COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

Date: December 04, 2019 To: Elianna Florido San Joaquin County Environmental Health Department From: Darryl Dinson, Smart & Final Stores Re: cc393/ Stockton - Return to Compliance Certification Violation #102 - Failed to determine if a waste is a hazardous waste. This violation has been corrected. I contacted Ecolab, the manufacturer of Clean in Place Oven Cleaner (CIP) regarding the waste determination of the product. The Ecolab regulatory team advised me that CIP was a corrosive base. I have included a letter from Ecolab regarding CIP Oven Cleaner waste stream designation, and their contact information should you have any questions regarding the product. I have also included the CIP Cleaner SDS sheet for your reference. We contract UL WERCSmart to analyze our products to make our hazardous waste determinations and information is transferred to store scan guns, in addition if stores have difficulty making a determination the corporate office will assist making a waste determination. The corporate contact number is on the Haz Waste Training posters. Management spoke to the associate, Ritha Oeun, who was responsible for leaving the container adjacent to the hazardous waste rack and obtained a statement as to how the containers ended up outside. Oeun, placed the containers next to the rack for another associate to process, because of the traffic in and out of the receiving door the containers mistakenly ended up on a pallet outside. Management spoke to Ritha Oeun regarding the importance of making the waste determination immediately and placing it into the correct bin. I have included Ritha Oeun's statement regarding the incident. We are a Small Quantity Generator. Therefore, have our waste picked up on or before every 180 days of our accumulation start date. I have included our last two manifests to demonstrate the most recent pickup dates. We are contacted with US Ecology to have our waste picked up every four months (120 days) to ensure we are in compliance with our generator status. I have included the scope of work from our contract with US Ecology indicating that they will service our stores every four months. We contacted Ecolab regarding the instructions on the CIP Oven Cleaner label. Their regulatory team advised us that the current containers did not require any additional special handling or special storage. I have included a letter from Ecolab's regulatory affairs division, explaining the proper storage, and the SDS Sheet. (v#102 020590300JJK 08-29-19, v#102 020590300JJK 08-29-19, v#102 CIP Oven Cleaner - Smart and Final - US - Proper Storage, v#102 CIP Oven Cleaner Waste Stream Designation, v#102 ECOLAB CIP CLEANER SDS, v#102 Employee Statement re EcoLab, v#102 US ECOLOGY MSA12032019)