waste Generator OIR
<br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com
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