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c. Bin composition v contents <br /> After an exhaustive review of the regulation governing the labeling requirements for generators <br /> of hazardous waste, and advice from outside counsel, CosmoProf respectfully disagrees with <br /> the inspector's interpretation that "composition" means "contents." <br /> Specifically, the applicable code section, 22 CCR§66262.34(f), provides as follows: <br /> (f)Generators who accumulate hazardous waste on site without a permit or grant of interim status <br /> shall comply with the following requirements: <br /> (1)the date upon which each period of accumulation begins shall be clearly marked and visible for <br /> inspection on each container and portable tank, <br /> (2) the date the applicable accumulation period specified in subsection (a) or (d) of this section <br /> begins,for purposes of subsections (a) and(b) of this section, shall be clearly marked and visible <br /> for inspection on each container and tank,and <br /> (3) each container and tank used for onsite accumulation of hazardous waste shall be labeled or <br /> marked clearly with the words, "Hazardous Waste."Additionally, all containers and portable tanks <br /> shall be labeled with the following information: <br /> (A)composition and physical state of the wastes, <br /> (8) statement or statements which call attention to the particular hazardous properties of the <br /> waste(e.g.,flammable, reactive, etc.), <br /> (C)name and address of the person producing the waste. <br /> The listing of each individual item placed in a bin would be impractical and of little <br /> use. The key information is the general composition of the contents—e.g., soaps, <br /> shampoos, etc., not the specific product names. <br /> Moreover, please note that the U.S. EPA's recent Generator Improvement Rules stressed <br /> that what is important on the labels is the hazard description, not the contents, and that <br /> reporting of contents is not required. <br /> Therefore, at this time, CosmoProf does not intend to list by name all of the products <br /> placed inside a bin on the label, but rather, continue its practice of using the products <br /> listed on the pre-printed bin labels as examples only. <br /> 3. How are employees being helped to make correct waste determination? <br /> The materials provided to aid associates in making a hazardous waste determination are as <br /> follows: <br /> • Hazardous Material Management poster <br /> • Revised Hazardous Waste Training Guide, which includes a decision tree <br /> • New Hazardous Waste Categorization supplement <br /> • SDS website <br /> • Toll-free number to the corporate office <br /> • Retraining of the employees at this location <br /> 4. Ensuring compliance <br /> In addition to the more robust associate weekly inspection checklist in the Guide, a compliance <br /> checklist has been pushed out to all district managers. On a quarterly basis, DMs will now include a <br /> detailed hazardous waste compliance check in their store inspections. Finally, Loss Prevention <br /> 2 <br />