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Nicole Wilkinson <br /> rC "OHealth 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 28 , 2019 <br /> VIA UPS <br /> Ms . Elianna Florido ij <br /> San Joaquin County t ; , <br /> Environmental Health Department PR 01 2019 <br /> 1868 East Hazelton Ave . <br /> Stockton, CA 95205 ENVIPONMENTAL HEALTH <br /> (209) 468 - 3420 DEPARTMENT <br /> Re : CVS Pharmacy, Inc . , Store 16294 , Inspection Report Issued on March 15 , <br /> 2019 . <br /> Dear Ms . Florido : <br /> CVS Pharmacy, Inc . (CVS ) is in receipt of your Inspection Report (Report) issued to <br /> CVS Store 16294 on March 15 , 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 <br /> shipment of empty warfarin containers . Specifically, your concern pertains to the weight listed <br /> on several manifests showing shipment of empty containers with warfarin residue . Your <br /> inspection report correctly noted that the manifest does not appear to include the weight of the <br /> empty warfarin containers in the total amount of hazardous waste generated . Because this issue <br /> involves an analysis and history of both federal and California regulations and agency guidance <br /> to appreciate our current position and management practices , we offer the following explanation <br /> of why we assert that in California, an empty warfarin container must be managed as a hazardous <br /> waste, but because the container, as opposed to its residue , does not meet the definition of a <br /> hazardous waste under 22 CCR 66261 . 3 , the weight of the container should not be counted or <br /> included as a hazardous waste on the manifest . <br /> As you may know, on November 4 , 2011 , U . S . EPA issued a memorandum titled <br /> Containers that Once Held P-Listed Pharmaceuticals , in which EPA clarified that "it is only the <br /> residue in the non-RCRA-empty container that is considered a P -listed hazardous waste ; the <br /> container itself is not a hazardous waste . Accordingly, it is only the weight of residue in the <br /> C" pharmacy / caremark / minute clinic / specialty <br />