COMPLIANCE INFO_2019 - Laserfiche WebLink

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The materials provided to aid associates in making a hazardous waste determinations are as follows: o Hazardous Material Management poster o Revised Hazardous Waste Training Guide, which includes a decision tree (see copy of Guide) o New Hazardous Waste Categorization supplement (see copy of Supplement) o SDS website o Toll-free number to the corporate office o Re-training of the employees at this location *Please note that because this location is a small-quantity generator there is no recordkeeping requirement. However, Sally has voluntarily re-trained employees at this location and maintained such records to ensure that employees understand the training they have received. Item 109 CCR 66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days. • The generator copies of the two manifests identified in the inspection report have been submitted to DTSC by our third-party vendor. Item 110 CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years. • The signed designated facility copies of the eight manifests identified in the inspection report have been received by the store and put into their hazardous waste binder. • As part of the re-training, associates were refreshed on recordkeeping and documentation requirements,which includes the status of both generator and designated facility copies. • As requested, copies of the two (2) uniform manifests that were not found on site (017367377JJK (12/13/17) and 017416742JJK (6/27/17), respectively) are attached. o Please note that while we provided manifest 017416742JJK(6/27/17) as requested, the manifest is not for this Sally store but rather for a CosmoProf store in Pinole,CA. Item 111 CCR 66262.42(a)(c)(d) Failed to comply with uniform hazardous waste manifest exception requirements. • See above response. Item 401 CCR 66262.34(d)(2) Failed to store hazardous waste in a container that is in good condition. • All bin lids have been replaced. See file titled "Sally Store 10229—Bins." • As a part of the re-training, associates were instructed to check the condition of the bins and lids during their weekly inspection. Item 404 CCR 66262.34(d)(2) Failed to inspect hazardous waste storage areas at least weekly. • The SBH Hazardous Waste Training Guide was revised to include a more robust weekly inspection checklist, see Guide, pages 2 and 3. • As a part of the re-training, associates were required to read the Guide and to immediately implement the more detailed weekly inspection. • Additionally, beginning in February 2019, district managers are now charged with confirming compliance at their respective stores on a quarterly basis,which includes, but is not limited to, ensuring weekly inspections are conducted. See DM Compliance document. Item 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste. a. The words"Hazardous Waste" SBH utilizes preprinted container labels that include the words "Hazardous Waste." b. Name and address of generator The revised Guide instructs store associates to include the entity name (store name) as well as store number for the generator name on the bin label. See attached file titled "Sally Store 10229—Label." 2