How ChromaScape Stored Hazardous Waste Illegally While Workers Went Untrained

On April 9, 2025, EPA inspectors walked into ChromaScape LLC’s facility at 1514 Bushy Park Road, Goose Creek, South Carolina, and discovered what can only be described as a masterclass in regulatory contempt. This was a large quantity generator of hazardous waste that had systematically ignored federal environmental law for half a decade. The resulting Consent Agreement and Final Order, Docket No. RCRA-04-2026-4000(b), filed July 13, 2026, exposes not just isolated mistakes but a pattern of institutional indifference to worker safety and environmental protection.

ChromaScape manufactures colorants and additives used in wood mulch, printing inks, paper, recycled rubber, and specialty solutions. These are products that touch everyday consumer goods. The chemicals required to produce them include solvents, acids, and compounds exhibiting the hazardous waste characteristics of ignitability, corrosivity, and toxicity. Under the Resource Conservation and Recovery Act (RCRA), companies generating such waste face strict regulatory requirements designed to prevent contamination, fires, explosions, and worker exposure. ChromaScape violated nearly all of them.

The EPA and South Carolina Department of Environmental Services conducted a compliance evaluation inspection. What they found was not a paperwork error or a missed deadline. They found a five-year accumulation of solvent-contaminated wipes, untrained personnel handling toxic waste, falsified reports, and emergency plans so out of date that local firefighters didn’t have current copies.

The Non-Financial Ledger

The numbers in the settlement tell one story. The human and environmental reality tells another.

In Building C9-1, Spectral Lab Room, inspectors observed a 5-gallon yellow container labeled “Excluded Solvent-Contaminated Wipes.” The accumulation start date on the container read June 29, 2020. The inspection date was April 9, 2025. That container had been sitting there for 1,746 days. Federal regulations allow solvent-contaminated wipes to be stored for a maximum of 180 days under a specific exclusion. After that threshold, the material becomes regulated hazardous waste and must be disposed of under permit. ChromaScape exceeded that limit by nearly 1,600 days.

“At the time of the CEI, the EPA inspectors observed that solvent contaminated wipes in one 5-gallon closed yellow container labeled ‘Excluded Solvent-Contaminated Wipes,’ with an accumulation start date of June 29, 2020, in Building C9-1 Lab, Spectral Lab Room, had been stored for more than 180 days.”

Imagine walking into your workplace every day and seeing that container. Imagine being the laboratory technician who cleans equipment with those wipes, tosses them in that bin, and knows the date on the label hasn’t changed in years. You are not trained on hazardous waste regulations. You do not know that container represents a federal violation. You trust that management has handled it. Management has not.

The wipes themselves are contaminated with solvents used in the manufacturing process. These are typically flammable, volatile organic compounds. Prolonged storage increases the risk of vapor accumulation, container degradation, and accidental ignition. The lab is a confined space. A spark, a static discharge, or improper handling could turn that 5-gallon container into an ignition source.

ChromaScape’s workforce was left in the dark. The consent agreement explicitly states that laboratory employees who operate processes that generate hazardous waste and determine when laboratory chemicals become hazardous waste did not receive RCRA-specific training. These employees handle chemicals classified as ignitable, corrosive, reactive, and toxic. They make daily decisions about waste categorization. They were never taught how to do it correctly.

This is not an accident. This is a decision. Training costs money. It requires time, documentation, and ongoing refreshers. ChromaScape chose not to spend that money. The result is a workforce generating hazardous waste without understanding the legal, environmental, or personal safety implications of their actions.

There were other failures. Inspectors found an 8-ounce jar of unknown waste inside a 30-gallon container labeled “Excluded-Solvent Contaminated Wipes” on the second floor of Building C9-1. ChromaScape had made no hazardous waste determination on that jar. They did not know what it was. They did not test it. They stored it anyway. In the same building, a 2-gallon container of High-Performance Liquid Chromatography (HPLC) waste sat labeled with methanol, water, and dye. No hazardous waste determination. All liquid laboratory waste from the HPLC and Ultra Performance Liquid Chromatography (UPLC) machines was being sent to the wastewater treatment plant. No testing. No waste characterization. No compliance.

Federal law requires generators to make an accurate determination of whether a solid waste is hazardous. This is not optional. It is the foundational requirement of the entire RCRA regulatory scheme. Without accurate waste determinations, there is no way to ensure proper storage, labeling, transportation, or disposal. ChromaScape simply skipped this step. They treated unknown materials as non-hazardous by default and sent them into the waste stream.

Elsewhere in the facility, the Central Accumulation Area (CAA) held four 55-gallon hazardous waste containers missing hazard labels and four containers with no accumulation start date. These are not minor administrative oversights. Hazard labels communicate to workers, emergency responders, and waste transporters what dangers are present. Accumulation start dates enforce the 90-day storage limit for large quantity generators. Without these markings, there is no enforceable compliance. Containers can sit indefinitely. Workers do not know what they are handling. Firefighters arriving at an emergency have no idea what is burning.

ChromaScape also stored six 55-gallon containers of hazardous waste in the CAA for more than 90 days without obtaining a storage permit extension. Under RCRA, a large quantity generator can store hazardous waste on-site for up to 90 days without a permit, provided they meet specific conditions. Exceeding that limit converts the facility into an unpermitted storage facility, triggering far more stringent regulatory requirements. ChromaScape crossed that line and kept going.

The facility’s emergency preparedness was equally compromised. The contingency plan’s emergency equipment list did not include the location, physical description, or capabilities of each item. When an emergency occurs, responders need to know where the fire extinguishers are, what type they are, and what fires they can suppress. ChromaScape’s plan did not provide this information. Additionally, the updated 2022 contingency plan and Quick Reference Guide were never submitted to local emergency responders. The last submission occurred in November 2021. Firefighters, hospitals, and emergency management agencies were working with outdated information. If a major incident had occurred, response teams would have been operating blind.

ChromaScape also submitted quarterly hazardous waste reports to the South Carolina Department of Environmental Services that underreported waste quantities in January 2023, March 2023, January 2024, and February 2024. These reports are used by state regulators to track waste generation trends, identify compliance issues, and allocate enforcement resources. Falsified data undermines the entire regulatory system. It prevents accurate risk assessment. It allows violators to fly under the radar.

Finally, inspectors found improperly labeled universal waste. A 5-gallon container of used lithium-ion batteries in Maintenance Building B10-3 was labeled “Universal Waste” but missing the word “batteries.” A cardboard box of spent aerosol cans in Building C9-1 was not labeled as universal waste at all. Both containers lacked any indication of the accumulation start date, making it impossible to verify compliance with the one-year storage limit for small quantity handlers of universal waste.

These are not isolated incidents. They are symptoms of a facility-wide culture of non-compliance.

Legal Receipts

The consent agreement is a legal document, and its language is deliberate. Every finding is a recorded fact. Every alleged violation is a potential criminal referral if the company fails to comply. The document does not speculate. It does not editorialize. It states what inspectors observed.

“At the time of the CEI, the EPA inspectors observed that the Respondent had not made a hazardous waste determination on the following hazardous wastes: an 8-ounce jar that contained an unknown waste inside a 30-gallon closed container labeled ‘Excluded-Solvent Contaminated Wipes’ on the second floor of Building C9-1; one 2-gallon container of High-Performance Liquid Chromatography (HPLC) waste labeled with methanol, water, and dye as the contents in the laboratory in Building C9-1; and all the liquid laboratory waste from the HPLC and Ultra Performance Liquid Chromatography (UPLC) machines located in Building C9-1 sent to the wastewater treatment plant.”

“At the time of the CEI, the EPA inspectors reviewed RCRA-specific training records. The EPA inspectors observed that laboratory employees were not included in the training records provided. Furthermore, the Facility representative stated that laboratory employees, who operate processes that generate hazardous waste and/or determine when laboratory chemicals—which may be classified as ignitable, corrosive, reactive, and or toxic in nature—become a hazardous waste, did not receive RCRA-specific training.”

“At the time of the CEI, the EPA inspectors observed six 55-gallon containers of hazardous waste in the CAA that had been accumulating for more than 90 days without the Facility having first received an extension.”

“At the time of the CEI, the EPA inspectors observed that a copy of the Facility’s contingency plan and its QRG were most recently submitted to the Berkeley County Emergency Management Agency, State Emergency Response Commission Chemical Safety Board, and the onsite Fire Department in November 2021. There were no records available demonstrating that the contingency plan and its QRG were submitted to local emergency responders after the 2022 update.”

These are not allegations. These are documented observations. ChromaScape does not contest the factual findings. The consent agreement explicitly states that ChromaScape “neither admits nor denies the factual allegations” but agrees to the settlement. This is standard legal language, but the practical effect is clear: ChromaScape is paying $105,207 to make this go away without admitting wrongdoing on the record.

Societal Impact Mapping

Environmental Degradation

Hazardous waste that is improperly stored, uncharacterized, or sent to unpermitted disposal facilities does not vanish. It migrates. Solvent-contaminated wipes sitting in a laboratory for five years can off-gas volatile organic compounds into the indoor air. Laboratory waste sent to a wastewater treatment plant designed for domestic sewage, not industrial solvents, can bypass treatment processes and discharge into surface water. The consent agreement does not detail the downstream environmental fate of ChromaScape’s waste, but the violations create multiple contamination pathways.

Goose Creek sits within the Cooper River watershed, a critical estuarine system that drains into Charleston Harbor and the Atlantic Ocean. Industrial facilities in this region are part of a dense petrochemical and manufacturing corridor. Cumulative contamination from multiple sources degrades water quality, harms aquatic ecosystems, and threatens drinking water supplies. ChromaScape’s violations are one data point in a larger pattern of regulatory failure in South Carolina’s coastal plain.

The state has authorized its own hazardous waste program under RCRA, meaning South Carolina is responsible for day-to-day enforcement. The EPA retains oversight authority and can step in for independent enforcement actions, as it did here. The fact that this case required federal intervention suggests that state-level enforcement was insufficient. The violations were obvious, longstanding, and well-documented. A competent state inspection program should have caught them years earlier.

Public Health

Workers at ChromaScape were exposed to hazardous waste without adequate training, labeling, or emergency preparedness. This is not theoretical risk. This is daily occupational exposure. Solvent vapors cause dizziness, nausea, respiratory irritation, and long-term neurological damage. Corrosive chemicals cause chemical burns. Ignitable materials pose fire and explosion risks. Toxic compounds accumulate in the body and cause cancer, organ damage, and reproductive harm.

The absence of RCRA training means workers did not know how to protect themselves. They did not know how to identify hazardous waste. They did not know the legal requirements for storage, labeling, and disposal. They were kept ignorant by design. This is the definition of environmental injustice. The people closest to the hazard, the people generating the profit, are the least protected.

The community surrounding the facility is also at risk. Goose Creek has a population of approximately 45,000 people. Many residents live within a mile of industrial facilities. Air emissions, groundwater contamination, and emergency incidents do not respect property lines. When a facility fails to maintain updated emergency plans and does not train its workforce, the entire community is endangered. If a major fire, spill, or explosion occurs, first responders will not have accurate information. Evacuation plans will be based on outdated data. People will die.

Economic Inequality

ChromaScape settled for $105,207. The violations spanned five years. The company stored hazardous waste illegally for 1,746 days. It failed to train workers, falsified reports, and ignored emergency preparedness requirements. The penalty works out to roughly $21,041 per year of systematic non-compliance. For a manufacturing company generating over 1,000 kilograms of hazardous waste per month, this is a rounding error.

The consent agreement does not disclose ChromaScape’s annual revenue, but colorant and additive manufacturers in this sector typically generate millions of dollars in sales. The cost of compliance—proper training, waste characterization, emergency plan updates, and timely disposal—is a fraction of revenue. ChromaScape chose not to comply because the penalty for non-compliance was cheaper than the cost of compliance. This is rational economic behavior under a broken enforcement regime.

The penalty is also non-deductible for tax purposes, per 26 U.S.C. § 162(f), but that is a minor deterrent. The real issue is that the settlement contains no injunctive relief requiring operational changes, no independent monitoring, and no public disclosure requirements beyond the consent agreement itself. ChromaScape certifies that it is “currently in compliance” and that “all violations alleged herein, which are neither admitted nor denied, have been corrected.” There is no mechanism to verify that claim.

The EPA retains the right to inspect the facility in the future, but there is no mandatory follow-up. The state of South Carolina is responsible for ongoing oversight, and the state’s track record is poor. The system is designed to allow companies to pay a fine, sign a piece of paper, and return to business as usual.

Meanwhile, the workers who were never trained continue to show up for their shifts. The community surrounding the facility continues to live downwind and downstream. The regulatory agencies move on to the next case. Justice is not served. Compliance is purchased.

What Now?

ChromaScape’s Chief Executive Officer, Devlin Riley, signed the consent agreement. The company’s address is listed as 1555 E. Pleasant Valley Rd., Ste. 101, Independence, OH 44131, though the facility in question operates in South Carolina. Corporate leadership is responsible for the culture of non-compliance that allowed these violations to persist for five years.

The EPA’s Region 4 Enforcement and Compliance Assurance Division brought the action. Director Keriema S. Newman signed for the complainant. Regional Judicial Officer Michele Wetherington ratified the final order. These are the names and titles associated with the decision to settle for $105,207 rather than pursue harsher penalties, operational reforms, or criminal referrals.

There is no indication in the consent agreement that ChromaScape has installed independent monitoring, retained a third-party environmental auditor, or implemented any structural reforms beyond “certifying” current compliance. The document explicitly states that ChromaScape “waives any right to contest the allegations” and “waives its rights to appeal the Final Order.” The case is closed.

Watchlist

The following agencies have jurisdiction over ChromaScape’s operations and can receive public complaints, FOIA requests, and evidence of ongoing violations:

• U.S. Environmental Protection Agency, Region 4 (Atlanta Federal Center, 61 Forsyth Street SW, Atlanta, GA 30303)
• South Carolina Department of Health and Environmental Control (DHEC) (2600 Bull Street, Columbia, SC 29201)
• Occupational Safety and Health Administration (OSHA) (Columbia Area Office, 1835 Assembly Street, Suite 1468, Columbia, SC 29201)
• Berkeley County Emergency Management Agency (1003 Highway 52, Moncks Corner, SC 29461)

Resistance

Consent agreements are public records. The full 21-page document is available through the EPA’s online docket system and can be obtained via Freedom of Information Act (FOIA) request. Community members in Goose Creek have the right to request inspection reports, waste manifests, and emergency response plans. South Carolina’s public records law requires DHEC to disclose facility-level compliance data.

Local organizing efforts should focus on demanding real-time air quality monitoring around the facility, independent third-party audits of ChromaScape’s waste handling practices, and mandatory community notification of any future violations. Workers inside the facility should be informed of their rights under OSHA’s Hazard Communication Standard and the whistleblower protections available under RCRA Section 7001.

The broader goal is to shift enforcement policy away from consent agreements that let corporations pay nominal fines and toward structural reforms that eliminate the economic incentive to violate the law. That requires legislative action at the state and federal level, sustained public pressure, and coordination between labor unions, environmental justice groups, and frontline communities.

ChromaScape’s violations were preventable. They were the result of deliberate choices made by corporate management to prioritize cost savings over compliance. The penalty was a rounding error. The harm was real. The fight continues.