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rCVSHealth Ms. Florido September 28, 2018 Page 3 010076875FLE, 010788942FLE, 009156013FLE, and 010867665FLE. Attached please find the referenced manifests and the resubmission tracking number. Your item#115 relates to maintaining final signed copies of manifests from designated facilities for three years. To address your concern, we have obtained the TSDF signed copy of manifests numbers 008570609FLE, 008680847FLE, 010076417FLE, 008675487FLE, 011387023FLE and 010867665FLE,which are attached here for your reference. Please note that these manifests were available electronically at the store level through the EH&S Portal at the time of your inspection. We have provided reinforcement training to store personnel, to ensure they are able to access the EH&S Portal and can access three years of manifests. Your item#116 relates to completion of a hazardous waste manifest exception report for manifests 008675487FLE, 011387023FLE, 010867665FLE, 008570609FLE, 008680847FLE, and 0 1 0076417FLE. As you know, an exception report is required if a generator has not received a copy of a manifest with the handwritten signature of the owner or operator of the designated facility within 45 days of the date the waste was accepted by the initial transporter. Hazardous waste manifests generated at CVS Health retail locations are tracked at the corporate level to ensure the final destination copies are uploaded into the EH&S Portal in a timely manner by our vendor Stericycle. Hazardous Waste Training Your item#118 relates to completion of training on hazardous waste management and emergency response procedures. We understand that during your inspection you observed inconsistencies related to damages processing and onsite management of hazardous waste items. Below, we address each area of concern. Front Store Unsalable Items Processing As background, CVS's California hazardous waste management program requires front store retail colleagues to process unsaleable items (often referred to "damages"at the store level) daily. To determine whether an item is a waste, each item must be scanned using the RF Unit. Based on the condition of the item and RF Unit coding, which is programmed to identify items that are hazardous when they become wastes, disposition direction is provided to the store colleague. Based upon the disposition direction, items could be sent to a reverse logistics partner for donation/liquidation,placed into the dumpster(if determined to be non-hazardous/non- regulated waste), or placed into the appropriate hazardous waste tote(this process is described in further detail below). Unsaleable items awaiting processing have not been determined to be a waste and may be eligible for resale, liquidation or donation. Because unprocessed items could be returned to the sale floor, liquidated, or donated,they are not waste and thus also not a hazardous waste (and therefore not stored in labeled hazardous waste containers). If an item is determined to be hazardous waste, the RF Unit provides direction to store colleagues to bag the item into a self-sealing hazardous waste bag and place into the appropriate CVS pharmacy / caremark / minute clinic / specialty 364827630