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3. List of current contents on bin label <br /> Unfortunately,the word "Contents" on the pre-printed label is a misnomer. It was never the intention to list all <br /> of the products in the store that would fall under a given hazardous waste stream category. Rather,the list of <br /> products on the label is to aid the associates in determining the correct category. New labels are being designed <br /> which will change the word "Contents"to "Examples." <br /> 4. Misclassification of product <br /> The procedures for classifying hazardous waste have been reiterated to the manager and associates, i.e., check <br /> against Hazardous Material Management poster("Poster"), if still unsure, pull the Safety Data Sheet and look at <br /> sections 2 and 14, if still unsure after that, contact the corporate office. As mentioned in the inspection notes, <br /> most of the products that were misclassified were in fact listed on the Poster. Associates have been advised to <br /> slow down and be more methodical in the classification process. <br /> Violation 109 CCR 6626.23(1)(4); 110 CCR 66262.40(a); 111 CCR 66262.42(a)(c)(d) Failed to send generator manifest <br /> copies to DTSC within 30 days; Failed to keep signed copy of manifests from the designated facility for three years; <br /> Failed to comply with uniform hazardous waste manifests exception requirements <br /> Please be advised that the responsibility for sending generator manifest copies to DTSC was taken from the store level <br /> and assigned to CosmoProf's hazardous waste vendor late 2017. TSDF manifests 017367359JJK (10/24/17) and <br /> 015886584JJK (08/24/16) have been sent to the store and put into the hazardous waste binder; copies have been filed <br /> with DTSC. Manager and associates have been instructed to pay close attention to the status of manifests during their <br /> weekly inspection. They were also reminded that if they have not received the TSDF copy of the manifest within 35 days <br /> of pickup,to notify the corporate office. <br /> Violation 404 CCR 66262.34(d)(2) Failed to inspect hazardous waste storage area at least weekly. <br /> Store manager and associates have been instructed to increase diligence in inspecting all aspects of the hazardous waste <br /> storage area including, but not limited to,the condition of the bins and labels, manifest maintenance, classification of <br /> product, and hazardous waste handling. <br /> Violation 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste <br /> Please see response to Violation 106. <br /> With respect to the request for copies of CosmoProf's policy and procedures "on how it manages defective and returned <br /> items, and what type of items are returned to the warehouse," please be advised that there is no formal policy, per se, <br /> however, instructions to the stores (in the training material) are that any product that is damaged, defective, returned <br /> or otherwise cannot be sold or used is considered hazardous waste and must be damaged out of the system and <br /> processed as a hazardous waste. With the exception of some electrical appliances, products are not returned to the <br /> warehouse. <br /> Finally, regarding the classification of the wax warmer and waste wax,the waste wax was disposed of as hazardous <br /> waste (state toxic) out of an abundance of caution as it was not certain that it was hazardous. The wax warmer with <br /> melted wax on it was determined to be e-waste. If the agency believes that in such circumstances the wax warmer <br /> should have been disposed of as hazardous waste,we will instruct the stores accordingly. Please let us know. <br /> For your convenience, please find the following attachments: <br /> • Completed HW Emergency Information form <br /> • Training log <br /> • Manifests 017367359JJK and 015886584JJK <br /> 4 <br />