Laserfiche WebLink
ROGERS ,JOSEPH O'DONNELL www.rjo.com <br /> Elianna Florido, REHS <br /> San Joaquin County <br /> Environmental Health Dept. <br /> July 24, 2020 <br /> Page 2 <br /> 2. Walgreens' hazardous waste training program provides employees with <br /> hazardous waste handling responsibilities with specific information about hazardous waste <br /> characterization and handling, which includes proper labeling of each hazardous waste container <br /> and instruction on keeping lids closed when not adding or removing hazardous waste, in <br /> accordance with the CA hazardous waste laws. This proprietary and confidential training <br /> program includes use of labels and instruction for completion; an exemplar label is attached <br /> hereto. The individual employee questioned had just returned from leave and responded <br /> inaccurately at the time of the inspection; any failure to attach and complete an appropriate waste <br /> container label or failure to close the container was a temporary inadvertent employee error and <br /> was corrected at the time of inspection; management has reviewed proper procedures with the <br /> employee and refreshed training for all responsible employees. <br /> 106: Failed to Train Employees on Hazardous Waste Handing (102, 106, 403, <br /> 605). Those Walgreens' employees with hazardous waste responsibilities have been trained and <br /> have completed a program of online training at the store level, in addition to refresher training in <br /> person with management. Walgreens also provides multiple store level references for assistance <br /> with waste classification and labeling. <br /> Walgreens' hazardous waste training program provides employees with specific <br /> information about hazardous waste characterization and handling, which includes proper labeling <br /> of each hazardous waste container and instruction on keeping lids closed when not adding or <br /> removing hazardous waste, in accordance with the CA hazardous waste laws. This proprietary <br /> and confidential training program includes use of labels and instruction for completion; an <br /> exemplar label is attached hereto. Any failures to attach and fully complete an appropriate waste <br /> container label or failure to close the container was a temporary inadvertent employee error and <br /> has been corrected. <br /> 108: Failed to Complete, Sign or Date Manifest or Obtain from Transporter. <br /> Walgreens' environmental contractor manages hazardous and acute hazardous waste, prepares <br /> the manifest and transports the waste in accordance with the CA hazardous waste laws and <br /> federal D.O.T requirements. Walgreens' environmental contractor also assures that a copy of the <br /> manifest is delivered to DTSC and each manifest is available electronically at store level. <br /> Walgreens' environmental contractor properly handled and transported the empty warfarin <br /> containers, completed the manifest, and delivered the signed and dated manifest to DTSC, <br /> making a copy available electronically to the store. <br /> You have cited an August 2, 2018 letter from DTSC to the California Retailers <br /> Association repeating DTSC's conclusion in a December 24, 2015 letter stating that under <br /> California law, health care providers must manage warfarin containers emptied under normal <br /> 514088.1 <br /> A Professional Law Corporation <br />