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V CVSHealth Ms . Florido March 8, 2019 Page 3 managed as non-hazardous waste pharmaceuticals , so long as the pharmaceutical product has been fully dispensed . The specific studies – two from stakeholders ; one from Riverside County, California ; and one from EPA ' s Office of Research and Development – and EPA ' s conclusions regarding these studies are discussed at 80 Federal Register 58051 through 58054 of the proposed Pharmaceuticals Rule . These pages are attached . 2 . EPA emphasizes that allowing empty containers to be managed as non-hazardous waste without first triple rinsing the containers will decrease sewering of warfarin residues. EPA notes that in healthcare settings , if containers are triple rinsed, the rinsate will likely be poured down the drain, which is not good environmental practice . " [EPA] think [s] it is important that the residues be managed in a more controlled manner—such as in municipal solid waste landfills—rather than poured down the drain . 3 . EPA carefully assessed whether destruction of empty warfarin containers is warranted and ultimately determined that destruction is not necessary. Although EPA ' s proposed rule would have required destruction of empty containers , EPA ultimately did not finalize the requirement to destroy the empty containers prior to disposal , given the potential for worker safety concerns if required to crush or shred the containers . We emphasize the above points from the Pharm Rule because EPA carefully considered whether residue and empty containers should be managed as hazardous (or acute hazardous) waste . Based on (i) data (such as the studies that EPA reviewed) supporting the conclusion that very little residue remains in containers after the pharmaceuticals are dispensed, and (ii) for policy reasons (such as avoiding sewering of residues after triple-rinsing) , EPA determined that it is not appropriate to manage the residues or containers as hazardous (or acute) hazardous waste . California. We are aware that prior to EPA ' s publication of the Pharm Rule , DTSC issued a December 24 , 2015 interpretation rejecting EPAs November 4 , 2011 memorandum regarding empty containers . DTSC interpreted California' s regulations as more stringent than federal regulations and stated : "The distinction between the regulations is that the federal regulation specifically addresses the ` Residues of hazardous waste in empty containers ' . . . and California ' s regulation addresses the ` Contaminated Containers ' as whole entities . " The DTSC letter quoted California Code of Regulations , title 22 , section 662613 (r) : Any container, or inner liner removed from a container, which previously held a hazardous material , including but not limited to hazardous waste, and which is not empty as defined in subsection [ . . . ] (d) of this section, . . . shall be managed as a hazardous waste in accordance with this division and Chapter 6 . 5 of Division 20 of the Health and Safety Code (commencing with Section 25100) . CVS pharmacy / caremark / minute clinic / specialty I