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S r <br /> c <br /> D4 <br /> t — — 2 <br /> C <br /> `" Always use gloves.Sur <br /> Spill with absorbent ma <br /> �a <br /> I <br /> 1 a <br /> '"the absorbent material <br /> n.l . <br /> Sweep and clean the spill '' <br /> m <br /> s <br /> t <br /> Write bbsorbent and <br /> 9a, <br /> IdlovesfsQ If it - - <br /> i <br /> o <br /> it IS <br /> els hazardous,add b1990 A: <br /> e m ha a tlous waste conta ne/ <br /> G <br /> CIOS� !;. Ste <br /> •• <br /> •• <br /> 00000 Stericycie' <br /> • Environmental solutions <br /> Compliance Announcement <br /> St,-l*fustom <br /> - Oae.. Wade Xheel,OlrM:orol ae8ulatory Aealrs <br /> 11/30/3018 <br /> \�\\ Manifest Copy Distribinion-COPA/CA DTSC Missing Manaest Copies <br /> Comments: It has come to our attention that California CUPA inspectors are including citations or notice <br /> --lull of violations to our customers based upon the fact that the CUPA inspectors are notable to <br /> locate manifest information in the California DTSC's online manifest database.An <br /> t 2 r explanation of Stericycle's position on this matter is provided below. <br /> ry, Please contact me if you have any additional questions or need additional support. <br /> Guard the spill Alwa .. •"M„,� <br /> ys use gloves <br /> ill with absorbent Surr <br /> sp ° '� ... <br /> rbent mma.a.„ 1. There is no regulatory requirement in California for the Generator or Stericycle to <br /> g provide any <br /> evidence or proof of mailing manifests to the DTSC or to confirm or prove the manifests mailed to the <br /> DTSC are actually received.Stericycle does not mail manifest copies to the DTSC using a delivery <br /> ' method that confirms shipment or delivery of the manifest copies,since this is not a regulatory <br /> requirement,and as a result Stericycle does not have documentation or delivery receipts for manifests <br /> y mailed to the DTSC to"prove”delivery.However,we have confirmed that the Retail Client services <br /> 3 L Center,based in Peachtree Corners,GA,mails the Generator copy of manifests to the DTSC within 1-2 <br /> days of shipment,and the TSDF's that receive the shipment send their TSDF signed copy to the DTSC i <br /> WDrp in the \ the same day or next day after receiving the shipment. <br /> absorbent material Stericycle Stericycle encourages* Generators to challenge any citations or NOVs received for manifest copies that� <br /> Sweep and clean the spill are not able to be located on the D7SC's online manifest database.Stericycle has been informed <br /> directly from DTSC and specifically from the group within DTSC that manages the online manifest <br /> access portal that the DTSC is substantially delayed on uploading manifest copies they have received. <br /> The DTSC also informed Stericycle the online system has experience intermittent outages that - <br /> S �. prevented online access to manifest data. The DTSC indicated that all CUPA's had been informed of <br /> t these issues with their online database. <br /> Write 66sorbent " As mentioned above,Stericycle has confirmed that our Client Services Center and TSDF's have always <br /> destr'p don d art aril I been submitting the manifest copies on behalf of our customers to the DTSC.We believe the CUPA's <br /> °n bay 44 are basing these citations and NO'✓s off of their inability to find the manifest copies in the DTSCs <br /> if <br /> ItenT online system.The reason CUPA inspectors are not finding the manifests when they search the <br /> is hazardous,add ayste <br /> item is NOT because the manifests weren't submitted,it is because DTSC has not yet su <br /> hazardoushe a waste co tate <br /> 2850100"CourtNE <br /> /ry�1lVJ( Blaine,MN 55449 <br /> ' www.stericycleenvironmentaLcom <br />