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SAN.DIOAQUIN <br />COUNTY <br />Environmental Health Department <br />pharmaceutical waste if certain conditions are met.3 However, because the MWMA only regulates <br />Non-RCRA pharmaceuticals, RCRA pharmaceuticals, once expired and thus a waste, are still regulated <br />as RCRA hazardous waste. <br />The EHD defers to the letter from the US EPA Office of Solid Waste and Emergency Response <br />dated May 15, 1991, which states "This view is based on our understanding that the [reverse <br />distribution] system is established as a means to facilitate the recycling of reusable pharmaceutical <br />products, rather than a waste management system."4 Currently it has not been demonstrated to the EHD <br />that the pharmaceuticals are recycled or reused. <br />Additionally, CVS Health has not demonstrated that their reverse distribution system for <br />pharmaceuticals is not being used as a waste management service. It is important to point out that the <br />US EPA letter also states, ... a reverse distribution system cannot be used as a waste management <br />service to customers/generators without the applicable regulatory controls on waste management being <br />in place .,5 <br />Credit Focus: Santa Clara County <br />The EHD continues to focus on accurate hazardous waste determinations, 40 CFR 262.11. If <br />the solid waste is a hazardous waste we will continue to regulate as such. Creditworthiness does not <br />determine if the item is a waste or not. <br />Based on the reasons stated above, violations related to counting contaminated warfarin containers and <br />reverse distribution of RCRA waste pharmaceuticals remain open until corrective action has been <br />completed. <br />Should you have any additional questions or concerns, or wish to set up a time for a phone call or in- <br />person meeting, please feel to contact me at (209) 468-0343 or eflorido@sjgov.org. <br />Sincerely, <br />Elianna Florido, REHS <br />Registered Environmental Health Specialist <br />1868 East Hazelton Ave <br />Stockton, CA 95205 <br />P: (209) 468-0343 <br />E: efloridona,sj og v.org <br />cc: Michelle Henry, San Joaquin County EHD <br />Adriana Morales, CVS Health <br />Chris Yerzy, CVS Health <br />Shannon Slavens, CVS Health <br />s Wieckowski, Allen, and Williams, Assembly Bill -1442 Pharmaceutical waste, California Secretary of State, Sacramento, <br />CA, 2012. <br />Sylvia K. Lowrance, Returned Pharmaceutical Products (Correspondence from Sylvia K. Lowrance to Mark J. Schulz), <br />US EPA Office of Solid Waste and Emergency Response, RCRA Online (11606), Washington, D.C., 1991. (enclosed) <br />s Ibid. <br />2of2 <br />