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Facility Certification of Return to Compliance Target store T0853 3 environment. Rather, the entire purpose of sending the pharmaceuticals to Carolina Logistics is to make sure that the returned product is handled properly. Target also obtains value in the form of a credit confirming the status of the returned materials as a product. Because Target sends products to Carolina Logistics for reuse and reprocessing, it does not qualify under the definition of a waste under the Medical Waste Management Act. Cal. Health& Safety Code § 117690. To qualify as medical waste,the material in question must actually be a waste product. The California Health and Safety Code defines"waste"to mean: [A]ny solid, liquid, semisolid,or contained gaseous discarded material. Cal. Health and Safety Code § 25124. Here,there is no discarded product by Target, but instead, it is sent to Carolina Logistics for proper handling and value for the product is returned to Target. As the U.S. Environmental Protection Agency has stated, a product that is returned to and accepted by a supplier for resale or reprocessing is"not being discarded by the wholesaler, retailer or user and is not a hazardous waste." 45 Fed. Reg. 78540,Nov. 25, 1980. EPA explained the policy "avoid[s] causing many thousands of wholesalers, retailers and users from becoming generators of hazardous wastes because they will be able to return the materials for reuse instead of possibly discarding them." Id. at 78541. EPA further stated that pharmaceutical products returned to dispensers for credit have a monetary value to the dispensers and are not wastes. The California Department of Health Services has confirmed this understanding in its Self-Assessment Manual for Proper Management of Medical Waste, prepared with the California Healthcare Association. The Manual states that pharmaceuticals are not waste when they are returned or reprocessed. The manual explains that the MWMA"precludes materials that have intrinsic value(such as outdated pharmaceuticals that are returned for credit)from being classified as a medical waste. Accordingly, we believe Target's use of Carolina Logistics is the safe and appropriate way of dealing with these items. Please feel free to contact me directly with questions at (612) 304-8635 or by email at Aaron.Anderson@Tary,et.com. Thank you Sincerely, Target Corporation Aaron Anderson Environmental Compliance Coordinator at Perry Senior Group Manager Enclosed: Waste manifest 003302542JJK and LDR Contingency plan emergency information posting Environmental Services, 33 South 6th Street, CC-3735, Minneapolis, MN 55402