Hazardous Waste / Environmental Enforcement / Workers’ Rights

How Arcos Industries Dodged Hazardous Waste Law for Years

A weapons manufacturer supplying the U.S. military went five consecutive years without training a single employee on how to safely handle the flammable solvents, caustic chemicals, and toxic sludge they worked around every single day.

Arcos Industries, LLC makes welding and soldering consumables at its plant in Mount Carmel, Pennsylvania. Its customers include the U.S. military and the auto industry. Behind those polished government contracts, federal regulators found a facility running on hazardous waste management that was broken at every level: unlabeled containers, tanks without safety barriers, inspections that never happened, and nearly half a decade of workers left completely in the dark about the toxic materials surrounding them.

The EPA’s Region 3 enforcement office formally settled seven separate violations against Arcos through a Consent Agreement and Final Order filed September 29, 2025. The company paid $141,778 (roughly what it costs to buy one mid-range SUV, or about what a Pennsylvania teacher earns in three years) to close the matter without admitting or denying the facts.

This is a document-by-document account of what regulators actually found.

Seven Violations, Zero Excuses

EPA inspectors spent two days inside the Arcos facility on September 27 and 28, 2022. What they documented across seven formal counts paints a picture of a company that treated federal hazardous waste law as optional. Each violation below carried its own separate penalty exposure under the Resource Conservation and Recovery Act (RCRA), the federal law meant to ensure toxic industrial waste does not poison workers, communities, or the ground beneath them.

The Full Count: Seven Ways Arcos Broke the Law

The violations did not cluster around one bad month or one bad manager. They stretch across multiple systems, multiple years, and multiple legal obligations. This is a pattern of systemic non-compliance by a company that knew exactly what the rules were and chose, repeatedly, not to follow them.

The Timeline They Hoped You Would Never See

The violations documented by the EPA did not start with the 2022 inspection. Many of them began years earlier, and several continued for years after inspectors came and went. The chart below maps the documented start and end dates of each active violation period according to the EPA’s own findings.

The inspection happened in 2022. Six violations were simultaneously active on that date. But three of those violations kept running for two more years after inspectors left the building. A company that gets caught breaking the law and still does not fully fix the problem for another three years is not making an honest mistake. It is calculating how little it can get away with doing.

The Non-Financial Ledger

What the Fine Cannot Measure

The $141,778 ($141,778: roughly three years of a Pennsylvania public school teacher’s salary, or about what it costs to send one kid to a private university for four years) penalty paid by Arcos Industries closes a legal file. It does not close the account of what workers at that facility experienced across five years of working alongside unlabeled toxic waste, structurally untested tanks, and zero formal safety instruction.

The EPA’s findings document that Arcos workers handled flammable solvent waste, caustic wash water, and evaporator sludge every operating day, inside a facility where management had not provided a single hour of annual hazardous waste training from January 2020 through November 2024. That is five full years. According to the law, workers are supposed to receive initial training within six months of starting a position and annual refresher training every year after. Arcos did neither. Workers handling materials classified as D001 (ignitable), D002 (corrosive), and D007 (toxic, chromium-bearing) were doing so with whatever intuition they arrived with, not with the legal minimums the federal government requires.

Caustic waste can cause severe chemical burns to skin and eyes. Flammable solvents carry fire and explosion risk. These are not abstract hazards. They are the kind of injuries that send people to emergency rooms, cost workers their vision, their hands, or their lungs, and leave families with medical debt and lost wages while the company that exposed them to those risks keeps its production line running. The consent agreement confirms workers in those conditions received no formal refresher training for the entirety of the COVID-19 years and beyond, a period when every other workplace stress was already at a peak.

The hazardous waste tanks at the Arcos facility, including a 1,500-gallon caustic wash water tank and a 2,500-gallon caustic wash water tank, were operating for years without a professional engineer ever certifying they were structurally sound. These tanks were installed after 1993, meaning federal law required that certification from the start. It was completed only on May 14, 2025, under the pressure of regulatory enforcement. For the entire intervening period, the workers and the community surrounding the Mount Carmel facility operated within reach of tanks whose integrity nobody had formally verified. A structural failure in a caustic waste tank is not a paperwork error. It is a disaster with an address.

Legal Receipts: Straight from the Document

These are direct quotations and documented findings from the EPA Consent Agreement and Final Order, filed September 29, 2025. Nothing below is paraphrased.

“Respondent did not provide any hazardous waste training to its employees from January 2020 through November 2024. Hazardous waste training was provided to some of the required employees in December of 2024 and the remaining required employees in January of 2025.” — EPA Consent Agreement, Count 5, Paragraph 44

“Documentation of daily inspections was missing approximately 10 times per each month from 2020 through the Inspection in 2022.” — EPA Consent Agreement, Count 4, Paragraph 39

“Respondent stated that they were unsure how waste aerosol cans are disposed of or that they are disposed intact in the regular trash as nonhazardous waste.” — EPA Consent Agreement, Count 2, Paragraph 29

“The EPA also noted that the 2019 Biennial Report (submitted on February 3, 2020) did not include the following waste streams that were documented on 2019 hazardous waste manifests at the Facility: D001, D004, D035, D039.” — EPA Consent Agreement, Count 7, Paragraph 53

“EPA reserves the right to commence action against any person, including Respondent, in response to any condition which the EPA determines may present an imminent and substantial endangerment to the public health, public welfare, or the environment.” — EPA Final Order, Reservation of Rights, Paragraph 72

Societal Impact Mapping

Environmental Degradation

Arcos Industries operated a wastewater treatment hazardous waste tank (Tank #1) without secondary containment that meets federal law. The regulation is explicit: secondary containment must hold 100 percent of the capacity of the largest tank if it ruptures or overflows. Tank #1 had none. This means that for the full period between when that tank was placed in service and when inspectors arrived in September 2022, any leak, overflow, or rupture from that tank had no physical barrier between the facility floor and the surrounding environment.

The hazardous wastes involved include materials assigned EPA Hazardous Waste Numbers D002 (corrosive), D007 (toxic, containing chromium), D001 (ignitable), D035, and F005 (spent non-halogenated solvents). Chromium contamination in soil and groundwater is a serious long-term environmental threat. Mount Carmel, Pennsylvania sits in Northumberland County, a region where industrial contamination history is already well-documented. The failure to maintain secondary containment for a chromium-bearing and corrosive waste tank, for years, without professional engineering oversight, represents a real and unquantified release risk that no settlement payment addresses or remediates.

The company also failed to perform hazardous waste determinations on its aerosol can waste and corn cob particle waste streams, meaning it disposed of potentially hazardous materials as ordinary solid waste. That waste entered the general waste stream without the safeguards that hazardous material classification requires. Once improperly discarded hazardous waste enters a municipal disposal stream, the tracking and containment requirements of RCRA no longer apply to it.

Public Health

The Mount Carmel plant is a large quantity generator of hazardous waste. The categories of waste it generates include acid wastewater, caustic waste, evaporator sludge, spent solvents, and waste aerosol cans. These are not trace amounts. A large quantity generator classification means the facility produces 1,000 kilograms or more of hazardous waste per month. The people most immediately at risk are the workers inside the plant, followed by the community surrounding it.

Workers at the facility received no annual hazardous waste refresher training from January 2020 through November 2024. The legal training requirement exists precisely because proper handling technique, emergency response knowledge, and container management protocols are the primary barrier between a hazardous chemical exposure and a preventable injury. Without that training, workers handling D001 flammable solvents and D002 corrosives operate on guesswork. The human cost of a mishandled caustic burn, a solvent ignition, or an improperly stored container releasing fumes in a confined work space does not appear on any penalty schedule.

The failure to conduct daily inspections of four hazardous waste tanks, from January 2020 through April 2025, removed the detection mechanism designed to catch leaks, corrosion, and structural problems before they become exposures. The two caustic wash water tanks, holding 1,500 and 2,500 gallons respectively, went years without the routine visual checks that federal law treats as the absolute minimum. When inspectors are not looking at tanks daily, early warning signs of failure go unrecorded and unaddressed.

Economic Inequality

Mount Carmel, Pennsylvania is a small borough of roughly 10,000 people in a region that has watched industrial employment contract for decades. Workers at a facility like the Arcos plant often do not have the economic leverage to demand compliance with safety laws, consult lawyers, or report violations to regulators without risking their jobs. The five-year training blackout did not affect the executives who signed the paychecks or the lawyers who negotiated the settlement. It affected the line workers who showed up every day and handled chemicals they had no formal legal instruction to manage safely.

The $141,778 (roughly what three Pennsylvania factory workers earn combined in a full year) penalty Arcos paid represents a cost of doing business for a company supplying the U.S. military and the auto industry. The workers whose safety was compromised by the training gap, the tank failures, and the missing inspections bear the costs that never show up in a consent agreement: the health effects that may not manifest for years, the medical bills that insurance does not cover, and the absence of any formal acknowledgment that their employer put them at risk for half a decade.

The company is registered in Ohio and operates the Pennsylvania plant under that corporate structure. When regulators enforce a penalty, the corporation pays with company funds. When a worker is burned by caustic waste or exposed to chromium-bearing sludge in a facility with no secondary containment and no trained response protocol, they pay with their body. That asymmetry is the economic story underneath every line of this settlement document.