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San Joaquin County Environmental Health Department 1868 East Hazelton Avenue, Stockton, California 95205-6232 Telephone:(209)468-3420 Fax:(209)468-3433 Web:www.sogov.org/ehd RCRA Large Quantity Hazardous Waste Generator Inspection Report Facility Name: Facility Address: Date: TARGET T0853 2355 W KETTLEMAN LN, LODI March 08, 2019 SUMMARY OF VIOLATIONS (CLASS I,CLASS II,or MINOR-Notice to Comply) Item# Remarks 118 CCR 66265.16(a-c) Failed to complete training on hazardous waste management and emergency response procedures. Based on the types of violations observed,the facility employees are not trained on proper hazardous waste(HW) handling or the training provided has been inadequate. The following observations were made at the time of inspection: -A leaking container of Coppertone sunscreen was found double bagged and labeled as ST for State Regulated Waste, but found in a HW tote labeled FL for Flammable/Aerosol/Toxic(IMG 4817-4818). Marcy Castilla, a logistics team member for receiving/reverse logistics, placed the Coppertone sunscreen into a HW tote for State Regulated Waste at the time of inspection. -A Mad Mttr quantum pod in the color teal(containing a type of putti or molding material),was found bagged, labeled as ESIM, and in a HW tote labeled ST for State Regulated Waste(IMG 4819-4821). Marcy scanned the item using a hand-held scanner,which prompted her that the item was to be sorted as ESIM (IMG 4822).When asked how this item was determined to be placed in the HW tote for State Regulated Waste, Marcy stated she knew which tote the item should be placed in based on the amount of time and experience she has worked with Target. Marcy stated she has scanned items that are similar to the Mad Mttr quantum pod, and which are indicated by the hand-held scan gun to be placed in the HW tote for State Regulated Waste. Marcy did not seem aware of who to ask or what to do when questions come up regarding an item's hazardous waste determination. -An open tote labeled MJ Holding Last Vendor Credit Date 2/27 was found containing two bagged Erin Studios Toy Balls,which were leaking a slime-like material(IMG 4823-4824,4826,4828). Each toy ball had a Target label affixed to the item stating"Defective Attach slip to Item Place Item in Box E"and a date of 2/26/2019 or 3/3/2019 (IMG 4825,4827).When Marcy scanned one of the toy balls,the hand-held scanner prompted her that the item was to be sorted as ESIM(IMG 4830). Marcy stated that vendor items, such as the toy balls found, are placed in separate totes, all of which were open at the time of inspection, depending on which vendor the item is from. Marcy stated that if a vendor item is damaged or broken,the item is still placed in the appropriate vendor tote, until the vendor arrives at the facility and scans the damaged/broken items out of their inventory. Marcy stated she will then manage the damaged/broken items as hazardous waste, if applicable. Marcy stated in the case of the leaking toy balls, she would eventually place them in the HW tote for State Regulated Waste, based on knowledge of similar items she has scanned in the past, and was then prompted by the scanner to place those items in the State Regulated Waste tote. Marcy did not seem aware of who to ask or what to do when questions come up regarding an item's hazardous waste determination. -An empty container of Sealed Air Dry Foam Shampoo& Encapsulation Cleaner was found bagged inside a purple tote labeled ESIM Donate Only, located on a shelf adjacent the hazardous waste storage area(IMG 4832-4833). Marcy stated the empty cleaner container should not be in the donation bin, and another employee may have placed it in the bin by mistake. Marcy removed the empty shampoo container and placed it in a HW tote for State Regulated Waste. Personnel who handle hazardous waste shall be trained within six months of assignment and take part in an annual review of the initial training received. At a minimum,the training program shall be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: 1. procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; 2. key parameters for automatic waste feed cut-off systems; 3. communications or alarm systems; FA0006403 PR0525998 SCO01 03/08/2019 EHD 22-03 Rev.09/22/16 Page 8 of 10 RCRA Large Quantity Hazardous Waste Generator OIR