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SAN10 A Q U I N Environmental Health Department <br /> --COUNTY— <br /> pharmaceutical waste if certain conditions are met.' However,because the MWMA only regulates <br /> Non-RCRA pharmaceuticals, RCRA pharmaceuticals, once expired and thus a waste, are still regulated <br /> as RCRA hazardous waste. <br /> The EHD defers to the letter from the US EPA Office of Solid Waste and Emergency Response <br /> dated May 15, 1991,which states "This view is based on our understanding that the [reverse <br /> distribution] system is established as a means to facilitate the recycling of reusable pharmaceutical <br /> products,rather than a waste management system."4 Currently it has not been demonstrated to the EHD <br /> that the pharmaceuticals are recycled or reused. <br /> Additionally, CVS Health has not demonstrated that their reverse distribution system for <br /> pharmaceuticals is not being used as a waste management service. It is important to point out that the <br /> US EPA letter also states, "...a reverse distribution system cannot be used as a waste management <br /> service to customers/generators without the applicable regulatory controls on waste management being <br /> in place."' <br /> Credit Focus: Santa Clara County <br /> The EHD continues to focus on accurate hazardous waste determinations, 40 CFR 262.11. If <br /> the solid waste is a hazardous waste we will continue to regulate as such. Creditworthiness does not <br /> determine if the item is a waste or not. <br /> Based on the reasons stated above, violations related to counting contaminated warfarin containers and <br /> reverse distribution of RCRA waste pharmaceuticals remain open until corrective action has been <br /> completed. <br /> Should you have any additional questions or concerns, or wish to set up a time for a phone call or in- <br /> person meeting, please feel to contact me at(209) 468-0343 or eflorido@sjgov.org. <br /> Sincerely, <br /> Elianna Florido, REHS <br /> Registered Environmental Health Specialist <br /> 1868 East Hazelton Ave <br /> Stockton, CA 95205 <br /> P: (209) 468-0343 <br /> E: efloridogsj og v.org <br /> cc: Michelle Henry, San Joaquin County EHD <br /> Adriana Morales, CVS Health <br /> Chris Yerzy, CVS Health <br /> Shannon Slavens, CVS Health <br /> 3 Wieckowski,Allen,and Williams,Assembly Bill-1442 Pharmaceutical waste,California Secretary of State, Sacramento, <br /> CA,2012. <br /> 4 Sylvia K.Lowrance,Returned Pharmaceutical Products(Correspondence from Sylvia K.Lowrance to Mark J. Schulz), <br /> US EPA Office of Solid Waste and Emergency Response,RCRA Online(11606),Washington,D.C., 1991. (enclosed) <br /> s Ibid. <br /> 2 of 2 <br />