What AgLogic Sold, and What the Law Required

This case involves a single product, four shipments, and a label that the EPA had already updated twice. Here is what the enforcement record establishes.

• AgLogic Aldicarb Technical (EPA Reg. No. 87895-2) is a concentrated pesticide active ingredient. Aldicarb is a carbamate compound classified as a systemic insecticide and nematicide. It is absorbed by plants and kills insects, mites, and nematodes that feed on them. It is also acutely toxic to humans and animals, acting as a cholinesterase inhibitor that can cause seizures, respiratory failure, and death at sufficiently high doses.
• Under FIFRA Section 2(q)(1)(G), a pesticide is legally misbranded if its labeling does not include warning or caution statements adequate to protect health and the environment. Distributing a misbranded pesticide is a federal violation under FIFRA Section 12(a)(1)(E).
• The EPA approved an updated label for AgLogic Aldicarb Technical on August 23, 2019, and a further updated label on January 12, 2021. These updates materially increased the required personal protective equipment (PPE) and added a chemical hazard statement about reactive oxidizing agents.
• AgLogic imported its first two mislabeled shipments in April 2021, under Entry Numbers 916-44004664 and 916-44004763. By this date, the updated 2021 label had already been in effect for roughly three months.
• AgLogic imported two more mislabeled shipments in October and November 2022, under Entry Numbers 916-48022423 and 916-48285178. At this point, the approved label had been current for nearly two years.
• All four shipments were entered through the U.S. Customs and Border Protection’s ACE (Automated Commercial Environment) Data Processing System by licensed customs broker BDP World Houston on AgLogic’s behalf. The labels uploaded during that process are what triggered EPA review.

The Label Lie: What Workers Were Told vs. What They Needed

The specific gap between the outdated label AgLogic used and the current EPA-approved label reveals exactly what level of risk workers were exposed to without their knowledge.

• The PPE gap is not minor. A respirator protects the respiratory tract. Coveralls, chemical-resistant footwear, and gloves protect the skin from direct dermal absorption. Aldicarb can be absorbed through the skin, and dermal exposure is a primary route of poisoning for workers handling concentrated technical-grade material.
• The missing oxidizing agent warning is a storage and handling safety issue, separate from PPE. Aldicarb mixed with oxidizing chemicals can produce violent, hazardous reactions. Anyone storing this product in proximity to oxidizers, a common situation in agricultural chemical storage facilities, was never warned of this risk by the AgLogic label.
• Under 40 C.F.R. § 156.60, product labels are specifically required to carry hazard and precautionary statements for humans and domestic animals. The Precaution Statements section and the Physical and Chemical Hazards section both fell short of this requirement.
• Under 40 C.F.R. § 152.130, a registrant may only distribute or sell a product with the composition, packaging, and labeling currently approved by the EPA. There is no exception for importing material manufactured to an older specification. The obligation to update falls on the registrant.

The Non-Financial Ledger: What a Label Really Is

Here is what a pesticide label actually is, stripped of legal language. It is the only thing standing between a worker and a chemical they cannot see, smell in meaningful concentration, or identify as dangerous until it has already hurt them.

When you work with a substance like concentrated aldicarb, you trust the label. You have no other option. You are not a toxicologist. You do not have access to the EPA registration file. You read what is on the container, and you follow it. If the label says goggles and a respirator, you wear goggles and a respirator. You do not put on coveralls because the label did not tell you to. You do not put on chemical-resistant gloves because the label did not tell you to. You store the drums where you have always stored your chemicals, next to the other materials, because nothing on the label warned you that mixing or contact with certain agents could trigger a hazardous reaction.

That is the world AgLogic created for anyone who handled their product. The company knew the EPA had updated the label requirements, twice. The first update came in August 2019. The second, more stringent update came in January 2021. By April 2021, AgLogic was importing product with a label the EPA had already replaced. By November 2022, nineteen months after the final label update, they were still doing it.

This is not an abstraction. Aldicarb is a cholinesterase inhibitor. It disrupts the nervous system. Symptoms of exposure include excessive sweating, tearing, salivation, vomiting, muscle tremors, convulsions, and in acute cases, respiratory failure and death. The EPA does not upgrade protective equipment requirements on a whim. Those coveralls and those chemical-resistant gloves represent a specific, calculated judgment by regulators that skin contact with this product at handling concentrations presents a real and documented risk.

Every worker who handled those four shipments under the assumption that goggles and a respirator were sufficient was carrying a risk they did not consent to and did not know existed. The company that created that situation paid $22,000 to make the legal problem go away. That is less than the median annual salary of a farmworker in the United States. It is approximately what a single day of revenue looks like for a mid-sized chemical distributor.

The enforcement record does not tell us whether anyone was hurt. It does not have to. The violation is the exposure to risk itself, multiplied across every worker, every storage facility, every handler who received those four shipments and followed the instructions they were given in good faith.

Legal Receipts: What the Document Actually Says

These are verbatim quotes from the EPA Consent Agreement and Final Order, Docket No. FIFRA-04-2023-0728(b). No paraphrase. No editorial addition.

“The EPA determined that while the labels matched the EPA-approved label from 2012, they did not match the EPA-approved label from August 23, 2019, or the most recent EPA-approved label dated January 12, 2021.”

— Section IV, Findings of Facts, Paragraph 22

• This confirms the EPA identified the problem through its own review of labels uploaded into the CBP ACE system. AgLogic did not self-report or correct the label before being flagged.
• The phrase “most recent EPA-approved label” makes explicit that there were two rounds of updates AgLogic failed to implement. The label in use was not just one cycle behind; it predated two separate regulatory upgrades.
• The date “2012” in the document identifies the specific label version AgLogic was using. The violations were found on shipments in 2021 and 2022, meaning the label was at minimum nine years out of date on the first violation and ten years out of date on the last.

“Specifically, the Precaution Statements on the labels for the imported AgLogic Aldicarb Technical product stated that users and handlers should wear safety goggles and use a NIOSH-approved respirator whereas the most recent EPA-approved label states that users and handlers should wear coveralls, long-sleeved shirt and long pants, socks, chemical-resistant footwear, and gloves.”

— Section IV, Findings of Facts, Paragraph 22

• This paragraph documents the specific protective equipment gap in regulatory language. The old label covered one vector of exposure (inhalation). The current label covers three: inhalation, skin absorption, and dermal contact with contaminated surfaces underfoot.
• The absence of “socks” specifically suggests the regulators were concerned about contamination traveling from footwear to exposed ankle and lower-leg skin, a recognized pathway for agricultural chemical exposure. This level of specificity in the updated label reflects a risk assessment that the old label was failing workers in a documented way.

“Additionally, the Physical and Chemical Hazards section on the labels for the imported AgLogic Aldicarb Technical product was missing the following language from the most recent EPA-approved label: ‘Do not allow contact with oxidizing agents. Hazardous chemical reaction may occur.'”

— Section IV, Findings of Facts, Paragraph 22

• This is a separate and independent violation category from the PPE gap. This is a storage and chemical compatibility warning. Its absence means that anyone mixing this product, or storing it in proximity to oxidizers like chlorine compounds, bleach solutions, or nitrate-based fertilizers, had no warning that a dangerous chemical reaction was possible.
• Agricultural settings routinely store multiple chemical products together. The absence of this warning is a structural fire and explosion risk for storage facilities, not just a personal exposure risk for handlers.

“Respondent: (b) neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO; … (e) waives any right to contest the alleged violations of law set forth in Section V (Alleged Violations) of this CAFO; and (f) waives its rights to appeal the Final Order accompanying this CAFO.”

— Section VI, Stipulations, Paragraph 26

• This is the legal mechanism that lets corporations close enforcement cases without creating a public admission of wrongdoing. AgLogic simultaneously denies the facts happened and waives all rights to fight those same facts in court. This boilerplate protects the company from the document being used against them in civil litigation by harmed parties.
• The practical effect: the public record contains the EPA’s documented findings. AgLogic’s denial is a legal formality. The finding of violation stands in the record.

“Respondent acknowledges that this CAFO constitutes an enforcement action for purposes of considering Respondent’s compliance history in any subsequent enforcement actions.”

— Section VI, Stipulations, Paragraph 27(b)

• This clause is significant. Any future violation by AgLogic will be assessed against a compliance history that now includes a formal FIFRA enforcement action. Penalties for repeat offenders are substantially higher.
• FIFRA Section 14(a) allows penalties of up to $19,169 per day of violation for commercial registrants. The $22,000 total assessed here suggests either a negotiated reduction or that the EPA calculated this as a single episode rather than a per-day calculation across the 18-month violation window.

Inside the Violation: How the Label Failure Was Structured

The misbranding was not a single omission. It was the product of importing material whose label had fallen behind two separate regulatory updates, each covering a distinct safety category.

Societal Impact: Who Pays When Labels Lie

Public Health

The documented public health harm in this case is the creation of invisible, unconsented risk for every worker who handled AgLogic Aldicarb Technical during the violation window.

• Aldicarb is classified as a cholinesterase inhibitor, a class of pesticides that disrupt acetylcholinesterase, the enzyme that controls nerve-to-muscle signaling. Acute overexposure can cause muscle paralysis, respiratory failure, and death. Chronic low-level exposure is associated with neurological effects. The EPA does not set elevated PPE requirements for this chemical category without scientific basis.
• Dermal absorption is a primary exposure route for aldicarb. The upgrade from goggles-plus-respirator to full-body coverage with chemical-resistant gloves and footwear reflects a specific regulatory determination that skin contact with concentrated aldicarb technical material poses a meaningful absorption risk. Workers who followed the outdated label were exposed to this route of entry without protection.
• The missing oxidizing-agent hazard warning created a reactive chemical risk in any storage environment where aldicarb was stored near chlorine compounds, nitrate-based fertilizers, or other common agricultural oxidizers. A hazardous chemical reaction in a storage facility is a risk to every person in that building, not only the individual handling the product.
• Agricultural workers, who are the most likely downstream handlers of this product, are among the most under-protected labor populations in the United States. They have high rates of uninsurance, limited access to occupational health services, and face significant barriers to reporting workplace injuries. The workers least likely to know they were under-protected are the ones most likely to have been handling concentrated aldicarb technical material.

Economic Inequality

The $22,000 penalty reflects a structural enforcement gap that consistently prices compliance violations below the cost of compliance itself for large chemical distributors.

• The fine of $22,000 for four shipments of mislabeled concentrate over an 18-month period works out to approximately $5,500 per shipment. The cost of updating labeling on a pesticide product, which is primarily an administrative and printing cost, is a fraction of that amount. The penalty does not create a meaningful financial deterrent against future non-compliance.
• FIFRA authorizes penalties of up to $19,169 per day of violation for commercial entities. If the 18-month window between the first and last shipment were treated as continuous violations, the maximum potential penalty would be in the millions of dollars. The settlement of $22,000 represents a regulatory discount of approximately 99% from that theoretical maximum.
• AgLogic’s customs broker, BDP World Houston, uploaded the outdated labels into the CBP ACE system on the company’s behalf. The document does not indicate any penalty or action against the broker. The burden of enforcement fell entirely on the registrant, while intermediaries who handled the same non-compliant documentation faced no consequence.
• Workers who were harmed, if any, have no direct recourse from this enforcement action. The CAFO resolves only the EPA’s civil penalty claim. It explicitly preserves the EPA’s right to pursue other actions, but makes no provision for worker notification, medical monitoring, or compensation for anyone who handled the mislabeled product.

The Cost of a Life Metric

Who Was Involved and How

The enforcement action identifies a specific chain of entities, each with a defined role in how the mislabeled product entered U.S. commerce.

What Now: Where to Push

The settlement is closed. AgLogic certified compliance. The enforcement record exists. What happens next depends on pressure from outside the regulatory system.

The People Who Signed This Document

• Keriema S. Newman, Acting Director, Enforcement and Compliance Assurance Division, U.S. EPA Region 4: signed as complainant. Her division is the regulatory body responsible for FIFRA enforcement in the Southeast.
• Larry Hodges, PhD, Director of Regulatory Affairs, AgLogic Chemical LLC (email: larryhodges@meycorp.com): identified as the company’s representative in the Certificate of Service. His email domain, meycorp.com, suggests a parent or affiliated company relationship not identified in the source document.
• Tanya Floyd, Regional Judicial Officer: signed the Final Order. She ratified the consent agreement under 40 C.F.R. §§ 22.4(b) and 22.18(b)(3).
• Kimberly Tonkovich, Life Scientist, EPA Chemical Safety Land Enforcement Branch: the EPA’s case officer, named in proof-of-payment instructions and the Certificate of Service.

Watchlist: Regulatory Bodies With Ongoing Authority

• U.S. EPA Region 4 (Atlanta): Primary enforcement authority for FIFRA violations in the Southeast, including North Carolina. Any new AgLogic violation will now be assessed against this CAFO as prior history. FOIA requests to this office can surface additional inspection records.
• U.S. EPA Office of Pesticide Programs (OPP): The national office responsible for pesticide registration, label review, and approval. The OPP approved the 2019 and 2021 label upgrades. They can be petitioned to require electronic label verification at point of importation.
• U.S. Customs and Border Protection (CBP): The ACE system is the mechanism that caught this violation. Advocacy for mandatory EPA cross-verification before pesticide import clearance would close the gap that allowed four shipments to be accepted before a review was triggered.
• Occupational Safety and Health Administration (OSHA): OSHA’s agricultural worker protections intersect directly with FIFRA labeling requirements. OSHA does not have jurisdiction over FIFRA, but it has authority over workplace chemical hazard communication under 29 C.F.R. § 1910.1200. Workers who received product with inadequate safety data may have OSHA complaint grounds independent of this enforcement action.
• State Departments of Agriculture: In North Carolina and any other state where AgLogic Aldicarb Technical was distributed, state agricultural agencies have concurrent authority to investigate pesticide distribution violations. State-level complaints can trigger investigations that the federal CAFO does not preclude.

Grassroots Resistance and Mutual Aid

• If you handled this product: Document your exposures. Keep any shipping records, safety data sheets, or label copies you received. Contact your state department of agriculture or OSHA regional office to report receiving mislabeled pesticide product. You have standing to file a complaint independent of this enforcement action.
• Farmworker advocacy organizations like Farmworker Justice, the National Center for Farmworker Health, and local workers’ centers provide legal aid and health resources for agricultural workers who suspect pesticide exposure harm. These organizations also track FIFRA enforcement trends and can flag patterns of non-compliance that single cases do not reveal.
• FOIA the full inspection record: The CAFO reveals only what the EPA chose to include in the settlement document. A Freedom of Information Act request to EPA Region 4 for all documents related to Docket No. FIFRA-04-2023-0728(b) could surface inspection reports, correspondence, and the penalty calculation worksheet that determined $22,000 was the appropriate figure.
• Demand stronger import label verification: Contact your congressional representatives and the EPA Office of Pesticide Programs to demand that pesticide import entries require automated label version verification before CBP clearance is granted. The current system caught this violation. The question is how many similar violations it missed.
• Watch the compliance history clause: AgLogic acknowledged this CAFO goes on their compliance record. If they appear in a future enforcement action, that record must be cited. Subscribe to EPA enforcement alerts or set a public records monitor for AgLogic Chemical LLC, EPA Reg. No. 87895-2, and any associated entity operating from 121 South Estes Drive, Chapel Hill, NC.