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SAN 10AQUIN Environmental Health Department <br /> COUNTY Linda Turkatte, REHS, Director <br /> c' e <br /> Greatness gnaws sere. <br /> Kasey Foley,REHS,Assistant Director <br /> gCiFOF� <br /> PROGRAM COORDINATORS <br /> Robert McClellon,REHS <br /> Jeff Carruesco,REHS,RDI <br /> Willy Ng,REHS <br /> Muniappa Naidu, REHS <br /> Michael Kith,REHS <br /> June 4, 2019 <br /> VIA EMAIL <br /> Nicole Wilkinson <br /> CVS Health <br /> One CVS Drive—MC2340 <br /> Woonsocket, RI 02895 <br /> nicole.wilkinsongcvshealth.com <br /> (401) 770-7132 <br /> Re: San Joaquin County CVS Pharmacy locations - Hazardous Waste Inspections <br /> Dear Ms. Wilkinson, <br /> i <br /> The San Joaquin County Environmental Health Department(EHD) is in receipt of your return to <br /> compliance (RTC) letters in response to our Inspection Reports issued to each CVS Pharmacy store <br /> located in San Joaquin County. Thank you for your responses. The following is the EHD's response to <br /> two primary subjects discussed in your letters. <br /> 1 <br /> Counting Contaminated Warfarin Containers <br /> The EHD will continue to follow the Department of Toxic Substances Control's (DTSC) <br /> most recent reaffirmation, stated in the letter dated August 2, 2018,to continue to regulate the whole <br /> contaminated container as hazardous waste and not just the residual inside,per California Code of <br /> Regulations, title 22, section 66261.7(r).1 The EHD will continue to follow this position until DTSC <br /> formally changes their position on the subject, if at all. Thus, as stated in DTSC's 2018 letter, <br /> "California healthcare facilities (hazardous waste generators)must include the weight of the container <br /> and residue when completing a Uniform Hazardous Waste Manifest. The combined weight counts <br /> toward generator status."2 <br /> Reverse Distribution of RCR,4 Waste Pharmaceuticals <br /> The EHD will continue to regulate expired RCRA pharmaceuticals as hazardous waste, and thus <br /> will cite violations identified at the time of inspection relating to the improper management of <br /> hazardous waste. This decision is based on Assembly Bill No. 1442,which amended the Medical <br /> Waste Management Act (MWMA)to read expired pharmaceuticals (Non-RCRA only) are not <br /> 1 Ellen L.Haertle,Request to Reconsider The Regulatory Status of P-Listed RCRA Hazardous Waste Containers <br /> (Correspondence from Ellen L.Haertle to Angie Manetti),Department of Toxic Substance's Control, Sacramento,CA, <br /> 2018. (enclosed) <br /> 2 Ibid. <br /> 1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com <br />