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Hazardous Waste Management Section ® Corrosivity: A waste with a pH less than or equal to 2 or greater than or equal to 12.5. Expired Tresaderm and Dental Insta-Neg Pre Mix are examples of corrosive wastes. ® Reactivity: A waste that is very unstable and may explode. Banfield hospitals do not generate this type of waste. ® Toxic: Toxic wastes are harmful or fatal when ingested or absorbed (e.g., wastes containing mercury, lead, etc.). When toxic wastes are disposed, the toxic constituents may leach from the waste and pollute groundwater. Certain expired or waste vaccines containing mercury and expired barium sulfate are examples of toxic wastes. ® Listed Wastes: The EPA has developed specific lists of materials which it has determined are hazardous wastes. Two sets of listed wastes (P- and U -lists) are comprised of commercial chemical products, including certain pharmaceutical active ingredients. Waste, damaged or expired pharmaceuticals may be considered hazardous due to the listing of the active ingredient on the P -list or U -list. Expired Mycodex Flea and Tick Shampoo is one example of a U -listed hazardous waste found at Banfield. Banfield has evaluated its waste streams and identified four main categories of wastes, which will be managed separately. Based on estimated quantities of these wastes and in accordance with California's regulations, Banfield Pet Hospitals are small quantity generators (SQG) of hazardous waste, as less than 2,200 pounds (1,000 kilograms) of hazardous waste is generated per month. It is noted that Banfield Pet Hospitals would be classified as Conditionally Exempt SQGs (CESQGs) under federal regulations due to each location generating less than 220 pounds of hazardous waste each month. No acute or extremely hazardous wastes have been identified, which have a smaller generation threshold. Below is a description of the typical hazardous wastes that are generated by this hospital an appropriate storage protocols. All wastes will be stored in labeled, plastic containers provided by the hazardous waste disposal vendor. Only one container for each type of waste should be used and additional pick ups of waste should be requested if containers fill before scheduled pick ups. A. Expired Non -Controlled Pharmaceuticals This waste stream includes all non -controlled pharmaceuticals that have expired or are empty pharmaceutical bottles. The drugs should be in original manufacturer packaging, such as the glass or plastic bottle, dose packs, etc. Expired non -controlled pharmaceuticals may exhibit hazardous waste characteristics of ignitability, corrosivity, or toxicity and/or may be a U -listed waste. Container: A labeled container will be provided for expired or empty non -controlled pharmaceutical containers, which will have a tight fitting lid and be constructed of rigid plastic. The label will be compliant with label requirements, as discussed in Section III.A below, including the contents (expired pharmaceuticals and empty bottles), indication of the hazards associated with the waste (ignitable, toxic, and corrosive), and provide a location for hospital -specific information. Storage: At the time hospital staff conduct an inventory of the pharmacy or otherwise identify that a non -controlled pharmaceutical has expired or a drug container is empty, the pharmaceutical in its container or the empty container should be placed in a Stericycle hazardous waste bag (sealable) and the bag must be labeled with the drug name and/or DNC number. The bag is then placed in the Expired sY 10 Banfield