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RECEIVED BY SJCEHD (EF) on 8/9/2019 <br /> CONFIDENTIAL <br /> BIC <br /> Head Quarters-4900 E Dublin Granville Rd <br /> Columbus, OH 43081 <br /> LOTS Region 6-19331 Soledad Canyon Road <br /> Canyon Country, CA 91351 <br /> August 9th, 2019 <br /> Ms. Elianna Florido, REHS <br /> San Joaquin County Environmental Health Department <br /> Registered Environmental Health Specialist <br /> RE: Haz. Waste Generator Inspection Report 6.25.2019 <br /> Dear Ms. Elianna Florido, <br /> Big Lots takes its regulatory responsibility seriously, and it is our policy and practice to maintain <br /> compliance with all applicable laws and regulations. As observed during the inspection, we have a <br /> thorough and robust hazardous waste program that is appropriate for the scope and scale of the waste <br /> produced by a retail operation carrying an assortment of household consumer products. While we do <br /> not agree that all the observations and recommendations from the inspection constitute violations, let <br /> alone multiple violations from the same observation, we have taken these observations seriously and <br /> acted to improve our compliance program. Moreover, on July 30th, 2019, an independent member of <br /> our Asset Protection team verified on-site that the store team had made all the corrections set forth <br /> below. <br /> With respect to the specific points made during your most recent inspection at Tracy 4457, Big <br /> Lots responds as follows: <br /> Observation:#103 CCR 66262.40(c)Failed to retain hazardous waste determination including <br /> waste analysis on site for 3 years. <br /> This citation contains an incomplete quote of section 66262.40(c), which states: "A generator shall <br /> keep records of any test results, waste analyses, or other determinations made in accordance with <br /> section 66262.11 for at least three years from the date that the waste was last sent to on-site or off- <br /> site treatment, storage, or disposal." Section 26262.11, in turn, provides that the generator may make <br /> a waste determination by "applying knowledge of the hazard characteristic of the waste in light of the <br /> materials or the processes used, and the characteristics set forth in article 3 of chapter 11 of this <br /> division." <br /> Contrary to the report, the basis for hazardous waste determinations—our knowledge of the hazard <br /> characteristics-was available at the time of the inspection. The tools used in all California Big Lots' <br /> stores to make hazardous waste determinations, namely the Underwriters Laboratories WERCSmart <br />