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Nicole Wilkinson <br /> VCVSHealth Director,Corporate Environmental <br /> One CVS Drive—MC2340 <br /> Woonsocket,RI 02895 <br /> p 401-770-7132 <br /> c 401-256-7615 <br /> f 401-652-1941 <br /> nicole.wilkinson@cvsheath.com <br /> October 8. 2019 <br /> VIA UPS & EMAIL <br /> Ms. Michelle Henry <br /> San Joaquin County Environmental Health <br /> 1868 E Hazelton Ave. Stockton, CA 95205 <br /> (209)481-6217 <br /> Re: August In-Person Meeting Follow-Up <br /> Dear Michelle, <br /> I am writing to thank you and your team for taking the time to review our outstanding <br /> inspection issues in San Joaquin County during our in-person meeting in late August.Also, with <br /> the passage of time, it occurred to me that we should confirm our understanding as discussed in <br /> that meeting: that although your inspections will reflect open violations,the County will not <br /> pursue enforcement for these open issues as long as we continue to work with DTSC on a <br /> solution that aligns with EPA and California regulations. Our meeting and interaction with <br /> DTSC to date appear positive in this regard. <br /> The two main points of discussion during our recent meeting included(1)reverse <br /> distribution of potentially RCRA hazardous pharmaceuticals; and(2)the proper methodology for <br /> counting the weight of empty warfarin bottle residue. Again, you agreed to defer any <br /> enforcement on these issues as we work with DTSC to adopt Subpart P of the new management <br /> standards for pharmaceutical hazardous waste, which directly address these issues. <br /> We appreciate your careful consideration of these points and welcome our continued <br /> open communication as we work with DTSC and other stakeholders for a long-term solution. <br /> During our meeting you asked for additional information on both topics described above. The <br /> requested information is provided in the sections below. <br /> Reverse Distribution of Pharmaceuticals <br /> As discussed during the meeting,(we reviewed metrics from 1 '/2 years' worth of data <br /> during our meeting)only 3%of items returned for credit from San Joaquin County stores during <br /> the timeframe evaluated were not creditable after evaluation by the reverse distributor. In <br /> response to your inquiry regarding the breakdown of total items sent to the reverse distributor: of <br /> the 16,447 items sent to Genco from San Joaquin stores, only 8%would have been considered <br /> potentially RCRA hazardous pharmaceutical waste(if considered waste at the store pursuant to <br /> the adoption of the federal Pharmaceutical Waste Rule). <br /> CVS pharmacy I caremark /minute clinic specialty <br /> 40294225v1 <br />