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• 00 00 StericyCieg: 0Environmental Solutions Compliance Announcement To: Stericycle Customers From: Wade Scheel,Director of Regulatory Affairs Date: 11/30/2018 Re: Manifest Copy Distribution—CUPA/CA DTSC Missing Manifest Copies Comments: It has come to our attention that California CUPA inspectors are including citations or notice of violations to our customers based upon the fact that the CUPA inspectors are not able to locate manifest information in the California DTSC's online manifest database.An explanation of Stericycle's position on this matter is provided below. Please contact me if you have any additional questions or need additional support. There is no regulatory requirement in California for the Generator or Stericycle to provide any evidence or proof of mailing manifests to the DTSC or to confirm or prove the manifests mailed to the DTSC are actually received. Stericycle does not mail manifest copies to the DTSC using a delivery method that confirms shipment or delivery of the manifest copies, since this is not a regulatory requirement, and as a result Stericycle does not have documentation or delivery receipts for manifests mailed to the DTSC to "prove" delivery. However, we have confirmed that the Retail Client Services Center, based in Peachtree Corners, GA, mails the Generator copy of manifests to the DTSC within 1-2 days of shipment, and the TSDF's that receive the shipment send their TSDF signed copy to the DTSC the same day or next day after receiving the shipment. Stericycle encourages Generators to challenge any citations or NOVs received for manifest copies that are not able to be located on the DTSC's online manifest database. Stericycle has been informed directly from DTSC and specifically from the group within DTSC that manages the online manifest access portal that the DTSC is substantially delayed on uploading manifest copies they have received. The DTSC also informed Stericycle the online system has experience intermittent outages that prevented online access to manifest data. The DTSC indicated that all CUPA's had been informed of these issues with their online database. As mentioned above, Stericycle has confirmed that our Client Services Center and TSDF's have always been submitting the manifest copies on behalf of our customers to the DTSC. We believe the CUPA's are basing these citations and NOVs off of their inability to find the manifest copies in the DTSC's online system. The reason CUPA inspectors are not finding the manifests when they search the system is NOT because the manifests weren't submitted, it is because DTSC has not yet successfully loaded the 2850 10011 Court NE Pagel of 2 Blaine, MN 55449 www.stericycleenvironmental.com