I’ve had inspectors read into regulations before. But, this is the first time that I’ve heard an inspector require a certain knot. Does anyone on the list have any information regarding:
a. A specific closure device being required for MIW?
b. Testing or comparison of the closure method specified below?
c. How many of us are requiring a very similar closure method?
I believe DOT has very similar, if not identical language, for the shipping biological/infectious substances. If a shipping container passes equivalent federal testing requirements and obtains DOT certification, shouldn’t that closure method be acceptable to meet the same regulatory language requirement from CA? Maybe the time spent in a one to two hour hearing would be well worth the cost, considering the added expenses of a change of method, cost of an additional closure device or the increase cost in employee hours to comply with?
P.S. At the very least, the MW inspector will be assured that you have considered various options, considered/chosen the most effective, can justify the action/results and may even learn that there is more than one way to perform a task to meet compliance.
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
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