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2 b. Name and address of generator The revised Guide instructs store associates to include the entity name (store name) as well as store number for the generator name on the bin label. See attached file titled “Sally Store 10530 – Labels.” c. Hazardous properties SBH utilizes preprinted container labels that includes the hazardous properties, i.e., Universal, E-Waste, Aerosol/Flammable, Oxidizer, Corrosive Acid, Corrosive Base, and State Toxic. d. Physical state The revised Guide includes directions to circle the physical state(s), as applicable, on the bin labels of products put into hazardous-waste bins. e. Bin composition vs contents As previously stated in our return-to-compliance response for CosmoProf store #9331, through examination of the regulation and advice from counsel, SBH respectfully disagrees with the inspector’s interpretation that “composition” means “contents.” Please note that the word “contents” is not in the regulation and, moreover, that the U.S. EPA’s recent Generator Improvement Rules stressed that what is important on the labels is the hazard description, not the contents, and that reporting of contents is not required. Therefore, at this time, SBH does not intend to list by name all of the products placed inside a bin on the label, but rather, continue its practice of using the products listed on the pre-printed bin labels as examples only. Specifically, the applicable code section, 22 CCR §66262.34(f), provides as follows: (f) Generators who accumulate hazardous waste on site without a permit or grant of interim status shall comply with the following requirements: (1) the date upon which each period of accumulation begins shall be clearly marked and visible for inspection on each container and portable tank; (2) the date the applicable accumulation period specified in subsection (a) or (d) of this section begins, for purposes of subsections (a) and (b) of this section, shall be clearly marked and visible for inspection on each container and tank; and (3) each container and tank used for onsite accumulation of hazardous waste shall be labeled or marked clearly with the words, “Hazardous Waste.” Additionally, all containers and portable tanks shall be labeled with the following information: (A) composition and physical state of the wastes; (B) statement or statements which call attention to the particular hazardous properties of the waste (e.g., flammable, reactive, etc.); (C) name and address of the person producing the waste. f. Accumulation start date The revised Guide advises associates on accumulation date requirements. Finally, attached is the executed Return to Compliance Certification. I trust you will find this responsive to the violations and that Sally store #10530 is returned to compliance. Regards, Debbie Debbie Middleton Senior Paralegal, Environmental Compliance and Litigation