                      EPA/HQ Summary  -  Meeting with CVS

Attendees

CVS:		 	Nicole Wilkinson, Liz Ash

Troutman Sanders:	Greg Blount

EPA/HQ: 	Jessica Young, Kristin Fitzgerald, Drew Lausch, Laura Stanley, Josh Smeraldi

Date:			May 17, 2016

Location:  		EPA/HQ  -  Potomac Yard

Summary

EPA HQ met with representatives of CVS and their outside counsel to discuss the Hazardous Waste Pharmaceuticals Proposed Rule.  CVS stated that it is a priority for them for the rule to be finalized, although they would like to see some changes. 

CVS raised three issues. First, they do not agree that the point of generation for creditable pharmaceuticals should be at the store, especially for OTCs. They noted that they use the term "reverse distribution" when referring to the reverse flow of prescription pharmaceuticals and they use the term "reverse logistics" when referring to the reverse flow of OTCs. Second, they noted that some states have different interpretations of the empty container rule than EPA does. Third, they indicated that the company has decided against using a commercial nicotine reclamation company because the reclaimed nicotine is sold for use in e-cigarettes and CVS no longer sells any tobacco products, including e-cigarettes.



