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VCVSHealth <br /> Ms. Florido <br /> September 28, 2018 <br /> Page 7 <br /> lids must be kept closed all times when not adding or removing waste. To address your concern <br /> reinforcement training has been provided to store personnel on proper container management to <br /> ensure hazardous waste container closure when not adding or removing waste. The red basket <br /> you observed which did not have a lid contained unsaleable items/damages awaiting processing. <br /> As noted above, waste determinations on unsaleable items occurs when the item is scanned and <br /> processed using the unsaleables application on the RF unit. <br /> Weekly Inspections <br /> Your item#404 relates to conducting and documenting weekly inspections of hazardous <br /> waste container storage areas. As background, CVS's hazardous waste management program <br /> requires each retail store to conduct and properly document inspections of all hazardous waste <br /> storage areas on a weekly basis. The program also requires that retail stores maintain paper <br /> copies of completed weekly inspection logs in the store's EH&S binder for at least three <br /> years. Please note that in May 2018, CVS launched the electronic weekly inspection logs for all <br /> retail locations, which notifies and requires stores on a weekly basis to inspect hazardous waste <br /> areas. Completion of these logs is tracked by the Store Operations. Attached please find copies <br /> of the weekly inspection logs as requested. We have emphasized to store management the <br /> requirement that the store conduct, accurately document, and perform any corrective action <br /> during each weekly inspection. <br /> Labeling Hazardous Waste Container <br /> In your item# 601, you noted a container had an accumulation start date exceeding <br /> ninety days. We have confirmed this was a labeling issue,rather than an accumulation issue. As <br /> background, CVS Health has contracted with a licensed hazardous waste transporter, Stericycle, <br /> to conduct pickups at the store within ninety days of the prior pickup. During a waste pickup, all <br /> hazardous waste is removed from each Stericycle tote in the store's backroom and pharmacy, <br /> including waste from totes that are only partially full. CVS's hazardous waste management <br /> program requires that when a Stericycle tote is reused, a new hazardous waste label be affixed to <br /> the tote. The appropriate accumulation start date is added as soon as the first hazardous waste <br /> item is added to the tote. To address your concern, appropriate store personnel have been <br /> retrained on appropriate container labeling requirements and on adding the appropriate <br /> accumulation start date in particular. The content of this hazardous waste container(tote)was <br /> picked up by Stericycle during the most recent pickup at this location, on September 8, 2018. <br /> The manifest for this pickup is attached. <br /> Your item#605 also relates to labeling hazardous waste containers. Specifically, you <br /> observed a hazardous waste container with an incorrect accumulation start date, a hazardous <br /> waste container missing the physical state, and processed/bagged hazardous waste items stored <br /> outside of a properly labeled hazardous waste tote. As background, and as discussed above, <br /> CVS's hazardous waste management program has separate containers for the following <br /> hazardous waste types, which are labeled accordingly: Flammables, Flammable Aerosols and <br /> Combustibles; Corrosive Acids; Corrosive Bases; Oxidizers; Toxics& State Regulated Wastes; <br /> CVS pharmacy / caremark / minute clinic / specialty <br /> 364827630 <br />