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TROUTMA N <br /> SANDERS <br /> VIA FEDERAL EXPRESS <br /> Ms. Michelle Henry <br /> June 3, 2011 <br /> Page 2 <br /> daily basis. We expect these procedures to be included in updated Hazardous Waste <br /> Management Program training materials, which will be assigned to management-level store <br /> personnel later this summer. <br /> Likewise, regarding your concern, in violation number 999, with the language <br /> "potentially hazardous waste" and "Hazardous waste pending further evaluation," such language <br /> does not appear on the most recent version of CVS hazardous waste labels that are used on the <br /> totes (see attached). Those stores that currently have an older version of labels have been <br /> instructed to scratch through such language until receiving new labels. Additional revisions to <br /> CVS hazardous waste labels are underway and will be implemented with the next round of <br /> revised training modules. <br /> With respect to the concerns regarding an EPA ID number, in violation number 8, this <br /> store has been assigned EPA ID number CAL000363763, which is now active. DTSC <br /> documentation is attached for your reference. <br /> As to your concern, in violation number 20, that the clear plastic hazardous waste totes <br /> were not properly labeled, we have ensured that all containers have been properly labeled with <br /> all applicable hazardous waste generator requirements. Store management personnel have <br /> received additional training on these labeling and waste characterization requirements. <br /> Additionally,based on your concern regarding closure of clear plastic totes, in violation <br /> number 27, we have ensured that Store 9830 has received follow-up training concerning the <br /> requirement that all clear plastic totes be kept closed at all times except when new items are <br /> being added. <br /> Likewise, regarding your concern, in violation number 52, that hazardous waste <br /> management procedures did not appear to have been adequately provided to store employees, <br /> follow-up training has been provided to store employees regarding proper management of <br /> hazardous waste, including the proper disposal of photo processing waste. In addition, CVS is in <br /> the process of making a number of other improvements that will enhance and expand upon the <br /> hazardous waste training provided at the store level. Specifically, CVS has modified its <br /> pharmacy training module to help clarify the roles and responsibilities of pharmacy personnel <br /> and has added a general awareness training module that will be provided to all non-management, <br /> non-pharmacy personnel, including photo personnel. Copies of these draft modules were <br /> provided to the District Attorney task force earlier this year. These modules are currently under <br /> revision, and we expect that this additional training will be implemented in CVS stores in <br /> California later this summer. <br /> Based on the above, we believe the concerns expressed in your Inspection Report have <br /> been effectively addressed. Please do not hesitate to contact me with any additional questions or <br /> concerns. <br /> 2276465vl <br />