                      EPA/HQ Summary  -  Meeting with CVS

Attendees

CVS:		 	Nicole Wilkinson, Tegan Gelfand, Liz Ash, Donald Dempsey

Troutman Sanders:	Greg Blount

EPA/HQ: 	Byron Brown, Veronica Darwin, Barnes Johnson, Jessica Young, Kristin Fitzgerald

Date:			January 23, 2018, morning

Location:  		EPA/HQ 

Summary

EPA HQ met with representatives of CVS and their outside counsel to discuss the Hazardous Waste Pharmaceuticals Proposed Rule.  CVS noted that the need for national uniformity is very important to them. They have close to 7000 stores that are LQGs due to discarded nicotine replacement therapies being classified as acute hazardous waste.

CVS noted that they manage pharmaceuticals as hazardous waste starting in the store when they are damaged or leaking, not in manufacturer's packaging, or if they are expired.

CVS encouraged EPA to finalize the rule. 

