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V CVSHealth Ms . Florido October 12 , 2018 Page 2 If an item is determined to be hazardous waste, the RF Unit provides direction to store colleagues to bag the item into a self- sealing hazardous waste bag and place into the appropriate hazardous waste container . There is a separate tote for each of the following : Flammables , Flammable Aerosols and Combustibles ; Corrosive Acids ; Corrosive Bases ; Oxidizers ; Toxics & State Regulated Wastes ; and Universal Waste . The program prohibits any free liquids , whether contained in a self- sealing bag or not . Any item that is leaking or likely to leak must be double- bagged with absorbent to ensure that no free liquids are placed into the hazardous waste container It appears that during your inspection , you observed scanned items leaking without absorbent added, including a container of motor oil . The CVS ' s hazardous waste management program requires stores to process damages daily . Each item must be placed into self-sealing hazardous waste bags that serve as the initial container for each waste item , and they are required to remain closed except when adding waste . The program prohibits any free liquids , whether contained in a self- sealing bag or not . Any item that is leaking or likely to leak must be double- bagged with absorbent to ensure that no free liquids are placed into the hazardous waste container. Accordingly, appropriate store colleagues have been retrained on the proper unsaleables/damages process . On September 7 , 2018 Ted Lukawski , and on September 19 , 2018 Chris Yerzy, CVS Health Environmental Specialists retrained store colleagues at this location on the hazardous waste program, including the importance of placing bagged hazardous waste items into the correct hazardous waste totes in a timely manner, processing unsaleables/damages daily, properly bagging leaking items, and using only hazardous waste totes to store processed hazardous waste items . Attached please photo documentation of the hazardous waste area, showing processed unsaleable items processed and properly segregated into labeled hazardous waste totes . In regard to the open white cardboard box, labeled as "Damages , " and containing unsaleable unprocessed retail items on or near the shelves adjacent the hazardous waste area, these items have been processed to determine if they were hazardous waste , and have been placed in the appropriately labeled hazardous waste container, if determined to be hazardous waste . Appropriate store colleagues have been retrained on proper damages process according to the hazardous waste program, including the importance of placing bagged hazardous waste items into the correct hazardous waste tote in a timely manner, processing damages daily, and using only hazardous waste totes to store processed hazardous waste items . Annual Training/Training Records Regarding the store ' s hazardous waste training, CVS has developed the attached matrix which lists job duties related to hazardous waste management, a description of such duties , and a list of store- level responsible employees by category and job code . This matrix supplements the Training Program Plan and Course Overview on pages 6- 7 of the Program Overview (attached) and applies to all retail store locations . The type and amount of introductory and continuing training provided to store employees is discussed in the Program Overview. (; pharmacy / caremark / minute clinic / specialty