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rCVSHealth Ms. Florido September 28, 2018 Page 4 hazardous waste container. There is a separate tote for each of the following: Flammables, Flammable Aerosols and Combustibles; Corrosive Acids; Corrosive Bases; Oxidizers; Toxics & State Regulated Wastes; and Universal Waste. It appears that during your inspection, you observed non-hazardous waste containers used to temporarily hold and sort items during the Final Disposition process (unsaleables/damages processing). Accordingly, appropriate store colleagues have been retrained on the proper unsaleables/damages process. On August 31, 2018 Chris Yerzy, the Environmental Specialist for northern California, retrained store colleagues at this location on the hazardous waste program, including the importance of placing bagged hazardous waste items into the correct hazardous waste totes in a timely manner, processing unsaleables/damages daily, and using only hazardous waste totes to store processed hazardous waste items. Chris Yerzy returned to the store on September 14`h, 2018 to reinforce this additional training. Final Disposition Coding CVS has developed a sophisticated waste determination process that relies on the radio frequency unit(RF unit or"scan gun") used to track all inventory for every store in our network. The RF unit is tied to a database of ingredient-level information supplied by the product manufacturer that allows a third-party vendor (the WERCS) to identify hazardous characteristics and generate program logic within the database. Items that are "hazardous" under RCRA, or by state regulation, when disposed are flagged in the computer program that feeds the RF unit. This process also allows CVS to incorporate a number of conservative assumptions regarding waste determinations that help ensure that waste is being managed both properly and consistently at its stores across the country. Because of the nature of the retail industry, and the large and ever-changing retail and pharmaceutical inventories maintained by CVS and other retailers, making a hazardous waste determination in the absence of some sort of automated process that is integrated with our inventory system, presents serious logistical challenges. The RF unit logic is connected directly to the WERCS database of ingredient information so that the list of flagged "hazardous" items is updated on a daily basis. When a store colleague scans a flagged item and answers certain questions about the condition of the item, the RF unit instructs the colleague to place the item in a Stericycle sealed bag and into a hazardous waste box for later collection. By using programmable scan guns to process unsaleable items at the store level, CVS can control the manner in which these items are disposed. The RF unit is used by stores on a daily basis to scan items in and out of inventory. As part of its overall Hazardous Waste Management Program, CVS programmed the RF unit with logic that allows store-level colleagues to process unsaleable items or "damages" (a generic term used to describe all unsaleable merchandise regardless of the reason, including customer returns,broken items,product withdrawals or recalls, etc.). Using the "damages" logic, the RF unit asks the colleague a series of questions about the condition of the product. For example, one question is "is the item broken, leaking, or partially full?" If the answer to this question is "yes,"then the item is a"solid waste." CVS pharmacy / caremark / minute clinic / specialty 364827630