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V CVSHealth <br /> Nicole Wilkinson <br /> Director Corporate Environmental <br /> One CVS Drive—MC2340 <br /> Woonsocket,RI 02895 <br /> p 401-770-7132 <br /> c 401-256-7615 <br /> f 401-652-1901 <br /> nicole.wilkinson@cvshealth.com <br /> March 29, 2019 <br /> VIA UPS <br /> Ms. Elianna Florido RECEIVED <br /> San Joaquin County <br /> Environmental Health Department APP, Q 1 2019 <br /> 1868 East Hazelton Ave. <br /> Stockton, CA 95205 ENVIRONMENTAL HEALTH <br /> (209) 468-3420 <br /> PERMIT/SERVICES <br /> Re: CVS Pharmacy, Inc., Store 17412, Inspection Report Issued on March 1, <br /> 2019. <br /> Dear Ms. Florido: <br /> CVS Pharmacy, Inc. (CVS) is in receipt of your Inspection Report (Report) issued to <br /> CVS Store 17412 on March 1, 2019. This letter addresses your concerns noted in the above- <br /> referenced Report. Thank you for meeting with me and members of my team (Shannon Slavens <br /> and Chris Yerzy) during the CUPA Conference. We appreciate your willingness to meet and <br /> discuss the CVS Health Retail Hazardous Waste Program and our continued partnership. <br /> Hazardous Waste Manifests <br /> Item 113 relates to Box 11 (Total Quantity) information on manifests related to shipment <br /> of empty warfarin containers. Specifically, your concern pertains to the weight listed on several <br /> manifests showing shipment of empty containers with warfarin residue. Your inspection report <br /> correctly noted that the manifest does not appear to include the weight of the empty warfarin <br /> containers in the total amount of hazardous waste generated. Because this issue involves an <br /> analysis and history of both federal and California regulations and agency guidance to appreciate <br /> our current position and management practices, we offer the following explanation of why we <br /> assert that in California, an empty warfarin container must be managed as a hazardous waste, but <br /> because the container, as opposed to its residue, does not meet the definition of a hazardous <br /> waste under 22 CCR 66261.3, the weight of the container should not be counted or included as a <br /> hazardous waste on the manifest. <br /> M pharmacy / caremark / minute clinic / specialty <br />