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1 <br />2 <br />3 <br />4 <br />5 <br />6 <br />VA <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />26 <br />27 <br />28 <br />4.2 Reverse Distribution of Pharmaceuticals <br />4.2.a. Beginning no later than December 1, 2013, Defendant shall work with or continue <br />working with appropriate stakeholders from business and government, including the U.S. <br />Environmental Protection Agency, the U.S. Food and Drug Administration, the California <br />Department of Public Health and DTSC, either directly or through trade associations or informal <br />coalitions of interested parties, undertaking to promote federal regulatory reform regarding the <br />proper management of non -dispensable pharmaceuticals, including over-the-counter medications, <br />through "reverse distribution." Such work may include coordination and communication with <br />national retail trade associations. Progress on such work shall be included in the status reports <br />required by Paragraph 22 below. <br />4.2.b. During the term of this Final Judgment, the People shall only pursue a violation of <br />this Final Judgment or applicable law regarding the reverse distribution of pharmaceuticals if <br />Defendant is unable to demonstrate reasonable diligence in performing work on the federal <br />regulatory reform described in subparagraph 4.2.a above. For the purposes of this paragraph, <br />"pharmaceuticals" shall have the same meaning as "drug" as defined by the Federal Food, Drug, <br />and Cosmetic Act, 21 USC §321(g). Nothing herein shall prevent the People from pursuing <br />appropriate enforcement of this Final Judgment or applicable law regarding the reverse <br />distribution of non -dispensable pharmaceuticals for acts or omissions in violation of applicable <br />law occurring on or after one hundred eighty (180) days following receipt by Defendant of <br />written notice as provided by Paragraph 8 of the People's intent to do so. The Parties shall <br />attempt to resolve any such dispute by means of good faith informal negotiations. <br />5. CIVIL PENALTIES, SUPPLEMENTAL ENVIRONMENTAL PROJECTS, <br />COSTS, AND HAZARDOUS WASTE MINIMIZATION <br />Defendant shall, within twenty-one (21) business days after entry of this Final Judgment, <br />pay civil penalties, fund the supplemental environmental projects provided for in this Final <br />Judgment, and pay costs in the manner as set forth in Paragraphs 5.1, 5.2, 5.4, and 5.5 below. <br />Within twenty-one (21) business days after entry of this Final Judgment, Defendant shall deliver <br />all required payments to the District Attorney's Office for the County of San Joaquin, Attention: <br />7 <br />STIPULATION FOR ENTRY OF FINAL JUDGMENT AND PERMANENT INJUNCTION <br />