COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

Violation #103 - Failed to retain hazardous waste determination including waste analysis on site for 3 years. This violation has been corrected. We utilize the UL WERCSmart to make our hazardous waste determination for our products. The WERCS has a staff of chemists and regulatory analyst to assist us with making an accurate product waste determination. In addition, we partner with our waste hauler US Ecology to verify waste determinations as well. The product analysis is maintained on a data base which the stores can access via the store computer or the handheld scan gun. That data base is maintained and updated as products change as well. I have included screen shots of the WERCS database of the Easy Off Oven Cleaner and the Lysol Disinfectant spray indicating the WERCS determination as a Red-AF or Aerosol — Flammable for both products, and the SDS documents for each product. I also contacted our waste hauler, US Ecology for further explanation regarding the handling of aerosol products. I have included a letter from US Ecology regarding their methodology in how they handle aerosols. 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 also 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. (see violation #102 documents) (V#103 EASY OFF OVEN CLEANER —2019-12-03 Weres UPC Barcode - Powered By The Weres, v#103 EASY OFF OVEN CLEANER SDS, V#103 Lysol SDS, v#103 Lysol Spray Disinfectant—2019-12-03 Weres UPC Barcode - Powered By The Weres, v#103 Smart and Final Aerosol Letter.docx) Violation #106 - Failed to train employees on waste handling and emergency procedures. This violation has been corrected. All store associates were required to retrain in hazardous waste handling via the company online training platform. The manager was retrained on proper completion of the hazardous waste labels and maintaining of hazardous waste manifests. In addition, associates were advised of the information on the modified contingency plan and maps posted in the office, the hazardous waste accumulation rack and in the break room. Darryl Dinson, Environmental Compliance Manager, visited the store to retrain management on the company hazardous waste program and policy and utilized the hazardous waste self-inspection form as a guideline. The sign off for the training was included as an attachment. The (TBD) To Be Determined bins, will be eliminated, and the associates will make an immediate waste determination utilizing the WERCS scan system or contacting the corporate office. I have included a copy of the training sign off, the self-inspection form, and a link to the training video. We recently changed waste haulers from Strong Pak to US Ecology and were in the process of updating our training materials to reflect the change, we normally deploy our annual hazardous waste