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12/14/2012 |
Site Inspection |
Compliance Assistance Site Visit; Non-Handler - Compliance Assistance Site Visit; Universal Waste Transporter On December 14, 2012, Day M. Goldsmith And Janine Kraemer, Florida Department Of Environmental Protection (Fdep), Accompanied By Walter Adams, Plant Manager Of Daniels Sharpsmart Inc., Inspected Daniels Sharpsmart Inc. For Compliance With State And Federal Hazardous Waste And Used Oil Regulations.
Daniels Sharpsmart Inc. (Daniels Sharpsmart) Notified In 2012 As A Large Quantity Generator (Lqg) Of Hazardous Waste, A Large Quantity Handler (Lqh) Of Universal Waste (Uw) And Universal Pharmaceutical Waste (Upw), And A Universal Pharmaceutical Waste Transporter. The Facility Has Been At This Location Since 2010 And Employs Approximately Eight People. The Facility Is Connected To The Municipal Drinking Water And Domestic Wastewater Systems.
Inspection History
The Facility Has Never Been Inspected By The Department'S Hazardous Waste Program.
| Daniels Sharpsmart Inc. Was Inspected As A Non-Handler Of Hazardous Waste And A Universal Pharmaceutical Waste Transporter. The Facility Was In Compliance At The Time Of The Inspection. As Of The Date Of Inspection, Daniels Sharpsmart Inc. Has Not Conducted Any Upw Activities. Mr. Adams Was Provided A Copy Of The Universal Pharmaceutical Waste Rules By Email.
| Daniels Sharpsmart Is A Biomedical Waste Treatment Facility Which Is Starting Up Universal Pharmaceutical Waste Transfer And Transporter Services. The Facility Does Not Generate Any Hazardous Waste As Of The Time Of Inspection.
Inspection Narrative
The Inspection Began In The Biomedical Waste Treatment Area. The Facility Treats Biomedical Waste On-Site Using Steam Autoclaving. The Facility Does Not Treat Hazardous Waste Or Universal Pharmaceutical Waste. The Facility Has Not Begun Any Universal Pharmaceutical Activities And Does Not Have An Off-Site Upw Treatment Facility Established Yet. The Facility Will Transport Upw From Medical Facilities To The Facility, Repackage The Upw, And Transport It Out To A Treatment Facility. The Facility Will Only Be Disposing Of Upw And Will Not Be Taking Laboratory Waste From Facilities.
Mr. Adams Verified That The Facility Is Not Generating Any Hazardous Waste At This Time And Will Not Be Generating Hazardous Waste Once The Upw Activities Are Started. The Inspectors Sent Mr. Adams A Notification Form (Dep 8700), So That The Facility Can Remove The Lqg Status From Its Notification. As Of The Date Of This Report, No Updated Notification Has Been Received By The Department. | Daniels Sharpsmarts Casv | Daniels Sharpsmarts Casv |
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09/13/2018 |
Site Inspection |
Routine; Transporter On 09/13/2018, Edward Rysak And Kaelyn Malone, Florida Department Of Environmental Protection (Fdep, Department), Accompanied By Walter Adams, General Manager, Inspected Daniels Sharpsmart Inc For Compliance With State And Federal Hazardous Waste And Universal Waste Regulations. The Facility Originally Notified The Department Of Its Waste Activities And Was Issued Epa Id Fld984171850 On 11/30/2012. The Facility Most Recently Re-Notified Of Its Waste Activities And The Same Epa Id Number Was Re-Issued On 03/05/2018.
The Facility Has Been At This Location Since March 2010 And Currently Employs Only Two Workers That Are Involved With The Universal Pharmaceutical Waste Handling Process. Plant Operating Hours Are 4:00 Am – 9:00 Pm, Monday Through Friday. The Facility Is Closed On Weekends. The Facility Is Connected To The Municipal Wastewater Collection And Potable Water Systems. The Property Is Owned By Sbj Resch, Located At 2900 East 7th Ave, Ste 200, Tampa, Fl 33605.
Inspection History
The Facility Was Most Recently Inspected By The Department For Compliance With State And Federal Hazardous Waste And Universal Waste Regulations On 12/14/2012. No Violations Were Noted During This Inspection. | Daniels Sharpsmart Is A Biomedical Waste Management Facility Which Also Conducts Universal Pharmaceutical Waste (Upw) Transfer And Transportation Services. The Facility Takes In Upw From Medical Facilities, Repackages The Upw, And Transports It To A Treatment Facility For Incineration. All Incoming Biomedical And Upw Wastes Are Sorted Immediately Upon Entering The Facility And Managed In Separate Areas. A Digital Inventory System Is Used For Tracking Both Biomedical And Upw Wastes. A Scale Is Used To Keep Track Of The Total Volume Of Wastes Passing Through The Facility. Only Biomedical And Upw Wastes Are Managed At The Facility As Of The Date Of The Inspection.
Biomedical Waste And Upw Are Brought To The Facility In Either Disposable Containers Or Lined Reusable Containers. The Liners Are Thick, Transparent Plastic Bags. The Bags Are Tied/Sealed Closed With A Zip Tie And Removed From The Containers. If The Bags’ Contents Appear To Have Any Liquid Components, The Bags And All Contents Are Placed Into 55-Gallon Poly Drums. If The Bags’ Contents Are Solid Only, The Bags And All Contents Are Placed Into Lined, Triple-Walled Cubic Yard Fiberboard Boxes. The Drums And Cubic Yard Boxes Are Labeled With A Start Date Of Waste Accumulation, The Words “Universal Pharmaceutical Waste,” Dot Hazard Indication Placards, And Secured To Pallets For Shipment Offsite. No Issues Were Noted With Any Of The Containers In The Upw Waste Accumulation Area.
According To Mr. Adams, The Contents Of The Liner Bags Are Not Removed And The Bags Are Not Opened Once They Are Sealed And Removed From Their Original Reusable Waste Containers. The Reusable Containers Are Wiped Down With Bleach And/Or A Biocide Disinfectant And The Wipes Are Packaged With The Upw For Disposal. The Disinfectants Being Used At The Time Of Inspection Had A Ph Of 2.4 – 2.7 Standard Units And 11.4 Standard Units According To The Products' Safety Data Sheets, Which Were Available Onsite For Review During The Inspection. Disposable Containers And Their Contents Are Simply Logged, Weighed, Labeled, Then Stacked And Secured On Pallets To Be Sent Offsite For Incineration Similar To The Reusable Container Packaging Process.
Records
Logs Of The Inventory System For Tracking The Total Waste Transfer Volume Are Maintained Onsite And Were Available For Review. Uniform Hazardous Waste Manifests Were Also Available For Review And No Issues Were Noted. The Facility’S Waste Transporter Is Freehold Cartage And The Destination Facility Is Heritage Thermal Services, Inc, Located At 1250 Saint George Street, Unit 1, East Liverpool, Oh 43920-3461, As Of The Date Of The Inspection. The Facility’S Annual Universal Waste Handler Registration Was Most Recently Issued On 02/16/2018 And A Copy |
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04/07/2020 |
Site Inspection |
File Review; Hazardous Waste Transfer Facility On April 7, 2020, The Department Notified Representatives Of Daniel’S Sharpsmart Of A Planned Rcra Compliance Evaluation Inspection Scheduled For Daniel’S Sharpsmart, Inc. Located At 10705 Rocket Blvd, Ste 111, Orlando, Florida. The Advanced Notice Was Provided To The Facility Due To Potential Health Concerns Related To The Covid-19 Virus. Following The Inspection Notice, John White, Florida Department Of Environmental Protection (Fdep Or Department), Was Contacted By Alan Larosee, Director Of Compliance For Daniel’S Health, Owner Of The Facility. Due To Facility Personnel Health Concerns And The Inability To Maintain Social Distancing During The Inspection, Mr. Larosee Asked If The Physical Inspection Of The Facility Could Be Delayed To A Future Date And Paperwork Be Reviewed Now. Because The Majority Of The Waste And Associated Paperwork Managed By This Facility Originates At Hospitals The Department Agreed With The Request.
Daniel’S Sharpsmart Initially Notified The Department As A Hazardous Waste Transporter On October 5, 2012 And Completed The Registration Process On December 12, 2012. The Facility Last Notified As A Hazardous Waste Transporter And Transfer Facility On August 20, 2019. The Facility’S Status Was Acknowledged By The Department On August 22, 2019. The Facility Has Provided Documentation That The Transfer Facility Location Meets The Hazardous Waste Facility Siting Requirements Of 403.7211, Florida Statutes Per The Requirements In Florida Administrative Code (F.A.C.) 62-730.171(3)(A)(1).
The Inspection Was Prompted By The Department’S Receipt Of Three Manifest Discrepancy Reports For Hazardous Waste Managed By The Facility, One In February And Two In March 2020. Daniel’S Sharpsmart Was Last Inspected On September 13, 2018 As A Hazardous Waste Transporter For Compliance With State And Federal Hazardous Waste Regulations And No Violations Were Cited At That Time. | Daniel’S Sharpsmart Is A Hazardous Waste Transporter And 10-Day Transfer Facility And A Regulated Medical Waste Transporter.
Information Requested On April 7, 2020, Was Provided That Same Day By Kyle Little, Compliance & Safety Manager For Daniel’S Health. The Following Information Was Requested:
1. A Copy Of The Closure Plan Required By F.A.C. 62-730.171(3)(A)(5). The Purpose Of The Plan Is To Document How The Facility Will Verify No Contamination Is Present, Or Remains, On-Site Following Closure Of The Facility.
2. A Copy Of The Contingency Plan Required By F.A.C. 62-730.171(3)(A)(6).
3. A Map Of The Transfer Facility Meeting The Requirements Of F.A.C. 62-730.171(3)(A)(7).
4. A Copy Of The 10-Day Transfer Facility Log Meeting The Requirements Of F.A.C. 62-730.171(6). The Purpose Of The Log Is To Document When Each Waste Shipment Is Received On-Site And When The Waste Is Removed From The Property For Continuation On To The Destination Facility.
5. Documentation Of Personnel Training As Required By F.A.C. 62-730.171(4)(A) For Hazardous Waste Management Activities.
In Accordance With F.A.C. 62-730.171(3)(A)(5), A Closure Plan Is Required For The 10-Day Hazardous Waste Transfer Facility Demonstrating That The Transfer Facility Will Be Closed In A Manner Which Satisfies The Closure Performance, Notification, And Decontamination Standards Of 40 Cfr 265.111, 265.112, 265.114 And 265.115. The Closure Plan Provided On April 7, 2020 Was Determined To Meet The Requirements Identified In F.A.C. 62-730.171(3)(A)(5).
Review Of The Document Identified As A Contingency Plan, Dated January 2020, Found The Document Did Not Meet Any Of The Requirements For A Hazardous Waste Contingency Plan Identified In 40 Cfr Part 265 Subpart D. The Plan Provided Appeared To Be A Contingency Plan Related To Business Operations, Not Emergency Operations. This Information Was Relayed To Daniel’S Sharpsmart In An Email Dated April 29, 2020. On May 14, 2020, The Facility Provided A Copy Of The Actual Contingency Plan, Dated August 10, 2019. During Review Of The Contingency Pla |
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10/19/2020 |
Significant Noncompiler Penalty Authorization |
Generated-06/16/2020 ; Forwarded for Review-06/16/2020 ; Approved-10/08/2020 ; Finished-10/19/2020 |
188372 |
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11/02/2020 |
Warning Letter |
Drafted-06/16/2020 ; Forwarded for Review-06/19/2020 ; Approved-10/08/2020 ; Sent-11/02/2020 ; Finished-11/02/2020 |
188372 |
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12/14/2020 |
Submittal Received By Department |
Received-11/30/2020 ; Finished-12/14/2020 |
188372 |
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12/14/2020 |
Electronic Communication |
Finished-12/14/2020 |
188372 |
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01/14/2021 |
Short Form Consent Order |
Drafted-01/08/2021 ; Issued-01/11/2021 ; Executed-01/14/2021 ; Finished-02/10/2021 |
188372 |
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03/29/2021 |
Enforcement Tracking |
Finished-03/29/2021 |
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06/30/2022 |
Site Inspection |
Routine; Transfer Facility - Routine; Transporter On June 30, 2022, Michael Eckoff, Florida Department Of Environmental Protection (Fdep Or Department), Accompanied By Charles Rivera, Jr., Daniels Health, Inspected Daniels Sharpsmart, Inc. (Daniels Or Facility) For Compliance With State And Federal Hazardous Waste Transporter And Transfer Facility Regulations. The Facility Most Recently Notified The Department Of Its Waste Activities On January 17, 2022 And Was Originally Issued Epa Identification Number Fld984171850 On November 30, 2012.
Daniels Is Currently Registered As A Transporter Of Universal Waste Lamps And Devices, A Transfer Facility For Universal Waste Lamps, And A Transfer Facility For Universal Waste Devices. The Registration Expires On March 1, 2023. Daniels Is Also Registered As A Hazardous Waste Transporter. The Registration Expires On November 30, 2022. Liability Insurance Is Current Until September 30, 2022.
Inspection History (Past Five Years)
The Facility Was Inspected By The Department In April 2020 For Compliance With State And Federal Hazardous Waste Transportation Regulations. The Facility Was Out Of Compliance For Storing Hazardous Waste For Greater Than Ten Days, Accepting Hazardous Waste Without A Complete Manifest, Transporting Hazardous Waste Without A Manifest, Failure To Maintain A Complete Contingency Plan, Changing Information On Manifests After The Generator Signed The Manifest, And Failure To Maintain A Complete 10-Day Transfer Facility Log. The Case Was Resolved Through Issuance Of A Short Form Consent Order Assessing $5,120 In Civil Penalties And $500 In Department Costs.
The Facility Was Inspected By The Department In September 2018 For Compliance With State And Federal Hazardous Waste Transportation Regulations. No Potential Violations Were Noted At That Time. | Daniels Sharpsmart, Inc. Was Inspected As A Hazardous Waste Transporter And Transfer Facility And Was Not In Compliance At That Time. | Daniels Is A Hazardous Waste Transporter And 10-Day Transfer Facility And A Regulated Medical Waste Transporter.
Ninety-Nine Containers Of Hazardous Waste Pharmaceuticals Were Located In The 10-Day Transfer Facility. All Containers Were Being Properly Managed And Have Been In The 10-Day Transfer Facility For Less Than Ten Days.
Records
The Contingency Plan Was Dated August 2021. Charles Rivera, Jr. Is Listed As The Emergency Coordinator. The Facility Map Was Included In The Contingency Plan.
Review Of The 10-Day Transfer Facility Log Did Not Reveal Any Issues. All Information Required By Rule 62-730.171(6), Florida Administrative Code (F.A.C.), Appeared To Be Documented In The Log. The Containers Listed On The Log Were Present In The 10-Day Transfer Facility.
Review Of The Manifests For Transportation Services Revealed Daniels Is Using Epa Identification Number Ilr000169029. Epa Identification Number Ilr000169029 Is Not Registered In The State Of Florida For Transporting Hazardous Waste Nor Has Daniels Demonstrated Proof Of Liability Insurance [62-730.170(2)(A) And (F), F.A.C.].
Review Of Personnel Training Documentation Did Not Reveal Any Issues.
The Closure Plan Was Not Dated. |
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08/30/2022 |
Warning Letter |
Sent-08/30/2022 ; Finished-12/02/2022 |
193819 |
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10/11/2022 |
Meeting |
Finished-10/11/2022 |
193819 |
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05/01/2023 |
Short Form Consent Order |
Executed-05/01/2023 ; Finished-05/31/2023 |
193819 |
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05/31/2023 |
Enforcement Tracking |
Finished-05/31/2023 |
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05/31/2023 |
Letter |
Finished-05/31/2023 |
193819 |