Eleven Violations. One Inspection. One Day.

On August 6, 2024, EPA inspectors walked into Westak of Oregon’s facility at 3941 24th Avenue, Forest Grove, Oregon, and found a hazardous waste management program in near-total collapse. The company operates as a Large Quantity Generator of hazardous waste, a designation that comes with strict federal obligations designed specifically to protect workers and the surrounding community.

What inspectors found instead: open drums of hazardous waste, unlabeled containers holding toxic electroplating sludge, a pile of unidentified white powder on the floor around a container with warning labels on it, and four steel drums of used oil sitting without any required labeling. These are the basics. These are the minimum standards. Westak failed all of them simultaneously.

The violations span four separate federal regulatory frameworks: hazardous waste determination, Large Quantity Generator accumulation requirements, used oil generator rules, and universal waste management. Eleven discrete failures, all in one building, all on one afternoon.

White Powder on the Floor, Open Drums, No Answers

The most alarming single image in the EPA’s report is not a legal technicality. Inspectors documented an accumulation of white powder on the floor of the facility, around the open base of a container bearing multiple warning labels. Westak had not determined whether that powder was hazardous waste. It was sitting there, on the floor, in a facility where workers walk every day.

The EPA found two containers of hazardous waste sitting open with no active operations occurring, directly violating the requirement that such containers remain sealed at all times unless waste is actively being added or removed. Two additional cubic yard containers holding dewatered electroplating sludge lacked any “Hazardous Waste” labeling at all.

A third container of that same toxic sludge had no accumulation start date marked on it, meaning no one could legally confirm how long it had been sitting there, building up. The rules exist because time limits on hazardous waste storage are a safety mechanism, not a paperwork ritual.

The Non-Financial Ledger

What You Can’t Put a Dollar Amount On

The legal document in this case is precise about chemicals and containers. It is silent about the people who work the floor at 3941 24th Avenue every day. But the violations documented by the EPA paint a detailed picture of what those workers were exposed to, and what protections they were quietly denied.

Start with the eyewash station. Regulations require large quantity hazardous waste generators to test and maintain decontamination equipment to assure its proper operation in time of emergency. The EPA found a card on the eyewash station at the Westak facility recording that the last test had occurred in December 2023, more than eight months before the August 2024 inspection. An eyewash station is what a worker runs to when a chemical splashes in their face. It is the difference between a few minutes of discomfort and permanent eye damage. Westak’s workers had been operating for eight months without any confirmed assurance that this equipment actually worked.

The training failures compound this betrayal. Federal law requires large quantity generators to maintain written records of every employee working with hazardous waste: their job title, their name, a written description of their duties, and documentation of the specific training required for their role. The EPA found that Westak’s training program “lacked the specific items above and did not maintain records of the title, description, and name of the employee in each job related to hazardous waste, or provide a description of the training needed for those positions.” These workers were handling toxic electroplating byproducts. The company did not document what training they received to do it safely. The absence of that paperwork means there is no way to verify whether they received any adequate training at all.

Then there is the contingency plan. Every large quantity generator must maintain an emergency response plan that includes the location, physical description, and capabilities of every piece of spill control equipment on site. Westak had spill kits on site. Staff acknowledged this to inspectors. The contingency plan made no mention of them whatsoever. If a chemical spill had occurred, anyone consulting the emergency plan to find the spill kit would have found nothing. The plan was effectively useless for the specific emergency scenario of a hazardous material release, which is the entire reason you have a plan in a facility like this one.

And finally: three fiberboard boxes of universal waste lamps, each labeled with an accumulation start date, each exceeding the one-year legal limit for on-site storage. Universal waste lamps frequently contain mercury. The one-year rule exists because the longer they sit, the greater the risk of breakage, leakage, and worker exposure. Westak let all three boxes exceed that limit. The workers on that floor breathed the same air as those containers every single shift.

None of this makes headlines the way an explosion does. None of this produces a single dramatic moment that ends up in the news. This is the slow, grinding, daily variety of corporate negligence, where workers are systematically deprived of the protections they are legally owed, one expired test card and one missing label at a time. The $20,000 (roughly five months of a single median American worker’s wages) that Westak paid to close this case does not compensate a single person for any of it.

Legal Receipts: Straight From the Document

These Are the EPA’s Own Words

Violation “The EPA inspector observed that Respondent did not determine if a solid waste, in the form of an accumulation of white powder on the floor of the site, around the open base of a container bearing multiple warning labels, was also a hazardous waste at the point of generation.” EPA Docket No. RCRA-10-2025-0070 — Paragraph 3(a)

Violation “During EPA’s inspection, an eye wash station was observed with an attached card recording the date the equipment was tested. The card recorded the last test date of the eye wash as occurring in December, 2023, or more than eight months prior to the inspection. Failing to inspect the operation of all decontamination equipment, including the observed eye wash station, marks a failure to meet the requirements found at 40 C.F.R. § 262.34(a)(4).” EPA Docket No. RCRA-10-2025-0070 — Paragraph 3(b)(vi)

Violation “While reviewing the Facility’s contingency plan, it was observed that the plan failed to include any mention of spill control equipment (spill kits) even though site staff acknowledged they kept such equipment on-site for emergency (spill) response.” EPA Docket No. RCRA-10-2025-0070 — Paragraph 3(b)(iv)

Violation “During EPA’s inspection and reviewing the Facility’s training program, it was observed the training program materials submitted lacked the specific items above and did not maintain records of the title, description, and name of the employee in each job related to hazardous waste, or provide a description of the training needed for those positions.” EPA Docket No. RCRA-10-2025-0070 — Paragraph 3(b)(v)

Settlement “In signing this Agreement, Respondent: (1) admits that Respondent is subject to RCRA and its implementing regulations; (2) admits that EPA has jurisdiction over Respondent and Respondent’s conduct as alleged herein, (3) neither admits nor denies the factual allegations contained herein; (4) consents to the assessment of this penalty.” EPA Docket No. RCRA-10-2025-0070 — Paragraph 5

That third item in paragraph 5 is where corporate accountability goes to die. The EPA documents eleven violations in precise regulatory detail. Westak signs the check. Westak neither admits nor denies any of it. The record is sealed as “settled.” No admission. No accountability. No public reckoning. The VP of Operations, Andrew J. Takle, signed his name to this arrangement on May 30, 2025.

Societal Impact Mapping

Environmental Degradation

Westak of Oregon operates as a Large Quantity Generator of hazardous waste from on-site electroplating operations. Electroplating waste is serious business: the process generates heavy metal-laden sludges and liquid waste streams containing compounds like chromium, nickel, and cyanide, all of which appear on federal hazardous waste lists for a reason. The dewatered wastewater treatment sludges found in the unlabeled and improperly dated containers at the Westak facility are the direct byproduct of this process.

The white powder found accumulating on the floor of the facility around a warning-labeled container represents an uncontrolled release of an unidentified substance in a hazardous waste generation environment. Westak did not test or characterize that powder. That failure to determine hazardous waste status at the point of generation is precisely how low-level environmental contamination spreads undetected, through floor drains, on boot soles, into air currents, and eventually into soil and water.

Three boxes of mercury-containing universal waste lamps exceeded the one-year storage limit, increasing the risk of container degradation and mercury release inside the facility. Mercury does not stay in one place. It volatilizes. It moves through air. It bio-accumulates in ecosystems and human bodies over decades. The one-year rule exists specifically to prevent this slow-motion contamination from becoming a permanent problem.

Public Health

The workers inside Westak’s Forest Grove facility are the most direct victims of every violation documented in this report. They work in close proximity to open containers of hazardous electroplating sludge. They walk past unidentified white powder accumulating on the floor. They share air with mercury-containing lamps stored past their legal limits. They rely on an eyewash station that nobody tested for eight months.

The training program failures carry a specific and chilling implication: because Westak did not maintain records documenting who was trained on hazardous waste handling and what that training covered, there is no paper trail confirming whether adequate training actually occurred. When a chemical splash happens, or fumes build up, or a container leaks, a worker who has not been properly trained will not know the correct response. They may make it worse. They may be injured more severely. This is the direct, predictable, documented consequence of the failures the EPA found.

Forest Grove is a community of roughly 25,000 people. It sits in Washington County, one of the most densely populated counties in Oregon. An uncontrolled release of electroplating waste from a Large Quantity Generator in that context is a community health event, not a contained industrial incident. The regulations Westak violated are the barrier between the facility fence line and the public. When those barriers fail systematically and simultaneously, the community absorbs the risk.

Economic Inequality

The $20,000 fine (roughly the cost of a used Honda Civic, or about five months of income for an American earning the median wage) resolves eleven federal violations spanning four regulatory categories. It does so without requiring any admission of wrongdoing from Westak. The workers whose safety was compromised receive nothing from this settlement. There is no restitution mechanism in this agreement. There is no fund for medical monitoring of employees who worked near improperly stored hazardous materials.

Paragraph 12 of the settlement even specifies that Westak cannot claim the $20,000 as a tax deduction. That is the extent of the financial consequence. For a company operating as a Large Quantity Generator of hazardous waste with a full industrial electroplating operation, $20,000 is a rounding error in an annual compliance budget. The EPA’s own penalty worksheet, incorporated by reference into this agreement, produced that number after applying the statutory factors under RCRA.

The economic structure here is straightforward: the cost of compliance (proper labeling, testing equipment, training records, contingency plans) is higher than the cost of getting caught failing to comply. When fines are this small and admissions are not required, non-compliance becomes a rational financial calculation. The workers on the floor of that facility do not have the option of calculating the cost of their own exposure the same way.

The “Cost of a Life” Metric

What Now?

Who Signed It, Who Oversees It, and What You Can Do

Andrew J. Takle, VP of Operations at Westak of Oregon, signed the settlement agreement on May 30, 2025. His digital signature and email address (atakle@westak.com) are on the public record. The settlement was finalized by EPA Region 10 Enforcement and Compliance Assurance Division Director Edward J. Kowalski on June 9, 2025.

Regulatory Watchlist: These agencies have ongoing jurisdiction here.

• EPA Region 10 (Pacific Northwest): Primary enforcement authority under RCRA for hazardous waste violations at this facility. File public comments on settlement adequacy.
• Oregon Department of Environmental Quality (DEQ): Received statutory notice of these violations as required by law. Oregon DEQ holds concurrent state-level authority.
• OSHA (Occupational Safety and Health Administration): Worker training failures and untested emergency equipment are OSHA territory. File a confidential worker complaint at osha.gov.
• EPA RCRA Hotline and Tip Line: Report ongoing violations or non-compliance after settlement at epa.gov/enforcement.
• Oregon OSHA: State-level worker safety agency with independent jurisdiction over workplace hazard conditions described in this investigation.

The Ground Game

Forest Grove workers and Washington County residents have more power than a $20,000 fine suggests. Connect with Oregon environmental justice organizations like Neighbors for Clean Air or the Columbia Riverkeeper, both of which monitor industrial polluters in the Pacific Northwest. Talk to your coworkers. OSHA complaints can be filed confidentially. Oregon DEQ accepts public input on enforcement actions. A company that receives a visit from regulators after community pressure behaves differently than one that only hears from the EPA once a decade. Mutual aid starts with knowing what is happening in your neighborhood, and now you know.