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S AN 10 A Q U I N Environmental Health Department <br />COUNTY— Linda Turkatte, REHS, Director <br />Greatness grows here. <br />Kasey Foley, REHS, Assistant Director <br />PROGRAM COORDINATORS <br />Robert McClellon, REHS <br />Jeff Carruesco, REHS, RDI <br />Willy Ng, REHS <br />Muniappa Naidu, REHS <br />Michael Kith, REHS <br />June 4, 2019 <br />VIA EMAIL <br />Nicole Wilkinson <br />CVS Health <br />One CVS Drive — MC2340 <br />Woonsocket, RI 02895 <br />nicole.wilkinson(a,cvshealth.com <br />(401) 770-7132 <br />Re: San Joaquin County CVS Pharmacy locations - Hazardous Waste Inspections <br />Dear Ms. Wilkinson, <br />The San Joaquin County Environmental Health Department (EHD) is in receipt of your return to <br />compliance (RTC) letters in response to our Inspection Reports issued to each CVS Pharmacy store <br />located in San Joaquin County. Thank you for your responses. The following is the EHD's response to <br />two primary subjects discussed in your letters. <br />Counting Contaminated Warfarin Containers <br />The EHD will continue to follow the Department of Toxic Substances Control's (DTSC) <br />most recent reaffirmation, stated in the letter dated August 2, 2018, to continue to regulate the whole <br />contaminated container as hazardous waste and not just the residual inside, per California Code of <br />Regulations, title 22, section 66261.7(r).1 The EHD will continue to follow this position until DTSC <br />formally changes their position on the subject, if at all. Thus, as stated in DTSC's 2018 letter, <br />"California healthcare facilities (hazardous waste generators) must include the weight of the container <br />and residue when completing a Uniform Hazardous Waste Manifest. The combined weight counts <br />toward generator status, ,2 <br />Reverse Distribution of RCRA Waste Pharmaceuticals <br />The EHD will continue to regulate expired RCRA pharmaceuticals as hazardous waste, and thus <br />will cite violations identified at the time of inspection relating to the improper management of <br />hazardous waste. This decision is based on Assembly Bill No. 1442, which amended the Medical <br />Waste Management Act (MWMA) to read expired pharmaceuticals (Non-RCRA only) are not <br />1 Ellen L. Haertle, Request to Reconsider The Regulatory Status of P -Listed RCRA Hazardous Waste Containers <br />(Correspondence from Ellen L. Haertle to Angie Manetti), Department of Toxic Substance's Control, Sacramento, CA, <br />2018. (enclosed) <br />2 Ibid. <br />1868 E. Hazelton Avenue Stockton, California 95205 T 209 468-3420 F 209 464-0138 1 www.sjcehd.com <br />