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Florido, Elianna From: Middleton, Debbie <DMiddleton@Sallybeauty.com> Sent: Wednesday, May 15, 2019 11:01 AM To: Florido, Elianna Cc: Caldwell, Sheri Subject: RE: Cosmoprof & Sally Beauty Stores Haz Waste Inspections Follow -Up Attachments: USG.Sally.Poster_HazardousMatMangPoster_r4_052617.pdf,- USG.Sally.Poster_3 Rules_r3_ 08.23.2017.pdf; Hazardous Waste Categorization Supplement Training.pdf; Hazardous Waste Categorization Supplement Training.pdf Importance: High Hello Elianna, Because of the file size, the requested manifests and SDSs have been uploaded to our BOX account. I will send you an invitation for access here shortly. With respect to your request for waste determinations, as previously noted, CCR 66262.11 specifies how generators are to make waste determinations; 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 the attached copies of the training documents mentioned, and as requested, the specific SDSs for the products at issue are in a file in BOX, a link to which will be issued directly. I trust you will find this responsive to your request and will close out the noted violations for our respective CosmoProf and Sally Beauty Supply stores in San Joaquin County, CA. Please let me know if you have further questions or concerns. Kind regards, Debbie Debbie Middleton Senior Paralegal, Environmental Compliance and Litigation Sally Beauty Holdings, Inc. I Sally Beauty Supply LLC I Beauty Systems Group LLC I Arcadia Beauty Labs LLC 3001 Colorado Blvd., Denton, Texas 76210 Email: dmiddleton@sallvbeautv.com Ph: 940.297.4964, Fax: 940.297.4990