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TARGET <br /> 011841652FLE (6/21/18)— 7/11/18 <br /> 011841653FLE (6/21/18)— 7/25/18 <br /> 011552223FLE (5/29/18)— 6/12/18 <br /> 010278119FLE (2/1/17)— 2/13/17 <br /> - 010278120FLE (2/1/17)— 2/24/17 <br /> - 010261561 FLE (11/10/16)— 12/14/16 <br /> - 009858221 FLE (6/23/16)— 7/15/16 <br /> #3 Failed to complete training on hazardous waste management and emergency response procedures. <br /> (CCR66265.16(a-c)1 <br /> Response: Target's Corporate Compliance team has worked with Store T0738 to review best practices <br /> for properly sorting hazardous waste. Due to the variety of potentially hazardous retail chemicals that may <br /> be generated, all products that will be sold at Target are pre-evaluated for hazardous waste <br /> determinations in case the product becomes unusable and therefore a solid waste. Target uses a third <br /> party company called the WERCs to classify the hazardous waste characteristics and chemical <br /> compatibility of all products that will be sold at Target stores. The WERCs uses SDS sheets along with <br /> ingredient levels to classify each retail product based on EPA/State waste identification and chemical <br /> compatibility. After the classification is completed, the WERCs assigns a Target"smart-sort" label <br /> designation to each product to ensure proper chemical compatibility during storage. Non Retail products <br /> which have been classified as ESIM are brought to Reverse Logistics daily for processing. The store's <br /> product rotation process is separate from the hazardous management process, and the product rotation <br /> process for OTC is currently under review. <br /> The hazardous materials training summary along with Store T0738 training records are attached <br /> [Attachment B]. <br /> #4 Failed to maintain complete personnel training records[CCR 66265.16(d)1 <br /> Response: Target has recently updated training content, however the training documentation will still <br /> show the historic training completions by the store team. Modules that have been replaced are listed as <br /> expired on the report. A copy of the store training records is attached [Attachment B]. <br /> #5 Failed to keep hazardous waste containers closed except when adding or removing hazardous waste. <br /> [CCR 66262.34(171 <br /> Response: Target's Corporate Compliance team has worked with Store T0738 to review best practices <br /> for properly sorting hazardous waste. A photo of the hazardous waste storage area for Store T0738 is <br /> attached showing all containers are properly closed and labeled [Attachment C]. <br /> #6 Failed to completely label containers or portable tanks of hazardous waste. [CCR 66262.34(171 <br /> Response: Target's Corporate Compliance team has worked with Store T0738 to review best practices <br /> for properly sorting hazardous waste. A photo of the hazardous waste storage area for Store T0738 is <br /> attached showing all containers are properly closed and labeled [Attachment C]. <br /> Corporate Compliance&Ethics,33 South 6th Street,CC-3625, Minneapolis,MN 55402 <br />