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V CVSHealth Ms . Florido March 8 , 2019 Page 3 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 66261 . 7(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) . (Emphasis added) . DTSC further stated : When DTSC observes a hazardous waste that is comprised of non- empty containers having RCRA P - listed hazardous waste residues inside them, DTSC considers the entire container and residue combination as " the hazardous waste " that must be properly managed to protect human health and the environment . Accordingly, generators must include the weight of the container and not just the mass of container residue when computing the amount of acute hazardous waste generated (i . e . handling each residue and its associated container as a whole entity of hazardous waste) . (Cal . Code Regs . , tit . 225 § 66261 . 100 , subd . (a) (2) . ) DTSC reaffirmed its position regarding empty containers in a letter dated August 2 , 2018 . We do not dispute that the California regulatory language is somewhat different than federal regulations . However, there is an interpretation much more appropriate than DTSC ' s prior �; pharmacy / caremark / minute clinic / specialty