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Elianna Florido, REHS <br /> San Joaquin County Environmental Health Department <br /> Registered Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br /> P: (209)468-0343 1 F: (209)468-3433 1 E: eflorido@slgov.org <br /> Please note that my email has changed to eflorido@sigov.org <br /> From: Middleton, Debbie<DMiddleton@Sallybeauty.com> <br /> Sent: Wednesday, May 15, 2019 11:01 AM <br /> To: Florido, Elianna <eflorido@sogov.org> <br /> Cc: Caldwell, Sheri<SCaldwell@Sallybeauty.com> <br /> Subject: RE: Cosmoprof&Sally Beauty Stores Haz Waste Inspections Follow-Up <br /> Importance: High <br /> Hello Elianna, <br /> Because of the file size,the requested manifests and SDSs have been uploaded to our BOX account. I will send you an <br /> invitation for access here shortly. <br /> With respect to your request for waste determinations, as previously noted, CCR 66262.11 specifies how generators are <br /> to make waste determinations; under subsection (b), listed wastes are presumed to be hazardous unless the generator <br /> has testing or generator knowledge to support a non-hazardous waste determination. SBH manages listed wastes as <br /> hazardous based on their listing and does not seek to exclude such wastes from regulation based on either testing or <br /> generator knowledge. No records are required for such determinations because they are based on regulatory <br /> listings. Subsection (b) provides that, for wastes that are not listed,the waste determination can be made based upon <br /> either testing or generator knowledge. SBH relies upon generator knowledge and training to make such waste <br /> determinations. Like most retailers,the basis of that knowledge is the classification scheme reflected in the SBH <br /> Hazardous Material Management poster displayed in the storage area,the HW Training Guide, HW Categorization <br /> Supplement, Safety Data Sheets, and any other relevant information that suppliers may provide to retailers. SBH does <br /> not individually evaluate each of the thousands of products its carries but instead relies upon general product classes for <br /> management;for example, aerosols, astringents, fragrances, hair sprays and nail polishes are indicative of the types of <br /> products that would be considered flammable. Employees are trained to look for these and similar products and <br /> management them accordingly. See the attached copies of the training documents mentioned, and as requested,the <br /> specific SDSs for the products at issue are in a file in BOX, a link to which will be issued directly. <br /> I trust you will find this responsive to your request and will close out the noted violations for our respective CosmoProf <br /> and Sally Beauty Supply stores in San Joaquin County, CA. <br /> Please let me know if you have further questions or concerns. <br /> Kind regards, <br /> Debbie <br /> Debbie Middleton <br /> Senior Paralegal,Environmental Compliance and Litigation <br /> Sally Beauty Holdings,Inc.I Sally Beauty Supply LLC I Beauty Systems Group LLC I Arcadia Beauty Labs LLC <br /> 3001 Colorado Blvd., Denton,Texas 76210 <br /> 4 <br />