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<br /> <br /> <br />www.erm.com Project No.: 0565667 Client: Amazon.com Services LLC 17 December 2020 Page 9 <br />HAZARDOUS WASTE SOURCE REDUCTION EVALUATION REVIEW AND PLAN <br />Amazon.com Services LLC – OAK4 <br />SOURCE REDUCTION MEASURES <br />4. SOURCE REDUCTION MEASURES <br />Generators subject to SB 14 are required to identify and evaluate potential source reduction measures for <br />each major waste stream. The primary objectives are: <br />„ To develop and screen source reduction measures; <br />„ To conduct a detailed analysis of potentially viable source reduction measures; and <br />„ To set up an implementation schedule for the selected measures. <br />For each potentially viable source reduction measure, the generator must conduct an analysis of its <br />feasibility. When evaluating a potentially viable source reduction measure, the generator must consider <br />important factors, such as any expected changes in the amount of hazardous waste generated, technical <br />feasibility, economic evaluation, effects on product quality, employee health and safety implications, <br />permits and variances, and possible releases or discharges. <br />Amazon evaluated the source reduction approaches noted in 22 CCR 67100.5(j) and factors contained in <br />22 CCR 67100.5(k). Only those measures further discussed herein were deemed to be appropriate or <br />applicable to Amazon’s operations. <br />Waste at the facility includes expired and damaged products. As part of Amazon’s current operations, the <br />following waste reduction measures are in place: <br />„ Reduce product loss (e.g., damaged in onsite conveyance systems) through preventive maintenance <br />and/or improvements to process equipment (e.g., product conveyance systems); <br />„ Work with suppliers, vendors, and/or transporters to reduce product loss via damage in shipment to <br />Amazon or between Amazon facilities; <br />„ Increase the use of reverse logistics to increase reuse and recycling, where practicable; <br />„ Repackage or correct very small damage to packaging so items can still be sold; or <br />„ Donate items that meet Amazon’s donation standards. <br />Amazon has minimal to no control over when and how products are damaged in transit. All meaningful <br />source reduction measures that are technically and economically feasible have already been <br />implemented. No other reduction measures have been identified that would provide substantial waste <br />reduction. <br /> <br />5. IMPLEMENTATION <br />Amazon will continue implementing current waste reduction measures for as long as they remain <br />economically feasible. <br /> <br />6. NUMERICAL GOALS <br />As Amazon has little to no control over when and how products are damaged in transit, Amazon cannot <br />commit to a waste reduction goal. Amazon will continue to implement current waste reduction measures <br />to reduce the generation of hazardous waste for as long as it remains economically feasible.