EPA alleged that the Pennsylvania foam-products manufacturer missed three annual deadlines for reporting its processing of diisocyanates. Bryn Hill agreed to an $8,969 penalty, while neither admitting nor denying the specific factual allegations.
What the record shows
- EPA alleged that Bryn Hill Industries processed more than 25,000 pounds of diisocyanates in each of the 2021, 2022 and 2023 calendar years.
- The agency alleged that required reports for all three years were filed after their July 1 deadlines.
- The 2021 and 2022 reports were allegedly more than two years and more than one year late, respectively.
- All three filings occurred after an EPA inspection on October 1, 2024, although the order does not say the inspection caused the filings.
- Bryn Hill consented to an $8,969 civil penalty and certified that it was currently compliant regarding the alleged violations.
- The company neither admitted nor denied the specific factual allegations, but waived its right to contest them in this proceeding or appeal the final order.
Critical distinction: This is a chemical-reporting case. The order does not establish an unlawful chemical release, exposure, injury or environmental contamination.
The information for Bryn Hill Industries’ 2021 diisocyanates report was due on July 1, 2022. According to an EPA settlement, a complete report did not arrive until about November 4, 2024. By then, the agency had inspected the company’s Yeadon, Pennsylvania facility and another annual deadline had passed.
EPA alleged the same basic failure across three reporting years: Bryn Hill processed enough of the listed chemical to trigger federal reporting requirements, but did not submit the required form to EPA and Pennsylvania on time. The reports were eventually filed in October and November 2024.
The missing act was disclosure, not permission to process
The Emergency Planning and Community Right-to-Know Act requires covered facilities to submit an annual toxic chemical inventory report when they manufacture, process or otherwise use a listed chemical above the applicable threshold. For these allegations, the threshold for diisocyanates processed during a calendar year was 25,000 pounds.
Facility is covered
EPA alleged that the plant had at least 10 full-time employees and operated under an industrial classification covered by the rule.
Threshold is exceeded
EPA alleged that Bryn Hill processed more than 25,000 pounds of diisocyanates in each relevant year.
Annual report is due
A Form R or eligible Form A must be submitted to EPA and the state by July 1 of the following year.
The company’s facility manufactured urethane and other foam products, according to the order. The document does not identify the exact quantity of diisocyanates processed in any year. It says only that the amount exceeded the 25,000-pound threshold each time.
| Activity year | Report deadline | EPA-alleged filing date | Approximate delay |
|---|---|---|---|
| 2021 | July 1, 2022 | On or about November 4, 2024 | More than two years |
| 2022 | July 1, 2023 | On or about November 4, 2024 | More than one year |
| 2023 | July 1, 2024 | On or about October 25, 2024 | Nearly four months |
The inspection came before all three filings
An EPA Region 3 representative conducted a compliance evaluation inspection at the facility on October 1, 2024. The settlement places the first late filing about 24 days later, followed by the other two reports in early November.
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The three annual reporting deadlines passed, according to EPA’s allegations.
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EPA Region 3 conducted a compliance evaluation inspection at the Yeadon facility.
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Bryn Hill filed the complete report for the 2023 activity year, EPA alleged.
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The company filed complete reports for the 2021 and 2022 activity years, according to the settlement.
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EPA filed the Final Order, making the settlement effective and ordering Bryn Hill to comply with its terms.
The chronology is clear. The reason for the eventual filings is not. The supplied order does not state that EPA’s inspection prompted them, describe how the deadlines were missed or identify who within the company was responsible.
- EPA’s position
- Three untimely-reporting claims under Section 313 of EPCRA, one for each year from 2021 through 2023.
- Company’s position
- Bryn Hill admitted EPA’s jurisdiction for this proceeding but neither admitted nor denied the specific factual allegations.
- Binding outcome
- The company consented to the $8,969 assessment, waived its right to contest the allegations or appeal, and was ordered to follow the agreement.
- Compliance claim
- Bryn Hill certified, after personal investigation and to the best of its knowledge and belief, that it was currently compliant regarding the alleged violations.
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