He seems to be interpreting the very strict interpretation of "....shall be tied...". Does California publish interpretations like OSHA does?
You also might be able to convince him that the "goose-necking" you're doing is more effective. We do that in asbestos removal. Then put the bag in another bag - neck first - and gooseneck the outer bag as well. That would be quite a slow-down for a high throughput operation though.
What about plastic cable (“zip”) ties? You could fold the bag over like you’re doing, and secure it by wrapping the fold with one or more cable ties.
We had a medical waste inspection and nearly got by unscathed. Seems the MW inspector wants us to put a granny knot in the top of the red MW bags. The problem with a granny knot is that we lose a third of the bag volume, and liquid leaks out unless you pull it tight with the strength of Hercules. We're a high throughput operation and as a MW LQG we take out lots of MW bags all day long.
California Medical Waste Act says in Section 118280 (a) - Containment and Storage: "The bags shall be tied to prevent leakage or expulsion of contents during all future storage, handling, or transport."
We gather the top, tightly twist, fold over, and secure with multiple wrappings of autoclave tape. The MW inspector insists on a knot. And we really don't want to do a hearing on this.
Anybody have another suggestion? Maybe something you've tried, like autoclave bag clips? Clamps?
Maybe it's time to invent and market niche device.
Eric Clark, MS, CCHO, CHMM
Safety & Compliance Officer
Los Angeles County Public Health Lab