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SAN J 0 A Q U 1 N Environmental Health Department
<br /> U ; i y 1 Iii AMENDED
<br /> 11/26/2019
<br /> RCRA Large Quantity Hazardous Waste Generator Inspection Report
<br /> Facility Name: Facility Address: Date:
<br /> Banfield Pet Hospital#1188 1 10520 Trinity Pkwy, Stockton November 20, 2019
<br /> SUMMARY OF VIOLATIONS
<br /> (CLASS I,CLASS II,or MINOR-Notice to Comply)
<br /> Item# Remarks
<br /> 407 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 SCO01 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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