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CONFIDENTIAL BIC Head Quarters-4900 E Dublin Granville Rd Columbus, OH 43081 LOTS Region 6-19331 Soledad Canyon Road Canyon Country, CA 91351 iPod application and Big Lots Hazardous Waste Program poster, were available at this store. Moreover, the three years of manifests that demonstrate the hazardous waste determinations made regarding waste generated by this store are maintained at Big Lots corporate headquarters and were readily available for production and inspection. As such, documentation regarding the "missing" hazardous waste determinations was available at the time of the inspection (see further discussion regarding these manifests below). To specifically address the candle mentioned in the report, the report fails to note that the candle was considered customer damaged merchandise and was stored in our designated damaged/returns bin at our front registers. This bin had not yet been fully processed at time of inspection, but the hazard determination had already been made based on the manager on duty's ("MOD") experience. The MOD at each store is responsible for making hazard determinations. All MODS are trained to use the UL WERCSmart application and Big Lots Hazardous Waste Program poster. Based on earlier scans of multiple types/brands of scented candles with similar ingredient statements, physical states, compositions and warning statements, the MOD followed the UL WERCSmart direction that these candles are not hazardous waste. Accordingly, the candle was managed as non-hazardous waste. There is no requirement in the regulations that items determined to be non-hazardous waste must be marked as such. Regardless, in response to the inspection report, store leadership was retrained on proper use of the UL WERCSmart iPod application and Big Lots Hazardous Waste Program documentation to make all hazardous waste determinations. All MODS will continue to be trained and recertified on an annual basis. District and Regional leadership will continue to regularly audit these training records to verify completion. Observation:#106 CCR 66262.34(4)(2)Failed to train employees on waste handling and emergency procedures. Contrary to the statement in the report, proper training of all employees had occurred, with the exception of one MOD who was not on duty at the time of the inspection. The MOD who had not yet been trained was not tasked with making any hazard determinations prior to their training. An error by an employee does not mean that he or she was not adequately trained. It simply means they erred. Notably, the inspector reviewed the training records at the time of inspection and observed all employees who handle hazardous waste, had completed their annual recertification. The attached proof of training was available at the store and offered for review. Regardless, in response to the concerns of the inspector, store leadership was retrained on the importance of making hazardous waste determinations at time of occurrence (see attached proof of retraining and training materials titled Haz. Waste 201). Leadership was also retrained on proper use