Laserfiche WebLink
Facility Certification of Return to Compliance <br /> Target Store T2347 <br /> 2 <br /> Violation#21 66265.173(a)CCR <br /> The clear container observed was used to bring damaged products to receiving and was not being used as <br /> a waste storage container. All hazardous waste containers are kept closed at all times unless actively <br /> adding or removing items. <br /> Violation#27 66262.40(a)CCR <br /> The store photo lab has not yet shipped any photo waste. <br /> Violation#30 25160.2 HSC <br /> All waste manifests(3)are on-site and available for review. They are also enclosed for your records. <br /> Violation#93 40 CFR 262.34(d)(5)(iii) <br /> Store team members are trained on managing hazardous chemicals, including dealing with chemical <br /> spills. Store leadership has addressed spill clean procedures at several recent team huddles(team <br /> meeting)to ensure a consistent process. <br /> Violation#57 66265.17 CCR <br /> The Environmentally Sensitive Items Management(ESIM)program segregates products that are not for <br /> donation and marked as environmentally sensitive into five categories: (1)flammable/aerosol/toxic,(2) <br /> corrosive(basic),(3)corrosive(acidic),(4)oxidizer,and(5)state regulated.The store receiving specialist <br /> is utilizing the ESIM sorting poster to determine the correct tote for each item based on product type. <br /> This ensures that incompatible products are segregated. <br /> Violation#75 &#76 66273.13-66273.15 CCR <br /> Spent fluorescent lamps are stored in a lamp tracker box with a universal waste label. See enclosed <br /> picture. <br /> Violation#78 66273.16 CCR <br /> The section you cite in your inspection report is a reserved section with no regulation. The only universal <br /> waste training section that we found was CCR Section 66273.36,which does not apply to"[p]ersons who, <br /> in the course of their normal duties,only generate universal wastes from onsite sources and place them in <br /> accumulation containers, areas or locations." CCR Section 66273.36(a)(2).Target's universal waste is <br /> generated onsite,and we do not believe that this training requirement applies.However,Target has <br /> established best practices for the appropriate handling of universal wastes.Facilities Management <br /> Technician,Robert,has reviewed these procedures. <br /> Violation#90 CFR 262.34(d)-(f),66262.34(d)(22)CCR <br /> Agency telephone numbers posted at all phones with external lines have been updated. <br /> Violation#93 118000 and 118215 HSC <br /> Genco Pharmaceutical Services(GPS)has developed a web-based tool that allows the pharmacist to input <br /> the National Drug Code(NDC)of the pharmaceutical that needs to be returned(e.g. damaged,expired <br /> product)to determine if it can be returned or if it meets the designation of a hazardous or medical waste. <br /> If the pharmaceutical does meet the definition of a hazardous or medical waste,the pharmacist can not <br /> execute the return process to GPS. Instead they are prompted to place the pharmaceutical in a satellite <br /> waste container located in the pharmacy. Target utilizes Clean Harbors to transport and incinerate the <br /> waste pharmaceuticals. <br /> As discussed above,we take your inspection report very seriously and wish to work with the County to <br /> resolve this matter. However,we also are concerned that the County's interpretation of the applicable <br /> rules is at odds with the State of California's interpretation and those of other agencies. We are also <br /> Corporate Risk and Responsibility, 1000 Nicollet Mall, TPN-1132, Minneapolis, MN 55403 <br />