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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone: (209) 468-3420 Fax: (209) 468-3433 Web: www.sogov.org/ehd RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: CVS PHARMACY #16223 2800 NAGLEE RD, Tracy January 28, 2019 SUMMARY OF VIOLATIONS (CLASS I, CLASS II, or MINOR - Notice to Comply) Item # Remarks 118 CCR 66265.16(a -c) Failed to complete training on hazardous waste management and emergency response procedures. Based on the types of violations observed, the facility employees are not trained on proper hazardous waste handling or the training provided has been inadequate. The following was observed inside the CVS Pharmacy: - An open blue bin labeled "Weekly Strong Pak Accumulation Bin," "Loose Pills (Bagged)," and "Amber Vials (Capped)" was observed on a counter. The blue bin contained a smaller container labeled "Empty Strong Pak Bags," three loose pills individually bagged an (see photos IMG 3855-3856). According to Daniel Drewniak, the pharmacy manager, pharmaceuticals placed in this blue bin are processed once a week, at which point they are placed in the "Strong Pak" hazardous waste tote. - According to Daniel Drewniak, the pharmacy manager, the tote labeled "Genco Not Processed" contained pharmaceuticals that expire in February and March of 2019 and are waiting to be sent to Genco. The following pharmaceuticals were found in this tote (IMG 3857): - An amber vial of warfarin sodium tablets (IMG 3858-3859) - A warfarin sodium tablets manufacturer bottle marked with a black "X" (IMG 3858-3859) - Four amber vials of armour thyroid tablets, guanfacine hcl tablets, glyburide tablets and diphenhydramine capsules (IMG 3860-3861) The above listed pharmaceuticals were found in the "Genco Not Processed" tote, although the blue "Weekly Strong Pak Accumulation Bin" was labeled for amber vials. Personnel who handle hazardous waste shall be trained within six months of assignment and take part in an annual review of the initial training received. At a minimum, the training program shall be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: 1. procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; 2. key parameters for automatic waste feed cut-off systems; 3. communications or alarm systems; 4. response to fires or explosions; 5. response to ground -water contamination incidents; and 6. shutdown of operations. The owner or operator shall maintain the following documents and records at the facility: 1. the job title for each position at the facility related to hazardous waste management, and the name of each employee filling each job; 2. written job description for each position listed above; 3. written description of the type and amount of both introductory and continuing training that will be given to each person filing positions listed above; 4. records that document that the training has been given to and completed by facility personnel. Training records on current employees shall be kept until closure of the facility. Training records on former employees shall be kept for at least three years from the date the employee last worked at the facility. Immediately provide employees with initial or refresher hazardous waste training. Submit a copy of the roster, syllabus, and training materials to the EHD. FA0023489 PR0541027 SCO01 01/28/2019 EHD 22-03 Rev. 09/22/16 Page 7 of 10 RCRA Large Quantity Hazardous Waste Generator OIR