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VCVSHealth Ms . Florido March 8, 2019 Page 9 all violations related to reverse distribution of non- saleable , potentially creditable , pharmaceuticals were cleared on September 13 , 2017 . Although CVS does not agree that whether an item will receive credit is the appropriate test to determine whether a retailer is appropriately using reverse distribution, we do agree that Santa Clara appropriately chose not to focus on whether pharmaceuticals sent to Genco were expired . CVS Final Judgment Last, as you know, on April 16 , 2012 , CVS entered a Final Judgment with the State of California, which was entered into by San Joaquin County, among other counties . Paragraph 4 . 2 (a) of the Final Judgment requires that CVS initiate work and stay active in "federal regulatory reform regarding the proper management of nondispensable pharmaceuticals , including over-the- counter medications , through ` reverse distribution . " ' As you may know, CVS was very involved in the California retailer working group — comprised of retailers , regulators, and California District Attorneys — regarding state regulatory reform on these issues . CVS remains involved in both California and national reform efforts on these issues , through CVS ' s own efforts and the efforts of industry groups , such as the Retail Industry Leaders Association and the National Association of Chain Drug Stores . Paragraph 4 . 2 (b) of the Final Judgment requires that "the People shall only pursue a violation of this Final Judgment or applicable law regarding the reverse distribution of such nondispensable pharmaceuticals if [CVS] has failed to demonstrate reasonable diligence in performing work on the federal regulatory reform described in subparagraph 4 . 2 (a) , " and only after a ninety-day advance notice had been provided by "the People " of an intent to resolve any dispute regarding proper reverse distribution . Because the Final Judgment was a joint agreement with many jurisdictions , we would expect that any such advance notice of dispute with CVS ' s reverse distribution process would involve all parties to the Final Judgment and would follow the notice and dispute resolution requirements of this Final Judgment at Paragraph 4 . 2 and 15 . Based on the above, we respectfully urge that you reconsider your position with respect to the above-referenced violations related to reverse distribution of pharmaceuticals . Container Labeling Item 605 of your Report refers to the proper labeling of hazardous waste containers . During your inspection you observed a hazardous waste container holding used flu vaccine vials, however, the label did not reflect the correct physical state and contents of the container . Mr. Yerzy met with Ms . Coronel and reinforced the existing training she has been provided regarding the proper labeling of hazardous waste containers . Attached , see photographic documentation that the container has been properly labeled . LIVS pharmacy / caremark / minute clinic / specialty