CALA News & Views | Issue 57 | Impact

(Resource Conservation and Recovery Act) hazardous waste [e.g., Coumadin / Warfarin, Epinephrine, Humalog, Insulin, Nicotine (non-OTC NRTs), Inhalers (if they contain an ignitable propellant)] and CDPH regulates medical waste. Both DTSC and CDPH confirmed that RCFEs are not considered health care facilities and generally do not generate medical waste when disposing of resident-owned medications. Medication disposal for medications stored and taken at the RCFE (which is a residence) are not regulated by the Medical Waste Management Act (CDPH) or federally regulated under RCRA. DTSC only regulates RCRA hazardous waste pharmaceuticals generated by businesses, not households. If the RCFE generates any of their own hazardous waste in the course of operating their business (e.g., hazardous waste generated from the maintenance of an emergency power generator), then that waste would not be household hazardous waste. The waste would be considered “generated in the course of operating a business” and the RCFE would be required to comply with all hazardous waste generator requirements including obtaining a hazardous waste ID number. While DSS works to align medication destruction requirements with current state and federal law, CALA will continue advocating for a more practical, compliant framework that reflects how communities operate today. Until regulations are updated, providers must continue to follow Title 22 § 87465(i) for medication disposal or obtain a waiver for any alternative process. Providers should also be aware that approximately half of counties regulate medical waste at the local level and may have different requirements. You can find a directory for the local enforcement agencies (LEAs)

here to ensure compliance for communities within their jurisdiction.

Securing Key LIC 602A Change Based on feedback from CALA and other stakeholders, DSS revised the LIC 602A to remove language regarding a resident's ability to leave the facility unsupervised due to physical limitations. CALA raised concerns that this question was being interpreted inconsistently and was intended to identify residents at risk of unsafe wandering, not those who use mobility aids such as walkers. The change, found in Question 2h on page 5 of the revised form, helps promote a more accurate and consistent assessment process for residents. Important Clarification on Medication Pre-Pouring Policy In response to concerns raised by CALA and providers regarding inconsistent enforcement, DSS confirmed that staff may temporarily transfer medications to an individual cup or utensil to support resident self-administration and are not required to bring the original medication container to the resident's room. DSS also committed to reinforcing this guidance with LPAs statewide to promote consistent application of policy. This outcome highlights the importance of members sharing real-world compliance challenges with CALA, enabling us to pursue targeted clarifications, improve regulatory consistency and advocate for practical implementation of requirements in the field. Clarification on Reporting Requirements CALA sought clarification from DSS following concerns raised by members after some LPAs interpreted Title 22 § 87211 to require reporting routine hospital visits as unusual incidents. In a written response, DSS confirmed

CALA NEWS & VIEWS I ISSUE 57 | NOVEMBER 2026 12