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TROUTMAN SANDERS VIA FEDERAL EXPRESS Ms. Michelle Henry RECEIVED October 3, 2011 Page 2(7,; I 11 IRO ?AdL HEALTH As to your concern, in Violation number 20, that the "Ox" and "C -B" hazar o RVI ES containers were not properly labeled, we have ensured that all hazardous waste containers are properly labeled in accordance with California regulations, including the accumulation start date. The language "Hazardous waste pending further evaluation" does not appear on the most recent version of CVS hazardous waste labels that are used on the totes. Those stores that currently have an older version of labels have been instructed to scratch through such language until receiving new labels. Reformatted labels, which do not state "pending further evaluation," will be provided by StrongPak in connection with the upcoming 2011 program training. Additionally, the StrongPak bags bearing the text "Potentially Hazardous Waste" that may have been observed at the time of the inspection are no longer being supplied to CVS stores. All StrongPak bags obtained from the vendor now state "Hazardous Waste." Any outdated stock may still being used, provided the store colleagues cross out the term "Potentially." With respect Violation number 30, and your concern with the presence of an empty 55 - gallon drum that may have once held photo hazardous waste, we are working with CVS's photo processing vendor, Kodak, to ensure that any empty drums provided to stores for the purpose of managing hazardous photo processing waste water are properly labeled. Regarding Violation number 50, concerning storing hazardous waste for greater than 180 days, we have confirmed that the most recent hazardous waste pick-up at Store 3908 occurred on July 27, 2011 (see attached manifests). Prior to that, the store was serviced by StrongPak on April 28, 2011 (see attached manifests). Therefore, despite lacking an accumulation start date, the waste observed on site at the time of the inspection had not been accumulated for longer than 180 days. Store management has been re-trained on completing hazardous waste storage labels, and all labels are now properly completed. Regarding your concern, in Violation number 52, that hazardous waste management procedures did not appear to have been adequately provided to store employees, follow-up training has been provided to store management regarding proper management of hazardous waste. In addition, with its 2011 program re-training, CVS is expanding the training provided at the store level. The program materials now include four training modules — Front Store, Pharmacy, Photo, and Basics — that are assigned to store colleagues according to their job responsibilities. All store colleagues will be assigned at least one training module via LEARNet, CVS's web -based training platform. In addition, the program materials include a Program Overview and an Environmental, Health and Safety (EH&S) Binder, which will be provided to each store and used as a repository for hard copies of the training modules, additional supporting information, and program -related records, such as hazardous waste manifests. In response to your request, training records for Course 500141, Hazardous Waste Management Program, are enclosed. Copies of 2011 program training materials and the reformatted labels were recently provided to David Irey and Mitch Disney; they are also provided here for your review and reference. 23111190