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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 /> Contrary to the inspection report, signed copies of all manifests were retained at Big Lots corporate <br /> headquarters and were readily available for production and inspection. As the regulations do not <br /> specify where the manifests must be kept, Big Lots Hazardous Waste Management Program (in <br /> consultation with outside counsel and the relevant California District Attorneys) utilizes centralized <br /> data management at its corporate headquarters for efficient and reliable storage of the manifests. As <br /> such, copies of manifests referenced as missing in the inspection report on 7.15.2019 were available at <br /> the time of the inspection. In response to the inspection report, copies of 3 years' worth of manifests <br /> were mailed to the DTSC Report Repository on 8.9.2019 and are attached with this letter (see attached <br /> copies of manifests referenced in inspection report). <br /> Observation:#301 CCR 66262.34(4)(2)Facility not maintained to minimize the release of a <br /> hazardous waste. <br /> In response to the above discrepancy, store leadership secured the aisle in question to prevent <br /> customer and employee access. The spills observed were identified to be hazardous based on UL <br /> WERCSmart iPod application and Big Lots Haz Waste Program documentation. The spilled chemical <br /> powder was cleaned up using a damp paper towel to control the dust. All clean up materials and <br /> corresponding product containers were collected in a Ziploc style storage bag and sealed properly. <br /> That bag was then placed in a second Ziploc bag and sealed properly. The bag was then labeled with <br /> product description, UPC and employee initials. The bag was then placed in the correct haz waste tote, <br /> per UL WERCSmart iPod. Required information was then written on non-saleable material checklist. <br /> Leadership was retrained on proper clean up procedures and proper use of the Underwriters <br /> Laboratories WERCSmart iPod application and Big Lots Haz Waste Program documentation to make all <br /> hazardous waste determinations. All MODS will continue to identify potential spillages of haz waste <br /> during weekly Haz Waste Manager audits. All new store employees will continue to be trained within <br /> 30 days of hire and recertified on an annual basis. District and Regional leadership will continue to <br /> regularly audit chemical aisles throughout the sales floor during store visits. <br /> Observation:#605 CCR 66262.34(f) Failed to completely label containers or portable tanks of <br /> hazardous waste. <br /> In response to the above observation, store leadership immediately corrected the labeling on all <br /> hazardous waste totes and processed bags as directed by the inspector. Store leadership was <br /> retrained on all hazardous waste program labeling and container management requirements. <br /> We welcome the opportunity to discuss our responses in this letter at your convenience. If you have <br /> any questions or require additional information, please contact the undersigned directly. <br />