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manatt <br /> manatt I phelps I phillips <br /> Elianna Florido <br /> November 16, 2018 <br /> Page 2 <br /> 119—Employee Training Records <br /> Training records for Rite Aid 6000 prior to 2018 are enclosed as Exhibit 2. We are <br /> including for the past 5 years. Additional training records retained by Rite Aid include copies of <br /> historical CBTs (computer based training) used to conduct each year's training (satisfying the <br /> written description of the training provided), and written job descriptions for each person <br /> receiving the training. Due to these size of those historical records, we are omitting them from <br /> this response, but we are happy to make these additional records available for your review. <br /> 403 /605—Processing of Returns /Damages <br /> As noted in the Inspection Report, the procedure used at Rite Aid 6000 is to process all <br /> damages and returns on a daily basis (each morning) Rite Aid, and other retailers, have found <br /> that daily processing of such items, when the task can be assigned to one (or a small number) of <br /> employees, results in improved hazardous waste handling compliance by our stores. The items <br /> listed in the Inspection Report were returns or other items that were awaiting this daily <br /> processing, and as such, a hazardous waste determination had not yet been made on these items. <br /> Because no hazardous waste determination had been made on these items the violations alleged <br /> in the Inspection Report (failure to close containers and failure to label containers) are without <br /> merit. <br /> One exception to this rule to note—Rite Aid's policy is to immediately process any <br /> damaged or returned item (liquid or otherwise)where the potentially hazardous product is or has <br /> the potential to leak from the original packaging. <br /> 605—Labeling of Accumulation Labels <br /> All labels included in the Inspection Report have been fully filled out. Further, during <br /> our in-person re-training (discussed above), proper(and complete) labeling of accumulation <br /> labels was discussed with the store associate at Rite Aid 6000. <br /> Sincerely, <br /> atthew Williamson <br /> 204761895.1 <br />