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ROGERS ,JOSEPH O'DONNELL www.rjo.com <br /> Elianna Florido, REHS <br /> San Joaquin County <br /> Environmental Health Dept. <br /> August 26, 2020 <br /> Page 2 <br /> 2. The item referenced was properly stored and awaiting disposition in <br /> accordance with Walgreens' policies and was not damaged or expired. There was no violation of <br /> CCR 66262.11 <br /> 3. Walgreens' hazardous waste training program provides employees with <br /> hazardous waste handling responsibilities with specific information about hazardous waste <br /> characterization and handling, which includes proper labeling of each hazardous waste container <br /> and instruction on disposition of product close to expiration date. An exemplar label is attached <br /> hereto. <br /> Items referenced that were pulled and quarantined for any of several reasons <br /> unrelated to hazardous waste were temporarily stored and inadvertently remained past expiration <br /> dates. This situation was addressed and brought into compliance with Walgreens' policies and <br /> applicable CA hazardous waste laws. All items referenced were corrected and any failure to <br /> attach and fully complete an appropriate waste container label was inadvertent employee error <br /> and has been corrected. <br /> 104: No Modified Contingency Plan. Walgreens' hazardous waste training <br /> program specifies that all locations post required continency plan information next to telephones, <br /> which includes telephone numbers of the emergency coordinator and fire department as well as <br /> locations of spill control materials and fire extinguishers. Employees with hazardous waste <br /> handling responsibilities are trained to check posting areas for compliance. This proprietary and <br /> confidential training program includes compliance with CCR 66262.34(d)(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 (102,106, 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, and exemplar label is attached <br /> hereto. Any failure to follow Walgreens' policies as to disposition of items close to expiration <br /> by placing in an appropriately labeled waste container was a temporary inadvertent employee <br /> 515893.1 <br /> A Professional Law Corporation <br />