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VCVSHealth Ms. Florido March 20, 2019 Page 5 working with our waste vendor to re -push these manifests with complete scanned images to the portal. Training /Training Records Item 118 of your Report relates to the store's training plan. As background, CVS has developed the attached matrix which lists job duties related to hazardous waste management, a description of such duties, and a list of store -level responsible employees by category and job code. This matrix supplements the Training Program Plan and Course Overview on pages 6-7 of the Program Overview (attached) and applies to all retail store locations. The type and amount of introductory and continuing training provided to store employees is discussed in the Program Overview. Please note that in some cases, responsible employee(s) may delegate certain job duties to other employees as long as these employees are properly trained according to the training matrix. Additionally, CVS requires all store colleagues to be trained within the first six months after hire, and annually thereafter, to CVS's hazardous waste management program through one or more training modules available via our web -based training system, LEARNet. Colleagues are assigned training modules according to the scope of his or her job responsibility. Training records are maintained online as well, and should be accessible by each store employee. We have obtained a consolidated training record for Store 16223, which is included here for your review. Container Closure and Labeling Items 118, 403, and 605 of your Report refer to the blue "Akrobin," used to store pharmaceutical items awaiting the weekly scan process. As background, the open bin (blue akrobin) referenced in your inspection report is a temporary storage tray used to hold pharmaceutical items awaiting evaluation. The open tray is not labeled with a hazardous waste label because the items contained therein are product and have not yet been evaluated to determine whether they will be managed through CVS's reverse distribution vendor, returned to stock, or will be managed as a waste at the store level. Items temporarily stored in this tray are evaluated at least weekly by pharmacy personnel. Upon evaluation, they are either packaged for transport to CVS's reverse distribution vendor, returned to stock, or are managed through the store's Hazardous Waste Management Program. During our in-person meeting at the CUPA Conference, you mentioned that the blue Akrobin contains a sticker with language which refers to the "StrongPak" process. This language was originally developed during early development of the program, and referred to the entire evaluation process in CVS Health pharmacies. Upon your request we have issued new bin labels to address your concern. The new labels include the following language: "Unsaleable Product Awaiting CFRx Processing." Items 118 and 605 of your Report also refer to a closed container labeled "Genco Not Processed." During your inspection you observed this container, containing pills in amber vials and manufacturer packages. It appears the pharmacy was utilizing this container to store pharmaceutical items also awaiting the weekly scan. Upon evaluation, these items are either pharmacy / caremark / minute clinic / specialty 364827630