Environmental Enforcement • Hazardous Waste • Fresno, California
Ten Months. Seven Barrels. $110,801.
TL;DR
- Univar Solutions USA, LLC, a major chemical distribution company, was caught by EPA inspectors on December 14, 2022, storing hazardous waste illegally at their facility at 4465 E Florence Avenue, Fresno, California.
- Seven containers of hazardous waste, including ignitable, corrosive, and toxic materials, sat at the Fresno facility for over 10 months without the required permit. The illegal storage ran from February 6, 2022 through December 14, 2022.
- The waste included materials classified under federal codes D001 (ignitable), D002 (corrosive), D003 (reactive), D005 (barium toxicity), and D035 (methyl ethyl ketone toxicity). These are the categories regulators use for substances that can burn, eat through containers, explode, and poison groundwater.
- The company settled with the EPA for $110,801. Univar Solutions neither admitted nor denied the specific factual allegations, a standard legal maneuver that lets corporations pay their way out without ever going on record as guilty.
- The EPA case was signed off by Regional Judicial Officer Beatrice Wong and filed by Regional Hearing Clerk Ponly Tu on May 7, 2025, more than two years after the inspection caught the violations.
- Under the settlement, this fine cannot be deducted as a business expense on federal taxes. That is one of the very few sharp teeth in this agreement.
A Chemical Giant, A Fresno Warehouse, and A Permit They Never Bothered to Get
Univar Solutions is one of the largest chemical distributors in the world. The company moves industrial chemicals, cleaning agents, solvents, and specialty compounds to clients across multiple sectors. Their Fresno, California facility on East Florence Avenue sits in a commercial and light-industrial corridor in a city that has long ranked among the most polluted urban areas in the state. The San Joaquin Valley, where Fresno sits, carries a well-documented air quality crisis. The communities surrounding industrial facilities in that valley already absorb more than their share of environmental risk.
On December 14, 2022, EPA inspectors from Region IX conducted a compliance evaluation inspection at the Fresno facility. What they found was straightforward and documentable: seven containers of hazardous waste sitting on-site without a valid permit, in violation of federal and California hazardous waste management law. The waste had been accumulating since at least February 6, 2022, meaning it had been there for more than ten months before inspectors arrived. Univar Solutions had no permit to store it, had not applied for a permit, had not been granted an extension, and had not met the conditions for any accumulation exemption.
The law is specific. Under both federal RCRA regulations and California’s authorized hazardous waste program, a facility can hold hazardous waste on-site for up to 90 days without a formal storage permit, provided strict conditions are met: containers must be labeled, waste must remain at or near the point of generation, and volume must stay within set limits. Univar Solutions met none of the required conditions. The waste exceeded the allowable volume. It was not accumulated at or near the generation point. At least one container was not properly labeled. The company blew past the 90-day window by more than seven months.
The hazardous waste codes involved in this case paint a specific picture of what was sitting in those containers. D001 is the classification for ignitable waste, material that can combust. D002 covers corrosive waste, substances that can chemically burn human tissue or degrade container materials and potentially leak. D003 designates reactive wastes, materials that can react violently with water, air, or other substances. The D001, D005, and D035 codes also applied to discarded paint cans: D005 indicates barium toxicity, and D035 covers methyl ethyl ketone, an industrial solvent with health implications for people exposed to it through skin contact, inhalation, or ingestion.
These are the categories that the federal hazardous waste system designed the permit requirement to address. The whole point of requiring a permit for hazardous waste storage is to ensure that trained oversight, proper containment infrastructure, emergency response protocols, and regulatory scrutiny are in place before materials like these are left to sit for months at a time. Univar Solutions, a company with the legal, compliance, and operational resources of a global chemical distributor, did not bother with the process. They let the containers sit and hoped nobody checked.
Someone did check. The settlement agreement signed in May 2025, nearly two and a half years after the inspection, cost the company $110,801. Univar Solutions, under the terms of the Consent Agreement and Final Order, certified compliance with RCRA, paid the penalty, and moved on. The company never had to go to court. They never had to admit to a single factual allegation. The agreement resolved the matter, in the agency’s own words, because settling “without the filing of a complaint or the adjudication of any issue of fact or law is in their respective interest and in the public interest.”
The Non-Financial Ledger: What the Settlement Doesn’t Pay For
The $110,801 penalty paid by Univar Solutions closes the federal civil enforcement case. It compensates the government. It does not compensate the people who live and work near 4465 E Florence Avenue in Fresno. It does not reimburse the anxiety of a parent who finds out their neighborhood warehouse was keeping containers of ignitable, corrosive, reactive, and toxic waste without any of the regulatory oversight designed to prevent accidents. It does not restore the sense of security that comes from knowing the businesses in your community are following the rules that exist to keep you safe.
Fresno is a working-class city. The neighborhoods surrounding light-industrial corridors in Fresno are home to a disproportionate number of low-income residents and people of color who already contend with some of the worst air quality in the United States. The San Joaquin Valley sits in a geographic basin that traps pollution. Communities there have been fighting for clean air, clean water, and meaningful environmental enforcement for decades. The East Florence Avenue corridor is the kind of address where a company like Univar Solutions sets up a distribution facility: close to transportation routes, cheap enough for industrial use, and far from the zip codes where corporate executives live.
The permit system under RCRA is designed to provide a layer of enforceable protection between hazardous materials and the public. A permitted facility must meet specific standards for container integrity, labeling, emergency preparedness, and personnel training. Inspectors have a framework for evaluating compliance. In the absence of a permit, none of those standards are being actively monitored. The seven containers at the Univar Solutions Fresno facility sat outside that oversight structure for the better part of a year. During that time, if a container had failed, if a corrosive waste had leaked, if an ignitable material had sparked, there would have been no permit file for first responders to consult, no established emergency coordinator for the facility, no external regulatory check on what was stored and how.
The workers inside that warehouse deserve a place on this ledger. People who show up to a facility to do their jobs have a right to know what hazardous materials are present, how they are being stored, and whether proper safety protocols are in place. The RCRA permit system creates documentation, accountability, and training requirements that protect workers directly. A company operating an unpermitted hazardous waste storage situation is a company that has made a choice, implicitly or explicitly, to operate outside the safety framework that protects the people doing the physical work on site. The settlement document does not tell us whether any workers raised concerns, whether anyone internally flagged the violations, or whether the decision to let the waste accumulate without a permit was deliberate, negligent, or the result of a compliance function that nobody at the company was adequately staffed or empowered to run.
There is a specific kind of institutional betrayal embedded in this story. The federal government authorized California to run its own hazardous waste program precisely so that enforcement could be closer to the communities affected. California’s Hazardous Waste Control Law exists because the state decided its residents deserved robust, localized protection. The EPA’s role here is to backstop that state program and ensure federal RCRA compliance. That entire structure, built over decades of environmental advocacy and regulatory development, was quietly bypassed by a major chemical distributor that let hazardous waste sit in containers for ten months because the company apparently calculated that the risk of getting caught was acceptable.
And the calculation turned out to be correct. Univar Solutions paid $110,801. For a company operating at the scale of a global chemical distribution enterprise, that figure is a rounding error. The penalty was real; the deterrent is a question worth asking. The document notes that penalties are set in part to provide incentive for compliance. But incentive requires that the cost of violation exceed the cost of compliance. If compliance with RCRA storage permit requirements costs more than $110,801 per violation cycle, the math does not favor the public interest. The people of Fresno did not get to vote on that calculation. They simply lived with the results.
Legal Receipts: The Documents Speak
Every quote below is reproduced directly from the Consent Agreement and Final Order, U.S. EPA Docket No. RCRA-09-2025-0041, filed May 7, 2025. Nothing has been paraphrased. These are the words on record.
“Based on information gathered during the CEI, and additional information obtained subsequent to the CEI, EPA determined that from February 6, 2022—December 14, 2022, Respondent had stored seven (7) hazardous waste containers over the 90-day accumulation limit.” CA/FO Paragraph 24 — Docket No. RCRA-09-2025-0041
“At the time of the CEI, Respondent did not apply for or have a permit or grant of interim status to store hazardous waste under 22 C.C.R. § 66270.1 [see also 40 C.F.R. § 270.1].” CA/FO Paragraph 23 — Docket No. RCRA-09-2025-0041
“EPA alleges that by failing to satisfy the requirements of 22 C.C.R § 66262.34(a) [see also 40 C.F.R. § 262.17(a)], Respondent failed to meet the conditional requirements for permit exemption and therefore operated a hazardous waste management facility without a permit in violation of 22 C.C.R. § 66270.1 [see also 40 C.F.R. § 270.1].” CA/FO Paragraph 25 — Docket No. RCRA-09-2025-0041
“Respondent agrees to pay a civil penalty in the amount of ONE HUNDRED TEN THOUSAND EIGHT HUNDRED AND ONE DOLLARS ($110,801) (‘Assessed Penalty’) within thirty (30) calendar days of the Effective Date of this CA/FO.” CA/FO Paragraph 26 — Docket No. RCRA-09-2025-0041
“Complainant and Respondent agree that settling this action without the filing of a complaint or the adjudication of any issue of fact or law is in their respective interest and in the public interest.” CA/FO Paragraph 5 — Docket No. RCRA-09-2025-0041
“Respondent: (a) admits the jurisdictional allegations of this CA/FO; (b) neither admits nor denies specific factual allegations contained in this CA/FO; (c) consents to the assessment of any stated civil penalty, to the issuance of any specified compliance or corrective action order, and to any conditions specified in this CA/FO; and (d) waives any right to contest the allegations and its right to appeal the proposed final order accompanying this consent agreement.” CA/FO Paragraph 33 — Docket No. RCRA-09-2025-0041
“In executing this CA/FO, Respondent certifies under penalty of law to EPA that it has taken all steps necessary to return to full compliance with RCRA, 42 U.S.C. § 6901 et seq., and its implementing regulations.” CA/FO Paragraph 35 — Docket No. RCRA-09-2025-0041
“EPA alleges that Respondent did not meet the conditions for exemption under 22 C.C.R. § 66262.34(e) because Respondent stored waste in excess of the 55-gallon volume limitation for satellite area accumulation, Respondent did not accumulate waste at or near the point of generation, and with respect to at least one (1) container, Respondent did not comply with applicable labelling requirements.” CA/FO Paragraph 23, Footnote 3 — Docket No. RCRA-09-2025-0041
“Full compliance with this CA/FO shall only resolve Respondent’s liability for federal civil penalties for the violations specifically alleged herein and does not in any case affect the right of the EPA to pursue appropriate injunctive or other equitable relief or criminal sanctions for any violations of law.” CA/FO Paragraph 43 — Docket No. RCRA-09-2025-0041
“Nothing in this CA/FO shall constitute or be construed as a release from any other claim, cause of action or demand in law or equity by or against any person, firm, partnership, entity or corporation for any liability it may have arising out of or relating in any way to the generation, storage, treatment, handling, transportation, release, or disposal of any hazardous constituents, hazardous substances, hazardous wastes, pollutants, or contaminants found at, taken to, or taken from the Facility.” CA/FO Paragraph 45 — Docket No. RCRA-09-2025-0041
“This CA/FO shall apply to and be binding on Respondent, Respondent’s officers, directors, partners, agents, employees, contractors, successors and assigns. Action or inaction of any persons, firms, contractors, employees, agents, or corporations acting under, through, or for Respondent shall not excuse any failure of Respondent to fully perform its obligations under this CA/FO. Changes in ownership, real property interest, or transfer of personal assets shall not alter Respondent’s obligations under this CA/FO.” CA/FO Paragraph 6 — Docket No. RCRA-09-2025-0041
“Penalties, interest, and other charges paid pursuant to this Agreement shall not be deductible for purposes of federal taxes.” CA/FO Paragraph 32 — Docket No. RCRA-09-2025-0041
The Timeline of Non-Compliance
Source: U.S. EPA Docket No. RCRA-09-2025-0041, Paragraph 24. The compliance window (legal accumulation period) ended approximately May 7, 2022. Waste remained on-site an additional 7+ months before EPA inspection on December 14, 2022.
Societal Impact Mapping: The Ripple Effects Nobody Settled For
Environmental Degradation
The Fresno facility generated hazardous waste carrying codes D001, D002, D003, D005, and D035. Each of these categories represents a specific environmental threat profile. Ignitable wastes (D001) pose fire risk: if a container fails or is improperly handled, the resulting fire or explosion can release combustion byproducts, including toxic smoke, into the surrounding air. Corrosive wastes (D002) can degrade the structural integrity of storage containers themselves, raising the likelihood of a ground-level or below-grade leak that could contaminate soil. Reactive wastes (D003) are substances that can react violently under certain conditions, including exposure to water or heat, producing hazardous gases or triggering secondary fires.
The D005 (barium) code indicates the presence of materials that can leach barium into soil and groundwater. Barium contamination in drinking water is a serious concern regulated under the Safe Drinking Water Act because it can cause damage to the heart, blood vessels, and kidneys with chronic exposure. The D035 code for methyl ethyl ketone (MEK) indicates a solvent classified as hazardous due to its toxicity, flammability, and potential to contaminate groundwater. MEK volatilizes readily, meaning that even from improperly sealed containers, it can off-gas into ambient air inside an enclosed facility.
The source document confirms these materials were held in an unpermitted state for more than ten months. An unpermitted facility is not subject to the continuous regulatory scrutiny, container inspection schedules, and emergency preparedness infrastructure required of permitted storage facilities. Seven containers of materials spanning five distinct hazardous waste codes existed outside that protective system for the better part of a year. The source document does not record any release event or spill during this period, but the entire point of the permit system is prevention, and prevention was absent for more than 300 days.
Public Health
The California Air Resources Board consistently ranks the San Joaquin Valley Air Basin among the most polluted air sheds in the United States. Fresno County carries elevated rates of asthma hospitalization, cardiovascular disease, and respiratory illness compared to statewide averages. The communities surrounding industrial corridors in Fresno are among those most exposed to cumulative air toxics burdens. These existing vulnerabilities mean that any additional source of uncontrolled chemical exposure, including volatile organic compounds like MEK off-gassing from improperly managed containers, adds load to bodies already under strain.
Workers at the Univar Solutions Fresno facility represent the most directly exposed population. RCRA’s hazardous waste management framework requires that permitted facilities maintain training records, emergency coordinators, and documented safety protocols. Those requirements do not exist in a vacuum. They exist because repeated regulatory and academic research has confirmed that chemical workers face elevated risks of occupational illness when hazardous materials are not properly classified, stored, and managed. A company operating outside the permit system is a company where the regulatory check on worker safety compliance is structurally absent.
Beyond the facility walls, the general public near East Florence Avenue had no way of knowing that improperly stored ignitable, corrosive, and reactive materials were being held without regulatory oversight in a warehouse in their neighborhood. Environmental justice principles hold that communities must have meaningful access to information about industrial hazards affecting them. The permit system is one of the mechanisms that creates a public record of what is stored, where, and under what conditions. Operating outside that system denied the surrounding community the transparent information to which they are entitled under the law that Univar Solutions was found to have violated.
Economic Inequality
The $110,801 fine resolves this case. For Univar Solutions, a company that operates at a global scale across the chemical distribution industry, that figure represents a fraction of one percent of meaningful operational expenditure. The alternative, obtaining and maintaining a proper hazardous waste storage permit, carries its own costs: application fees, compliance infrastructure, ongoing inspection readiness, and documented training programs. The enforcement structure revealed by this settlement raises a direct question about whether the penalty is calibrated to create genuine deterrence or whether it functions as a de facto licensing fee for non-compliance.
Economic inequality in environmental enforcement is a documented pattern in the United States. Facilities located in wealthier, predominantly white communities tend to receive faster regulatory response and steeper penalties, as studies by environmental justice researchers have documented over decades. Fresno’s East Florence Avenue is not that neighborhood. The surrounding population carries disproportionate economic vulnerability alongside its environmental burden. When regulatory fines are set at levels a company’s legal department can process as a cost of doing business, the communities absorbing the environmental risk of that non-compliance are subsidizing corporate savings with their health and their safety.
The settlement structure itself encodes economic inequality. Univar Solutions has the legal resources to negotiate a Consent Agreement and Final Order, to engage in months of administrative proceedings, to neither admit nor deny facts while simultaneously certifying compliance, and to pay $110,801 without meaningful financial distress. A small business owner in Fresno who accumulated hazardous waste past the 90-day limit would face the same regulatory penalty structure but without the legal infrastructure to navigate it favorably. The gap between how corporate entities and individual residents experience environmental enforcement is a gap that benefits well-resourced companies at the expense of the communities they operate in.
The “Cost of a Life” Metric
The total civil penalty Univar Solutions agreed to pay for operating an unpermitted hazardous waste facility for over 10 months in a community already burdened by some of the worst air quality in the United States.
What this number means in human terms:
The U.S. EPA’s own regulatory analysis typically uses a “Value of a Statistical Life” (VSL) figure of approximately $11.6 million when calculating the benefits of environmental regulations. At that benchmark, the fine paid here represents less than 1% of one statistical life in regulatory value. Expressed differently: the fine amounts to roughly $293 per day of illegal storage across the 377-day violation period. The daily cost to Univar Solutions of non-compliance was lower than the daily rate of many basic business services. The people of Fresno paid the difference in environmental risk.
Note: EPA VSL benchmark referenced from standard regulatory impact analysis methodology. The $293/day figure is derived from $110,801 divided by 377 days (Feb 6 to Dec 14, 2022) as documented in the source.
What Now? Who Answers for Fresno
Corporate Roles on Record (Named in Source Document)
- Ryan Barker — Listed as Respondent contact for Univar Solutions, 4465 East Florence Ave, Fresno, CA 93725 (Certificate of Service)
- Amy C. Miller-Bowen, Director — Enforcement and Compliance Assurance Division, U.S. EPA Region IX (signed for Complainant)
- Beatrice Wong, Regional Judicial Officer — U.S. EPA Region IX (issued the Final Order)
- Daniel Fernandez — Enforcement and Compliance Assurance Division, EPA Region 9 (enforcement contact)
- Laura Friedli, Assistant Regional Counsel — U.S. EPA Region IX, Hazardous Waste Section I (legal counsel for Complainant)
- Ponly Tu, Regional Hearing Clerk — U.S. EPA Region IX (filed and certified the document, May 7, 2025)
Note: The source document does not name Univar Solutions board members, C-suite executives, or facility managers beyond Ryan Barker. Corporate leadership names above that level are [REDACTED – Not in Source].
Regulatory Watchlist: Bodies With Jurisdiction
- U.S. EPA Region IX — Primary enforcer; signed this settlement. Monitor their public enforcement actions database at epa.gov for future Univar filings.
- California Department of Toxic Substances Control (DTSC) — California’s state-level hazardous waste enforcement body. File public information requests for inspection records of the Fresno facility.
- California Air Resources Board (CARB) — Regulates air toxic emissions, including VOCs like MEK, in the San Joaquin Valley.
- San Joaquin Valley Air Pollution Control District (SJVAPCD) — Regional air quality authority with enforcement jurisdiction over Valley industrial facilities.
- Occupational Safety and Health Administration (OSHA) — Jurisdiction over worker safety at the facility. Hazardous waste storage practices directly implicate worker protection standards.
- U.S. DOJ Environment and Natural Resources Division — The settlement reserves EPA’s right to refer criminal sanctions for violations of law. DOJ is the body that would pursue such referrals.
What You Can Do Right Now
- Search the EPA’s ECHO (Enforcement and Compliance History Online) database at echo.epa.gov for the Facility ID CAD981382849 to see the full compliance history of the Fresno site.
- Contact the California DTSC at dtsc.ca.gov to request public records on inspection history for Univar Solutions Fresno.
- Connect with local environmental justice organizations in Fresno and the San Joaquin Valley, including the Central California Environmental Justice Network (CCEJN), who have been fighting for accountability in this air basin for years.
- Attend public comment periods for EPA RCRA enforcement policy. The size of penalties in consent agreements is subject to policy decisions that the public has the right to challenge on the record.
- Support mutual aid networks in Fresno that are doing the on-the-ground work: food security, health access, and environmental monitoring in communities that regulatory settlements don’t reach.
- Share this article. The settlement was public record the day it was filed. Sunlight is the one resource regulators cannot manufacture.
The source document for this investigation is attached below.
Please visit this link on the EPA’s website to read the Consent Agreement between the EPA and Univar Solutions LLC: https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/E180AF2CAEE87E3585258C850006E1D4/$File/Univar%20Solutions%20USA%20LLC%20(RCRA-09-2025-0041)%20-%20Filed%20CAFO.pdf
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