CALA News & Views | Issue 49 | Top 5

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Make sure your communities all have active safety committee meetings that meet monthly to review and discuss employee safety and Cal/OSHA compliance. Perform regular walkthrough safety inspections of your communities to ensure that common Cal/OSHA violations are identified and corrected; some examples include: a. Blocked electric panels. b. Blocked or non-compliant emergency eyewash stations (cannot be eyewash bottles and must be able to flush the eyes continuously for 15 minutes). If employees use corrosive cleaning chemicals, then eyewash/emergency showers may be required, based on employee exposure. c. Improper disposal of sharps and/or biohazard waste; make sure sharps containers are not “FULL.” d. Fire extinguishers that are not inspected monthly and/or blocked. 4

5 e. Electrical hazards, such as damaged electrical cords and tools. Make sure your communities contact the home office and/or legal counsel immediately for guidance if there is a Cal/OSHA inspection, serious injury/illness that must be reported to Cal/OSHA or they receive an employee complaint letter from Cal/OSHA.

Senior Living communities must have written workplace violence prevention plans in place by July 1, 2024. Cal/OSHA recently published its model program for workplace violence prevention, along with a “fact sheet” on the new Cal/OSHA requirements to help employers develop their own policies. These resources can be found on Cal/OSHA’s webpage at https://www.dir.ca.gov/dosh/ puborder.asp

BONUS TIP

Hazardous Waste This section contributed by Samir J. Abdelnour, Hanson Bridgett’s Environment, Natural Resources and Land Use practice group CALA members learned more about additional requirements for handling and disposing of hazardous waste during two webinars offered last September. For more information, please visit CALA’s Webinars webpage to access both webinars and handouts, and read on for five tips to help maintain compliance when dealing with hazardous waste.

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Understand the difference between medical waste and hazardous waste If a pharmaceutical waste is classified as “hazardous” under the federal Resource Conservation and Recovery Act (“RCRA”), it must be managed as hazardous waste and cannot be managed as medical waste. This means different rules apply for registration, the types of waste containers that can be used, accumulation time limits and disposal of the wastes. Document your pharmaceutical waste management program Your community should have easily accessible documents that describe how to properly manage medical waste and how to properly manage hazardous waste. These documents should also include lists of commonly encountered pharmaceutical wastes at your facility that fall into each category. Training, training, training! whether each pharmaceutical waste they are handling is a medical waste or a hazardous waste, and the proper procedures for each one. They should also know where at the community they can find documentation and guidelines 2 3 Every employee whose job involves handling pharmaceutical waste should be trained to know

for how to handle each waste, and what to do if they are unsure which category a waste falls into. Good housekeeping matters Make sure waste containers are properly labeled, accumulation time limits are observed and waste management program documentation is readily accessible. When you have all these things in place, it signals to a waste inspector that your facility takes these issues seriously. Work with, not against, your local waste inspector and regulatory agency When an inspector comes to your community, your employees should be trained to be cooperative and respectful. The inspector has a right to be there and do their job. The more they feel like you are working with them to ensure compliance, the more flexibility they will give you to fix issues they identify. Also, when in doubt, reach out and ask for assistance. Your local agency is there to help you maintain compliance, but if they don't think you are making a good effort, they can issue citations and impose fines, or worse, refer you to a prosecutor. 4 5

JANUARY 2010, VOLUME 1 6 CALIFORNIA ASSISTED LIVING ASSOCIATION