COMPLIANCE INFO_2019 - Laserfiche WebLink

Home Browse Search

110CWHealth October 8. 2019 VIA UPS & EMAIL Ms. Michelle Henry San Joaquin County Environmental Health 1.868 E Hazelton Ave. Stockton, CA 95205 (209) 481-6217 Re: August In -Person Meeting Follow -Up Dear Michelle, Nicole Wilkinson Director, Corporate Environmental One CVS Drive — MC2340 Woonsocket, RI 02895 p 401-770-7132 c 401-256-7615 f 401-652-1941 nicole.wilkinson@cvsheath.com I am writing to thank you and your team for taking the time to review our outstanding inspection issues in San Joaquin County during our in-person meeting in late August. Also, with the passage of time, it occurred to me that we should confirm our understanding as discussed in that meeting: that although your inspections will reflect open violations, the County will not pursue enforcement for these open issues as long as we continue to work with DTSC on a solution that aligns with EPA and California regulations. Our meeting and interaction with DTSC to date appear positive in this regard. The two main points of discussion during our recent meeting included ( 1) reverse distribution of potentially RCRA hazardous pharmaceuticals; and (2) the proper methodology for counting the weight of empty warfarin bottle residue. Again, you agreed to defer any enforcement on these issues as we work with DTSC to adopt Subpart P of the new management standards for pharmaceutical hazardous waste, which directly address these issues. We appreciate your careful consideration of these points and welcome our continued open communication as we work with DTSC and other stakeholders for a long-term solution. During our meeting you asked for additional information on both topics described above. The requested information is provided in the sections below. Reverse Distribution of Pharmaceuticals As discussed during the meeting, (we reviewed metrics from 1 '/2 years' worth of data during our meeting) only 3% of items returned for credit from San Joaquin County stores during the timeframe evaluated were not creditable after evaluation by the reverse distributor. In response to your inquiry regarding the breakdown of total items sent to the reverse distributor: of the 16,447 items sent to Genco from San Joaquin stores, only 8% would have been considered potentially RCRA hazardous pharmaceutical waste (if considered waste at the store pursuant to the adoption of the federal Pharmaceutical Waste Rule). CW pharmacy / caremark / minute clinic / specialty 40294225v1