Enforcement and Inspection, Environmental

EPA Enforcement Roundup Q1 2025

In the first quarter (Q1) of 2025, the EPA finalized 196 settlement agreements with companies small and large across the United States. This represents a decrease in enforcement actions—down from 215 penalties issued in Q4 of 2024. The actions taken resulted in $6,089,365 in fines. Here are some of the highlights.

CAA violations yield biggest fine from EPA

The largest Q1 fine assessed by the EPA was to an oil and natural gas company, which must pay $1,023,690 for violations of the Clean Air Act (CAA). One of its facilities in Illinois was cited for violations of the regulation for motor vehicle and engine fuels. Specifically, the chemical manufacturing plant:

  • Exceeded the ultra-low sulfur diesel (ULSD) sulfur standards
  • Exceeded the maximum annual average benzene standards
  • Misreported batch and production volumes
  • Failed to collect representative samples of ULSD

There were additional enforcement actions taken against 32 other entities for CAA violations, with penalties ranging from $800 to $500,000. In all, CAA violations accounted for $3,932,912 in Q1.

FIFRA violations

A national wholesale distributor of janitorial equipment and supplies agreed to settle with the EPA to resolve violations of the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Allegedly, the Georgia facilities sold or distributed seven different unregistered pesticide products, including disinfecting wipes. As part of the agreement, the company will pay a $299,880 penalty.

The EPA has also reached a settlement agreement with an air distribution systems manufacturer for violating FIFRA regulations. While selling, producing, and distributing a product with pesticidal claims, the company was not registered with an EPA establishment number. A $137,700 fine has been issued.

EPCRA violations bring five- and six-figure fines

The EPA continues its consistent enforcement of the Emergency Planning and Community Right-to-Know Act (EPCRA):

  • A plastic manufacturing company in Ohio was penalized $205,917 for EPCRA violations, including failure to submit hazardous chemical inventory forms for plastics materials, oil, lead, and sulfuric acid from 2019 to 2023. The company was also cited for allowing plastic materials, oil, lead, and sulfuric acid in amounts equal to or greater than the minimum threshold level.
  • In Utah, the EPA fined a cold chain logistics company $56,248 to resolve EPCRA violations. Officials found the company allowed anhydrous ammonia in the facility to exceed the threshold level of applicability and failed to submit emergency and hazardous chemical inventory forms to the appropriate authorities.
  • A $25,000 penalty was issued to an Ohio-based public refrigerated warehousing company for EPCRA violations. According to officials, from 2019 to 2021, the company failed to submit a completed emergency and hazardous chemical inventory form for anhydrous ammonia, sulfuric acid, and lead.

Emphasizing clean water

The EPA cited 58 different entities for violations of the Clean Water Act (CWA), including space exploration and home construction facilities for National Pollutant Discharge Elimination System (NPDES) and dredge and fill material permit violations, as well as a pallet manufacturer for failure to conduct sampling or monthly inspections. The fines totaled $670,622 and ranged from $820 to $148,378.

TSCA violations

A Minnesota textile waste recycling facility was fined $112,155 for violating the Toxic Substances Control Act (TSCA). The textile company failed to comply with reporting and recordkeeping requirements, including the TSCA Preliminary Assessment Information Rule (PAIR) form.

The EPA issued a $55,000 penalty to a liberal arts college in Illinois for TSCA violations, specifically related to lead paint. Officials cited the college for failure to include the following statements in lease agreements:

  • A lead warning statement
  • A statement disclosing the presence of any known lead-based paint and/or lead-based paint hazards
  • Appropriate lists of records or reports available to the lessor in the contract
  • An affirmation statement by the lessee
  • A certification of the accuracy of provided information

A construction and contracting company in Missouri agreed to pay $48,511 to resolve violations of TSCA’s pre-renovation lead education rule. After reviewing records, the EPA determined that the company failed to apply for and obtain certification before commencing renovations, ensure the assignment of a certified renovator, and ensure all renovations were performed in accordance with work practice standards.

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