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IVCVSHealth Michelle Henry October 8, 2019 Page 2 Empty Warfarin Containers Based on EPA's November 2011 guidance and our experience in other states, CVS' s practice has been to count only the weight of the residue contained in empty containers that previously held warfarin-family pharmaceuticals, and not the weight of the containers themselves, toward the generator status calculations for CVS stores. In support of this practice, and in order to determine a reasonable estimate of the weight of the residue that may be found in containers generated at CVS's retail pharmacies, CVS conducted analytical testing on a representative sample of empty warfarin containers in March 2012. This testing involved both name brand and generic warfarin stock bottles,and it tested the largest stock bottles with the highest prescription strength warfarin found in a CVS retail pharmacy. The analytical results are attached for your review. You'll note that, after excluding any statistical outliers, the highest total residue weight in the containers tested was 19.8 mg(or 0.0000436 tbs). Using that value to determine a reasonable "not to exceed" number,CVS adopted a very conservative generation estimate of 1004 empty containers, and concluded that so long as no more than 1,000 empty warfarin containers are accumulated by a retail pharmacy at any one time,the collective weight of the residue in empty warfarin containers requiring disposal would not exceed 0.0436 lbs. Based on the above analysis, CVS includes clarifying language in Box 14 of hazardous waste manifests used for transportation and disposal of containers that previously held p-listed pharmaceuticals(i.e., empty warfarin containers). The clarifying language is as follows: "Residue weight does not exceed 4.4436 tbs." Because only whole numbers can be reported in Box 11 of hazardous waste manifests, in practice "1 lb." is reported when empty warfarin containers are shipped from CVS's retail locations. However, only 0.0436 lbs. of the 1 lb. listed on the manifest is counted toward the store's generator status. During our recent meeting, you had questions pertaining to manifest#0 1 0867666FLE, for a shipment of hazardous waste from Store#9830 on June 12,2018. Your question focused on the waste profile for warfarin residue, for which the manifest showed a bottle count of 77 bottles shipped. Box 29 (manifest page 2) showed a net ship weight of 1 pound of residue, and consistent with the process described above, Box 14 noted that the residue weight does not exceed 0.0436 tbs(since there were<1,000 bottles shipped). You also asked about the data CVS previously provided to San Joaquin County regarding CVS Target locations. As discussed, even if CVS counted the total weight of the bottles,the shipments would typically never exceed 2.2 pounds total for the warfarin residue profile. This information is included in the table below,which was discussed during our recent meeting. Upon request from Mr. Irey, we have since added the Store #9830 information and"Calculated Weight of Residue"column based on the 2012 testing described above. For reference, below we also include notes regarding the meaning of the various columns. ■ The "Gross Container/Box Weight"is collected by the technician at the time of each pickup and is entered into the vendor's system manually. • The"Tare Weight"is the estimated average weight of the prescribed boxes used to transport each shipment of warfarin residue bottles. CVS pharmacy / caremark /minute clinic/specialty 40294225vl