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SAN 10 A Q U I N Environmental Health Department <br /> C O U N T Y — Linda Turkatte, REHS , Director <br /> Greatness grows here . Kasey Foley, REHS , Assistant Director <br /> - gcrFOR? / <br /> - - PROGRAM COORDINATORS <br /> Robert McClellon , REHS <br /> Jeff Carruesco , REHS, RDI <br /> Willy Ng , REHS <br /> Muniappa Naidu , REHS <br /> Michael Kith , REHS <br /> June 4, 2019 <br /> VIA EMAIL <br /> Nicole Wilkinson <br /> CVS Health <br /> One CVS Drive — MC2340 <br /> Woonsocket, RI 02895 <br /> mcole .wilkinsongcvshealth. com <br /> (401 ) 770 - 7132 <br /> Re : San Joaquin County CVS Pharmacy locations - Hazardous Waste Inspections <br /> Dear Ms . Wilkinson, <br /> The San Joaquin County Environmental Health Department (EHD) is in receipt of your return to <br /> compliance (RTC) letters in response to our Inspection Reports issued to each CVS Pharmacy store <br /> located in San Joaquin County. Thank you for your responses . The following is the EHD ' s response to <br /> two primary subjects discussed in your letters . <br /> Counting Contaminated Warfarin Containers <br /> The EHD will continue to follow the Department of Toxic Substances Control ' s (DTSC) <br /> most recent reaffirmation, stated in the letter dated August 2, 2018 , to continue to regulate the whole <br /> contaminated container as hazardous waste and not just the residual inside, per California Code of <br /> Regulations, title 22, section 66261 . 7(r) . 1 The EHD will continue to follow this position until DTSC <br /> formally changes their position on the subject, if at all . Thus , as stated in DTSC ' s 2018 letter, <br /> "California healthcare facilities (hazardous waste generators) must include the weight of the container <br /> and residue when completing a Uniform Hazardous Waste Manifest. The combined weight counts <br /> toward generator status , ,2 <br /> Reverse Distribution of RCRA Waste Pharmaceuticals <br /> The EHD will continue to regulate expired RCRA pharmaceuticals as hazardous waste, and thus <br /> will cite violations identified at the time of inspection relating to the improper management of <br /> hazardous waste . This decision is based on Assembly Bill No . 1442 , which amended the Medical <br /> Waste Management Act (MWMA) to read expired pharmaceuticals (Non-RCRA only) are not <br /> 1 Ellen L. Haertle, Request to Reconsider The Regulatory Status of P-Listed RCRA Hazardous Waste Containers <br /> (Correspondence from Ellen L. Haertle to Angie Manetti), Department of Toxic Substance ' s Control, Sacramento, CA, <br /> 2018 . (enclosed) <br /> 2 Ibid. <br /> 1868 E . Hazelton Avenue Stockton , California 95205 1 T 209 468 -3420 F 209 464 - 0138 1 www . sjcehd . com <br />