COMPLIANCE INFO_2019 - Laserfiche WebLink

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o Revised Hazardous Waste Training Guide, which includes a decision tree (see copy of Guide) o New Hazardous Waste Categorization supplement (see copy of Supplement) o SDS website o Toll-free number to the corporate office o Re-training of the employees at this location *Please note that because this location is a small-quantity generator there is no recordkeeping requirement. However, Sally has voluntarily re-trained employees at this location and maintained such records to ensure that employees understand the training they have received. Item 109 CCR 66262.23(a)(4) Failed to send generator manifest copies to DTSC within 30 days. • The generator copies of the three manifests identified in the inspection report have been submitted to DTSC by our third-party vendor. Item 110 CCR 66262.40(a) Failed to keep signed copy of manifests from the designated facility for three years. • The facility copies of the manifest identified in the inspection report has been received by the store and put into their hazardous waste binder. • As part of the re-training, associates were refreshed on recordkeeping and documentation requirements,which includes the status of both generator and designated facility copies. • As requested, a copy of manifest 017403095JJK (7/27/18) is attached. Item 111 CCR 66262.42(a)(c)(d) Failed to comply with uniform hazardous waste manifest exception requirements. • See above response. Item 401 CCR 66262.34(d)(2) Failed to store hazardous waste in a container that is in good condition. • All bin lids have been replaced. See file titled "Sally 1679—Bins." • As a part of the re-training, associates were instructed to check the condition of the bins and lids during their weekly inspection. Item 403 CCR 66262.34(d)(2) Failed to keep hazardous waste containers closed except when adding or removing hazardous waste. • At the time of the inspection, a can of AGEbeautiful Root Touch Up Spray Temporary Hair Color was discovered behind the Universal/eWaste bin. o As a part of the re-training, associates were required to read the Guide and to immediately implement the more detailed weekly inspection, which includes a thorough inspection of the hazardous waste area. o See attached training log. Item 404 CCR 66262.34(d)(2) Failed to inspect hazardous waste storage areas at least weekly. • The SBH Hazardous Waste Training Guide was revised to include a more robust weekly inspection checklist, see Guide, pages 2 and 3. • As a part of the re-training, associates were required to read the Guide and to immediately implement the more detailed weekly inspection. • Additionally, beginning in February 2019, district managers are now charged with confirming compliance at their respective stores on a quarterly basis,which includes, but is not limited to, ensuring weekly inspections are conducted. See DM Compliance document. Item 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste. a. The words"Hazardous Waste" SBH utilizes preprinted container labels that include the words "Hazardous Waste." b. Name and address of generator The revised Guide instructs store associates to include the entity name (store name) as well as store number for the generator name on the bin label. See attached file titled "Sally 1679—Label." 2