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ROGERS ,JOSEPH O'DONNELL www.rjo.com Elianna Florido, REHS San Joaquin County Environmental Health Dept. July 24, 2020 Page 2 106: Failed to Train Employees on Waste Handling And Emergency Procedures (106, 403,605). Those Walgreens' employees with hazardous waste responsibilities have been trained and have completed a program of online training at the store level, in addition to refresher training in person with management. Walgreens also provides multiple store level references for assistance with waste classification and labeling. Walgreens' hazardous waste training program provides employees with specific information about hazardous waste classification and handling, which includes use of a variety of aids for classification, and training on observance of the nature and state of the items and placement of waste in appropriately labeled containers in accordance with the CA hazardous waste laws. This proprietary and confidential training program includes proper use of labels and instruction for completion; an exemplar label is attached hereto. Any failure to place the waste in the appropriate container or attach and complete an appropriate waste container label was a temporary inadvertent employee error; management has reviewed proper procedures with employees with hazardous waste handling responsibilities and refreshed training for all responsible employees. Any failure to place waste in the appropriate container was corrected at the time of inspection and any failure to attach and fully complete an appropriate waste container label has been corrected. 108: Failed to Complete, Sign or Date Manifest; or Obtain Dated Signature of Transporter. Walgreens' environmental contractor manages hazardous and acute hazardous waste, prepares the manifest and transports the waste in accordance with the CA hazardous waste laws and federal D.O.T requirements. Walgreens' environmental contractor also assures that a copy of the manifest is delivered to DTSC and each manifest is available electronically at store level. Walgreens' environmental contractor properly handled and transported the empty warfarin containers, completed the manifest, and delivered the signed and dated manifest to DTSC, making a copy available electronically to the store. You have cited an August 2, 2018 letter from DTSC to the California Retailers Association repeating DTSC's conclusion in a December 24, 2015 letter stating that under California law, health care providers must manage warfarin containers emptied under normal conditions as hazardous waste and count the empty container toward generator status. Walgreens disagrees with DTSC's position taken in both its December 24, 2015 letter and its August 2, 2018 letter. There is nothing in those letters that explains why or on what legal or scientific basis the container itself must be weighed toward generator status. Although warfarin is listed as an acute waste, the miniscule amount of residue, if any, determined through testing, shows it would take millions of bottles to make 1 lb. of residue. What each DTSC letter does state is that California does not agree with U.S. EPA's approach in not managing these empty bottles as hazardous waste, and that"DTSC will review this issue again when U.S. EPA's rules 514079.1 A Professional Law Corporation