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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 5 <br /> and which is not empty as defined in subsections (b) or(d) of this section, <br /> . . . shall be managed as a hazardous waste... <br /> Walgreens' testing is consistent with that of U.S. EPA and shows that the amount <br /> of residue, if any, remaining when pharmaceuticals have been removed using the practices <br /> commonly employed to remove materials from that type of container, is effectively non-existent, <br /> and the container is empty. Nonetheless, Walgreens' environmental contractor manages these <br /> containers as hazardous waste and transports them in accordance with applicable D.O.T <br /> regulations. Because there is insufficient residue to weigh, Walgreens' environmental contractor <br /> lists the lowest increment available on the manifest form; listing a 1 lb. increment as "residue last <br /> contained"in section 9 of the form and the number of empty containers in section 14. (See <br /> attached manifests 013124255 FLE—CNT 20 empty bottles; 014905828 FLE—CNT 30 empty <br /> bottles). According to federal law, these warfarin stock bottles are "empty"; they should also be <br /> considered empty under California law and should not count toward generator status. The <br /> manifests are properly completed and submitted pursuant to CCR 66262.23(a). A manifest <br /> correction letter is not required. <br /> 605: Failed to Completely Label Containers or Portable Tanks of Hazardous <br /> Waste. Those Walgreens' employees with hazardous waste responsibilities have been trained <br /> and have completed a program of online training at the store level, in addition to refresher <br /> training in person with management. Walgreens also provides multiple store level references for <br /> 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; an exemplar label is attached <br /> hereto. Any failure to attach and complete an appropriate waste container label or place the <br /> waste in the appropriate container was a temporary inadvertent employee error; management has <br /> reviewed proper procedures with employees with hazardous waste handling responsibilities and <br /> refreshed training for all responsible employees. Any failure to place waste in the appropriate <br /> container or fully complete an appropriate waste container label has been corrected. <br /> 515893.1 <br /> A Professional Law Corporation <br />