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VCVSHealth Ms. Florido March 29, 2019 Page 5 discussed in the Program Overview. Please note that in some cases, responsible employee(s) may delegate certain job duties to other employees as long as these employees are properly trained according to the training matrix. Additionally, CVS requires all store colleagues to be trained upon hire, and annually thereafter, to CVS's hazardous waste management program through one or more training module available via our web -based training system, LEARNet. Colleagues are assigned training modules according to the scope of his or her job responsibility. Training records are maintained online as well, and should be accessible by each store employee. We have obtained a consolidated training record for Store 16982, which is included here for your review. Containey� Labeling Item 605 of your Report refers to the proper labeling of hazardous waste containers. During your inspection you observed two containers in the pharmacy, one of which was labeled "Non -Viable Hazardous Pharmaceutical Waste" and the other labeled "Expired." The "Non -Viable" container held bagged loose pills, empty warfarin bottles, and liquid medicines, however, the label did not reflect the correct physical state and contents of the container. The "Expired" container held two bags of individually identified pills which were inadvertently placed in this container rather than the "Non -Viable" container. While we understand these concerns were addressed during your visit, please be advised that Chris Yerzy, Environmental Specialist, has since provided reinforcement training to the pharmacy management staff regarding proper labeling and storage of hazardous waste. Attached, see photographic documentation of the appropriately labeled hazardous waste container. Akrobin Label During your inspection you observed a blue bin (Akrobin) labeled "Weekly StrongPak Staging Bin.," "l. Amber Vials," and "2. Loose Pills." In your "Notes" you request an explanation for the wording on this label. As background, the open bin (blue Akrobin) referenced in your inspection report is a temporary storage tray used to hold pharmaceutical items awaiting evaluation. The open tray is not labeled with a hazardous waste label because the items contained therein are product and have not yet been evaluated to determine whether they will be managed through CVS's reverse distribution vendor, returned to stock, or will be managed as a waste at the store level. Items temporarily stored in this tray are evaluated at least weekly by pharmacy personnel. Upon evaluation, they are either packaged for transport to CVS's reverse distribution vendor, returned to stock, or are managed through the store's Hazardous Waste Management Program. During our in-person meeting at the CUPA Conference, you mentioned that the blue Akrobin contains a sticker with language which refers to the "StrongPak" process. This language was originally developed during early development of the program, and referred to the entire evaluation process in CVS Health pharmacies. Upon your (`,�/S pharmacy / Caremark /minute clinic /specialty