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Elianna Florido [EH] From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Tuesday, February 26, 2019 12:39 PM To: Elianna Florido [EH] Cc: Caldwell, Sheri Subject: Response to NOV Issued to CosmoProf Store#8728 Attachments: Cosmoprof#8728_804 W 11th St Tracy_2019 HW Inspection Report.pdf; SBH Hazardous Waste Training Guide 2019.pdf, Hazardous Waste Categorization Supplement Training.pdf, CosmoProf 8728 - Training Log.pdf, Confirmation - Generator Manifests to DTSC.pdf; RTC Certification - CP 8728 by DWM.pdf Importance: High Follow Up Flag: Flag for follow up Flag Status: Flagged Elianna, In response to your inspection report of January 8, 2019 for CosmoProf Store#8728 in Tracy, CA, please see the following: Item 106 CCR 66262.34(d)(2) Failed to train employees on waste handling and emergency procedures. • All associates have re-trained on waste handling and emergency procedures. See copy of training log*. The materials provided to aid associates in making a hazardous waste determinations are as follows: o Hazardous Material Management poster 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 two manifests identified in the inspection report have been submitted to DTSC by our third-party vendor. See file titled "Confirmation—Generator Manifests to DTSC." Item 605 CCR 66262.34(f) Failed to completely label containers or portable tanks of hazardous waste. "The Corrosive Bases HW tote label listed "examples"which did not include the type of item contained in the tote,which was a Wella Professionals Koleston Perfect Permanent Creme Hair Color." As previously stated in our return-to-compliance responses for other Sally and CosmoProf stores you have inspected in San Joaquin County,through examination of the regulation and advice from counsel, SBH respectfully disagrees with the inspector's interpretation that "composition" means "contents." Please note that the word "contents" is not in the regulation and, moreover,that the U.S. 1