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AMY P. MCMORROW <br />404.885.3267 telephone <br />404.962.6624 facsimile <br />amy.mcmorrow@troutmansanders.com <br />October 3, 2011 <br />Ms. Michelle Henry <br />San Joaquin County Environmental Health Department <br />600 East Main Street <br />Stockton, CA 95202-3029 <br />(209) 468-3420 <br />TROUTMAN SANDERS LLP <br />Attorneys at Law <br />Bank of America Plaza <br />600 Peachtree Street, NE, Suite 5200 <br />Atlanta, GA 30308-2216 <br />404.885.3000 telephone <br />troutmansanders.com <br />!• i <br />Re: Hazardous Waste Program Inspection Report Issued to CVS/pharmacy <br />Store No. 3908 (Inspected June 30, 2011). <br />Dear Ms. Henry: <br />As you are aware, our firm represents CVS Pharmacy, Inc. (CVS) with respect to <br />environmental compliance issues that arise at its stores in California. This letter responds to the <br />Inspection Report and Notice to Comply issued to CVS Store 3908 on September 2, 2011. <br />As to Violation number 7, regarding the timeliness with which damaged products are <br />characterized and processed and the return of such products to the distribution center, CVS's <br />current program requires store personnel to engage in a waste determination prior to sending <br />damaged/leaking items, customer returns, expired products, etc. to the Distribution Center. <br />While the StrongPak technicians provide an additional layer of review and verification at the <br />time of service, the waste determinations are being made by store personnel. We have confirmed <br />that this program is being followed at Store 3908. <br />As part of its 2011 program re-training, CVS is expanding upon these waste determination <br />procedures. Store colleagues will be required to place any leaking items in a self-sealing bag <br />with absorbent immediately upon receipt in order to segregate the item from other, potentially <br />incompatible, items. The items would then be processed out of inventory and, if determined to <br />be hazardous, into the correct hazardous waste container as soon as practicable based on staffing <br />availability, but at least on a daily basis. Damaged or returned items that are not leaking would <br />not be immediately bagged, but would be set aside and also undergo a waste determination and <br />be processed out of inventory on at least a daily basis. These procedures are included in 2011 <br />Hazardous Waste Management Program training materials. Training on these materials is <br />scheduled to begin in the next several weeks. <br />ATLANTA CHICAGO HONG KONG LONDON NEW YORK NEWARK NORFOLK ORANGE COUNTY PORTLAND <br />RALEIGH RICHMOND SAN DIEGO SHANGHAI TYSONS CORNER VIRGINIA BEACH WASHINGTON, DC <br />