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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 /> handling responsibilities are trained to check posting areas for compliance. This proprietary and <br /> confidential training program includes compliance with CCR 66262.34(4)(2). Any failure to <br /> post or include required information in the contingency plan was an inadvertent employee error <br /> and was corrected at the time of inspection. <br /> 106: Failed to Train Employees on Waste Handling And Emergency <br /> Procedures (106, 605). Those Walgreens' employees with hazardous waste responsibilities <br /> have been trained and have completed a program of online training at the store level, in addition <br /> to refresher training in person with management. Walgreens also provides multiple store level <br /> references for assistance with waste classification and labeling. <br /> Walgreens' hazardous waste training program provides employees with specific <br /> information about hazardous waste classification and handling, which includes proper labeling of <br /> each hazardous waste container and placement of waste in appropriately labeled containers 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. Any failure to attach and complete an appropriate waste container label or place the <br /> waste in the appropriate container was a temporary inadvertent employee error; management has <br /> reviewed proper procedures with employees with hazardous waste handling responsibilities and <br /> refreshed training for all responsible employees. Any failure to place waste in the appropriate <br /> container was corrected at the time of inspection and any failure to attach and fully complete an <br /> appropriate waste container label has been corrected. <br /> 108: Failed to Complete, Sign or Date Manifest; or Obtain Dated Signature <br /> of Transporter. Walgreens' environmental contractor manages hazardous and acute hazardous <br /> waste, prepares the manifest and transports the waste in accordance with the CA hazardous waste <br /> laws and federal D.O.T requirements. Walgreens' environmental contractor also assures that a <br /> copy of the manifest is delivered to DTSC and each manifest is available electronically at store <br /> level. 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 /> conditions as hazardous waste and count the empty container toward generator status. <br /> Walgreens disagrees with DTSC's position taken in both its December 24, 2015 letter and its <br /> August 2, 2018 letter. There is nothing in those letters that explains why or on what legal or <br /> scientific basis the container itself must be weighed toward generator status. Although warfarin <br /> 514077.1 <br /> A Professional Law Corporation <br />