Quarter Billion Burritos, Zero Safe Practices @ Camino Real Foods

The Human Cost

The Non-Financial Ledger

Anhydrous ammonia is not an abstract regulatory concept. It is a colorless gas that attacks the respiratory system on contact, causes severe chemical burns to the skin and eyes, and at sufficient concentrations, kills. The threshold that triggers federal emergency planning requirements is 500 pounds. Camino Real Foods held well over 10,000 pounds of it at their Vernon, California facility, enough to qualify under the most stringent federal safety tier and enough to reach people outside the plant’s walls if something went wrong.

Vernon is a small, densely industrial city surrounded by working-class Los Angeles neighborhoods. The EPA’s own legal documents confirm that “public receptors” sit within the distance to the endpoint for the worst-case release from the Camino Real facility. That phrase, written in the flat language of regulatory filings, means: if that ammonia got out, it could reach people who live nearby.

The workers inside the building faced the most immediate exposure. EPA inspectors found that Camino Real failed to consider language as a potential barrier to employees accessing safety training and documentation. The workforce in Southern California food processing plants is predominantly Spanish-speaking. Federal law requires that employees “knowledgeable in the process” be consulted on hazards and that their understanding be confirmed. At Camino Real, the agency determined this was not happening. Workers were operating daily around a lethal refrigerant system with, at minimum, serious questions about whether they had been given the information they needed to protect themselves.

The physical state of the facility made this worse. Inspectors walked through and found ammonia piping that was unlabeled, meaning workers could not identify what was running through the lines around them. The main shutoff valve, called the King valve, which is the critical control point in an ammonia emergency, was not identified. Ammonia alarms in the machinery rooms were unlabeled. The emergency exhaust fans designed to vent a release were discharging horizontally and downward, not upward, meaning in an event they could direct toxic gas toward people rather than away from them. This is not paperwork noncompliance. These are conditions that determine whether a worker survives an accident.

The company had not reviewed or certified its written operating procedures since 2013. For nearly a decade, the instructions workers were supposed to follow for handling ammonia systems had gone without a single formal check to confirm they were accurate or current. No one in management signed off on a single page of those procedures in all that time. The people on the floor were working from a document that the company itself had structurally abandoned.

When incidents did occur, the investigation system required by federal law to track what went wrong and fix it was, per the EPA’s findings, inadequate. Corrective actions were proposed but not documented as resolved. The same problems could recur without any institutional record that they had happened before.

From the Official Record

Legal Receipts

“EPA determined that Respondent lacked documentation that its equipment complies with recognized and generally accepted good engineering practices (‘RAGAGEP’), such as doors that were not equipped with panic hardware, exposed electrical wiring and conduit, extension cords used as permanent wiring, doors that were not tight-fitting and tight-sealing, lack of labelling for ammonia piping, not identifying the main shutoff valve (King valve), emergency exhaust and temperature-control fans discharging horizontally and downwards, unlabelled ammonia alarms, not having ammonia alarms in its ammonia machinery rooms, unlabelled natural gas piping and hydraulic oil piping, corrosion on multiple pieces of equipment, unsupported ammonia piping, ammonia transfer vessel nameplates corroded beyond recognition, frosted site glass on the ammonia high pressure receiver, missing warning labels on electrical panels, and unsealed pipe penetrations in ammonia machinery rooms.”

— EPA Docket No. MM-09-2026-0093, Count II, ¶ 28

“EPA determined that Respondent failed to complete an annual certification of its operating procedures since 2013.”

— EPA Docket No. MM-09-2026-0093, Count IV, ¶ 38

“EPA determined that Respondent failed to consider language as a potential barrier or employee access to RMP-related training, documentation, and participation.”

— EPA Docket No. MM-09-2026-0093, Count VII, ¶ 50

“EPA observed significant ice buildup on the ammonia recirculation vessel and piping in the main refrigeration system, damaged vapor barrier and insulation in numerous locations on the roof and on ammonia piping in the main refrigeration system, and broken electrical wiring in the main refrigeration system.”

— EPA Docket No. MM-09-2026-0093, Count V, ¶ 42

“Respondent did not have any documentation of its contractor policy, did not have a list of its contractors who work in and around its ammonia refrigeration system, and did not have evaluation records of its contractors.”

— EPA Docket No. MM-09-2026-0093, Count VIII, ¶ 54

The Rules and How They Fell Short

Regulatory Gray Zones

The legal framework that governs facilities like Camino Real’s is well-established, but its enforcement depends entirely on inspection, and inspections are infrequent. The structure of the law created an environment where non-compliance could persist for years without detection.

• Self-certification is the core compliance mechanism. Under 40 C.F.R. § 68.69(c), the annual certification that operating procedures are current requires only the facility operator’s own signature. Camino Real skipped this for nine consecutive years. No external party was required to verify whether those procedures were actually being reviewed. The law entrusts compliance to the company being regulated.
• The Risk Management Program relies on periodic inspections rather than continuous oversight. EPA inspected this facility in July 2022. The violations documented range from physical deterioration (corroded nameplates, ice buildup) to administrative gaps (no contractor list, lapsed procedure certifications). The physical deterioration, in particular, does not happen overnight. The gap between when these conditions developed and when they were officially discovered is not recoverable from the source, but the nature of the deficiencies is consistent with years of neglect.
• The Tier II inventory filing failure (Count I) represents a gap in community right-to-know. EPCRA Section 312 requires facilities to file hazardous chemical inventory reports annually with state and local emergency planners and the fire department. When Camino Real failed to timely submit these, local first responders and emergency planners were operating with incomplete information about what was stored at this facility. The law created the reporting obligation, but the enforcement mechanism for catching late filers depends on regulators noticing the absence of a submission.
• The settlement’s self-certification of compliance (paragraph 64 of the CA/FO) repeats the same structural weakness that allowed noncompliance in the first place. Camino Real certifies “under penalty of law” that it has returned to full compliance. The settlement imposes no independent third-party audit requirement to verify that certification.