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Elianna Florido [EH] From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Wednesday, October 31, 2018 9:40 AM To: Elianna Florido [EH] Cc: Caldwell, Sheri Subject: Response to CosmoProf#9331 - HW Amended Report Attachments: Cosmoprof#9331_1453 W March Ln_2018 HW Amended Report.pdf; HW Emergency Information.pdf, HW Training Log - CP#9331.pdf, 9331- STOCKTON-0285-15884359.pdf, 9331-STOCKTON-0380-15886584.pdf; Return to Compliance Certification - Executed.pdf Importance: High Follow Up Flag: Follow up Flag Status: Flagged Inspector Florido, In response to your amended inspection report of October 4, 2018 for CosmoProf Store#9331 in Stockton, CA, please see the following: Violations 104 CCR 66262.34(d)(2); 105 CCR 66262.34(s)(2) No modified contingency plan; no emergency coordinator CosmoProf responds that the modified contingency plan was completed and posted near the telephones of the store. As the emergency coordinator and alternate emergency coordinator are a part of the information required on the form, both violations have been returned to compliance. Violation 106 CCR 66262.34(d)(2) Failed to train employees on waste handling and emergency procedures There were several aspects of"failure to train" identified under this heading,they are: 1. Facility generator name on hazardous waste bin label Our bin labels are preprinted with "SBH Location#" in the facility name line. "SBH" is the Securities and Exchange Commission ticker symbol for Sally Beauty Holdings, Inc., which is the parent company of Sally Beauty Supply LLC and Beauty Systems Group dba CosmoProf,the operating entities under which our retail stores operate. Therefore, CosmoProf contends that the addition of the store number fully complies with the facility generator name requirement. We also note that prior to transportation by our licensed hazardous waste hauler, new labels with the full generator name are placed on the shipping containers. 2. Physical state of contents on bin label The store manager has been instructed that indicating the physical state of the contents of the hazardous waste bins is a requirement and must be done so going forward. Manager is to train associates accordingly. 3. List of current contents on bin label Unfortunately,the word "Contents" on the pre-printed label is a misnomer. It was never the intention to list all of the products in the store that would fall under a given hazardous waste stream category. Rather,the list of products on the label is to aid the associates in determining the correct category. New labels are being designed which will change the word "Contents"to "Examples." 1