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V CVSHealth <br /> Ms . Florido <br /> March 8, 2019 <br /> Page 4 <br /> interpretation, yet still fully protective of human health and the environment. It is important to <br /> not overlook that California ' s regulation states that empty containers must be managed as a <br /> hazardous waste . California' s regulation does not say that empty containers must be counted <br /> toward a facility ' s generator status because containers do not meet the definition of hazardous <br /> waste under California regulations . See 22 CCR 66261 . 3 . <br /> Based on the 2015 DTSC letter discussed above , which states that DTSC may revisit the <br /> empty container issue when EPA issues the Pharm Rule , we anticipate that DTSC is likely to <br /> reevaluate its position on empty containers . In the meantime, based on (i) EPA ' s data and <br /> conclusions — namely that EPA has investigated and determined that very small amounts of <br /> residues remain in containers after pharmaceuticals are dispensed , and EPA ' s ultimately decision <br /> to not require management or counting of the residue or containers as hazardous (or acute <br /> hazardous) waste ; and (ii) California regulatory language clearly states that non-empty <br /> containers must be managed as hazardous waste, we request that the County conclude that <br /> CVS ' s management requirements for containers that previously held warfarin are compliant with <br /> California regulations . Importantly, CVS manages all containers that previously held warfarin- <br /> family pharmaceuticals as hazardous waste during hazardous waste accumulation at the store <br /> level and when transported, and all containers that previously held warfarin are ultimately <br /> incinerated . CVS ' s approach provides protection to human health and the environment well <br /> above the protection that EPA has concluded (in the Pharm Rule) is warranted , and counting <br /> warfarin empty containers toward CVS ' s generator status would provide no additional <br /> protection . CVS ' s management requirements also comply with the "management" requirement <br /> of the California regulations . <br /> Item 115 relates to maintaining copies of manifests onsite . To address your concern, we <br /> have obtained the TSDF signed copy of manifest number 011434014FLE , which is attached here <br /> for your reference . Please note that, as part of the Hazardous Waste Program , these manifests are <br /> available electronically at the store level through the Environmental Health and Safety Reports <br /> Portal . We understand that at the time of your inspection, just the LDR Form had been uploaded <br /> to the portal in error . We are working with our waste vendor to re-push these manifests with <br /> complete scanned images to the portal . <br /> Item 116 relates to completion of hazardous waste manifest exception reports for <br /> manifest number 011434014FLE . As you know, an exception report is required if a generator has <br /> not received a copy of a manifest with the handwritten signature of the owner or operator of the <br /> designated facility within 45 days of the date the waste was accepted by the initial transporter . <br /> Hazardous waste manifests generated at CVS Health retail locations are tracked at the corporate <br /> level to ensure the final destination copies are uploaded into the EH& S Portal in a timely manner <br /> by our vendor Stericycle . To address your concern, we have obtained the TSDF signed copy of <br /> this manifest, attached here for your reference . <br /> M pharmacy / caremark / minute clinic / specialty <br />