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TARGE-If RECENED FEB 2 3 2006 February 21, 2006 ENVIRONMENT HEALTH Michelle Le PFR",11IT/SERVICES Registered Environmental Health Specialist San Joaquin County Environmental Health Department 304 E. Weber Ave., Third floor Stockton, California 95202-2708 RE: Inspection Reports, ja,,rget Store T0313, 4707 Pacific Ave., Stockton Store T1862, 10424 Trinity arkway, Stockton Store 0738, 2800 Naglee Road, Tracy Dear Ms. Le: Thank you for the opportunity to respond to your inspection findings at the above referenced Target stores. As the reports are identical, please allow us to respond on behalf of the three stores. As you may be aware, Target has an active nationwide program to reduce, and eliminate where possible, materials that go to solid waste landfills and hazardous waste facilities. At the federal level, Target has incorporated Environmental Protection Agency (EPA) concepts that include, among others, donating "leftovers to someone else to use". Target further recognizes California Integrated Waste Management Board's (CIWMB) promotion of donating products to community organizations to be used for their intended purpose. To this end, Target recognizes that products that may not be saleable due to "imperfections" and not meeting our guest's "standards" have inherent value in that they can be used solely for their intended purpose. For this reason, Target donates useable, viable products that can be safely and effectively used for their intended purpose. Charitable and community organizations, from homeless shelters to battered women's shelters to humane societies have and continue to use these viable products throughout the country solely for their intended purpose, which dualistically eliminates competition for valuable landfill space and keeps useable products out of hazardous waste facilities' waste streams. The following represents Target's response to your inspection. 25189.5 HSC Disposal of HW at an unauthorized point Target is donating useable, viable product with inherent value to charitable and community organizations to be used solely for its intended purpose. Target did not declare nor intend the products to be waste in any manner, therefore, the product packages are not labeled "hazardous waste". Based on the above criteria, the inspection finding is not applicable. 66262.34 CCR "Failed to properly label containers of hazardous waste" As stated above, Target is donating, viable product with inherent value to charitable and community organizations to be used solely for its intended purpose. The products carry the same labels as when packaged by the manufacturer. Target did not declare nor intend the products to be waste in any manner, therefore, the product packages are not labeled "hazardous waste". Based on the above criteria, the inspection finding is not applicable. Environmental Services, 33 South Sixth Street, CC3425, Minneapolis, MN 55402