The Non-Financial Ledger

A 55-gallon drum filled with waste paint material sat in the production area of a manufacturing plant in Waterloo, Iowa. No label. No date. No indication of what was inside or how dangerous it was. The person walking past it every day to do their job had no way of knowing how long it had been sitting there, what it contained, or what to do if it caught fire.

This is not a hypothetical. EPA inspectors documented this exact drum during their two-day inspection in July 2024. The facility had filled it roughly two weeks before the inspection and still had not labeled it with a basic accumulation start date, a legal requirement designed to prevent hazardous waste from sitting forgotten and untracked in a production environment for months or years.

The workers at CPM Waterloo did not choose to work around unlabeled hazardous waste. They showed up. They did their jobs. And at some point during a shift, someone was handling a container that offered them no information about the chemical they were exposed to. No hazard pictogram. No signal word. No indication of whether the contents were ignitable, corrosive, reactive, or toxic. Three containers with hazardous waste were found missing all of those warnings at once.

Hazardous waste labeling rules exist because of the people who learned the hard way what happens when they do not. Workers who developed chemical burns from unlabeled corrosives. First responders who walked into chemical fires without knowing what they were fighting. Communities that discovered their groundwater was contaminated because nobody tracked where the drums went.

The $12,500 penalty CPM agreed to pay does not compensate a single worker for the risk they absorbed. It does not fund medical monitoring. It does not go to the community of Waterloo. It goes to the United States Treasury. The settlement agreement is explicit: CPM neither admits nor denies the factual allegations. The violations are documented. The accountability is minimal. The workers absorbed the cost with their bodies.

Legal Receipts: What the Documents Actually Say

The following are direct quotations from the EPA Expedited Settlement Agreement and Final Order, Docket No. RCRA-07-2025-0206, filed September 22, 2025.

“During the RCRA inspection, the inspector documented that the Facility was a small quantity generator, and that the Facility failed to obtain an EPA identification number from the Administrator prior to the four offsite shipments of hazardous waste.”

“During the RCRA inspection, the inspector documented that the Facility used bills of lading for four offsite hazardous waste shipments and therefore failed to prepare the required Manifests for these four offsite shipments of hazardous waste.”

“During the RCRA inspection, the inspector observed three hazardous waste storage containers that the Facility had failed to properly label with the words, ‘Hazardous Waste.'”

“During the RCRA inspection, the inspector observed a full 55-gallon container of waste paint related material in the paint operations area that the Facility had failed to label with an accumulation start date. The Facility had filled this container approximately two weeks prior to the RCRA inspection.”

“Full payment of the civil penalty shall only resolve Respondent’s liability for federal civil penalties for the violations alleged herein. The EPA reserves the right to take any enforcement action with respect to any other past, present, or future violations of RCRA or any other applicable law.”

Societal Impact Mapping

Public Health

Unlabeled hazardous waste containers and missing Manifests are direct threats to the people who live and work near industrial facilities. Here is what the documented violations mean for human health.

• Three containers storing hazardous waste materials lacked any indication of their contents’ hazard characteristics. Workers handling, moving, or accidentally contacting those containers had no warning of whether they were dealing with flammable, corrosive, reactive, or toxic materials.
• A full 55-gallon drum of waste paint material in the active production area carried no accumulation start date. Waste paint products can contain heavy metals including lead and chromium, as well as volatile organic compounds; without tracking when accumulation began, there is no mechanism to prevent the material from sitting on-site past legal time limits and degrading into a more hazardous state.
• Two used oil containers were not labeled “Used Oil.” Used oil can contain heavy metals and toxic additives from its use in industrial machinery. Workers who cannot identify used oil by its container label cannot apply proper handling procedures, and emergency responders face unknown hazards if a spill or fire occurs.
• Four hazardous waste shipments left the facility without EPA Manifests. Without Manifests, there is no documented confirmation that those shipments reached a licensed disposal facility. Improperly disposed hazardous waste is a primary vector for soil and groundwater contamination that affects communities for decades.

Economic Inequality

The economics of environmental non-compliance fall heaviest on working-class communities and the workers inside these facilities, while the costs to corporations remain minimal.

• The $12,500 civil penalty is the entire financial consequence CPM faces for six documented RCRA violations, including four untracked hazardous waste shipments. For a company operating an industrial manufacturing facility, this amount is a rounding error in annual operating costs.
• The workers at the CPM Waterloo facility absorb the actual risk. They are the people who walk past unlabeled drums, who handle containers without knowing whether the contents are ignitable or toxic. The settlement provides them nothing: no medical monitoring, no hazard pay, no remediation fund.
• The $12,500 penalty is not tax-deductible for CPM. The settlement agreement makes this explicit. But it is also not directed to the community of Waterloo, Iowa. It goes to the U.S. Treasury, where it is indistinguishable from any other federal revenue.
• The penalty structure for small quantity generator violations creates a predictable cost-benefit for corporations: the fine for getting caught is far lower than the cost of full compliance infrastructure. This financial asymmetry is a structural incentive for non-compliance, and it is working-class workers and communities that bear the resulting risk.

The “Cost of a Life” Metric

What Now?

CPM Waterloo has certified compliance as of the settlement signing, but the EPA reserves the right to pursue any additional violations. Here is who is accountable and where pressure can be applied.

Key Signatories on the Settlement

• Sean M. Callison, Secretary and General Counsel, CPM, Waterloo: Signed the settlement agreement on behalf of the company on September 4, 2025.
• Jeremy Jones, Environmental Health and Safety Specialist, CPM, Waterloo: Named in the certificate of service as the respondent contact; received the filed ESA at jeremy.jones@cpm.net.
• David Cozad, Director, EPA Region 7 Enforcement and Compliance Assurance Division: Approved the agreement on September 12, 2025.
• Karina Borromeo, Regional Judicial Officer: Signed the Final Order filed September 22, 2025.

Watchlist: Regulatory Bodies with Ongoing Jurisdiction

• EPA Region 7: Retains authority to take enforcement action on any past, present, or future RCRA violations not covered by this settlement. Contact: R7_Hearing_Clerk_Filings@epa.gov.
• Iowa Department of Natural Resources: Received notice of these violations per RCRA Section 3008(a)(2). Iowa DNR’s Environmental Services Division (Ed Tormey, Administrator) and Solid Waste and Contaminated Sites Section (Mike Sullivan, Section Supervisor) are copied on this case. Iowa DNR can pursue parallel state enforcement actions.
• OSHA (Occupational Safety and Health Administration): Worker exposure to unlabeled hazardous materials is a parallel OSHA Hazard Communication Standard violation. OSHA Region 7 covers Iowa and can investigate independently of EPA.

What You Can Do

• If you work at or near the CPM Waterloo facility at 4050 Leversee, Waterloo, Iowa, you have the right to request the EPA inspection report through a Freedom of Information Act (FOIA) request to EPA Region 7 to understand the full scope of what was documented.
• Connect with Iowa Citizens for Community Improvement (Iowa CCI), a grassroots organization with a track record of holding industrial polluters accountable in Iowa communities. They have existing relationships with state regulators.
• Workers at the facility can file confidential complaints with OSHA Region 7 regarding hazardous material handling conditions. OSHA complaints from workers carry independent investigative authority separate from the EPA action.
• Contact the Iowa DNR directly at ed.tormey@dnr.iowa.gov or michael.sullivan@dnr.iowa.gov to ask what, if any, state-level enforcement action Iowa is pursuing in parallel with the EPA settlement.
• The settlement is now public record. Share it. Workers in Waterloo have a right to know that their facility was cited for six hazardous waste violations and that the financial consequence was $12,500.