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V CVSHealth Ms. Florido November 2, 2018 Page 3 Summary. As discussed above, the store's EPP Summary is considered part of the CVS Contingency Plan. The evacuation plan is also included in the contingency plan document. CVS locations are equipped with a sounding fire alarm system, a pull station to activate the alarm, a back door alarm, and an automatic smoke detection system. The fire alarm is a signal of evacuation and indicates that all colleagues and customers should evacuate the store. The contingency plan document, on page 12, describes the evacuation plan and all store colleagues should follow the CVS Emergency Procedures plan, available on-site. Hazardous Waste Manifests Your item#114 relates to sending generator manifest copies to the California Department of Toxic Substances Control (DTSC). We have confirmed that CVS's hazardous waste hauler, Stericycle, provides copies of generator manifests to DTSC on behalf of CVS for all hazardous waste pickups at CVS stores in California. However, out of an abundance of caution, we have requested Stericycle to resubmit manifests numbers 0 1 1434102FLE, 011434101FLE, ffM7243FLE, 011387244FLE,-OM 76084FLE, O- 76083FLE, 60g629254FLE, 008629256FLE, 0101 77074FLE,-008553729FLE, and 008-679999FLE. Attached please find the referenced manifests. Hazardous Waste Training Your item#118 relates to completion of training on hazardous waste management and emergency response procedures. We understand that during your inspection you observed inconsistencies related to damages processing and onsite management of hazardous waste items. Below, we address each area of concern. Final Disposition Coding CVS has developed a sophisticated waste determination process that relies on the radio frequency unit (RF unit or "scan gun") used to track all inventory for every store in our network. The RF unit is tied to a database of ingredient-level information supplied by the product manufacturer that allows a third-party vendor (the WERCS) to identify hazardous characteristics and generate program logic within the database. Items that are "hazardous" under RCRA, or by state regulation, when disposed are flagged in the computer program that feeds the RF unit. This process also allows CVS to incorporate a number of conservative assumptions regarding waste determinations that help ensure that waste is being managed both properly and consistently at its stores across the country. Because of the nature of the retail industry, and the large and ever-changing retail and pharmaceutical inventories maintained by CVS and other retailers, making a hazardous waste determination in the absence of some sort of automated process that is integrated with our inventory system, presents serious logistical challenges. The RF unit logic is connected directly to the WERCS database of ingredient information so that the M pharmacy / caremark/minute clinic/ specialty