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ecole Wilkinson <br />VCVSHealth Director, Corporate Environmental <br />One CVS Drive — MC2340 <br />Woonsocket, RI 02895 <br />p 401-770-7132 <br />c 401-256-7615 <br />f 401-652-1901 <br />nicole.wilkinson@cvshealth.com <br />November 1, 2019 <br />VIA UPS RECEIVED <br />Mr. Jesse Easter NOV U 4 2019 <br />San Joaquin County Environmental Health Department <br />1868 E. Hazelton Avenue L,NVIIZONNIENTAL, 1141?AL F14 <br />Stockton, CA 95205-6232 1)FIIAKrNIENT <br />Re: CVS Pharmacy, Inc., Omnicare of Northern California, Medical Waste Inspection <br />Report, Issued on October 21, 2019. <br />Dear Mr. Easter, <br />CVS Pharmacy, Inc. (CVS) is in receipt of your Medical Waste Inspection Report issued on <br />October 21, 2019 following your inspection of Omnicare of Northern California on October 2, 2019. This <br />letter addresses your concerns noted in the above -referenced Report. <br />Your first concern relates to containerization and segregation of Pharmaceutical waste. CVS <br />Health, in coordination and consultation with one of its waste haulers, has elected to follow guidance <br />provided by the California Department of Toxic Substances Control that pharmaceutical wastes can be <br />"self -declared" as RCRA hazardous waste and therefore can be managed in accordance with RCRA <br />management standards. This guidance was memorialized in the attached memo to file, prepared by <br />Angela Manuel, Stericycle Legal Counsel. Sections 117690 (a) and 117700(e) of the California Medical <br />Waste Management Act (MWMA) exclude from the definition of "medical waste" those pharmaceutical <br />wastes regulated by the federal Resource Conservation and Recovery Act of 1976 (RCRA) and managed <br />as RCRA hazardous wastes. CVS has chosen to follow this same guidance in partnership with Clean <br />Harbors, the waste hauler contracted for all Omnicare services. As such, non-RCRA hazardous waste <br />generated at Omnicare facilities is managed as hazardous waste at the final destination facility. <br />Your second concern relates to the storage requirements of biohazardous waste. After a close <br />review of the definition of "biohazardous waste" recorded in the MWMA, we respectfully assert that <br />Omnicare of Northern California does not produce waste that meets this classification. As background, <br />Omnicare produces non-infectious sharps and syringe waste generated during the medication <br />compounding process. Sharps waste is stored in rigid, closed containers with labels which include the <br />biohazard symbol in accordance with the storage requirements for sharps waste from 118285 of the <br />MWMA. This waste is also never onsite for more than thirty days before being removed by Clean <br />Harbors. Since Section 118225 of the MWMA indicates that non-infectious sharps waste can be disposed <br />of as solid waste, non-infectious sharps waste produced at Omnicare facilities is actually over -managed <br />because it is managed as non-RCRA hazardous waste. Based on the above, we respectfully assert that <br />this waste stream is not required to be stored under 32°F nor removed within seven days of generation. <br />M pharmacy / caremark / minute clinic / specialty <br />