Loading...
The URL can be used to link to this page
Your browser does not support the video tag.
Home
My WebLink
About
alameda-revsion-3-2-22-final-revised-4-5-archive
SUBMITTED BY: + ALAMEDA COUNTY DEPARTMENT OF ENVIRONMENTAL HEALTH SAFE DRUG DISPOSAL DRUG STEWARDSHIP PLAN April 10, 2020 As Revised on March 4, 2022 2 © Inmar 2022. Contents I. INTRODUCTION ...............................................................................................................................................3 II. OVERVIEW ........................................................................................................................................................3 III. DEFINITIONS ...................................................................................................................................................4 IV. GENERAL INFORMATION ................................................................................................................................5 V. COLLECTION COMPONENTS .........................................................................................................................6 A. Convenient and Equitable Access...............................................................................................................6 B. Collection Points – Kiosks ...........................................................................................................................7 C. Mail-Back Services ................................................................................................................................... 13 D. Collection Events ............................................................................................................................................ 16 Location Planning ..................................................................................................................................... 17 Event Staffing and Oversight .................................................................................................................... 17 Execution Procedures ............................................................................................................................... 17 Collection Event Promotion ....................................................................................................................... 18 Collection Event Fees and Costs .............................................................................................................. 18 VI. TRANSPORTATION AND DISPOSAL INFORMATION .................................................................................. 18 VII. POLICIES AND PROCEDURES..................................................................................................................... 20 VIII. OUTREACH PROGRAM DESIGN.................................................................................................................. 22 A. Promotion ................................................................................................................................................. 22 B. Standardized Instructions ......................................................................................................................... 23 C. Website and Toll-Free Number ................................................................................................................ 23 D. Impact Measurement ................................................................................................................................ 25 E. Traditional Media ...................................................................................................................................... 25 F. Additional Promotional Considerations .................................................................................................... 27 IX. ANNUAL REPORTING ................................................................................................................................... 28 X. PATIENT PRIVACY ........................................................................................................................................ 29 XI. GOALS ............................................................................................................................................................ 30 XII. ADDITIONAL PLAN CONSIDERATIONS ....................................................................................................... 31 APPENDIX ............................................................................................................................................................... 32 Appendix A-1: Confirmed Authorized Collectors ........................................................................................ 33 Appendix A-2: Potential Authorized Collectors ........................................................................................... 35 Appendix A-3: Confirmed Mail-Back Sites ................................................................................................. 38 Appendix A-4: Target Mail-Back Sites ........................................................................................................ 41 Appendix B: Kiosk Signage & Mailer Instructions ...................................................................................... 42 Appendix C: Promotion Material ................................................................................................................. 47 Appendix D: Applicable Permits And Licenses .......................................................................................... 53 Appendix E: Compliance History................................................................................................................. 55 3 © Inmar 2022 I. Introduction Inmar submits this Product Stewardship Program Plan (“Plan”) for all Unwanted Product, regardless of who produced them, in compliance with the Alameda County Safe Drug Disposal Ordinance 2016 located at Title 6, Chapter 6.53, (“Ordinance 6.53”) and the Alameda County Safe Drug Disposal Regulations, (“Regulations”), for the management, collection, transportation, and disposal of Unwanted Product from the Residents of the Alameda County. All capitalized terms not otherwise defined shall have the same meaning as in Ordinance 6.53 and the Regulations. Inmar’s Plan will provide a comprehensive safe drug disposal Stewardship Program that will include compliant drug Collection Methods supported by outreach and education Programs to increase Resident awareness and participation. The Plan will provide safe, secure, and convenient access on an ongoing basis for Residents across the County and will be funded by participating covered manufacturers. The Program will also provide reporting on collection metrics and results of Resident education and outreach campaigns. II. Overview Inmar’s Plan is compliant with Ordinance 6.53 and the Regulations. The Plan provides for safe, secure and convenient access to Unwanted Covered Drug Drop-off locations on an ongoing basis for Residents across Alameda County and will be funded and paid for in accordance with Ordinance 6.53.040 (B). Inmar’s Plan also meets all requirements specified in Article 9.1 of Title 16 CCR Division 17 for Prescription Drug Take-Back Services (“BOP Article 9.1”). Inmar’s Plan will accept all Unwanted Covered Drugs regardless of who produced them and there will be no point-of-sale or point-of-collection fee charged to residential generators. Pursuant to the Regulation, § 7, Inmar’s Plan includes the following components: General Information: Plan Participants, Inmar coordinator information, website and telephone information; Collection Components: A description of the collection systems to provide convenient ongoing collection service for all Unwanted Products in accordance with the Regulation § 7 (D); Transporter & Disposal Information: A description of the transportation and disposal systems to be used in accordance with the Regulations § 7 (E) & (F) and the Ordinance 6.53.060; Policies and Procedures: A description of the policies and procedures to be followed by Persons handling Unwanted Covered Drugs; Patient Privacy: A description of how patient information on Drug packaging will be handled; Public Education & Promotion: A description of Inmar’s public education outreach and promotion strategy required in the Regulation § 7 (G) and the Ordinance 6.53.070, including a copy of standardized instructions for Alameda County Residents, signage developed for Collection Points and required promotional materials; Plan Goals: A proposal as to Inmar’s short-term and long-term goals under the Plan in accordance with the Regulations § 7 (H); Reporting: A description of the annual reporting Inmar will provide pursuant to the Regulation § 15 and the Ordinance 6.53.080; and Miscellaneous: Separating Covered Drugs from packaging where possible and recycling of Drug packaging where feasible. 4 © Inmar 2022. As required in the Ordinance 6.53.050 (B) (6), Inmar will submit any proposed changes, other than collection of non-prescription covered drugs, to the Department in writing for approval, prior to implementation of any changes. III. Definitions - the following is a list of definitions for terms used other than those terms defined in the Ordinance and Regulations: Auto-injector (or Auto Injector) means an unused or partially used Pre-filled Injector Product with a retractable or otherwise securely covered needle. Auto-Injector Mail-Back Package means a pre-paid, pre-addressed, FDA-cleared Sharps Container and outer shipment Package for the collection and disposal of Pre-filled Injector Products. Authorized Collector means the operator of a Collection Point. Board of Pharmacy means the California State Board of Pharmacy. Carrier means the common carrier used to transport Unwanted Covered Drugs. Container means the cardboard box which both supports the Inner Liner inside the Kiosk during medicine collection and becomes the outer shipping Package when the Inner Liner is full and/or removed from the Kiosk. Collection Point means a location which hosts an Inmar Kiosk for the collection of Unwanted Covered Drugs and is operated by an entity which has registered with the DEA as an Authorized Collector of Controlled substances under 21 CFR Section 1317. Collection System is Inmar’s term for the Collection Method that utilizes permanent Collection Kiosks at fixed locations. Collection Method means one of the three Collection types (Kiosk, Mail-Back, or Event) authorized for collection and disposal of home-generated Controlled substances by the DEA under 21 CFR Section 1317. DEA means the U.S. Drug Enforcement Administration. DEA Rule means the DEA Final Rule, “Disposal of Controlled Substances,” 79 Fed. Reg. 53520 et seq. adopted on September 9, 2014 and codified at 21 CFR 1317. DOT means the U.S. Department of Transportation. Drop-door means the door on the Kiosk where Unwanted Covered Drugs are deposited by Residents. Inhaler Mail-Back Envelope (Envelopes) means a pre-paid, pre-addressed envelope for the collection and disposal of inhalers. Inmar Plan means the Product Stewardship Plan presented in this submittal. Inner Liner means the liner placed inside the Container which meets the requirements of 21 CFR Section 1317.60. Kiosk means a metal receptacle into which Residents deposit Unwanted Covered Drugs and which meets the requirements of 21 CFR Section 1317. Kiosk Drop-off Service means a Collection Method in which Residents deposit Unwanted Covered Drugs into a Kiosk operated by an Authorized Collector at an Authorized Collection Site. Liner Kit is a set of three (3) pre-labeled and pre-paid cardboard box Containers, liquid barriers, and serialized, puncture-resistant Inner Liners. Law Enforcement Agency or LEA is a Federal, State, tribal, or local law enforcement office or agency. Mail-Back Service means a Collection Method in which Residents return Unwanted Covered Drugs utilizing prepaid and pre-addressed Mail-Back Envelopes or Packages. 5 © Inmar 2022. Mail-Back Starter Kit means 20 Standard Mail-Back Envelopes with a visual reorder trigger, with instructions to Standard Mail-Back Distribution Sites on how to reorder additional Mail-Back Starter Kits. Mailer is Inmar’s generic term used to refer to all pre-paid, pre-addressed Standard and Inhaler Mail-Back Envelopes and Auto-Injector Mail-Back Packages. Non-participating means qualified entities not participating in an existing Approved Stewardship Plan as of February 11, 2021. Packaged Container means the full Inner Liner used in the Kiosk Drop-off Service after it is removed, secured within the Container, prepared, and sealed for transportation to a DEA Reverse Distributor. Pharmacy Employee means the designated contact person or persons at the Kiosk Drop-off Site. Pick-Up and Disposal Coordination Option means the method of Packaged Container disposal which an Authorized Collector selects when participating in the Inmar Plan. The three options, Self-Service Return, Technician-Assisted Return, and Full-Service Return, are described in detail in Section V (c) of the Inmar Plan. Required Languages means English, Spanish, Chinese, Vietnamese, and Tagalog (Filipino). Residents means human beings residing in the County of Alameda. “Residents” does not include business generators of pharmaceutical waste, such as hospitals, clinics, doctor’s offices, veterinary clinics, pharmacies, or airport security and law enforcement drug seizures. Standard Mail-Back Envelope Distribution Site means a location at which Residents may obtain one or more standard Mail-Back envelopes at no charge and which is provided by Inmar to meet the Service Convenience Goals established in the Ordinance. Standard Mail-Back Envelope (Envelopes) means a prepaid and pre-addressed Mail-Back Envelope for the collection and disposal of all Unwanted Covered Drugs except for those dispensed in an inhaler or auto-injector. IV. General Information a) Plan Participant(s) A list of Plan Participants with contact information will be provided to the Department annually. Any change in the Producer Participants will be provided to the Department within 30 days of the change. b) Inmar Plan Liaison Inmar Intelligence Nick Massaro, Manager, Consumer Drug Take Back Solutions 635 Vine Street Winston Salem, NC 27101 Email: nicholas.massaro@inmar.com Phone: 336-770-1992 c) Website Inmar’s Plan website: safemedicinedrop.com d) Telephone Number The toll–free number for County Residents to obtain information about Collection Points, 6 © Inmar 2022. educational materials and other aspects of the Plan is 888-371-0717. V. Collection Components A. Convenient and Equitable Access Pursuant to the Regulation § 7 (D) (i) and Ordinance 6.53.060 (A)-(C), and upon Plan approval, Inmar will initiate operations immediately to establish a system of Collection Points that provide convenient and equitable access to Residents across the County as outlined in the Ordinance. Collection Points are searchable to Residents in Google Maps, simply by typing “Drug Disposal,” or other similar phrases in the Google Maps applications. Inmar commits to collaboration with the Department to ensure alignment in the proper number and location of Unwanted Product Collection Points. It is Inmar’s intention to engage our existing pharmacy clients to become authorized Collection Points. It is not our intention to duplicate Kiosks that already exist in Plan Operators. Appendix A-1 includes a list of confirmed Authorized Collector Collection Points. Appendix A-2 includes a list of potential Collection Points. In accordance with the Ordinance 6.53.050 (A) (9), Inmar will correlate the number of Collection Points with the market share of the drugs sold in the County by the Plan Participants in the County. This will result in Inmar placing Kiosks at Collection Points in a proportion equal to or greater than the market share of drugs sold by the Plan Participants. Inmar is actively in discussions with its existing pharmaceutical returns client network seeking pharmacies interested in becoming Authorized Collectors. Inmar will utilize hospitals with on-site pharmacies and Law Enforcement Agencies as necessary to meet the goals of equitable and reasonably, convenient access for County Residents. Inmar will review any potential Authorized Collector Site against the California Board of Pharmacy License directory to validate the location holds an active retail, hospital or clinic license. Additionally, Sites will be required to provide evidence of current DEA registration. Inmar will notify the Department as new Collection Points become operational. Such notification will include the Collection Point’s contact information. To ensure the best possible access for the Residents of the County, Inmar also provides Mail-Back Services and Collection Events which are described in more detail in Section C. In order to establish geographically convenient access to the Kiosks and Mail-Back Sites we will utilize the 2019 census data which shows the incorporated cities and towns in the County. Our goal is to place at least one Mail-Back Distribution Site in each of these cities/towns and one additional for every twenty-five thousand (25,000) Residents. For areas where we are unable to secure a Drop-off Site or a Mail-Back Distribution Site we will work with the local Department to host a Collection Event at least once a year, but will reassess as the Program proceeds and more Drop-off Sites and/or Mail-Back Distribution Sites are operational in the County. 7 © Inmar 2022 B. Collection Points – Kiosks Pursuant to the Ordinance 6.53.060 (A) and Regulation § 8 (A) (v), Inmar complies with DEA regulation 21 CFR Parts § 1317.60 (c) and 1317.70 (f) and BOP Article 9.1 and seals all Kiosk Inner Liners and Mail-Back Envelopes. These Inner Liners and Envelopes shall not be opened, x-rayed, analyzed, or otherwise penetrated. Accordingly, their contents shall not be sorted or inventoried subsequent to being placed into a Drop-box or Mail-Back Envelope. Patient Privacy is addressed more specifically in Section VIII. Pursuant to the Ordinance 6.53.050 (A) (11)-(12), Inmar will give preference to Law Enforcement Agencies and retail pharmacies wherever possible to voluntarily serve as Drop-off Sites for Unwanted Covered Drugs. Inmar will work with all Collection Points to validate that the requirements in the Ordinance 6.53 and the Regulations including all relevant DEA and BOP Article 9.1 requirements are met. Kiosk Specifications and Design Inmar’s Kiosk is made in the USA and designed to be safe and secure as required. Produced from 16- gauge cold-rolled steel, and with an easy-to-use, Americans with Disabilities Act (ADA)-compliant Drop- box design, Residents can easily drop unused medications through the Drop-door and into the shippable Container and Inner Liner. The Container is a 275lb-rated box with a 6-mil, DEA-compliant Inner Liner. Inner liners are either 18 gallons or 35 gallons dependent upon geographical location and population density of the Kiosk location. This volume rating is printed directly onto our 6-mil DEA-compliant Inner Liners and have passed the tests prescribed in accordance with ASTM D 1922 and ASTM D 1709 . The Kiosk design itself exceeds standard security requirements. The top of the Kiosk is sloped, limiting the ability to stack items on top. In addition, the drop slot features an extended metal drop door that lowers into the Container to detect when product capacity is reached. When the drop door encounters resistance within the Kiosk, it is an indication that it is time to change the Container. This manual capacity indicator eliminates the need to change batteries and/or sacrifice the location of the Kiosk to be proximate to an electrical outlet. Lastly, the Container access door is reversible to allow for convenient placement in any appropriate location in the pharmacy. Per DEA requirements, Kiosks will be installed in the line of sight of Pharmacy or DEA registrant Employees and bolted to the floor or a permanent fixture. Inmar’s Kiosks have pre-drilled holes in the bottom for easier installation. It also features a 4-point locking system with steel projections in two center locations and the top and bottom of the door that are activated when locked for strengthened security. Top and bottom deadbolt locations are hidden from the outside to prevent break-ins. The Inmar Kiosk will have signage that communicates what is and is not allowed to be placed inside. The signage will also feature a website and toll-free telephone number (detailed further in Section VII) so users of the Program can ask questions and find more information. Inmar will work with the Department to design signage that meets the needs and requirements of the Program. See Appendix B for examples of signage. 8 © Inmar 2022. Inmar’s Kiosk is sent to the Authorized Collector along with enough supplies for 3 returns. Supplies include: ●Pre-addressed, pre-paid serialized Container ●Serialized Inner Liners to protect against puncture and provide a liquid barrier ●Easy-to-use zip ties to seal Inner Liner compliantly ●Absorbent pad for placement in the bottom of the Inner Liner bag Kiosk design features 9 © Inmar 2022. Pick-Up and Disposal Coordination Options For the safe on-site removal of contents and servicing of Kiosks, Inmar abides by the DEA regulations in 21 CFR 1300 et al. Inmar will work with each Authorized Collector to develop a Collection Program schedule that works specifically for their location - either full-service, technician-assisted or self-service option. Inmar will also be at the ready with service technicians should emergency service be required. For a pickup request outside of the normal schedule, the standard response time is 48 hours. Self-Service Returns Upon request by Authorized Collectors and upon receipt of approved petition for exception, Inmar will train Authorized Collectors to service the Containers on their own to allow for expedited servicing as they desire. The steps to service a Container are fast, efficient, and DEA-compliant. Inmar will provide Authorized Collectors with training materials including step-by-step instructions for tracking, sealing, shipping, and replacing of Collection Containers. Training materials also include instructions for the scheduling of Kiosk maintenance as necessary. The process for the pharmacy once a Kiosk is installed is as follows: ●Pharmacist receives the Liner Kit ●Pharmacy team (consisting of 2 Pharmacy Employees) constructs the Container with Inner Liner, inserts and securely locks the Kiosk ●Pharmacy team unlocks the Kiosk drop-door to enable consumer use ●Installation date of Inner Liner is documented and witnessed by on Tracking Sheet ●Once Kiosk is full, Pharmacy team members will jointly open Kiosk ●Container and Inner Liner is removed and documented on the Tracking Sheet. ●Container is packaged (Inner Liner is zip tied, outer box is taped) to be compliant with all DOT Hazardous Materials Regulations ●The sealed Inner Liner will not be opened, x-rayed, analyzed, or otherwise penetrated ●Replacement Container and Inner Liner is constructed, inserted, secured into Kiosk and documented on the Tracking Sheet 10 © Inmar 2022. ●Pharmacy team contacts FedEx for pickup of Packaged Container for shipping to authorized Disposal Facility for destruction ●If the Container (and Inner Liner) must be shipped at a later time (shipment cannot take place at time of service), storage of the Container behind pharmacy counter must be notated on the Tracking Sheet ●Replacement Container and Inner Liner is constructed, inserted, secured into Kiosk and documented on the Tracking Sheet ●Visually and physically inspect Kiosk to ensure proper operation. Should maintenance be necessary, refer to Training Materials provided to request service as required ●Kiosk Containers will be sent using Inmar’s DOT Special Permit #20499, from the pharmacy location via FedEx to Inmar’s third party contractor, 123 Compliant Logistics, LLC, a licensed DEA Reverse Distributor-Collector. o 123 Compliant Logistics will record the following information upon receipt of every individual Container: ▪Date received ▪Serialized barcode label information ▪FedEx Tracking information ▪Weight ▪Date transported to Disposal Facility ▪Disposal date ▪Manifest number o All information recorded will be transferred back to Inmar on a daily basis as part of the electronic raw data file via SSH File Transfer Protocol (SFTP). Any discrepancies observed at 123 Compliant Logistics will be recorded on discrepancy reports to prompt any corrective action. o All product shipped directly to 123 Compliant Logistics will be transported using their contracted, licensed hazardous waste transporter, TransChem Environmental, to the appropriate Disposal Facility to be incinerated quickly, securely, efficiently and in accordance with all DEA requirements. 123 Compliant Logistics will be responsible for all DEA Form 41 record keeping requirements. *At no point will the pharmacy have to store the filled Container for longer than 48 hours after calling FedEx. As part of the self-service option for Kiosk servicing, the pharmacist will be responsible for packaging the Container and Inner Liner for shipment and contacting FedEx for pickup. Typically, FedEx responds within 48 hours of request by phone. If the pharmacist utilizes the FedEx shipping portal, the pharmacist is able to request in the “Notes” field a specific pick-up time. Inmar will also reach out to its contacts at FedEx to ensure that local contacts are aware of Authorized Collection Sites and their needs related to quick turnaround. Technician-Assisted Returns Inmar will provide contracted employees who will be trained specifically in servicing Kiosks in a geographically-assigned area. These employees will establish a pattern for servicing the Authorized Collectors utilizing service metrics to establish an appropriate pattern of service. The service will include the following: Observation of the condition of the receptacle upon arrival Notification to the Pharmacy Employee of arrival Coordination of 2 Pharmacy Employees to witness change out of Container (and Inner Liner) Removal, packaging, and documentation of the Inner Liner and Container from the Kiosk 11 © Inmar 2022. Replenishment of new supplies for renewed operation General clean-up and wipe down of Kiosk Notation of Inner Liner serial number removed, and replacement Inner Liner serial number installed along with signatures by 2 Pharmacy Employees (witnesses) Removal of Packaged Container to be placed behind the pharmacy counter to await FedEx pick up Technician calls FedEx to schedule pickup of the Packaged Container unless otherwise agreed upon by Pharmacy Employees in writing Final signature from Pharmacy Employees of completion of service event. Kiosk Containers will be sent using Inmar’s DOT Special Permit #20499, from the Pharmacy location via FedEx to Inmar’s third party contractor, 123 Compliant Logistics, LLC, a licensed DEA Reverse Distributor-Collector. o 123 Compliant Logistics will record the following information upon receipt of every individual Container: •Date received •Serialized barcode label information •FedEx Tracking information •Weight •Date transported to Disposal Facility •Disposal date •Manifest number o All information recorded will be transferred back to Inmar on a daily basis as part of the electronic raw data file via SSH File Transfer Protocol (SFTP). Any discrepancies observed at 123 Compliant Logistics will be recorded on discrepancy reports to prompt any corrective action. o All product shipped directly to 123 Compliant Logistics will be transported using their contracted, licensed hazardous waste transporter, TransChem Environmental, to the appropriate Disposal Facility to be incinerated quickly, securely, efficiently and in accordance with all DEA requirements.123 Compliant Logistics will be responsible for all DEA Form 41 record keeping requirements. *At no point will the pharmacy have to store the filled Container for longer than 48 hours after calling FedEx. Full-Service Returns Inmar will offer on-site service for the collection, replacement, and shipping of full Containers (and Inner Liners). This all-inclusive Program removes the burden for the Authorized Collector and the Pharmacy Employees. Inmar will initiate standard service intervals for each Collection Point. Once a pattern of usage has been established, the service schedule will be adjusted with the agreement of the Authorized Collector to provide the best overall service with minimal interruption. Inmar will work with the Authorized Collector to adjust the schedule based on utilization of the Kiosk. Inmar will provide two employees with all appropriate DEA and DOT function specific training to specifically service Kiosks. Upon installation of the Kiosk, the process for Full-Service Events will include the following: ●Pharmacist receives the Liner Kit 12 © Inmar 2022. ●Pharmacist contacts preassigned Full Service staff to construct Container with Inner Liner, insert and securely lock Kiosk. ●Full Service staff will unlock the Kiosk drop door to enable consumer use ●Once the Kiosk is full (or until routine schedule is established), pharmacist contacts preassigned Full Service staff service ●Upon arrival, Full Service staff will observe the condition of the Kiosk ●Full Service staff will notify pharmacist of arrival ●Full Service staff will remove the Container and Inner Liner and document on the Tracking Sheet. ●Container is packaged (Inner Liner is zip tied, outer box is taped) to be compliant with all DOT Hazardous Materials Regulations ●The sealed Inner Liner will not be opened, x-rayed, analyzed, or otherwise penetrated. ●Replacement Container and Inner Liner is constructed, inserted, secured into Kiosk and documented on the Tracking Sheet by the Full Service staff ●Full Service Staff will perform general clean-up and wipe-down of Kiosk ●Full Service Staff will unlock the Kiosk Drop-door to enable consumer use ●Installation date of Inner Liner is documented and on Tracking Sheet ●The sealed Inner Liner will not be opened, x-rayed, analyzed, or otherwise penetrated ●Full Container (and Inner Liner) will to be taken directly to FedEx by Full Service staff to be sent directly to authorized Disposal Facility for destruction ●Final signature from pharmacists upon completion of the Full-Service Event is obtained ●Kiosk Containers will be sent using Inmar’s DOT Special Permit #20499, from the pharmacy location via FedEx to Inmar’s third party contractor, 123 Compliant Logistics, LLC, a licensed DEA Reverse Distributor-Collector. o 123 Compliant Logistics will record the following information upon receipt of every individual Container: •Date received •Serialized barcode label information •FedEx Tracking information •Weight •Date transported to Disposal Facility •Disposal date •Manifest number o All information recorded will be transferred back to Inmar on a daily basis as part of the electronic raw data file via SSH File Transfer Protocol (SFTP). Any discrepancies observed at 123 Compliant Logistics will be recorded on discrepancy reports to prompt any corrective action. o All product shipped directly to 123 Compliant Logistics will be transported using their contracted, licensed hazardous waste transporter, TransChem Environmental, to the appropriate disposal facility to be incinerated quickly, securely, efficiently and in accordance with all DEA requirements. 123 Compliant Logistics will be responsible for all DEA Form 41 record keeping requirements. Auto-Replenishment of Kiosk Supplies Regardless of service option selected, the supplies used to collect and transport Unwanted Product are provided in automatically-replenished “Kits” of three. Each Kit includes: pre-labeled, pre-addressed and pre- paid cardboard box Containers, liquid barriers and serialized, puncture-resistant Inner Liners. The Kits, when 13 © Inmar 2022. packaged with the interior components, are approximately 6 inches thick. The Mailer is cinched tightly around the inner components, which makes for a very easy-to-store Kit. Kits can be stored behind the pharmacy counter, behind a door, or under or behind a desk, with no ongoing maintenance required. Upon receipt of the Container (and Inner Liner) at our destruction partner’s site, an electronic raw data file via SSH File Transfer Protocol (SFTP) with the weight, serialized barcoded label information and tracking information is passed to Inmar. This information is then received and entered into our Order Management log and Inbound Receipts log. The system tracks when the second of the three Inner Liners is received at the destruction partner. Inmar then initiates a reorder trigger for the next Kit to be shipped. Auto replenishment reduces the amount of inventory maintained at the Collection Point while maintaining sufficient supplies to keep the Kiosk continuously operable. C. Mail-Back Services Pursuant to the Ordinance 6.53.050 (A) (5), Inmar will provide prepaid and pre-addressed Mail-Back Envelopes to Residents containing written instructions for returning unused or unwanted medication. Mail- Back Envelopes will be provided at Mail-Back Distribution Sites and will also be available directly from Inmar via the Program website and toll-free telephone number. Appendix A-3 represents locations identified as targeted Mail-Back Distribution Sites. Once a location has been accepted as a Mail-Back Distribution Site, Inmar will send a stack of prepaid, pre-addressed Unwanted Covered Drugs Mail-Back Envelopes to that location as a Mail-Back Starter Kit. Mail-Back Envelopes will accept all Unwanted Covered Drugs, including pills, creams and liquids, and schedule II-V Controlled substances. However, inhalers and auto-injectors will require the use of different Mail-Back Packages (described below) and will not be included in the Starter Kit. The Starter Kit will include 20 Mail-Back Envelopes sent to each location. Inmar will track the unique identifier for all Mail- Back Envelopes sent to each location for fulfillment and logistical purposes. Inmar will add a visual reorder trigger in the box of Envelopes. Once the location gets to the reorder trigger in the box, the visual 14 © Inmar 2022. reorder trigger will instruct the location to email Inmar for another Kit. This service model ensures that there is no 'down time' at the Site for Envelopes. If a location begins to use a larger number of Envelopes, the number of fulfilled Envelopes sent to that location will be increased. Inmar is committed to providing all pharmacies an option to supply their customers with information regarding Mail-Back Service options. Inmar will provide pharmacies with small cards that can be handed out to County Residents that may need access to this service. The card will instruct them to either call or visit the Program website to locate the nearest Kiosk or request a Mailer. Additionally, we will reach out to pharmacies filling prescriptions by mail to include the cards for the same options. Requesting Return Envelopes County Residents will be able to request up to three (3) Unwanted Covered Drug Envelopes at a time via the Program website or toll-free number. County Residents will receive the Unwanted Covered Drug Envelope no later than 10 business days from date of request. Both the Unwanted Covered Drugs and Inhaler Envelopes will meet DEA rule requirements under § 1317.70(c): ●Pre-addressed, postage paid ●Nondescript, and do not indicate what may be inside ●Waterproof, tamper-evident, tear-resistant, and sealable ●Contain a unique ID number that allows for tracking ●Include instructions for the user that indicate the process for mailing the Package, substances that can be sent, notice that Packages can only be mailed in the US customs territory, and notice that the only Packages provided by the Authorized Collector will be accepted ●No personally-identifiable information will be required Both Envelopes are white in color with a gray interior and are 7” x 10”. The Envelopes include a 3” perforated lip security seal. They are distributed by our third party contractor 123 Compliant Logistics, Inc. A sample envelope is shown below: Sample Inhaler Envelope County Residents will be able to request one Inhaler Envelope at a time via the Program website or toll- free number. County Residents will receive the Inhaler Envelopes no later than 10 business days from date of request. 15 © Inmar 2022. Sample Auto Injector Container County Residents will also be able request one auto-injector Mail-Back Container at a time via the Program website or toll-free number. County Residents will receive the Inhaler Envelopes no later than 10 business days from date of request. Auto-Injector Containers will meet all DOT requirements and will be fulfilled by 123 Compliance Logistics, LLC. See below for specifications and sample. Specifications Access Petals Dimensions (in.) 7.5 x 3.6 x 3.6 in. Color Red Lid Type Hinge Cap Liquid Absorbing Pad Product has liquid absorbing pad Universal Biohaz Sym Product has universal biohaz symbol Volume (L) 1.4 qt 16 © Inmar 2022. Mail-Back Instructions Mail-Back instructions to County Residents for all types of Mailers are provided in Appendix B. Mail-Back Tracking All Mailers (Unwanted Covered Drugs Envelopes, Inhaler Envelopes and Auto-Injector Containers) will have a unique, serialized identification number. Once the Mailer arrives at the destruction facility, the serial number, among other information, will be noted before final disposition. Please see the Disposal Section VI for additional information as to what information is retained for reporting purposes. Mailers distributed directly to Residents via the website or via toll-free phone number requests will be tracked by Inmar when sent to Residents and tracked at the destruction facility when they are returned. This tracking process will allow Inmar to report the number of Mailers distributed and returned in the Annual Reporting provided to the Department, as required. Participating Collection Points and Mail-Back Distribution Sites Appendix A provides lists of where Inmar has established Collection Points and Mail-Back Distribution Sites. These lists include: ● Appendix A-1 Confirmed Authorized Collectors ● Appendix A-2 Potential Authorized Collectors ● Appendix A-3 Confirmed Mail-Back Distribution Sites ● Appendix A-4 Target Mail-Back Distribution Sites D. Collection Events Inmar will provide Kiosks at regional locations convenient to the public and will conduct and promote Drug Take-Back Days in conjunction with a local Law Enforcement Agency. Our intention is to meet convenience standards by supplementing Collection Kiosks with Mail-Back locations in each supervisorial district. Semi-annually, the gaps in coverage and convenience that exist in each district will be evaluated, as well as progress being made against set collection goals to determine the need for Collection Events. 17 © Inmar 2022. As a result of any identified gaps, we will plan and execute a Collection Event to provide additional support for the underserved population. For the convenience of the public, Inmar will work with the Department, local Law Enforcement Agencies and local communities to determine the appropriate number of Take-Back Day Events and their regional locations. So long as State and local health orders allow, Events will include the monthly one-day Events coordinated with the Household Hazardous Waste Department. Location Planning Locations of Collection Events will be determined based on the population centers that are most in need while taking into consideration their access to Collection Kiosks and Mail-Back Distribution Sites. Once the area of need is identified by the means described in Section V(a) above, Inmar will explore locations where it is feasible to host a Collection Event. Most often this will be at a Law Enforcement Agency or a satellite LEA location nearest the target area. However, Inmar has relationships with many other organizations that may be interested in hosting a Collection Event. We may determine these locations to be even more convenient for Residents if they are places that the population is already visiting on a regular basis or can accommodate unique situations such as drive-through collection during peak flu and virus seasons. Additionally, Inmar will consider the willingness or availability for LEAs to provide oversight at the selected location. Inmar will ensure any selected locations meet all applicable laws and regulations. Event Staffing and Oversight In compliance with DEA 1317 (a)-(b), Inmar will ensure that at least one Law Enforcement Agency personnel is present at each Collection Event. LEAs will be responsible for maintaining any records of removal, storage, or destruction of the Controlled substances collected in a manner that is consistent with that Department’s recordkeeping requirements for illicit Controlled substances evidence. In addition, any Controlled substances collected at Collection Events will be stored and transferred for destruction in a manner that prevents the diversion of these substances. Inmar will also provide at least two staff members to be present to assist LEAs with logistics, coordination and/or other needs during the event. It will be Inmar’s responsibility to coordinate with the County and LEAs to ensure compliance with all applicable laws and regulations. The Inmar team will work with the designated LEA to ensure that all material collected is placed in compliant Collection Kiosks and any material that does not meet legal requirements is rejected. Execution Procedures As required by DEA 1317.65, law enforcement officers employed and authorized by the LEA will maintain control and custody of the collected substances from the time the substances are collected from the ultimate user or person authorized to dispose of the ultimate user decedent's property until secure transfer, storage, or destruction of the Controlled substances has occurred. Inmar recognizes and will ensure that only ultimate users and persons entitled to dispose of an ultimate user decedent's property in lawful possession of a Controlled substance in Schedule II-V may transfer these substances to law enforcement during the Collection Event. No other person will handle the Controlled substances at any time. 18 © Inmar 2022. At the conclusion of Collection Events, Inmar will work with LEAs to ensure that the collected materials are properly weighed, packaged and shipped to Inmar’s designated destruction partner (see Section VI) in compliance with all applicable laws. As is standard practice for Kiosk returns under this Plan, Inner Liners will be tracked via their unique identifiers from shipment location to the designated destruction facility. Inmar will make certain that LEAs keep a record of the following information after the transfer of Controlled substances as a result of any Collection Events: ● Unique identification number of the sealed Inner Liner transferred ● Size of the sealed Inner Liner transferred (e.g., 35-gallon) ● Name, address, and registration number of the reverse distributor to whom the Controlled substances were transferred. Collection Event Promotion Inmar will work with the local Law Enforcement Agency or other designated location on any advertisement, promotion, set-up and tear down of the event and community engagement in person. Inmar will provide all promotion for the Collection Event, including local advertising, LEA (or other location organization), social media, and press releases to local news outlets. Collection Event Fees and Costs Inmar will pay all administrative and operational costs associated with Collection Events as part of this Plan. VI. Transportation and Disposal Information Pursuant to Ordinance 6.53.060 (A) Inmar complies with all local, State, and Federal laws and regulations applicable to disposal of medical waste and Controlled substances. In accordance with Ordinance 6.53.060 (B), Inmar subcontracts with a trusted, permitted partner for hazardous waste disposal. Kiosk Containers will be sent using Inmar’s DOT Special Permit #20499, from the Authorized Collector via FedEx to Inmar’s third party contractor, to 123 Compliant Logistics, LLC, a licensed DEA Reverse Distributor-Collector. All Mailers will be sent via USPS to 123 Compliant Logistics. 123 Compliant Logistics will record the following information upon receipt of every individual Container and Mailer: ●Date received ●Serialized barcode label information ●FedEx Tracking information (Kiosk Containers only) ●Weight ●Date transported to disposal facility ●Disposal date ●Manifest number (if applicable) All information recorded will be transferred back to Inmar on a daily basis as part of the electronic raw data file via SSH File Transfer Protocol (SFTP). Any discrepancies observed at 123 Compliant Logistics will be recorded on discrepancy reports to prompt any corrective action. 19 © Inmar 2022. 123 Compliant Logistics operates in full compliance with DEA § 1317.75(c) which prohibits handling substances after they have been deposited into a Collection Kiosk. All product shipped directly to 123 Compliant Logistics will be transported using their contracted, licensed hazardous waste transporter, TransChem Environmental to the appropriate disposal facility to be incinerated quickly, securely, efficiently and in accordance with all DEA requirements. 123 Compliant Logistics will be responsible for all DEA Form 41 record keeping requirements. Please refer to the table on the next page for the contracted disposal locations. In reference to Ordinance 6.53.060 (B), 123 Compliant Logistics, TransChem Environmental and FedEx will comply with all local, State and Federal laws and regulations surrounding the transportation and disposal of Unwanted Covered Drugs. Information on FedEx’s 5-year record of penalties, violations and/or regulatory orders received is detailed in its SEC filings found on http://investors.fedex.com/financial-information/sec-filings/default.aspx. All other relevant permits and compliance history can be found in Appendix D. Company Name Contact Information Registration Information Service Provided 123 Compliant Logistics, LLC 2626 N 29th Ave Phoenix, AZ 85009 Rory Buske 602-612-4140 DEA Reverse Distributor- Collector: R90571264 DEA Reverse Distributor-Kiosk Liners 123 Compliant Logistics, LLC 1888 M Street, Suite B Agawam, MA 01001 Chris Ellis 480-695-2015 DEA Reverse Distributor- Collector: R90595946 DEA Reverse Distributor-Mail- Back Packages Clean Harbors Aragonite 11600N. Aptus Rd. Aragonite, UT94029 Michael Marlow 435-884-8100 EPA ID: UTD981552177 Hazardous Waste Incinerator - All Unwanted Covered Drugs Clean Harbors El Dorado, LLC 309 American Circle El Dorado, AR 71730 Dan Roblee 870-863-7173 EPA ID: ARD069748192 Hazardous Waste Incinerator - All Unwanted Covered Drugs Veolia ES Technical Solutions, L.L.C 7665 Highway 73 Port Arthur, TX 77640 David Michaelis 281-216-9618 EPA ID: TXD000838896 Hazardous Waste Incinerator - All Unwanted Covered Drugs TransChem Environmental 542 East 27th Street Tuscon, AZ 85713 520-829-5651 DOT Registration: 052119550060B Hazardous Materials Safety Permit: US-1341480-AZ-HMSP Hazardous Waste Transporter - All Unwanted Covered Drugs FedEx Eric Stillson 800-469-9993 Common Carrier – Kiosk Containers USPS Jackie Purcell 919-501-9394 Common Carrier – All Mail-Back Packages 20 © Inmar 2022. VII. Policies and Procedures Inmar will ensure that it acts in compliance with all applicable laws, rules, and regulations as specified by the Program requirements and require by contract where applicable that vendors and Collection Points are also compliant with all laws, regulations, and legal requirements. Inmar, Collection Points, and vendors will specifically be required to comply with The Controlled Substances Act, 21 USC SS 801-971 and 21 CFR SS 1317; United States Department of Transportation Hazardous Materials Regulation, 49 CFR parts 100-185; California Board of Pharmacy, title 16, Article 9.1 and all applicable Alameda County Ordinances and Regulations. The DEA Rule defines Authorized Collectors as Law Enforcement Agencies and additionally as retail pharmacies, reverse distributors, hospitals, or clinics with onsite pharmacies, and certain other entities that are registered with DEA as an Authorized Collector. Inmar has established standard operating procedures that require Authorized Collectors to adhere to these standards. Any Authorized Collector agreements specifically require their compliance ensuring their commitment to compliant operation of the Collection Points and shipping of contents in compliance with the DEA regulations. A refusal to sign the agreement or comply with the DEA regulations would be a reason why an Authorized Collector would be excluded from the Inmar Stewardship Plan. Documentation and Tracking Pursuant to the Ordinance 6.54.050 (A) (7) and the Regulation § 8 (A) (iii – iv), the below section outlines the Plan’s management practices, policies, and procedures. Collection Containers and Inner Liners will have a serialized identification number to enable tracking at all stages of the return process illustrated below. Tracking is well-documented as evidenced by the Inmar serialization tracking form that is included at the end of this section. This form must be completed and witnessed by two authorized Pharmacy Employees, which assures compliance and safety across the Program, and internally by both the Stewardship Organization and the Authorized Collector. 21 © Inmar 2022. The purpose of this form is to document the use of the serialized Inner Liner throughout the collection process and to help the Authorized Collector meet DEA and Board of Pharmacy record-keeping requirements. Inmar will require each Authorized Collector to understand and comply with all Federal, State, and local regulatory requirements pertaining to Unwanted Covered Drugs applicable at the authorized Collection Point. The serial numbers, date acquired, and signature of one authorized Pharmacy Employee must be completed upon receipt of the Container and Inner Liner. As illustrated above, the date installed is to be completed by two authorized Pharmacy Employees with their names and signatures. The date the Container and Inner Liner are removed from the Kiosks is also to be noted with names and signatures. Finally, the date the Container and Inner Liner are shipped is noted with authorized names and signatures. Authorized Collectors must maintain a copy of the completed form, a copy of the FedEx tracking information, and other records as applicable, on file at the Collection Point for at least two years. Transport The Authorized Collector will properly seal, store securely, and arrange for pickup of the sealed Inner Liner and its contents from the registered location in a manner consistent with DEA regulations. The Container will include a pre-addressed and prepaid shipping label. The FedEx representative will take possession of the Container and deliver the Container to an approved destruction facility for witnessed incineration. Disposal Once the Container/Inner Liner arrives at the destruction facility, the serial number will be noted before final disposition, which will allow Inmar to report the number of Containers/Inner Liners distributed and returned by each Collection Point in the Reporting provided to Alameda County, as required. Compliance with Applicable Laws Inmar operates across 44 states and the District of Columbia and maintains compliance with all applicable Federal, State, and local laws. Upon approval to act as a Plan Owner, Inmar, its vendors and Collection Points will comply with the Program requirements. 22 © Inmar 2022. VIII. Outreach Program Design A. Promotion Inmar will execute a comprehensive and measurable public outreach strategy to drive awareness of the Plan and maximize participation pursuant to the Ordinances 6.53.050 (A) (8) and 6.53.070, and the Regulations §7 (G) and § 8 (A) (vi-vii). In addition to preventative education, Inmar’s strategy is designed to ensure that where and how to return Unwanted Products is widely understood by Residents, pharmacists, retail pharmacies, health care facilities and providers, veterinarians, and veterinary hospitals. Pursuant to the Ordinance 6.53.070, the individual components of Inmar’s public outreach strategy are detailed below. Across all tactics, key messages will include, but not be limited to, the following: ●Promote safe storage of all drugs, wanted or unwanted, by Residents in their homes; ●Discourage stockpiling and storage of Unwanted Products in the home ●Describe where and how to return Unwanted Products ●Discourage improper disposal of drugs (e.g., flushing or solid waste collection) ●Identification of locations and Collection Events in the County as part of National Consumer Drug Take-Back Events ●Identification of Collection Events included in the County’s Household Hazardous Waste Department as included on Stopwaste.org. If more than one Stewardship Plan is approved by the Department, Inmar will seek to coordinate its promotional activities with other approved Programs. This coordination will begin upon plan approval with the goal of establishing a single system of promotion within 90 days of approval. However, the timeline of when this single system of promotion can be fully implemented will depend on the cooperation and availability of the other approved Plan Operators. Coordination efforts will include providing a single website and toll-free telephone number to access information about Collection services for all approved Stewardship Plans. Inmar will work with the existing Plan Operator to provide the Director with a mutually agreed upon document which outlines the principles of coordination and specifies the required elements of the single-system of promotion. Inmar will work with the current Plan Operator to coordinate on the following elements: 1)Jointly agree on website name with approval by the Department, 2)Jointly agree on toll-free telephone number, 3)Jointly agree to fund the website and toll-free number fairly, 4)Provide a joint document to the Department detailing the plan, 5)Meet immediately to discuss any confusion by ultimate users and take action to address, and 6)The approved Plan Operators will design and seek approval for a county-wide Program logo which will be readily recognizable for use on Kiosks, educational materials, the website and other ultimate user facing materials. 23 © Inmar 2022. Although Inmar is willing to coordinate promotional activities with other approved Plan Operators, Inmar will execute its comprehensive and measurable public outreach strategy to drive awareness of the Plan and maximize participation pursuant to the Ordinances 6.53.050 (A) (8) and 6.53.070, and the Regulations §7 (G) and § 8 (A) (vi-vii) separately from other Plan Operators. The outreach strategy is outlined further below and in the Goals section. Outreach Materials Inmar will provide easily-consumable educational materials for dissemination to interested parties including Residents, pharmacists, retailers, and health care practitioners upon request and at no charge. Materials will be available in English, Spanish, Chinese, Vietnamese and Tagalog. These materials will: ●Provide instruction on how to safely store covered drugs at home ●Inform of the risks of disposing of Unwanted Products in inappropriate waste streams (e.g., solid waste collection, sewer, or septic systems) ●Outline how to participate in the Plan for safe disposal of Unwanted Products. All materials will be easily understandable by interested parties with varying levels of English proficiencies as well as in the Required Languages and will leverage explanatory graphics to aid in comprehension. Please see Appendix C for example materials. B. Standardized Instructions Collection Kiosk Signage The Collection Kiosks themselves will be readily-recognizable. The standard color for the Kiosks is bright green for easy identification, and each Kiosk is adorned with clear graphical instructions for proper use, which will be provided in the English and Spanish and available in the other Required Languages upon request. Please see Appendix B for an image of the Collection Kiosk and disposal instructions. C. Website and Toll-Free Number Website Inmar will provide a mobile-optimized website, appropriately translated into the Required Languages, which will publicize collection options and educate interested parties. Inmar will use enhanced search engine optimization to ensure easy location and access. Specifically, the website will: ●Leverage Inmar’s collaboration with Google Maps to allow interested parties to find the nearest Collection Point or Mail-Back Distribution Site via an interactive map. The list of locations will be updated monthly to ensure accuracy. ●Location list will be inclusive of all Kiosks located in the County including those operated by other Plan Owners. 24 © Inmar 2022. ●Allow interested parties to request prepaid Mail-Back Envelopes. ●Include educational and outreach materials promoting safe storage of covered drugs Retailers or pharmacies interested in participating in the Plan will be able to request more information through the website. Please see Appendix C for images of the website interface and functionality. Toll-Free Number Inmar will operate a multi-lingual, live operator (English, Spanish, Chinese, Vietnamese and Tagalog) toll- free call center that interested parties can call to learn more about the Plan, take-back events, and best practices for disposal of Unwanted Products. Callers will be validated by zip code for applicable County Plan offerings. County Residents will also be able to request information about the nearest Collection Point or Mail-Back Envelope Distribution Site, or request that a prepaid Mail-Back Envelope is sent to them. The call center is operated with live operators and will be staffed with a third party service to assist with live translation in the required languages. All operators are trained to assist an answer questions related to any and all questions related to the Stewardship Plan operation including but not limited to Authorized Collector Kiosk support and service requests. 25 © Inmar 2022. D. Impact Measurement Pursuant to the Ordinance 6.53.080 (A) (7), Inmar will provide a description of outreach initiatives in its annual report, but also aims to provide more frequent and actionable reporting on the impact of such initiatives. With specific regard to social influencer marketing and targeted media, Inmar’s measurement tools and philosophies have continuously set the industry standard with their emphasis on transparency and quantifiability over vanity metrics and theoretical explanations. Reporting will include: ●Third-party-verified Content View & Engagement reporting ●Engagement breakdown by social platform, including Time on Content ●Social Content Ad™ (aka social media ad) performance data ●Total Media Value (TMV) calculations ●Thumbnail links to all influencer content, and performance metrics for individual influencer posts (including TMV for each post). E. Traditional Media Inmar has a system in place that allows us to efficiently deploy local media using traditional tactics for general awareness and programmatic media to sustain a presence throughout the years. Below are details broken out by medium that cover recommended placements. Direct Mail o Public service announcement (PSA) postcard sent to local residents (5x7 post card) General Public Option #1: Entire County Option #2: Select Zip Codes Option #3: Select Neighborhoods/Streets Option #4: New Resident Mailers (mail to those that move INTO the area) Pharmacies List Purchase by zip code Health Care Providers List Purchase by zip code Veterinary Providers List Purchase by zip code Public Health Facilities List Purchase by zip code Print Ads o Run ads in local papers for 3-4 weeks to announce PSA o Selection of papers based on budget Television o Use viewership data and combine it with third-party data to find in market audiences and deliver an efficient and effective campaign across all viewing screens (Streaming, OTT, Mobile, Television, On-Demand) 26 © Inmar 2022. o Whether by geography, content, audience, or addressability, target your audiences precisely. o Track campaign performance with transparent metrics and get recommendations on how to optimize your next one. o 22 Zones in the greater Bay Area Berkeley CA Contra Costa Delta Valley Fremont Hayward Lake CA Livermore Marin Mid Peninsula Napa North Peninsula Oakland Redwood Empire San Francisco San Jose Santa Rosa Silicon Valley East Silicon Valley West South Peninsula Tri Cities Tri Valley Vallejo Channels local networks such as NBC, ABC, CBS, FOX and cable, streaming networks such as ESPN, Fox News, HGTV, Lifetime, Comedy Central, Bravo, CNN, CNBC, ESPN Deportes, Food Network, Fox Sports, FS1, Golf, History in Espanol and many more Radio o PSA o Top 8 stations in the greater Bay Area market highest ratings/reach KCBS-AM All News Entercom 8.4 KQED-FM News/Talk KQED 7.5 KNBR-AM All Sports Cumulus 4.8 KLLC-FM Hot AC Entercom 4.7 KISQ-FM AC iHeartMedia 4.3 KOIT-FM AC Bonneville 4.1 KIOI-FM AC iHeartMedia 3.2 KSAN-FM Classic Rock Cumulus 3.2 Programmatic Media o Leverage Inmar network of transparent retail audiences, to serve behaviorally targeted display and/or video ads o Geo-Targeting: Inmar will upload physical locations of drug receptacles and target individuals within close proximity to build awareness and encourage usage 27 © Inmar 2022. F. Additional Promotional Considerations Authorized Collector Marketing Support To drive awareness and participation at a local level, Inmar will provide individual Authorized Collectors with a variety of marketing assets including in-store signage, social media content kits, press release templates, a radio ad script, and scripts for Pharmacy Employees to let County Residents know that they can safely dispose of their Unwanted Product at that location. Authorized Collectors will be able to request additional marketing materials through the toll-free number. Please see Appendix C for example materials. Social Influencer Marketing Each Inmar Intelligence social influencer campaign progresses through four stages: Plan, Discover, Activate, and Measure. Plan In the Plan stage, we leverage our in-house social insights toolkit, to create content themes and targeting parameters. The Inmar team pulls data across 36MM social engagements to lend insight into trending topics, ideal campaign timing, and key audience demographics. For example, our social media toolkit may illustrate that conversations around National Consumer Drug Take-Back Day spike three weeks prior to the event in certain regions, among a specific demographic. With this knowledge in hand, Inmar Intelligence works with our influencers to curate and distribute content related to National Consumer Drug Take-Back Day and distribute it to the target audience who live in a specific area in the three weeks leading up to the Event. Discover The Discovery stage is where influencers are matched to the campaign. Inmar Intelligence has a private, invite-only community of influencers each individually vetted for content quality, historical performance and audience quality. Activate Once the influencers have been selected, it is time to start creating and distributing content. Influencers are provided with a brief that outlines the key message, desired outcomes, and any parameters or restrictions. Outside of the brief, influencers are given creative liberty to ensure that the content still feels authentic and will resonate with their followers. Importantly, partners have the ability to approve content to ensure it meets their requirements before it is published. Upon distribution, influencers organically reach thousands of engaged followers and subscribers on their respective social platforms. Inmar Intelligence’s Media Operations team closely monitors the performance of each individual post and compares it to benchmark data. Particular emphasis is put on metrics such as engagements, clicks, and shares (as opposed to views and impressions) because the former metrics suggest action and deep engagement rather than a passive (or even unconscious) glance at the content. Measure For the entirety of the campaign, an online dashboard enables us to continuously monitor campaign performance. All metrics reported within the dashboard are third-party verified. Inmar has a curated network of more than 12,000 highly-vetted influencers who are experts at creating authentic, compelling 28 © Inmar 2022. content that can drive awareness and inspire participation among covered entities. Inmar utilizes sophisticated influencer selection, data-driven content distribution, and audience re-engagement tactics to ensure that content is hyper-relevant and that the covered entities receiving the content are the ones most inclined to take action. Content can focus on an array of topical themes, however, based on the Program requirements Inmar’s recommendation would be one, or a combination of, the following: ●Tips for safe storage of medications in the home prior to disposal ●Education about the implications of improper drug disposal ●Promotion of the Product Stewardship Plan, including directions on where and how to participate. Cross Promotion with Stopwaste.org Inmar can leverage any of the tactics described in this section to promote the stopwaste.org website and social media channels in a manner mutually agreed upon with the County, including, but not limited to: ●Referencing the stopwaste.org website and social media channels on educational and outreach materials, as well as in-store signage ●Referencing the stopwaste.org website and social media channels in social media and PR content kits provided to Authorized Collectors ●Running a social influencer marketing campaign to drive influencers’ followers to the stopwaste.org website and social channels ●Delivering optimized paid media ad units driving a targeted cohort of covered entities to stopwaste.org. In cross-promoting stopwaste.org with the LifeInCheck™ Consumer Drug Take-Back Program, Inmar can provide covered entities with a broader view of what it means to dispose of Unwanted Products in a safe and sustainable way. Biennial Survey To measure the effectiveness of the comprehensive and measureable public outreach strategy, Inmar will conduct a biennial survey of County Residents as well as pharmacists, veterinarians, and health professionals separately who interact with patients on use of medicines after the first full year of operation of the Stewardship Plan. The aim of the survey questions will be to measure the percent awareness of the Stewardship Plan, assess to what extent drop-off sites and other collection methods are convenient and easy to use, and assess knowledge and attitudes about risks of abuse, poisonings, and overdoses from prescription and non-prescription drugs used in the home. IX. Annual Reporting Pursuant to the Ordinance 6.53.080 and the Regulation §15 as the Department advises and annually thereafter, Inmar will submit a report describing the Plan’s activities during the previous reporting period. The report will include: a. Report Narrative with the following subsections: i. Executive summary to include a brief description of collection and disposal efforts during the reporting period 29 © Inmar 2022. ii. A Summary of the Plan goals to include degree of success and opportunities of unmet goals iii. Proposed Goals to be accomplished in the upcoming year iv. A description of the collection efforts of the past year v. A description of education and public outreach efforts of the past year vi. Safety and Security report including any known security and safety incidents at Collection Points along with any corrective or other action taken in response to the incident, law enforcement involved or any litigation arbitrations or other legal proceedings arising out of or involving the incident. b. Report Data containing the following: i. All Producers participating in the Plan ii. Each Collection Site location: host Site name and address, weight of collected Unwanted Products over the past year and number of times Unwanted Products were picked up for transportation iii. Mail-Back Program to include number of Mail-Back Envelopes distributed, returned and total weight of collected Unwanted Products iv. For each Disposal Facility: name address and telephone number, total weight of collected Unwanted Products disposed. X. Patient Privacy Inmar provides significant training to our participating Authorized Collectors and strictly follows the DEA guidelines for the proper handling of the Plan Kiosks and Inner Liners. This begins with the proper training of the Authorized Collector in the compliant operation of the Kiosks and proper preparation, removal, and packaging of the Container. It also involves the training of the Inmar staff that may come into contact with the full Container to ensure proper handling. Inmar strictly complies with State and Federal statutes and regulations including, but not limited to, the DEA guidelines cited below. According to the DEA - As provided in §§ 1317.60(c) and 1317.70(f), Inner Liners shall be sealed immediately upon removal from the permanent outer Container; sealed Inner Liners and returned Mail- Back Containers shall not be opened, x-rayed, analyzed, or otherwise penetrated. Accordingly, their contents shall not be sorted or inventoried subsequent to being placed into Kiosks or Mail-Back Containers. To clarify this, § 1317.75(c) was modified to add the prohibition against individually handling substances after they have been deposited into Collection Kiosks. Inmar has a long history of serving both commercial and government clients with stringent Program requirements. For example, Inmar’s pharmacy applications manage Protected Healthcare Information (PHI) and are HIPAA compliant. Additionally, as part of Inmar’s Rx Returns (reverse distribution) business, we work very closely with regulators to implement compliant procedures covering the DEA, Boards of Pharmacy, EPA, and other tangential regulatory entities. Data protection, privacy, and adherence to applicable regulations are the foundation of Inmar service capabilities. Any and all patient information on drug packaging will be promptly destroyed. 30 © Inmar 2022. XI. Goals Program Collection Goals 90 Days 12 Months ●Initiate Plan operation ●Increase Authorized Collection Points in the County ●Inmar’s goal is to achieve 100 Kiosks distributed jointly, in combination with other Plan Owners, across the County to provide equitable and reasonably convenient access to Residents. ●Establish Mail-Back Programs and/or Take-Back Events in areas that are underserved by Collection Points. ●Provide and communicate system for pharmacies to request Mail-Back Envelopes. Program Promotion Goals 3 Months 6 Months 12 Months 18 Months ●Website launch ●Covered entity educational materials ●Authorized Collector marketing support materials ●Direct mail communication & print add marketing commences ●Website functionality updates o Return Envelope requests o Educational materials uploaded o Authorized Collector Kiosk maintenance resources and requests o Collection Point and Mail-Back Envelope Distribution Site list updated (ongoing) ●Initiate social influencer and targeted media outreach (1 influencer campaign and 2 promoted LifeInCheckTM posts per month) ●Television & radio campaigns initiated ●Website functionality updates o Translation into specified languages o Collection Point and Mail-Back Envelope Distribution Site list updated (ongoing) ●Continue social influencer and targeted media outreach (1 influencer campaign and 2 promoted LifeInCheckTM posts per month) ●Continue television & Radio campaigns ●Website functionality updates o Collection Point and Mail-Back Envelope Distribution Site list updated (ongoing) ●Continue social influencer and targeted media outreach (1 influencer campaign and 2 promoted LifeInCheckTM posts per month) ●Direct mail and print add marketing continues ●Continue television & radio campaigns 31 © Inmar 2022. XII. Additional Plan Considerations Existing Plan Owners If more than one Stewardship Plan is approved by the Department, Inmar will seek to coordinate its promotional activities with other approved Programs. This coordination will begin upon Plan approval with the goal of establishing a single system of promotion within 90 days of approval. However, the timeline of when this single system of promotion can be fully implemented will depend on the cooperation and availability of the other approved Plan Operators. Coordination efforts will include providing a single website and toll-free telephone number to access information about Collection services for all approved Stewardship Plans. Inmar will work with the existing Plan Operator to provide the Director with a mutually agreed upon document which outlines the principles of coordination and specifies the required elements of the single-system of promotion. Inmar will work with the current Plan Operator to coordinate on the following elements: 1.Jointly agree on website name with approval by the Department, 2.Jointly agree on toll-free telephone number, 3.Jointly agree to fund the website and toll-free number fairly, 4.Provide a joint document to the Department detailing the plan, 5.Meet immediately to discuss any confusion by ultimate users and take action to address, and 6.The approved Plan Operators will design and seek approval for a state-wide Program logo which will be readily recognizable for use on Kiosks, educational materials, the website and other ultimate user facing materials. Although Inmar is willing to coordinate promotional activities with other approved Plan Operators, Inmar will execute its comprehensive and measurable public outreach strategy to drive awareness of the Plan and maximize participation pursuant to the Ordinances 6.53.050 (A) (8) and 6.53.070, and the Regulations §7 (G) and § 8 (A) (vi-vii) separately from other Plan Operators. The outreach strategy is outlined further above and in the Goals section. Package Separation & Recycling DEA §1317.75(c) prohibits handling substances after they have been deposited into a Collection Kiosk. For this reason, Inmar is unable to separate and recycle drug packaging. However, Inmar can execute educational Programs, as outlined in Section VI, to encourage County Residents to separate Unwanted Products from their packaging and recycle the packaging prior to disposal. Even though regulations prevent us from recycling drug packaging, Inmar still has a vested interest in reducing waste and improving our environment. We will continue to look for opportunities to expand our eco-friendly efforts in the County. 32 © Inmar 2022. Appendix A. Collection Points & Mailer Sites 32 A-1: Confirmed Authorized Collectors 33 A-2: Potential Authorized Collectors 35 A-3: Confirmed Mail-back Sites 38 A-4: Potential Mail-back Sites 41 B. Kiosk Signage & Mailer Instructions 42 C. Promotion Material 47 D.Applicable Permits, Licenses 55 E.Compliance History 53 33 © Inmar 2022. Appendix A-1: Confirmed Authorized Collectors Site Name Site Address Site City Zip District SAFEWAY PHARMACY #2708 2227 SOUTH SHORE CENTER Alameda 94501 3 SAFEWAY PHARMACY #3281 2600 5TH ST. Alameda 94501 3 SAFEWAY PHARMACY #0951 867 ISLAND DRIVE BRIAN / PHARMACY Alameda 94502 3 SAFEWAY PHARMACY #0691 1444 SHATTUCK PLACE Berkeley 94709 5 Univ of Cal Univ Health Services (CS) Tang Center, 2222 Bancroft Way Room 1115 Berkeley 94720 5 SAFEWAY PHARMACY #1953 7499 DUBLIN BLVD Dublin 94568 1 Lucky Store #712 34101 FREMONT BLVD Fremont 94555 2 SAFEWAY PHARMACY #0993 3902 WASHINGTON BLVD Fremont 94538 1 Lucky Store #711 40055 MISSION BLVD Fremont 94539 1 SAFEWAY PHARMACY #1931 46848 MISSION BLVD Fremont 94539 1 Lucky Store #714 5000 MOWRY AVE Fremont 94538 1 SAFEWAY PHARMACY #0971 22280 FOOTHILL BOULEVARD Hayward 94541 2 Lucky Store #715 22555 MISSION BLVD Hayward 94541 2 Lucky Store #716 25151 SANTA CLARA ST Hayward 94544 2 Lucky Store #722 1951 HOLMES ST Livermore 94550 1 Lucky Store #721 2000 PORTOLA AVE Livermore 94550 1 SAFEWAY PHARMACY #1257 4495 FIRST ST Livermore 94551 1 TIB Pharmacy 7999 Gateway Blvd., Suite 110 Newark 94560 2 Lucky Store #736 247 E 18TH ST Oakland 94606 3 SAFEWAY PHARMACY #3132 5100 BROADWAY Oakland 94611 5 SAFEWAY PHARMACY #2870 6310 COLLEGE AVE Oakland 94618 5 Lucky Store #744 6155 W LAS POSITAS Pleasanton 94566 4 SAFEWAY PHARMACY #2856 6790 BERNAL AVE Pleasanton 94566 4 Lucky Store #767 1300 FAIRMONT DR San Leandro 94578 3 34 © Inmar 2022. Lucky Store #768 15840 HESPERIAN BLVD San Lorenzo 94580 3 SAFEWAY PHARMACY #1197 1790 DECOTO ROAD Union City 94587 2 Lucky Store #782 32300 DYER ST Union City 94587 2 35 © Inmar 2022. Appendix A-2: Potential Authorized Collectors Site Site Address Site City Zip District Status WAL-MART PHARMACY 10-5426 40580 ALBRAE STREET FREMONT 94538 1 In Discussion WAL-MART PHARMACY 10-2989 44009 OSGOOD ROAD FREMONT 94539 1 In Discussion WAL-MART PHARMACY 10-1972 2700 LAS POSITAS RD LIVERMORE 94551 1 In Discussion KAISER FOUNDATION HOSP 300-G PULLMAN STREET LIVERMORE 94550 1 In Discussion WAL-MART PHARMACY 10-2031 30600 DYER STREET UNION CITY 94587 2 In Discussion KAISER FOUND HLTH PLAN, INC 3555 WHIPPLE ROAD UNION CITY 94587 2 In Discussion WAL-MART PHARMACY #5434 15555 HESPERIAN BLVD. SAN LEANDRO 94579 3 In Discussion WAL-MART PHARMACY 10-5611 3112 SANTA RITA RD. PLEASANTON 94566 4 In Discussion WAL-MART PHARMACY 10-2161 4501 ROSEWOOD DR PLEASANTON 94588 4 In Discussion KAISER FOUNDATION HEALTH PLAN 5600 STONERIDGE MALL ROAD PLEASANTON 94588 4 In Discussion CHILDREN'S CLINIC PHARMACY 747 52ND STREET OAKLAND 94609 5 In Discussion EAST BAY AIDS CENTER OUTPATIENT PHARMACY 3100 SUMMIT ST, 2447A OAKLAND 94609 5 In Discussion KAISER PERMANENTE PHARMACY #181 1795 SECOND ST SUITE B BERKELEY 94710 5 In Discussion Alta Bates Summit Medical Center- Herrick Campus 2001 Dwight Way Berkeley 94704 5 In Discussion CVS PHARMACY # 17628 2800 DUBLIN BLVD DUBLIN 94568 1 Notified MAXOR NATIONAL PHARMACY SERVICES LLC 5325 BRODER BLVD DUBLIN 94568 1 Notified DBA COSTCO PHARMACY #778 43621 PACIFIC COMMONS BLVD FREMONT 94538 1 Notified CVS PHARMACY # 17592 43950 PACIFIC COMMONS BLVD FREMONT 94538 1 Notified DBA: WALGREENS # 02660 41400 BLACOW RD FREMONT 94538 1 Notified DBA: WALGREENS # 04517 2600 MOWRY AVE FREMONT 94538 1 Notified LIRX 1860 MOWRY AVE, STE 102 FREMONT 94538 1 Notified DBA: WALGREENS # 02366 3860 DECOTO ROAD FREMONT 94555 1 Notified DBA COSTCO PHARMACY #146 2800 INDEPENDENCE DR LIVERMORE 94550 1 Notified DBA: WALGREENS #15163 1620 FIRST ST. LIVERMORE 94550 1 Notified CVS PHARMACY # 16275 4300 LAS POSITAS RD LIVERMORE 94551 1 Notified DBA: WALGREENS # 02401 21463 FOOTHILL BLVD. HAYWARD 94541 2 Notified DBA: WALGREENS # 06502 23958 HESPERIAN BLVD HAYWARD 94541 2 Notified DBA COSTCO PHARMACY #1061 28505 HESPERIAN BLVD HAYWARD 94545 2 Notified CVS PHARMACY # 17265 19661 HESPERIAN BLVD HAYWARD 94541 2 Notified PLEASANT CARE PHARMACY 1652 B STREET HAYWARD 94541 2 Notified CVS PHARMACY # 16804 2499 WHIPPLE RD HAYWARD 94544 2 Notified 36 © Inmar 2022. DBA: WALGREENS # 02306 1138 W TENNYSON RD HAYWARD 94544 2 Notified DBA: WALGREENS # 04659 164 W. JACKSON ST. HAYWARD 94544 2 Notified CORAM HEALTHCARE CORP OF NORTHERN CALIFO 3160 CORPORATE PL HAYWARD 94545 2 Notified EVERGREEN PHARMACEUTICAL OF CALIFORNIA, dba OMNICARE OF HAYWARD 20967 CABOT BLVD HAYWARD 94545 2 Notified KPNC-HAYWARD CLINIC OP- Clinic 27303 SLEEPY HOLLOW HAYWARD 94545 2 Notified SKILLED NURSING PHARMACY 21150 CABOT BOULEVARD HAYWARD 94545 2 Notified TIB PHARMACY LLC 5886 MOWRY SCHOOL ROAD NEWARK 94560 2 Notified ENTIRELYPETS PHARMACY LLC 34571 SEVENTH STREET UNION CITY 94587 2 Notified MASONIC HOME PHARMACY 34400 MISSION BLVD UNION CITY 94587 2 Notified RITE AID #5943 1650 DECOTO ROAD UNION CITY 94587 2 Notified DBA: WALGREENS # 04050 1916 WEBSTER ST. ALAMEDA 94501 3 Notified DBA: WALGREENS #15666 1600 PARK ST ALAMEDA 94501 3 Notified SUTTER INFUSION & PHARMACY SERVICES #2 1105 ATLANTIC AVENUE ALAMEDA 94501 3 Notified VERSAILLES PHARMACY 2801 ENCINAL AVE ALAMEDA 94501 3 Notified LA CLINICA DE LA RAZA 3451 EAST 12TH STREET OAKLAND 94601 3 Notified NEW CHINATOWN PHARMACY 719 E 12TH ST OAKLAND 94606 3 Notified DBA: WALGREENS #10526 3250 LAKESHORE AVE STE B OAKLAND 94610 3 Notified DBA COSTCO PHARMACY #118 1900 DAVIS ST SAN LEANDRO 94577 3 Notified KPNC-SAN LEANDRON OP #921- Clinic 2500 Merced St Flr#1 SAN LEANDRO 94577 3 Notified ONEPOINT PATIENT CARE, LLC 1599 FACTOR AVE. SAN LEANDRO 94577 3 Notified DBA: WALGREENS # 07274 1456 136TH AVE SAN LEANDRO 94578 3 Notified DOLPHIN HEALTH PHARMACY 7400 MACARTHUR BLVD OAKLAND 94605 4 Notified DBA: CVS/PHARMACY # 09929 2000 MOUNTAIN BLVD OAKLAND 94611 4 Notified DBA: WALGREENS # 03295 8102 INTERNATIONAL BLVD OAKLAND 94621 4 Notified DBA: WALGREENS # 02150 1763 SANTA RITA RD PLEASANTON 94566 4 Notified RALEY'S PHARMACY #316 5420 SUNOL BLVD. PLEASANTON 94566 4 Notified CLEAR CHOICE PHARMACY 3059 HOPYARD RD. PLEASANTON 94588 4 Notified DBA: CVS/PHARMACY # 09595 1382 SOLANO AVE ALBANY 94706 5 Notified CVS PHARMACY # 17044 1057 EASTSHORE HWY ALBANY 94710 5 Notified CVS PHARMACY # 17673 2187 SHATTUCK AVE BERKELEY 94704 5 Notified DBA: WALGREENS #10045 2310 TELEGRAPH AVE BERKELEY 94704 5 Notified PRIME HEALTH PHARMACY 2915 TELEGRAPH AVE, STE 100 BERKELEY 94705 5 Notified 37 © Inmar 2022. PHARMACA INTEGRATIVE PHARMACY 1744 SOLANO AVENUE BERKELEY 94707 5 Notified DBA: WALGREENS # 02314 1050 GILMAN ST BERKELEY 94710 5 Notified CVS PHARMACY # 17624 1555 40TH STREET EMERYVILLE 94608 5 Notified STANFORD EMERYVILLE HEALTH CENTER PHARMA 5800 HOLLIS STREET, ROOM 2325 EMERYVILLE 94608 5 Notified DBA: WALGREENS # 01537 3232 FOOTHILL BLVD OAKLAND 94601 5 Notified WEST OAKLAND HEALTH CENTER 700 ADELINE STREET OAKLAND 94607 5 Notified AIDS HEALTHCARE FOUNDATION/AHF PHARMACY 400 THIRTIETH STREET OAKLAND 94609 5 Notified DBA: WALGREENS # 03170 3400 TELEGRAPH AVENUE OAKLAND 94609 5 Notified NICHOLS HILL PRESCRIPTION PHARMACY 2844 SUMMIT STREET OAKLAND 94609 5 Notified COMMUNITY, A WALGREENS PHARMACY #16477 3009 BROADWAY OAKLAND 94611 5 Notified OAKLAND CLINIC PHARMACY 5220 CLAREMONT AVE OAKLAND 94618 5 Notified PHARMACA INTEGRATIVE PHARMACY, INC. 5729 COLLEGE AVE. OAKLAND 94618 5 Notified 38 © Inmar 2022. Appendix A-3: Confirmed Mail-Back Sites Site Name Site Street Address Site City Zip District Status Sutter Care at Home - Hospice 1025 Atlantic Avenue, Suite 350B Alameda 94501 3 Confirmed Mail-Back Site Lucky California-700 815 MARINA VILLAGE PKWY ALAMEDA 94501 3 Confirmed Mail-Back Site Safeway-676 1500 Solano Ave Albany 94706 5 Confirmed Mail-Back Site Alta Bates Outpatient Pharmacy 2001 Dwight Way Berkeley 94704 5 Confirmed Mail-Back Site Lifelong Medical Care 2031 6th Street Berkeley 94710 5 Confirmed Mail-Back Site Lifelong Medical Care 2031 Sixth Street Berkeley 94710 5 Confirmed Mail-Back Site Safeway-768 20629 Redwood Rd Castro Valley 94546 4 Confirmed Mail-Back Site Lucky-704 3443 CASTRO VALLEY BLVD CASTRO VALLEY 94546 4 Confirmed Mail-Back Site Lucky California-750 2840 DUBLIN BLVD DUBLIN 94568 1 Confirmed Mail-Back Site Safeway-1932 4440 Tassajara Rd Dublin 94568 1 Confirmed Mail-Back Site Safeway-1953 7499 Dublin Blvd Dublin 94568 1 Confirmed Mail-Back Site Pak 'N Save-3125 3889 San Pablo Ave Emeryville 94608 5 Confirmed Mail-Back Site Lucky-712 34101 FREMONT BLVD FREMONT 94555 2 Confirmed Mail-Back Site Lucky California-713 35820 FREMONT BLVD FREMONT 94536 2 Confirmed Mail-Back Site Lifescript Pharmacy 39039 Paseo Padre Parkway Suite 201 Fremont 94538 1 Confirmed Mail-Back Site FoodMaxx -409 39441 FREMONT BLVD FREMONT 94538 1 Confirmed Mail-Back Site Lucky-711 40055 MISSION BLVD FREMONT 94539 1 Confirmed Mail-Back Site HALLERS LTC PHARMACY 4067 PERALTA BOULEVARD Fremont 94536 1 Confirmed Mail-Back Site 39 © Inmar 2022. Haller's LTC Pharmacy 4067 Peralta Boulevard Fremont 94536 1 Confirmed Mail-Back Site Lucky-714 5000 MOWRY AVE FREMONT 94538 1 Confirmed Mail-Back Site Lucky-715 22555 MISSION BLVD HAYWARD 94541 2 Confirmed Mail-Back Site Lucky California-716 25151 SANTA CLARA ST HAYWARD 94544 2 Confirmed Mail-Back Site FoodMaxx -406 27300 HESPERIAN BLVD HAYWARD 94545 2 Confirmed Mail-Back Site Lucky California-722 1951 HOLMES ST LIVERMORE 94550 1 Confirmed Mail-Back Site Lucky-721 2000 PORTOLA AVE LIVERMORE 94550 1 Confirmed Mail-Back Site FoodMaxx -462 39966 CEDAR BLVD NEWARK 94560 2 Confirmed Mail-Back Site FoodMaxx -417 10950 INTERNATIONAL BLVD OAKLAND 94603 4 Confirmed Mail-Back Site Lucky California-734 1963 MOUNTAIN BLVD OAKLAND 94611 4 Confirmed Mail-Back Site Lucky-736 247 E 18TH ST OAKLAND 94606 3 Confirmed Mail-Back Site FoodMaxx -484 3000 EAST 9TH STR OAKLAND 94606 3 Confirmed Mail-Back Site Specialty Mental Health - Oakland 310 8th Street, Suite 210 Oakland 94607 3 Confirmed Mail-Back Site Mindful Health Solutions - Oakland 3300 Webster Street, Suite 402 Oakland 94609 5 Confirmed Mail-Back Site Crossroads Home Health - Oakland 333 Hegnberger Road, Suite 710 Oakland 94621 4 Confirmed Mail-Back Site Crossroads Hospice - Oakland 333 Hegnberger Road, Suite 710 Oakland 94621 4 Confirmed Mail-Back Site Safeway-908 3550 Fruitvale Ave Oakland 94602 4 Confirmed Mail-Back Site Aids Healthcare Foundation - Oakland 400 30th Street, Suite 300 Oakland 94609 5 Confirmed Mail-Back Site Home Care Assistance - Oakland 5275 Broadway Oakland 94618 5 Confirmed Mail-Back Site Alegre Home Care - East Bay 5767 Broadway, Suite 201 Oakland 94618 5 Confirmed Mail-Back Site 40 © Inmar 2022. Bonita House Inc. 6333 Telegraph Avenue, Suite 102 Oakland 94609 5 Confirmed Mail-Back Site New Chinatown Pharmacy 719 East 12th Street Oakland 94606 3 Confirmed Mail-Back Site California Sinus Center 5924 Soneridge Drive Suite 207 Pleasanton 94588 4 Confirmed Mail-Back Site Lucky-744 6155 W LAS POSITAS PLEASANTO N 94566 4 Confirmed Mail-Back Site Lucky California-767 1300 FAIRMONT DR SAN LEANDRO 94578 3 Confirmed Mail-Back Site MEDICAL ARTS PHARMACY 13847 EAST 14TH STREET SUITE 103 San Leandro 94578 3 Confirmed Mail-Back Site Specialty Mental Health - San Leandro 433 Callan Avenue, Suite 301 San Leandro 94577 3 Confirmed Mail-Back Site FoodMaxx -416 699 LEWELLING BLVD SAN LEANDRO 94579 3 Confirmed Mail-Back Site Lucky California-768 15840 HESPERIAN BLVD SAN LORENZO 94580 3 Confirmed Mail-Back Site FoodMaxx -463 30073 INDUSTRIAL PARKWAY SW UNION CITY 94587 2 Confirmed Mail-Back Site Lucky-782 32300 DYER ST UNION CITY 94587 2 Confirmed Mail-Back Site 41 © Inmar 2022. Appendix A-4: Target Mail-Back Sites Site Site Address Site City Zip Status Asian Health Services 555 Ralph Appezzato Memorial Pkwy Alameda 94501 Target Mail-Back ASC Pharmacist Consultants, Inc. 248 3rd St Albany 94706 Target Mail-Back Lifelong Medical Care 3260 Sacramento Ave Berkeley 94703 Target Mail-Back Stat Med PC 1667 Amador Valley Blvd Dublin 94568 Target Mail-Back IDEXX Labs - Fremont 46700 Lakeview Blvd Fremont 94538 Target Mail-Back Eurofins 42501 Albrae St Fremont 94538 Target Mail-Back Eurofins DiscoverX Fremont 42501 Albrae St Fremont 94538 Target Mail-Back Bay Area Community Health 2300 Mowry Ave Fremont 94538 Target Mail-Back Bay Area Community Health 40924 Fremont St Fremont 94538 Target Mail-Back Washington Township Medical Group, Inc Student & Business Ser Fremont 94538 Target Mail-Back Grand Lake Gardens 401 Santa Clara Ave Oakland 94610 Target Mail-Back Piedmont Gardens 110 41st St Oakland 94611 Target Mail-Back Asian Health Services 190 11th V Street Oakland 94607 Target Mail-Back Asian Health Services 310 8th St Oakland 94607 Target Mail-Back Asian Health Services 345 9th St Oakland 94607 Target Mail-Back Asian Health Services 416 8th St Oakland 94607 Target Mail-Back Asian Health Services 835 Webster St Oakland 94607 Target Mail-Back Planned Parenthood Mar Monte 1682 7th Street Oakland 94607 Target Mail-Back Piedmont Primary Care 1345 Grand Ave Oakland 94610 Target Mail-Back Aids Healthcare Foundation 238 E 18th St Oakland 94606 Target Mail-Back Aids Healthcare Foundation 400 30th St. Oakland 94609 Target Mail-Back Aids Healthcare Foundation 389 30th St Oakland 94609 Target Mail-Back Veterinary Specialty Center of Seattle 1961 Mountain Blvd Oakland 94611 Target Mail-Back TestAmerica Pleasanton 1220 Quarry Ln Pleasanton 94566 Target Mail-Back Neighborhood Health Center 4361 Railroad Ave Pleasanton 94566 Target Mail-Back ESS Corporate Headquarters 604 143rd Ave San Leandro 94578 Target Mail-Back Asian Health Services 101 Callan Ave San Leandro 94577 Target Mail-Back Jane Wardzinska, MD 13487 E 14th St San Leandro 94578 Target Mail-Back Tiburcio Vasquez Health Center 39270 Alvarado Niles Rd Union City 94587 Target Mail-Back 42 © Inmar 2022. Appendix B: Kiosk Signage & Mailer Instructions Note: all promotional material will be updated upon coordination with other approved Plan Operators and these images are merely examples of the content that will be included. 43 © Inmar 2022. 44 © Inmar 2022. Sample Mail-back Insert for Covered Drugs 45 © Inmar 2022. Sample Inhaler Mail-back Insert 46 © Inmar 2022. Sample Auto-injector Mail-back Insert 47 © Inmar 2022. Appendix C: Promotion Material Note: all promotional material will be updated upon coordination with other approved Plan Operators and these images are merely examples of the content that will be included. 1. Sample Education Materials 48 © Inmar 2022. 49 © Inmar 2022. 2. Sample Authorized Collector Marketing Support 50 © Inmar 2022. 51 © Inmar 2022. 3. Website Interface and Functionality 52 © Inmar 2022. 4. Sample Social Influencer Content 53 © Inmar 2022. Appendix D: Applicable Permits and Licenses $1850 $1850 2,2N,3, 3N,4,5 2,2N,3, 3N,4,5 04-30-2022 04-30-2022 123 COMPLIANT LOGISTICS, LLC 188 M ST SUITE B AGAWAM, MA 010012043 123 COMPLIANT LOGISTICS, LLC 188 M ST SUITE B AGAWAM, MA 010012043 03-26-2021 03-26-2021 R90595946 R90595946 REVERSE DISTRIB-COLLECTOR REVERSE DISTRIB-COLLECTOR 55 © Inmar 2022. Appendix E: Compliance History TransChem Environmental 542 E. 27th Street Tucson, AZ 85713 520-829-5651 Record of any penalties, vuilatons or regulmory orders rece1ved in the prevlous five 15) years. Penalties Data of Penalty Dascription of Penalty Fine Y/N Ramady Violations Regulatory Orders Description of Violation Fine Y/N Fine Y/N Remedy Remedy TransChem Environmental has no violations, penalties or regulatory orders in the past 5 years. Enforcement Action Summary Report Facility Aragonite Date Recieved Agency Alleged Violation Proposed Penalty Status Resolution Date Penalty PaidEnforcement Type 10/20/2016 UDEQ 1)Storage facility for water supply had a leak at the time of inspection, 2) the public water supply storage vessel showed signs of a leak. $0.00 Resolved w/o Penalty 12/14/2016 $0.00Notice of Violation Description of Resolution:Repaired the tanks.EA Number: 2/8/2017 UDEQ - DDW Failure to monitor and report for pesticides and volatile organic compounds in 2016. $0.00 Resolved w/o Penalty 2/15/2017 $0.00Notice of Violation Description of Resolution:Updated testing was conducted.EA Number: 5/16/2018 UDEQ - Division of Air Quality Failure to submit stack test results, deviation reports, leak detection and repair reports, Benzene NESHAP reports, semi-annual reports and compliance certifications in a timely manner. $23,750.00 Resolved 5/21/2018 $23,750.00Notice of Violation Description of Resolution:EA Number: Friday, August 13, 2021 Page 1 of 4 1/28/2019 US DEA 1)Failure to file annual inventory, 2) delinquent filing of quarterly ARCOS reports, failure to maintain a separate file for Schedule 1 and 2 and Schedule 3 through five controlled substances, 4)failure to record time of annual inventory. $120,000.00 Resolved 5/8/2019 $96,000.00Notice of Violation Description of Resolution:Payment of a civil penalty.EA Number: 9/26/2019 Utah Department of Commerce Failure to report to the division any adverse action taken by another licensing jurisdiction. $300.00 Resolved 10/10/2019 $300.00Penalty Notice Description of Resolution:Paid civil penaltyEA Number: 1/23/2020 UDEQ The facility's Public Water System rating is expected to be downgraded for the following deficiencies: 1) area within 50 feet of a storage tank not graded to prevent standing water, 2) lack of an approved DWSP plan at two locations. $0.00 Pending $0.00Compliance Advisory Description of Resolution:EA Number: 4/8/2020 UDEQ 29 alleged violations resulting from the annual inspection conducted in the Fall 2019. $106,840.00 Pending $0.00Notice of Violation Description of Resolution:EA Number:2001004 Friday, August 13, 2021 Page 2 of 4 7/15/2020 Alabama Board of Pharmacy 1)Conducting operations in the State but failing to timely renew a permit, 2) Failure to conduct business in accordance with the State rules because of violations settled with the US DEA in January 2019. $10,000.00 Resolved 8/10/2020 $10,000.00Consent Administrative Order Description of Resolution:Paid a civil penalty.EA Number:19-L-0162 8/31/2020 US EPA Incineration of materials in violation of the prohibition on dilution of certain hazardous wastes by incineration. $0.00 Pending $0.00Warning Letter/Notice Description of Resolution:EA Number: 12/9/2020 Alabama Board of Pharmacy 1)Failure to disclose an enforcement action in another jurisdiction on a permit application and applicable Alabama Board of Pharmacy rules violations from lack of disclosure. $2,000.00 Resolved 2/24/2021 $2,000.00Compliant Description of Resolution:Paid an administrative penalty.EA Number:20-L-0097 12/15/2020 Arizona Board of Pharmacy Failure to notify the Board of a prior enforcement action in another jurisdiction. $250.00 Resolved 1/26/2021 $250.00Penalty Notice Description of Resolution:Entered into a consent order.EA Number: Friday, August 13, 2021 Page 3 of 4 1/15/2021 US EPA 1)Failure to monitor emissions form the Corrosives Unit, Blended Waste Feed, Aqueous Waste Feed, and Sludge Waste Feed operation, 2)24 open ended valves on the carbon system, 3)a rupture disk operating above the no detectable emissions standard, 4) Failure to record the date of first repair attempt, 5) Excess emissions from 12 pressure relief devices and 5 connectors, 6) Failing to record information on equipment tagged for repair, 7) Storing light liquid material in containers that had leaks, 8) Failure to adequately train employees to conduct Method 21 monitoring, 9) Failure to use equipment that adequately monitors for Method 21, 10) Failure to repair 3 pieces of equipment in 15 days. $470,000.00 Pending $0.00Warning Letter/Notice Description of Resolution:EA Number: 2/26/2021 Bureau of Alcohol, Tobacco and Fire Arms Failure to timely/accurately enter all required explosive inventory identification and quantity information in a daily summary of magazine transaction (per magazine) $0.00 Resolved w/o Penalty 2/26/2021 $0.00Warning Letter/Notice Description of Resolution:Provided corrective actions to the Agency.EA Number: 3/26/2021 UDEQ 12 alleged violations related to permit conditions on waste storage conditions, timing, training and rejection procedures identified during the 2020 annual inspection. $0.00 Pending $0.00Notice of Violation Description of Resolution:EA Number:NOV 2102003 Friday, August 13, 2021 Page 4 of 4 Enforcement Action Summary Report Facility El Dorado Date Recieved Agency Alleged Violation Proposed Penalty Status Resolution Date Penalty PaidEnforcement Type 3/14/2019 ADEQ 1)Allowing water to remain in secondary containment longer than 24 hours, thus impeding the ability to monitor for leaks, 2) failure to properly document inspections for secondary containment. $8,000.00 Resolved 5/17/2019 $8,000.00Notice of Violation Description of Resolution:Entered into the administrative consent order.EA Number:LIS 19-048 11/21/2019 ADEQ 1)Opacity issues at kiln 1, 2) Opacity issues at kiln 2 and 3) Open diverts at kiln 2 require additional explanation to the air regulators. $10,020.00 Resolved $6,513.00Notice of Violation Description of Resolution:Paid a civil penalty and provided ergonomic hose reloading equipment to the El Dorado fire department.EA Number:LIS 21-120 12/9/2019 Delaware Dept. of Natural Resources Failure to provide the Department of Natural Resources with facility copies of infectious waste manifests received from Delaware generators. $0.00 Resolved w/o Penalty 1/8/2020 $0.00Notice of Violation Description of Resolution:Supplied the required manifests.EA Number:19-SW-43 Wednesday, December 8, 2021 Page 1 of 3 8/25/2020 ADEQ Discharge exceedance of the effluent limitation for Mercury at the 007 outfall during the 2nd Quarter of 2020. $0.00 Pending $0.00Warning Letter/Notice Description of Resolution:EA Number: 8/31/2020 US EPA Incineration of materials in violation of the prohibition on dilution of certain hazardous wastes by incineration. $0.00 Pending $0.00Warning Letter/Notice Description of Resolution:EA Number: 10/22/2020 ADEQ Mercury stormwater exceedance.$0.00 Pending $0.00Warning Letter/Notice Description of Resolution:EA Number: 2/11/2021 FRA A rail car not sealed appropriately because the bolts on the manway were not tool tight. $5,000.00 Resolved 3/11/2021 $4,000.00Notice of Non-Compliance Description of Resolution:Paid civil penalty.EA Number:FRA No. ZCED 2020- 1(HMT) 2/19/2021 FRA Bolts on a rail car manway were not tool tight.$2,000.00 Resolved 3/11/2021 $1,500.00Notice of Non-Compliance Description of Resolution:Paid civil penalty.EA Number:FRA No. ZCED 2020- 2(HMT) Wednesday, December 8, 2021 Page 2 of 3 3/30/2021 ADEQ 1)Storage of rejected explosives while waiting to obtain transportation permits to remove them from the site. $0.00 Dismissed 5/25/2021 $0.00Notice of Violation Description of Resolution:Arkansas DEQ withdrew the alleged violation due to extenuating circumstances.EA Number: Wednesday, December 8, 2021 Page 3 of 3 Page 1 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken 2/15/2017 ATF No Violations 3/9/2017 CAA TCEQ Alleged Violations: 1.) Failure to maintain the Carbon Monoxide 4/18/2017 Received NOV incinerator.5/27/2017 Submitted Corrective Action Plan 100 parts per million by volume (ppmv) at the incinerator. 9/29/2017 documentation was received and no further action required temperatures. rates at the Incinerator. combined Arsenic-Beryllium-Chromium emissions at the Incinerator. rate of 17.10 pounds per hour during start-up at the Incinerator. 6/15/2017 TPDES TCEQ No Violations - Three Areas of Concern 8/9/2017 Received a letter from the TCEQ stating no violations are alleged. 2/22/2018 OPCC TCEQ Alleged Violations 4/26/2018 Received Notice of Violation. 1.) Failure to maintain the CO emission rate at the 5/25/2018 Submitted a Response to NOV. Incinerator.10/15/2018 Received a letter from TCEQ stating no further action required. 2.) Failure to limit Carbon Monoxide concentration at 100 parts per million by volume (ppmv) at the 3.) Failure to maintain Incinerator minimum combustion temperatures. 4.) Failure to maintain Beryllium, Selenium, and Chromium emission rates at the Incinerator. VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX Page 2 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX 5.) Failure to limit combined Arsenic-Beryllim- Chromium emissions at the Incinerator. 6.) Failure to maintain Mercury emission rates at the Incinerator. 7.) Failure to limit Mercury emissions at the Incineraotr. 8.) Failure to maintain the Hazardous Wsate Permit miminum voltage requirements at the Ionizing Wet Scrubber. 9.) Failure to maintain EPA and Hazardous Waste Permit minimum voltage requirments at the Ionizing Wet Scrubber (IWS) equipment. 6/13-21/2018 RCRA TCEQ Alleged Violations 9/21/2018 Submitted a response to TCEQ. 1.) Failure to maintain inspection records as required 1/4/2019 Received Letter from TCEQ stating no further action required. by permit. 2.) Failure to Maintain aisle space to allow unobstructed movement of personnel and emergency response equipment. Additional Issues 3.) A concern the regulated entity may not be meeting the requirements of properly maintaining an accuarate storage inventory amount. 4.) The concern is the regulated entity may not be meeting the requirements of properly storing incompatible waste. Page 3 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX 7/18/2018 Transportation TCEQ No Issues Found Ten Day Yard 1.) Paperwork Error on the Chain of Custody 10/19/2018 Posted required public notice in all Veolia Port Arthur Buildings 10/22/2018 Submitted copy of Monitoring Violation Public Notice and Certificate of Delivery to TCEQ. No further action required. 1/17/2019 CAA TCEQ Alleged Violations 3/18/2019 Received NOV letter 1.) Failure to maintain tons per year emissions for 4/25/2019 Submitted Corrective Action Plan permitted sources on a 12 month rolling period basis.10/1/2019 Received letter from TCEQ stating no further action required. 2.)Failure to maintain the Hazardous Waste Permit minimum voltage requirements at the Ionizing Wet Scrubber (IWS) equipment. 3.)Failure to comply with the EPA and the Hazardous Waste Permt minimum voltage requirements at the Ionizing Wet Scrubber (IWS) equipment. 4.) Failure to comply with the EPA minimum kilovolts-amps requirement at the Wet Electrostatic Precipitator (WESP). 5.) Failure to maintain the CO emission rate at the Incinerator (EPN INCINSTK). 6.) Failure to limit Carbon Monoxide concentration to 100 parts per million by volume (ppmv) at the Incinerator. 7.) Failure to maintain Incinerator minimum combustion temperatures. Page 4 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX 8.) Failure to certify the Permit Compliance Certification. 9.) Failure to report all instances of deviations. 6/25/2019 LQG/UIC/Ten day facility TCEQ No Alleged Violations 8/1/2019 Received Letter from TCEQ stating no violations are being alleged. 12/16/2019 DEA DEA DEA controlled substances inventory was not 1/17/2020 Veolia submitted a formal biennial inventory of controlled conducted. No DEA controlled substances were substances to the DEA. The inventory was zero(0). present at the Veolia site at the time. 1/22/2020 Foreign Soil Permit USDEA No Alleged Violations 2/14/2020 TSD/LQG/Used Oil TCEQ Alleged Violations 6/12/2020 Received NOV Letter 1.) Failure to follow the Waste Analysis Plan 7/15/2020 Submitted Corrective Action Plan to TCEQ. 2.) Failure to separator protect storage containers 10/26/2020 Received No Further Action Letter holding hazardous waste that is incompatible with any waste or other material stored nearby in other containers. 3.) Failure to provide the hazardous waste accumulation (>1 year) was solely for the purpose of holding of such quantities of hazardous waste as are necessary to facilitate proper disposal. 4.) Failure to post the "TCEQ Permit Unit No._" sign at the permitted facility unit. 5.) Failure to maintain disposal records for the disposal of waste oil. 6.) Failure to maintain adequate (e.g., include inspector's full name and time of inspection) monthly safety inspection records (e.g., fire extinguishers, first aid Page 5 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX kits, Self-Contained Breathing Apparatus (SCBA), showers, and Table III.E.3. - Emergency Equipment of the Contingency Plan) for a period of 3 years. records of the Protective Gear Designated for Emergency Use. 8.) Failure to maintain the date and nature of any repairs or other remedial actions documented on the weekly Container Storage Areas inspections. 9.) Failure to follow a written schedule for inspecting security devices. 2/14/2020 UIC TCEQ No Alleged Violations 2/14/2020 Transfer Facility Compliance TCEQ No Alleged Violations 3/2/2020 Received letter from the TCEQ stating no alleged violations. 2/26/2020 Public Drinking Water TCEQ Alleged Violation 6/29/2020 Received NOV letter from TCEQ. 1.) Failure to perform maintenance and housekeeping 7/22/2020 Submitted Corrective Action Plan to TCEQ. practices used by a PWS to ensure the good working 11/24/2020 Received letter from TCEQ stating no further action required. condition and general appearance of the systems' facilities and equipment. Area of Concern 1.) Failure to have a complete and up-to-date monitoring plan. 3/2/2020 OPCC TCEQ Alleged Violations 6/9/2020 Received NOV letter 1.-3.) Failure to comply with the EPA and the 7/8/2020 Submitted Corrective Actin Plan to TCEQ. Hazardous Waste Permit minimum voltage 10/20/2020 Received letter from TCEQ stating no further action required. requirements at the Ionizing Wet Scrubber (IWS) Page 6 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX equipment. 4.) Failure to maintain the CO emission rate of 17.10 pounds per hour at the Incinerator (EPN INCINSTK). to 100 parts per million by volume (ppmv) at the Incinerator. 6.- 7.) Failure to maintain Incinerator minimum combustion temperatures. 8.) Failure to comply with the EPA minimum kilovolts-amps requirement at the Wet Electrostatic Precipitator (WESP). 9.) Failure to conduct leak detection and repair monitoring. 8/4/2020 Wastewater TCEQ Alleged Violations 1.) Failure to report any effluent violation that 8/7/2020 Submitted noncompliance notifications to the TCEQ. deviates from the permitted effluent limitation by 9/30/2020 Received letter from TCEQ stating no further action required. more than 40% to the Regional office and the Enforcement Division within five working days of becoming aware of the noncompliance. The noncompliance occurred in September 2019. 12/11/2020 RCRA TCEQ No Violations 1/6-8/2021 ATF No Violations 1/11/2021 OPCC TCEQ Alleged Violations - NOV 1/27/2021 Received Notice of Violation 1.) Failure to maintain an emission rate below the 1/27/2021 Received Notice of Enforcement Page 7 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX allowable Carbon Monoxide (CO) emission limits of 2/3/2021 Submitted a request to reconsider 17.1 pounds per hour (lbs/hr) from Emission Point Enforcement based on significant Number (EPN) INCINSTK.improvements over the past three 2.) Failure to maintain the CO gas concentration years. below 100 parts per million by volume (ppmv) at 4/16/2021 Received Proposed Agreed Order the EPN INCINSTK.7/13/2021 Submitted a signed agreement order and penalty payment 3.) Failure to maintain the EPA and the Hazardous of $3,420. Waste Permit minimum voltae of 10 kilovolts at the Ionizing Wet Scrubber (IWS) equipment. 4.) Failure to maintain the EPA minimum kilovolts- amps requirement of 15.8 kVA at the Wet Elecrostatic Precipitator (WESP). 5.) Failure to comply with the EPA and the Hazardous Waste Permit minimum voltage requirements at the Ionizing Wet Scrubber (IWS) equipment. Violations - NOE 1.) Failure to maintain emissions below the allowable Caron monoxide (CO) emission limit of 17.1 lbs/hr from EPN INCINSTK. 11/9-10/2021 RCRA TCEQ Alleged Violations 1.) The investigator observed three Waste Determination records which have been marked incorrectly, in a manner which indicated the wastes would be hazardous and these wastes were Industrial Class 1 and Class 2. The waste determinations were corrected. Page 8 Inspection Name of inspector and Alleged Violations VEOLIA Responses and/or Corrective Date Type of inspection Regulatory Agency Actions Taken VEOLIA ES TECHNICAL SOLUTIONS, L.L.C. PORT ARTHUR, TX 2.) Failure to place a Waste Stream Identification/ classification of the waste on Manifest 001968617VES 72 © Inmar 2022. Clean Harbors – Aragonite Compliance History Compliance history provided via ECHO.EPA.GOV https://echo.epa.gov/detailed-facility-report?fid=110000906985#history110000906985 SourceID Statute Status Type Type Date UTD981552177 RCRA Violation Permit Condition or Requirement PCR 03/26/2021 UTD981552177 RCRA Violation TSD - General Facility Standards 264.B 03/26/2021 UTD981552177 RCRA Violation Manifest System-Recordkeeping, Rpting, Notifying 73 © Inmar 2022. UTD981552177 RCRA Violation Permit Condition or Requirement PCR 04/08/2021 UTD981552177 RCRA Violation State Statute or Regulation XXS 04/08/2021 UTD981552177 RCRA Violation Listing- Air Emisions Standards- Tanks/Containers Leaks 74 © Inmar 2022. UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Specific - Boilers and Industrial Furnaces 266.H 05/30/2019 UTD981552177 RCRA Violation Generators - General 262.A 05/30/2019 UTD981552177 RCRA Violation Generators - Manifest 262.B 05/30/2019 UTD981552177 RCRA Violation Generators - Manifest 262.B 05/30/2019 UTD981552177 RCRA Violation Generators - Records/Reporting 262.D 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - Manifest/Records/Reporting 264.E 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - General Facility Standards 264.B 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - Manifest/Records/Reporting 264.E 05/30/2019 UTD981552177 RCRA Violation TSD - Container Use and Management 264.I 05/30/2019 UTD981552177 RCRA Violation Transporters - General 263.A 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - Preparedness and Prevention 264.C 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation State Statute or Regulation XXS 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - Manifest/Records/Reporting 264.E 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Transporters - General 263.A 05/30/2019 UTD981552177 RCRA Violation TSD - Air Emission Standards for Equipment Leaks 76 © Inmar 2022. UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation LDR - General 268.A 05/30/2019 UTD981552177 RCRA Violation TSD - General Facility Standards 264.B 05/30/2019 UTD981552177 RCRA Violation TSD - General Facility Standards 264.B 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation TSD - Air Emission Standards - Tanks/SI/Containers Leaks Leaks 77 © Inmar 2022. UTD981552177 RCRA Violation TSD - General Facility Standards 264.B 05/30/2019 UTD981552177 RCRA Violation TSD - Preparedness and Prevention 264.C 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Permit Condition or Requirement PCR 05/30/2019 UTD981552177 RCRA Violation Generators - Manifest 262.B 05/30/2019 UTD981552177 RCRA Violation Generators - General 262.A 05/30/2019 UTD981552177 RCRA Violation LDR - General 268.A 05/30/2019 UTD981552177 RCRA Violation Used Oil - Burners of Off-Spec for Energy Recovery Recovery Leaks Leaks Leaks Leaks Tanks/SI/Containers Tanks/SI/Containers Tanks/SI/Containers Tanks/SI/Containers Tanks/SI/Containers Tanks/SI/Containers 78 © Inmar 2022. Clean Harbors – El Dorado Compliance History Compliance history provided via ECHO.EPA.GOV https://echo.epa.gov/detailed-facility-report?fid=110000521221 SourceID Statute Status Type Type Date ARD069748192 RCRA Violation Generators - General 262.A 09/03/2021 ARD069748192 RCRA Violation Generators - Pre-transport 262.C 07/22/2019 ARD069748192 RCRA Violation TSD - Preparedness and Prevention 264.C 07/22/2019 ARD069748192 RCRA Violation Generators - Pre-transport 262.C 07/22/2019 ARD069748192 RCRA Violation Generators - Pre-transport 262.C 07/22/2019 ARD069748192 RCRA Violation TSD IS-Container Use and Management 265.I 07/22/2019 ARD069748192 RCRA Violation TSD - Container Use and Management 264.I 07/22/2019 ARD069748192 RCRA Violation TSD - Container Use and Management 264.I 07/22/2019 ARD069748192 RCRA Violation Permit Condition or Requirement PCR 07/22/2019 ARD069748192 RCRA Violation Permit Condition or Requirement PCR 07/22/2019 ARD069748192 RCRA Violation TSD - Tank System Standards 264.J 07/22/2019 ARD069748192 RCRA Violation TSD - Tank System Standards 264.J 07/22/2019 ARD069748192 RCRA Violation TSD - Air Emission Standards for Equipment Leaks Veolia – Port Arthur Compliance History Compliance history provided via ECHO.EPA.GOV https://echo.epa.gov/detailed-facility-report?fid=110035783658 SourceID Statute StatusType Violation Violation Type Date TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 79 © Inmar 2022. TXD000838896 RCRA Violation LDR - General 268.A 02/14/2020 TXD000838896 RCRA Violation LDR - Storage Prohibitions 268.E 02/14/2020 TXD000838896 RCRA Violation Permits - General Information 270.A 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020 TXD000838896 RCRA Violation TSD - General Facility Standards 264.B 02/14/2020 TXD000838896 RCRA Violation TSD - Container Use and Management 264.I 02/14/2020 TXD000838896 RCRA Violation State Statute or Regulation XXS 02/14/2020