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V CVSHealth Ms. Florido November 2, 2018 Page 4 list of flagged "hazardous" items is updated on a daily basis. When a store colleague scans a flagged item and answers certain questions about the condition of the item, the RF unit instructs the colleague to place the item in a Stericycle sealed bag and into a hazardous waste tote for later collection. By using programmable scan guns to process unsaleable items at the store level, CVS can control the manner in which these items are disposed. The RF unit is used by stores on a daily basis to scan items in and out of inventory. As part of its overall Hazardous Waste Management Program, CVS programmed the RF unit with logic that allows store-level colleagues to process unsaleable items or "damages" (a generic term used to describe all unsaleable merchandise regardless of the reason, including customer returns,broken items,product withdrawals or recalls, etc.). Using the "damages" logic, the RF unit asks the colleague a series of questions about the condition of the product. For example, one question is "is the item broken, leaking, or partially full?" If the answer to this question is "yes,"then the item is a"solid waste." Your Report mentions that a"Tell Me Your Wish Lucky Ariul"hand cream was found in the flammable hazardous waste tote. Your Report noted that when asked about this item, the store manager indicated that he was unsure how to inquire about the final disposition direction given by the scan gun. Store colleagues are provided with resources, including hazardous waste posters and final disposition guidance in the hazardous waste storage areas which directs colleagues to call the Environmental Hotline if they have questions pertaining to the retail hazardous waste program. Additional training on these resources has been provided to store personnel, to ensure that questions pertaining to final disposition direction on the scan units are directed to the Corporate Environmental Team via the Environmental Hotline. Unsalable Items Processing As background, CVS's California hazardous waste management program requires front store retail colleagues to process unsaleable items (often referred to "damages"at the store level) daily. To determine whether an item is a waste, each item must be scanned using the RF Unit. Based on the condition of the item and RF Unit coding, which is programmed to identify items that are hazardous when they become wastes, disposition direction is provided to the store colleague. Based upon the disposition direction, items could be sent to a reverse logistics partner for donation/liquidation,placed into the dumpster(if determined to be non-hazardous/non- regulated waste), or placed into the appropriate hazardous waste tote (this process is described in further detail below). Unsaleable items awaiting processing have not been determined to be a waste and may be eligible for resale, liquidation or donation. Because unprocessed items could be returned to the sale floor, liquidated, or donated, they are not waste and thus also not a hazardous waste (and therefore not stored in labeled hazardous waste containers). If an item is determined to be hazardous waste,the RF Unit provides direction to store colleagues to bag the item into a self-sealing hazardous waste bag and place into the appropriate hazardous waste container. There is a separate tote for each of the following: Flammables, Flammable Aerosols and Combustibles; Corrosive Acids; Corrosive Bases; Oxidizers; Toxics& M pharmacy/ caremark /minute clinic / specialty