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W CVSHealth Ms. Florido March 29, 2019 Page 4 interpretation, yet still fully protective of human health and the environment. It is important to not overlook that California's regulation states that empty containers must be manaked as a hazardous waste. California's regulation does not say that empty containers must be counted toward a facility's generator status because containers do not meet the definition of hazardous waste under California regulations. See 22 CCR 66261.3. Based on the 2015 DTSC letter discussed above, which states that DTSC may revisit the empty container issue when EPA issues the Pharm Rule, we anticipate that DTSC is likely to reevaluate its position on empty containers. In the meantime, based on (i) EPA's data and conclusions — namely that EPA has investigated and determined that very small amounts of residues remain in containers after pharmaceuticals are dispensed, and EPA's ultimately decision to not require management or counting of the residue or containers as hazardous (or acute hazardous) waste; and (ii) California regulatory language clearly states that non -empty containers must be managed as hazardous waste, we request that the County conclude that CVS's management requirements for containers that previously held warfarin are compliant with California regulations. Importantly, CVS manages all containers that previously held warfarin - family pharmaceuticals as hazardous waste during hazardous waste accumulation at the store level and when transported, and all containers that previously held warfarin are ultimately incinerated. CVS's approach provides protection to human health and the environment well above the protection that EPA has concluded (in the Pharm Rule) is warranted, and counting warfarin empty containers toward CVS's generator status would provide no additional protection. CVS's management requirements also comply with the "management" requirement of the California regulations. Item 114 relates to sending generator manifest copies to the Department of Toxic Substances Control (DTSC). We have confirmed that CVS's hazardous waste hauler, Stericycle, provides copies of generator manifests to DTSC on behalf of CVS for all hazardous waste pickups at CVS stores in California. We do note that the regulatory requirement pertains to sending generator copies to DTSC, and not to any requirement that the copies are contained in the DTSC database. However, out of an abundance of caution, we have requested Stericycle to resubmit manifests numbers 011392884FLE, 011392883FLE, and 011392678FLE, 011392677FLE, and 010867630FLE, and 008680793. Attached please find the referenced manifests. Training/Training Records Items 118 and 119 of your Report relate to the store's training plan and annual completion of hazardous waste management training. 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 �/S pharmacy / Caremark /minute clinic /specialty