The Non-Financial Ledger

How Long This Took to Resolve

The EPA’s inspection and the final order were separated by nearly two years. Here is every documented event from the source material, in order.

What the Government Documents Actually Say

Every quote below comes directly from EPA Docket No. CAA-04-2024-0304(b). Nothing is paraphrased.

“The emergency shutoff valves (King Valve) for the new and old high-pressure receivers (HPRs) could not be operated from ground level. A fixed ladder was attached to the old HPR. However, it would require emergency response personnel to walk on the top of the tank to reach the King Valve.”

• This is the most critical safety failure in the document. The King Valve is the primary shutoff for liquid and gas flow in an ammonia system. If a release begins, that valve must be closed immediately. At this facility, closing it required climbing onto a pressurized tank, which is precisely the location you do not want to be standing when ammonia is escaping.
• Federal standards cited in the document (IIAR 2, both 1984 and 2014 editions) are unambiguous: isolation valves identified as part of the emergency shutdown procedure must be directly operable from the floor or chain-operated from a permanent work surface. Neither condition was met for either receiver.

“The emergency eyewash station and safety shower on the exterior of the building could not be easily accessed by personnel leaving the ammonia machine room (AMR). The shower is not visible from the exit stairway in the AMR, is adjacent to the low temperature recirculator and ammonia pump and requires personnel to move around the stairway leading to the roof.”

• ANSI/ISEA Z358.1 (2009), the industry standard cited in the order, requires the unit to be reachable in no more than ten seconds and on a path free of obstructions. This station was hidden from the exit and blocked by equipment. A worker with ammonia in their eyes, operating on instinct in pain, would not find it in ten seconds.
• ANSI/IIAR 2 (2014) and ANSI/IIAR 9 (2020) both require a minimum of two eyewash and safety shower units: one inside the machinery room, one outside. The document does not confirm both conditions were met.

“An extension cord had been cut and fashioned into permanent wiring in the AMR.”

• NFPA 70 (2020), the National Electrical Code, explicitly prohibits flexible cords from being used “as a substitute for the fixed wiring of a structure.” Someone at this facility did exactly that, in a room where an ammonia leak combined with an electrical arc or spark creates a compounded hazard scenario.
• The same section of NFPA 70 prohibits cords attached to building surfaces, run through walls, or used anywhere they cannot be inspected and replaced safely. This cord was cut and embedded as infrastructure.

“Anhydrous ammonia visual alarms outside the machinery room were not properly labeled or indicated otherwise as ammonia leak detection alarms.”

• Both ANSI/IIAR 2 (2014) and ANSI/IIAR 9 (2020) require that ammonia leak detection alarms be identified by signage adjacent to the visual and audible alarm devices. Without that signage, a worker outside the machinery room who sees a flashing light has no way of knowing whether it signals an ammonia leak or a general fire alarm, which requires completely different responses.
• This is not a paperwork problem. Unlabeled alarms delay evacuation decisions and delay emergency calls to the fire department. Every second of that delay matters with a substance like anhydrous ammonia.

“Ammonia piping was not properly labeled in numerous locations on the roof, in the AMR, on the new ice maker, and on evaporators.”

• Proper labeling under ANSI/IIAR 2 (2014) and ASME A13.1 (2015) requires each pipe to identify: the word “AMMONIA,” the physical state of the ammonia, the pressure level (high or low), the pipe service, and the direction of flow. Unlabeled pipes mean that maintenance workers, contractors, and emergency responders working the system cannot instantly identify what is inside the pipe, at what pressure, or which direction it flows.
• This failure affects both routine maintenance safety and emergency response. A firefighter entering the building during a release cannot afford to guess.

Societal Impact Mapping

Public Health

Anhydrous ammonia at industrial scale is not a local inconvenience. It is a mass casualty risk. Every safety failure documented at this plant directly increases the probability of an event that would harm workers, neighbors, and first responders.

• Anhydrous ammonia is immediately dangerous to life and health at 300 parts per million. At the concentrations that a catastrophic release from 146,200 pounds of pressurized gas could produce, the compound kills by asphyxiation and chemical burns to the respiratory tract. Workers inside the AMR during a release would have seconds, not minutes.
• The blocked and mislabeled emergency eyewash station directly extends the window of chemical exposure for any worker who contacts ammonia during routine operations or an incident. Chemical burns to the eyes from anhydrous ammonia can cause permanent vision loss within seconds of contact; ANSI’s ten-second access standard exists precisely because of this injury profile.
• The unlabeled ammonia leak detection alarms outside the machinery room mean that workers in adjacent areas of the building cannot distinguish an ammonia alarm from any other alarm. This delays evacuation and delays calls to emergency services, extending the exposure window for everyone in the facility.
• The corroded and improperly supported piping represents an ongoing structural failure risk. Metal fatigue, vibration damage, and corrosion all increase the probability of a pipe failure that releases ammonia. The EPA document notes surface corrosion in “various locations” and piping sagging from lack of support in multiple spots on the roof, areas subject to freeze-thaw stress and wind loading.
• Florence, Kentucky, is a suburban community in Boone County, directly adjacent to the Cincinnati metro area. A large-scale ammonia release would not be contained to the facility. Shelter-in-place orders, road closures, and potential evacuations would affect surrounding residential neighborhoods, schools, and businesses. The settlement’s own supplemental project acknowledges this: the fire department needed a thermal drone, chemical suits, and evacuation sleds specifically to respond to this plant.

Economic Inequality

The penalty structure in this case illustrates a fundamental imbalance in how chemical safety risk is distributed and how its violation is priced.

• The total civil penalty assessed was $13,066. The EPA’s own supplemental environmental project requirement was $48,996, nearly four times the fine, because regulators recognized that the local fire department needed to be better equipped to handle an emergency at this plant. The company’s neighbors bear the risk; the company pays a fraction of the cost to address it.
• SFC Global Supply Chain, Inc. operates as part of a commercial food supply chain. The workers in the ammonia machinery room are the employees at the bottom of that supply chain, the ones physically closest to the chemical hazard and the least likely to have any power over how the machinery room is maintained or what safety upgrades get budgeted.
• The $13,066 fine does not create any meaningful financial deterrent. For a corporation operating a facility that processes enough ammonia to require EPA Risk Management Program Level 3 classification, which places it among the highest-risk industrial categories, a five-figure penalty is a rounding error. The math signals that non-compliance is affordable.
• The communities surrounding industrial facilities storing threshold quantities of hazardous substances are disproportionately working-class. They receive the environmental and safety burden of industrial operations while the financial benefits, profit, tax revenue structures, and supply chain margins, flow elsewhere. The $13,066 penalty does not compensate them for bearing that risk.
• The settlement required SFC Global to publicly state, in any communications about the supplemental project: “This project was undertaken in connection with the settlement of an enforcement action taken by the U.S. Environmental Protection Agency for alleged violations of the federal laws.” This disclosure requirement exists because without it, corporate PR would describe a generous donation to the local fire department, erasing the regulatory failure that made the donation necessary.

The “Cost of a Life” Metric

The EPA assessed a civil penalty. Then it required a supplemental project. The numbers tell the real story of how the agency values risk at this scale.

The Equipment List That Tells You Everything

As part of the settlement, SFC Global was ordered to purchase and donate emergency response equipment to the Florence Fire/EMS Department within six months of the final order. The equipment list is itemized in Appendix A of the consent agreement and is reproduced here in full from that document.

• 2x Multi Rae Pro gas detection monitors (model MCB3-A31REZ-420) with cradle. These detect multi-chemical atmospheric hazards in real time. The fire department needed two of them specifically to respond to potential ammonia releases.
• Demand flow regulators and calibration gases for the detection equipment, needed to keep the monitors properly calibrated and operational for emergency use.
• 1x DJI Mavic 3 Thermal Drone. A thermal imaging drone allows first responders to assess the extent of a chemical release, identify hot zones, and locate victims without placing additional personnel in the hazard area. This is what responding to a large ammonia release looks like at scale.
• 12x Fully Encapsulated Training Suits (6 in XL, 6 in 2XL). These suits protect the entire body from chemical exposure during training exercises. They are required because responders who have never suited up in a chemical environment cannot function effectively in a real one.
• 8x Level A Suits (4 in XL, 4 in 2XL). Level A is the highest level of chemical protection available. These are vapor-tight, designed for entry into environments with immediately dangerous concentrations of toxic or unknown chemicals. The Florence Fire/EMS Department now has them because of SFC Global’s plant.
• 4x Chemical tape (Chem Tape) rolls for scene perimeter marking during chemical incidents.
• Hazmat boots in five sizes (sizes 9 through 13, four pairs each), 50 hazmat overboots in three sizes, and 30 hazmat gloves in three sizes. Protective footwear and gloves for the response team entering the hazard zone.
• 1x Hazmat ICS Flip Chart Easel Board and 1x collapsible easel. These are command coordination tools for managing a hazmat incident scene. The Incident Command System requires structured coordination; these materials are how that coordination happens at the scene perimeter.
• 1x Slyde Evacuation Sled (5-pack). Evacuation sleds are used to move incapacitated victims, including unconscious or chemically exposed workers, out of a hazard zone when they cannot walk. The settlement required five of them.
• 1x Decontamination Shower System. A portable decontamination shower for removing chemical contamination from victims and responders before transport to medical care.

What Now? The Watchlist and What You Can Do

SFC Global Supply Chain, Inc. certified compliance with all relevant requirements at the time the CAFO was signed. The violations, per the settlement, have been corrected. But the enforcement record now exists, and future violations at this facility will be evaluated against this compliance history.

Who Is Accountable

• The contact named in the Certificate of Service for SFC Global Supply Chain, Inc. is Dave Windham, reachable at the Florence, KY facility (7605 Empire Drive, Florence, Kentucky 41042; 859-371-0500). The email on file is Dave.Windham@schwans.com, which indicates an affiliation with Schwan’s Company, placing SFC Global within that corporate structure.
• The EPA case is administered by Justin Stark, Case Development Officer, North Air Enforcement Section, Air Enforcement Branch, EPA Region 4 (Stark.Justin@epa.gov; (404) 562-8305).
• The Consent Agreement was signed by Keriema S. Newman, Director, Enforcement and Compliance Assurance Division, EPA Region 4, and ratified by Regional Judicial Officer Tanya Floyd on July 5, 2024.

Regulatory Watchlist

• U.S. EPA Region 4: Primary enforcement authority for Clean Air Act Section 112(r) and the Risk Management Program at this facility. Any future violations at 7605 Empire Drive will be reviewed against this enforcement action’s compliance history. Contact: R4 Regional Hearing Clerk at r4_regional_hearing_clerk@epa.gov.
• EPA Office of Emergency Management (OEM): Administers the Risk Management Program nationally. Facilities like this one are required to submit and update Risk Management Plans. Those plans are public records and can be reviewed at the EPA’s RMP database.
• OSHA (Occupational Safety and Health Administration): Has parallel jurisdiction over process safety management (PSM) at facilities with large quantities of hazardous chemicals. The violations documented here, particularly the inaccessible shutoffs, the unlabeled alarms, and the improvised electrical wiring, have direct PSM equivalents under 29 C.F.R. § 1910.119. OSHA and EPA coordinate on such facilities; a separate OSHA inspection record may exist.
• Kentucky Division for Air Quality: The state-level regulator with concurrent authority over air emissions and chemical safety programs operating under state implementation plans. Kentucky residents can file complaints about industrial facilities at the state level independently of EPA.
• U.S. Chemical Safety and Hazard Investigation Board (CSB): An independent federal agency that investigates industrial chemical accidents. If a release occurs at a covered facility, the CSB investigates the root causes independently of enforcement. Their investigation reports are public and often more detailed than enforcement settlements.

What You Can Actually Do

• Locate your nearest RMP-covered facility. The EPA’s RMP database (searchable at epa.gov) lists every facility in the country required to file a Risk Management Plan, including what chemicals they store and in what quantities. If you live near one, you have the right to know it.
• Request Local Emergency Planning Committee (LEPC) records. Every county in the U.S. is required to have a LEPC under the Emergency Planning and Community Right-to-Know Act (EPCRA). These committees maintain information about hazardous chemical facilities in your area and develop emergency response plans. You can attend their meetings. They are open to the public.
• File a formal comment or complaint with EPA Region 4. If you are a worker at or neighbor of this facility or any similar RMP-covered site, you can submit formal complaints about safety conditions to EPA Region 4 at r4_regional_hearing_clerk@epa.gov. Document specific observations. Regulatory action often begins with public tips.
• Support workers’ rights organizations in the industrial sector. Workers inside facilities like this one are the people closest to the chemical hazard and often the least empowered to report safety failures without fear of retaliation. Organizations that provide legal support, whistle-blower protection information, and worker organizing resources in manufacturing and supply chain sectors create the pressure that enforcement agencies respond to most consistently.
• Push for penalty reform. A $13,066 penalty for eight violations at a facility storing nearly 15 times the federal danger threshold is not a deterrent. Contact your federal representatives and demand that Congress revisit the civil penalty caps under Clean Air Act Section 113(d). The maximum per-day, per-violation penalty has not kept pace with inflation or corporate revenue scales. The math on deterrence is broken by design.