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V CVSHealth Ms. Florido November 2, 2018 Page 6 training modules available via our web-based training system, LEARNet. Colleagues are assigned training modules according to the scope of his or her job responsibility. Training records are maintained online as well, and should be accessible by each store employee. We have obtained a consolidated training record for Store 3908, which is included here for your review. On October 10, 2018 Chris Yerzy, CVS Health Environmental Specialists retrained store colleagues at this location on the hazardous waste program, including the importance of placing bagged hazardous waste items into the correct hazardous waste totes in a timely manner, processing unsaleables/damages daily, properly bagging leaking items, labeling correctly hazardous waste totes, and using only hazardous waste totes to store processed hazardous waste items. Please note that the in person training performed by Mr. Yerzy is not recorded in the consolidated records since we consider it to be supplemental of the annually required hazardous waste training. Attached please photo documentation of the hazardous waste area, showing processed unsaleable items processed and properly segregated into labeled hazardous waste totes. Reverse Distribution of Non Dispensable Pharmaceuticals Your items#201 and#203 relate to sending non-dispensable potentially creditworthy pharmaceuticals to Genco a FedEx company ("Genco"). Specifically, you observed documentation indicating that nine 10 mg tablets of Warfarin Sodium were sent to Genco. To address your concern we believe that a general overview of CVS's reverse distribution process is beneficial. Genco is an out-of-state reverse distributor licensed for the receipt of dangerous drugs by the California State Board of Pharmacy as provided under Health and Safety Code section I I7690(b)(3)(A). Genco evaluates non-leaking, recalled and potentially creditworthy pharmaceuticals in original manufacturer packaging that can no longer be dispensed("non- dispensable pharmaceuticals") products on CVS's behalf to assess and issue manufacturer credit. Importantly, your Inspection Report noted that"Genco does not have a permit from the DTSC to received hazardous waste." It's important to note that pharmaceuticals sent to Genco are considered product, not waste. Upon receipt of a shipment from a CVS store, Genco uses an extensive and ever-changing database to evaluate the pharmaceuticals received to evaluate and process credit. Once Genco makes a credit determination, Genco handles the pharmaceutical in accordance with manufacturer instruction. Non-creditworthy prescription pharmaceuticals are managed at the store level as hazardous waste, shipped via a licensed hazardous waste transporter, and ultimately disposed at a licensed facility. Importantly, at the store-level, store colleagues are unaware of whether specific non-dispensable pharmaceuticals will ultimately receive manufacturer credit. IT systems used to process pharmaceuticals for return to reverse distributors varies among retailers and, as a result, visibility to records varies at the pharmacy level. Whether a manufacturer issues credit for a given non-dispensable pharmaceutical varies depending on various criteria, and thus the same pharmaceutical may be issued manufacturer credit for one shipment, and denied credit for the same pharmaceutical the following shipment. This highlights the benefit of using a third-party pharmaceutical reverse distributor. Retailers contract with reverse distributors to handle this �/$ pharmacy/caremark / minute clinic /specialty