How Miller Products Polluted, Endangered Workers, and Faced Zero Fines

A Factory Full of Hazardous Waste and Zero Accountability

Miller Products Company operates a contract screw machine shop and non-threaded fastener manufacturer out of 1015 N. Main Street, Osceola, Iowa. The company employs approximately 38 people and has been registered with the EPA as a hazardous waste generator since February 12, 1997. That is nearly three decades of knowing the rules exist.

On November 15, 2023, EPA inspectors showed up for a compliance check. What they found was not a minor clerical error or a paperwork gap. Inspectors documented a pattern of hazardous waste mismanagement that touched nearly every basic safety requirement on the books: storage time limits, container labeling, container closures, weekly inspections, emergency equipment, and employee training.

The waste in question includes what the documents describe as waste filter cake sludge classified as D007, a designation that means it contains chromium, a toxic heavy metal linked to cancer, kidney damage, and respiratory disease. This was sitting in open, unlabeled containers inside a facility with 38 workers who, by the EPA’s own findings, were not fully trained on what to do if something went wrong.

The Violations Were Systematic, Not Accidental

The EPA’s Consent Agreement and Final Order lays out the violations in clinical, bureaucratic language that obscures how reckless the underlying conduct actually was. Stripped of the legal framing, the picture is clear: Miller Products accumulated hazardous waste far longer than the law allows, stored it improperly, labeled almost none of it, inspected none of it on schedule, and left workers with no way to call for emergency help.

The company later transported those containers to a treatment, storage, and disposal facility more than 200 miles away — which is exactly what the law required them to do in the first place, before the deadline, with proper labels on every container. They did it only after federal inspectors forced their hand.

What 38 Workers Faced Every Single Day

Thirty-eight people showed up to work at Miller Products Company’s Osceola, Iowa facility every day. They ran screw machines and manufactured fasteners. They also worked in a building where containers of chromium-classified toxic waste sludge sat unlabeled, some open, some accumulating for more than 270 days. Not one of those containers told a worker what was inside or how dangerous it was.

Federal regulations require hazardous waste containers to be marked with three specific pieces of information: the words “Hazardous Waste,” an indication of the specific hazard (ignitable, corrosive, reactive, toxic), and the date accumulation began. The EPA inspector found that six containers at Miller Products had none of those three things. That means any worker who walked past those containers, knocked one over, or inadvertently came into contact with a leak had no way of knowing what they were dealing with.

The law also requires that every area where hazardous waste is generated or stored have a working device — a phone or a two-way radio — capable of summoning emergency help from police, fire departments, or emergency response teams. Miller Products had no such device at its central accumulation area. If a container ruptured, if someone was exposed, if a fire started — workers had no immediate way to call for help from the place where the danger lived.

That sentence from the official record is written in the dry, non-committal language of a government document. Translated into plain English: the people most likely to be exposed to toxic waste at this facility were the least equipped to recognize the danger or respond to it. Training on hazardous waste handling and emergency procedures is a legal requirement, not a bonus. Miller Products did not provide it fully to all its workers.

There is a particular kind of betrayal embedded in this situation. These are workers who trusted that their employer had met basic legal obligations to keep them safe. They were not told that the company was operating without a valid permit to store hazardous waste. They were not told that the containers near their workstations had been sitting there, accumulating toxic material, for nearly a year without being sent away for proper disposal. The company’s own signed settlement document states that it “neither admits nor denies” the specific factual allegations — a legal hedge that translates, in the real world, to their workers never getting a straight answer.

The D007 waste classification is not an abstraction. Chromium in its hexavalent form — the kind that shows up in industrial waste streams like the one produced at screw machine shops — is a known human carcinogen. Exposure through skin contact, inhalation of dust, or ingestion causes cancer, liver damage, kidney damage, and severe respiratory disease. Workers who were never told what was in those containers, who were never trained on what to do if something went wrong, and who had no emergency device to call for help, were the people most directly at risk from every single day this company remained out of compliance.

The Documents Don’t Lie. Read Them Yourself.

“At the time of the Inspection, the inspector observed four hazardous waste accumulation containers with accumulation start dates more than 180 days prior to the Inspection, one of which had an accumulation start date more than 270 days prior to the date of the Inspection.” — EPA Consent Agreement and Final Order, Paragraph 33

“At the time of the Inspection, the inspector observed that the Facility had six hazardous waste accumulation containers holding waste filter cake sludge (D007) that were not labeled with: 1) the words ‘hazardous waste’; 2) an indication of the nature of the hazard; and 3) the accumulation start date.” — EPA Consent Agreement and Final Order, Paragraph 41

“At the time of the Inspection, the Facility had not provided a working device for summoning emergency assistance at its central accumulation area.” — EPA Consent Agreement and Final Order, Paragraph 43

“Respondent has demonstrated that it is unable to pay any of the penalty in this matter. Because of Respondent’s inability to pay the penalty, therefore, Complainant conditionally agrees to resolve the claims alleged herein without payment of a civil penalty.” — EPA Consent Agreement and Final Order, Paragraph 61

“EPA reserves the right to enforce the terms and conditions of this Consent Agreement and Final Order by initiating a judicial or administrative action under Section 3008 of RCRA, 42 U.S.C. § 6928, and to seek penalties against Respondent in an amount not to exceed Seventy Thousand Seven Hundred Fifty-Two Dollars ($70,752) per day, per violation.” — EPA Consent Agreement and Final Order, Paragraph 66

This Is Bigger Than One Factory in Iowa

Public Health: The Body Count Nobody Tallied

The hazardous waste at Miller Products carried a D007 designation, meaning it contains chromium at concentrations high enough to require federal regulation. Chromium contamination does damage in multiple exposure pathways: skin contact causes ulceration and dermatitis; inhalation causes lung cancer and respiratory scarring; ingestion causes gastrointestinal damage, kidney failure, and liver disease. The World Health Organization classifies hexavalent chromium as a Group 1 carcinogen — the highest possible danger designation.

The company stored this material in open, unlabeled containers for more than 270 days. Workers who were acknowledged by the EPA to be undertrained on waste handling worked near this material daily. The settlement document does not assess whether any workers developed symptoms, sought medical treatment, or were injured. The EPA’s consent agreement process settled the violations and moved on, with zero requirement that Miller Products conduct worker health assessments or notify employees of their potential exposure.

The lack of a mandatory health evaluation for the 38 workers is a gap the government chose not to address. There is no mechanism in this settlement that tells a worker whether they were exposed, for how long, or at what level. Those workers are left to figure that out themselves, assuming they even know this enforcement action exists.

Environmental Degradation: What Leaks Don’t Announce Themselves

The EPA’s own regulations define disposal to include “the discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid waste or hazardous waste into or on any land or water so that such solid waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters, including ground waters.” The company stored containers of chromium waste without the weekly inspections the law requires to catch exactly this kind of slow-motion contamination event.

The facility sits at 1015 N. Main Street in Osceola, Iowa, a small city of roughly 4,600 people. The EPA inspection found containers that had been sitting uninspected for more than nine months. The settlement does not include any soil or groundwater sampling requirement to determine whether any of that material migrated into the surrounding environment during the period of non-compliance. The EPA reserved the right to act if it finds an “imminent and substantial endangerment,” but made no affirmative requirement to look for one.

Iowa sits over the Des Moines Lobe aquifer system and drains into the Missouri River basin. Chromium contamination in soil migrates slowly but persistently into groundwater, where it remains for decades and travels far beyond the original contamination point. The failure to require environmental sampling as part of this settlement means the surrounding community in Osceola has no official data confirming their groundwater is clean.

Economic Inequality: Who Really Pays When Companies Claim Poverty

The law allows the EPA to fine companies like Miller Products up to $124,426 per day per violation ($124,426 per day, enough to cover the average American worker’s full annual salary multiple times over). The EPA’s own civil penalty policy lists “inability to pay” as a mitigating factor — and Miller Products invoked it. The agency accepted their claim and walked away from every dollar of the fine.

This is the economic inequality baked into the system. A corporation that mismanages toxic waste, endangers its own workers, and operates without a permit for years can wipe out its entire legal liability by demonstrating it does not have the cash to pay. Meanwhile, any worker at that facility who developed a health condition linked to chromium exposure faces the full financial weight of the American healthcare system with no recourse from this settlement. The company escapes the bill. The workers do not.

The inability-to-pay provision was designed for genuine hardship cases. It was not designed to allow a company operating for decades to accumulate violations, get caught, plead poverty, and continue operations as if nothing happened. The EPA’s own reservation of rights language acknowledges it can still pursue criminal sanctions and injunctive relief if future violations occur — but the baseline penalty for what already happened is zero. There is no deterrent in a zero-dollar settlement for any other small manufacturer watching this case.

The Math They Don’t Want You to Do

The maximum penalty for violations occurring after November 2, 2015 and assessed on or after January 8, 2025 is $124,426 per day ($124,426 per day, enough to fully fund the average American worker’s wages for roughly three years). The company stored hazardous waste in violation of the law for at least 90 days beyond the legal limit. Multiply those numbers and you begin to understand the scale of liability that was simply erased from the ledger.

Who to Watch and What to Demand

The contact identified in this case as Respondent’s representative is Kerry Richardson at Miller Products Company, reached at the email address documented in the settlement. The settlement is binding on the company, its agents, successors, and assigns.

Regulatory Bodies With Jurisdiction Right Now

• EPA Region 7 : The agency that issued this order. They can pursue criminal sanctions and injunctive relief for any future non-compliance. Contact them to confirm Miller Products is complying with the settlement terms.
• Iowa Department of Natural Resources : Copied on this settlement. Ed Tormey (Acting Administrator, Environmental Services Division) and Mike Sullivan (Chief, Contaminated Sites Section) are on record. Iowa DNR has independent authority to act.
• OSHA : Worker safety during hazardous waste handling falls under OSHA jurisdiction. The undertrained workers and missing emergency equipment at Miller Products are potential OSHA violations independent of this EPA settlement.
• EPA Criminal Investigation Division : The EPA explicitly reserved the right to pursue criminal sanctions. Operating an unlicensed hazardous waste facility can carry criminal penalties under RCRA.

The Move From Here

File a public records request with EPA Region 7 for the full inspection report from the November 15, 2023 inspection — the source document attached to this article is the settlement, but the underlying inspection report contains the inspector’s firsthand observations and may contain additional detail not captured here. Iowa residents can also contact the Iowa DNR directly to ask whether the state is conducting independent follow-up.

If you work in a facility that generates or stores hazardous waste and you have never received formal training on waste handling and emergency procedures, that is a federal violation your employer is committing right now. Reach out to your regional OSHA office, contact a workers’ rights organization in your area, and connect with the Environmental Justice organizations active in Iowa, including Iowa Citizens for Community Improvement (Iowa CCI), who have long tracked industrial pollution’s disproportionate impact on rural and working-class communities. You have the right to a safe workplace. That right does not disappear because your employer claims they cannot afford to honor it.