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CONFIDENTIAL BIC Head Quarters-4900 E Dublin Granville Rd Columbus, OH 43081 LOTS Region 6-19331 Soledad Canyon Road Canyon Country, CA 91351 Observation:#106 CCR 66262.34(4)(2)Failed to train employees on waste handling and emergency procedures. Contrary to the statement in the report, proper training of all employees within 30 days of employment had occurred. An error by an employee does not mean that he or she was not adequately trained. It simply means they erred. Contrary to the observation, all training was up to date. Notably, the inspector reviewed the training records at the time of inspection and observed all managers had been trained between 5/13/2019-5/18/2019. Regardless, in response to the concerns of the inspector, store leadership was retrained on the importance of making hazardous waste determinations at time of occurrence (see attached proof of retraining and training materials titled Haz. Waste 201). Leadership was also retrained on proper use of the Underwriters Laboratories WERCSmart iPod application and Big Lots Haz Waste Program documentation to make all hazardous waste determinations. All new store employees will continue to be trained within 30 days of hire and recertified on an annual basis. District and Regional leadership will continue to regularly audit these training records to verify completion. Observation:#109 CCR 66262.23(a)(4)Failed to send generator manifest copies to DTSC within 30 days. In response to the above discrepancy, a copy of manifest 002175713PSC (4/2/19) was mailed to DTSC and Big Lots Stockton 1916. Copies of manifests 001994704PSC (10/10/2018) and 001913343PSC (7/23/2018) have been mailed to the DTSC. Observation:#110 CCR 66262.40(a)Failed to keep signed copy of manifests from the designated facility for three years. AND Observation:#111 CCR 66262.42(a)(c)(d)Failed to comply with uniform hazardous waste manifest exception requirements. Contrary to the report, signed copies of all manifests were retained and available at Big Lots corporate headquarters and were readily available for production and inspection. As the regs do not specify where the manifests must be kept, Big Lots hazardous waste management program (in consultation with outside counsel and the relevant California District Attorneys) utilizes centralized data management at its corporate headquarters for efficient and reliable storage of the manifests. As such, copies of manifests referenced as missing in inspection report on 6.27.2019 were available at the time of the inspection. In response to the report, copies of 3 years' worth of manifests were mailed to the DTSC Report Repository on 8.1.2019 and are attached with this letter (see attached copies of manifests referenced in inspection report).