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Elianna Florido [EH] From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Thursday, March 7, 2019 8:08 AM To: Elianna Florido [EH] Subject: Response to NOV Issued to CosmoProf Store #8784 Attachments: Cosmoprof #8784_1110 W Kettleman Ln_2019 HW Inspection Report.pdf; USG.Sally.Poster_HazardousMatMangPoster_r4_052617.pdf,- SBH Hazardous Waste Training Guide 2019.pdf; Hazardous Waste Categorization Supplement Training.pdf; CosmoProf 8784 - Training Log.pdf; CosmoProf 8784 - Bins and Bin Labels.pdf; CosmoProf 8784 - RTC Certification.pdf Importance: High Elianna, In response to your inspection report of January 10, 2019 for CosmoProf store #8784 in Lodi, CA, please see the following: Item 103 CCR 66262.40(c) Failed to retain hazardous waste determination including waste analysis on site for 3 years. • CCR 66262.11 specifies how generators are to make waste determination; under subsection (b), listed wastes are presumed to be hazardous unless the generator has testing or generator knowledge to support a non- hazardous waste determination. SBH manages listed wastes as hazardous based on their listing and does not seek to exclude such wastes from regulation based on either testing or generator knowledge. No records are required for such determinations because they are based on regulatory listings. Subsection (b) provides that, for wastes that are not listed, the waste determination can be made based upon either testing or generator knowledge. SBH relies upon generator knowledge and training to make such waste determinations. Like most retailers, the basis of that knowledge is the classification scheme reflected in the SBH Hazardous Material Management poster displayed in the storage area, the HW Training Guide, HW Categorization Supplement, Safety Data Sheets, and any other relevant information that suppliers may provide to retailers. SBH does not individually evaluate each of the thousands of products its carries but instead relies upon general product classes for management; for example, aerosols, astringents, fragrances, hair sprays and nail polishes are indicative of the types of products that would be considered flammable. Employees are trained to look for these and similar products and management them accordingly. See copies of the training documents mentioned. 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