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VCVSHealth <br />March 20, 2019 <br />VIA UPS <br />Ms. Elianna Florido <br />San Joaquin County <br />Environmental Health Department <br />1868 East Hazelton Ave. <br />Stockton, CA 95205 <br />(209) 468-3420 <br />Nicole Wilkinson <br />Director Corporate Environmental <br />One <br />as Drive — MC2340 <br />Woonsocket, RI 02895 <br />p 401-770-7132 <br />c 401-256-7615 <br />f 401-652-1901 <br />nicole.wilkinson@cvshealth.com <br />f�AR Z i 20i0 <br />ENVIRONMENTAL HEALTH <br />PFRt.4MSERVICES <br />Re: CVS Pharmacy, Inc., Store 16223, Inspection Report Issued on February 19, <br />2019. <br />Dear Ms. Florido: <br />CVS Pharmacy, Inc. (CVS) is in receipt of your Inspection Report (Report) issued to <br />CVS Store 16223 on February 19, 2019. This letter addresses your concerns noted in the above - <br />referenced Report. Thank you for meeting with me and members of my team (Shannon Slavens <br />and Chris Yerzy) during the CUPA Conference. We appreciate your willingness to meet and <br />discuss the CVS Health Retail Hazardous Waste Program and our continued partnership. <br />Hazardous Waste Manifests <br />Items 113, 114, and 115 in your Report all relate to hazardous waste manifests. <br />Item 113 relates to Box 11 (Total Quantity) information on manifests related to shipment of <br />empty warfarin containers. Specifically, your concern pertains to the weight listed on several <br />manifests showing shipment of empty containers with warfarin residue. Your inspection report <br />correctly noted that the manifest does not appear to include the weight of the empty warfarin <br />containers in the total amount of hazardous waste generated. Because this issue involves an <br />analysis and history of both federal and California regulations and agency guidance to appreciate <br />our current position and management practices, we offer the following explanation of why we <br />assert that in California, an empty warfarin container must be managed as a hazardous waste, but <br />because the container, as opposed to its residue, does not meet the definition of a hazardous <br />waste under 22 CCR 66261.3, the weight of the container should not be counted or included as a <br />hazardous waste on the manifest. <br />As you may know, on November 4, 2011, U.S. EPA issued a memorandum titled <br />Containers that Once Held P -Listed Pharmaceuticals, in which EPA clarified that "it is only the <br />residue in the non-RCRA-empty container that is considered a P -listed hazardous waste; the <br />