Corporate Misconduct Case Study: Custom Foods of America Incorporated & Its Impact on Public Safety
TLDR: At its food processing facility in Knoxville, Tennessee, Custom Foods of America Incorporated operated with 39,000 pounds of anhydrous ammonia, a highly hazardous chemical. An investigation by the Environmental Protection Agency (EPA) alleges the company endangered its workers and the public by failing to maintain basic safety standards. The EPA documented widespread corrosion on ammonia piping, missing and damaged safety labels, failed insulation leading to frost buildup, and a critical lack of required emergency safety equipment. Furthermore, Custom Foods of America allegedly failed to conduct mandatory safety audits for years and neglected to coordinate emergency plans with local first responders, even after expanding its chemical refrigeration system. Custom Foods of America settled the matter by agreeing to pay a $135,279 penalty, without admitting to any of the alleged violations.
Continue reading to explore the full details of the investigation and what this case reveals about corporate accountability in a system that prioritizes profit over people.
Introduction: A Ticking Time Bomb in Tennessee
In Knoxville, Tennessee, a disaster was waiting to happen. Inside the Custom Foods of America facility on Pleasant Ridge Road, nearly 20 tons of anhydrous ammonia—a toxic, suffocating gas—flowed through a sprawling refrigeration system. An accident could have been catastrophic, releasing a chemical cloud that would endanger workers and the surrounding community. This threat was the direct result of a documented pattern of corporate negligence.
Federal regulators from the Environmental Protection Agency stepped in, and their findings paint a disturbing picture of a company operating on the edge of safety. The case of Custom Foods of America is more than a story about a single company’s failures. It is a brutal illustration of a systemic rot, where the relentless pressures of neoliberal capitalism—deregulation, profit-maximization, and weak enforcement—create the conditions for such dangers to fester, hidden in plain sight.
Inside the Allegations: A Pattern of Corporate Misconduct
The government’s case against Custom Foods of America rests on a foundation of detailed, specific, and alarming observations made during an on-site inspection on July 18, 2023. The EPA alleges that Custom Foods of America violated the Clean Air Act’s Chemical Accident Prevention Provisions, a set of rules designed specifically to prevent the accidental release of extremely hazardous substances like anhydrous ammonia. The company’s facility housed 39,000 pounds of the chemical, nearly four times the 10,000-pound threshold that triggers the most stringent safety requirements.
Investigators found that Custom Foods of America failed to ensure its equipment complied with recognized and generally accepted good engineering practices (RAGAGEP). This manifested as visible, physical decay across the facility. Ammonia pipes, the veins of the hazardous system, were found with labels that were so faded and peeled they were unreadable. These labels are a first line of defense, designed to communicate the pipe’s contents, pressure, and flow direction to workers in an instant.
The physical integrity of the system was also allegedly compromised. The EPA documented extensive corrosion on ammonia piping throughout the facility, including in the main Ammonia Machinery Room, on pipes connected to the High-Pressure Receiver, and across both the “new” and “old” sides of the building’s roof. In some areas, the corrosion was described as “heavy,” affecting not just the pipes but their structural supports.
This kind of decay is a ticking clock, weakening the metal and increasing the likelihood of a rupture and a massive chemical release.
The problems continued with the equipment’s insulation. Investigators observed ammonia piping with breached and damaged insulation, as well as uninsulated pipes covered in frost buildup. Proper insulation is critical to prevent condensation and control temperature, and its failure can lead to further corrosion and system instability. Compounding these dangers was a shocking lapse in worker protection: the facility lacked a required eyewash and safety shower inside the machinery room, a non-negotiable piece of equipment for any space where workers are in close proximity to 20 tons of a hazardous chemical.
Timeline of Alleged Failures
The EPA’s investigation revealed that these were not recent issues but part of a prolonged period of neglect. The company’s failures in oversight and preparedness created a history of mounting risk.
| Date | Event |
| 2016 | The last documented compliance audit and the last time Custom Foods of America coordinated with local emergency responders. |
| 2018–2020 | Custom Foods of America expands its ammonia refrigeration system, increasing its capacity and potential risk, yet no new emergency coordination takes place. |
| July 12, 2023 | Custom Foods of America completes a new compliance audit, just six days before the EPA inspection and only after being notified that regulators were coming. |
| July 18, 2023 | The EPA conducts its on-site inspection, documenting widespread corrosion, missing safety equipment, and other violations. |
| March 26, 2024 | The EPA issues a formal Notice of Potential Violation to Custom Foods of America. |
| April 22, 2024 | Representatives from Custom Foods of America and the EPA meet to discuss the findings. |
| May 14, 2025 | The final settlement is filed, requiring Custom Foods of America to pay a $135,279 penalty while admitting no wrongdoing. |
Regulatory Capture & Loopholes: A System Designed to Fail
The story of Custom Foods of America highlights a fundamental weakness in America’s regulatory framework. The system is largely built on trust and self-reporting, a model that profit-driven corporations are incentivized to exploit. The law required Custom Foods of America to perform a comprehensive compliance audit at least once every three years. Yet, for seven years, from 2016 until the eve of a federal inspection in 2023, no such audit was completed.
Custom Foods of America only rushed to complete an audit when it knew regulators were on their way. This behavior reveals the cynical logic of legal minimalism: do the absolute least required, and only when you know you are being watched.
Under our neoliberal capitalistic economic system, where government oversight is deliberately underfunded and understaffed, this creates enormous loopholes. Evil corporations can operate for years in violation of the law, gambling that they will not be one of the few chosen for a random inspection.
The regulations themselves are clear, but without proactive and aggressive enforcement, they become mere suggestions. The EPA’s action in this case was reactive, triggered years after the alleged non-compliance began. The system did not prevent the danger… it only documented it after the fact. This is the essence of regulatory capture, where the framework designed to protect the public is so weakened that it primarily serves to create an illusion of safety.
Profit-Maximization at All Costs: The True Cost of Cutting Corners
Every single violation alleged by the EPA can be traced back to a single corporate driver: the maximization of profit. Maintaining equipment, replacing corroded pipes, updating insulation, conducting regular safety audits, and spending man-hours coordinating with local fire departments all represent costs that cut into the bottom line. Deferring these tasks is a simple, if reckless, way to boost short-term profitability.
The widespread corrosion documented by the EPA does not happen overnight. It is the result of prolonged neglect, a conscious decision to delay the costs of maintenance. The failure to conduct safety audits for seven years saved Custom Foods of America money on consultants and internal reviews. The failure to coordinate with emergency responders saved time and administrative costs.
In the calculus of late-stage capitalism, the potential for a catastrophic accident becomes a manageable risk weighed against the certainty of quarterly earnings. The health and safety of workers and the community become externalities—costs that are not reflected on Custom Foods of America’s balance sheet but are instead borne by society. Custom Foods of America chose to save money, and in doing so, it allegedly passed the risk onto its employees and the people of Knoxville.
The Economic Fallout: When Fines Become a Business Expense
Custom Foods of America ultimately agreed to pay a civil penalty of $135,279. To an average American family, this is a life-altering sum. To a corporation of its size, it is little more than a rounding error—a predictable cost of doing business. The economic model of neoliberalism does not view such penalties as a punishment for endangering the public, but as a fee for getting caught.
The fine is likely far less than the amount Custom Foods of America saved over seven years by allegedly skimping on maintenance, safety audits, and emergency planning. In this context, the penalty does not serve as a deterrent but as a grim incentive. It teaches corporations that it can be more profitable to violate the law and pay the occasional fine than to comply with it consistently.
The true economic fallout is therefore not the fine paid by Custom Foods of America, but the risks imposed on everyone else. The cost of a potential emergency response, the medical bills for injured workers, the long-term health impacts of a chemical leak—these are the costs that the system allows corporations to avoid. The public holds the risk, while the corporation protects its profits.
Environmental & Public Health Risks: A Clear and Present Danger
The threat posed by the facility’s alleged failures was direct and severe. Anhydrous ammonia is a dangerous chemical, capable of causing severe burns to the skin, eyes, throat, and lungs. A large-scale release can be lethal. The corrosion eating away at the facility’s pipes created multiple potential points of failure for a catastrophic leak.
The lack of an eyewash station inside the machinery room was a direct betrayal of worker safety. In the event of an ammonia spray, workers would have no immediate way to flush the chemical from their eyes and skin, drastically increasing the risk of permanent injury or blindness. This was a failure to provide the most basic line of defense in a hazardous environment.
Perhaps most damning was the failure to coordinate with local emergency planners. This meant that the very people who would be called to respond to a disaster—firefighters, paramedics, and hazmat teams—would arrive at the scene unprepared. They would lack up-to-date knowledge of the facility’s layout, the quantity and location of the ammonia, and any specific hazards related to the newly expanded system. This failure turned a potential industrial accident into a potential community-wide crisis, needlessly endangering the lives of first responders and the public.
Exploitation of Workers: Human Cost as an Acceptable Risk
The total failures at Custom Foods of America created direct and immediate threats to their workforce. The most glaring example was the absence of a required eyewash and safety shower inside the Ammonia Machinery Room, a space where workers are most intimately exposed to the dangers of the chemical. This fundamental piece of safety equipment is a worker’s last line of defense against a chemical splash that can cause permanent blindness or severe burns.
By failing to install and maintain this legally mandated equipment, Custom Foods of America effectively treated the health and safety of its employees as a discretionary expense. The established engineering standards requiring these devices exist precisely to protect human lives. Ignoring them represents a calculated decision where the risk to a worker’s body is deemed more acceptable than the cost of ensuring their protection, a grim hallmark of labor exploitation under late-stage capitalism.
Community Impact: Local Lives Undermined by Corporate Secrecy
The consequences of Custom Foods of America’s corporate negligence extended far beyond the facility’s walls, placing the entire surrounding community of Knoxville, Tennessee, in jeopardy. The company expanded its ammonia refrigeration system between 2018 and 2020, yet it had not performed any emergency response coordination activities with local responders since 2016. This created a critical information vacuum for the very people expected to run into a disaster, not away from it.
In the event of a chemical release, unprepared fire departments and hazmat teams would be arriving at a scene they do not fully understand. They would lack current knowledge of the expanded system’s layout, the precise locations of hazardous materials, and the specific emergency shutdown procedures. This failure to coordinate turns a manageable industrial accident into a potential large-scale public health crisis, risking the lives of first responders and residents alike. It demonstrates how a single corporation’s insular focus on its own operations can impose a tremendous and uncompensated risk upon the public.
The PR Machine: Corporate Spin Tactics and the Denial of Guilt
In the face of these serious allegations, Custom Foods of America deployed a classic corporate strategy to control the narrative and protect its brand. Custom Foods of America agreed to the terms of the settlement, including the $135,279 penalty, but in the final legal document, it “neither admits nor denies the factual allegations” set forth by the EPA. This legal maneuver is a cornerstone of corporate public relations.
This clause allows Custom Foods of America to make the legal problem disappear financially without ever having to confess to the dangerous conditions investigators documented. It prevents the public admission of fault that could tarnish its reputation, be used in future lawsuits, or require a genuine apology to its workers and community. It is a carefully constructed performance of accountability that sidesteps any actual admission of responsibility, a tactic that prioritizes image management over public transparency.
Wealth Disparity & Corporate Greed: A Fine That Functions as a Fee
The $135,279 penalty levied against Custom Foods of America illustrates the profound wealth disparity that defines our economic system. For an average family, such a sum would be financially ruinous. For a corporation named “Custom Foods of America Incorporated,” it is a trivial, manageable, and ultimately tax-deductible business expense.
This disparity reveals the flawed logic of using fixed financial penalties to deter corporate misconduct. When a fine is not scaled to a company’s revenue, it ceases to be a punishment and becomes a simple fee for non-compliance. The company can absorb the cost with ease, while the workers and community continue to bear the physical risk of Custom Foods of America’s cost-cutting decisions. This transforms justice into a transaction, where wealthy entities can simply pay for the right to endanger the public.
Global Parallels: A Pattern of Predation
The case of Custom Foods of America is a local manifestation of a global pattern of industrial behavior. Across the world, in countless sectors, the same story unfolds: maintenance is deferred, safety protocols are ignored, and hazardous materials are mismanaged in the relentless pursuit of profit. The alleged corrosion on the ammonia pipes in Knoxville echoes the systemic neglect seen in chemical plants and industrial facilities that have led to historic disasters elsewhere.
This pattern is a predictable feature, not a bug, of a globalized capitalist system that incentivizes corporations to externalize costs and risks. The pressure to compete forces companies to cut corners, and safety is often the first corner to be cut. The details may change, but the underlying logic remains the same, whether in Tennessee or anywhere else: the health of people and the environment is secondary to the financial health of the corporation.
Corporate Accountability Fails the Public
The final settlement in this case serves as a textbook example of how the concept of corporate accountability so often fails the public it is meant to protect. A penalty was paid, but no guilt was admitted. Custom Foods of America certifies it is now in compliance, but no individuals have been held personally liable for the years of alleged neglect.
This outcome treats the corporation as an abstract entity, shielding the executives and managers who make the decisions from any meaningful consequences. It reinforces the idea that public endangerment is not a moral failing requiring true accountability, but a regulatory issue to be resolved with a check. As long as the system allows individuals to hide behind the corporate veil, the cycle of negligence and settlement will continue, and public safety will remain a secondary concern.
Pathways for Reform & Consumer Advocacy
The failures exposed in this case point directly to the necessary pathways for meaningful reform. The current model of reactive, pre-announced inspections is clearly inadequate and must be replaced with a system of frequent, unannounced, and rigorous proactive enforcement. Fines must be scaled to a percentage of a company’s revenue to ensure they are genuinely punitive rather than a negligible cost of business.
Furthermore, the legal framework must be strengthened to allow for the piercing of the corporate veil, holding executives personally accountable for decisions that endanger workers and communities. Stronger whistleblower protections are also essential to empower employees to report safety violations without fear of retaliation. Without these structural changes, we are merely managing the symptoms of a broken system rather than curing the disease.
Modular Commentary: Legal Minimalism
The actions of Custom Foods of America provide a masterclass in the practice of legal minimalism—the art of doing just enough to appear compliant, but only when absolutely necessary.
The law required a safety audit every three years, yet Custom Foods of America went seven years without one. It was only after the EPA notified the facility of an upcoming inspection that an audit was hastily completed, just six days before regulators arrived. This is not the behavior of a company committed to the spirit of the law, which is continuous safety. It is the behavior of a company that treats the law as a bothersome checklist to be addressed only when an auditor is at the door, a philosophy that late-stage capitalism rewards.
Modular Commentary: How Capitalism Exploits Delay
Time, in a capitalist system, is a resource to be exploited, and the Custom Foods case shows how delay can be immensely profitable. For every year Custom Foods of America delayed conducting its safety audit and deferred coordinating with emergency responders, it saved money.
For every year it put off addressing the corrosion on its pipes, it avoided maintenance costs and protected its cash flow. The prolonged period of non-compliance, from 2016 to 2023, was a deliberate financial strategy to minimize costs and maximize profits. The slow-moving nature of regulatory enforcement creates a window of opportunity for corporations to profit from their own inaction, gambling that they will not be caught before the cost savings have been banked.
Modular Commentary: The Language of Legitimacy
The legal document that finalizes this case is a masterwork of bureaucratic language designed to neutralize the severity of the alleged harm. The core of the settlement rests on the phrase that Custom Foods of America “neither admits nor denies the factual allegations,” a legal incantation that magically transforms concrete dangers into abstract legal points. The entire proceeding is framed not as a matter of public endangerment, but as an “administrative penalty assessment” under Section 113(d) of the Clean Air Act.
This technocratic framing is deliberate. It discusses corroded pipes and missing safety showers in the same dispassionate tone as it discusses docket numbers and regulatory sub-sections. This language strips the situation of its human dimension, obscuring the reality that the case is about protecting people from a potentially lethal cloud of toxic gas. In the world of neoliberal governance, the risk of death and injury is translated into the sterile, manageable language of regulatory compliance, making it easier for all parties to treat the outcome as a successful transaction rather than a moral failure.
Modular Commentary: Monetizing Harm
While Custom Foods of America did not directly send invoices for its negligence, its business model effectively monetized the risk of harm. Every dollar not spent on replacing corroded pipes, conducting safety audits, or paying staff for emergency planning was a dollar that boosted the company’s bottom line. The profit was extracted not from a product, but from the deliberate deferral of the costs of operating safely.
This is a core feature of late-stage capitalism: the creation of value through the externalization of risk. Custom Foods of America privatized the financial gains from its cost-cutting, while it socialized the potential losses—the health of its workers and the safety of the Knoxville community. The business model was predicated on a gamble: that the profits saved by ignoring safety protocols would outweigh the eventual cost of any fines. In this sense, the potential for a catastrophic chemical release was an unwritten entry on the asset side of the company’s ledger.
Modular Commentary: Profiting from Complexity
The corporate structure of Custom Foods of America is straightforward, but Custom Foods of America profited from a different kind of complexity: the intricacy and opacity of the regulatory system itself. The dense web of federal regulations, from 40 C.F.R. Part 68 to the specific ANSI/IIAR engineering standards, creates a landscape that is difficult for the public to navigate and for government agencies to police effectively with limited resources.
A company can exploit this complexity by assuming, correctly in this case for many years, that its non-compliance will go unnoticed. It relies on the fact that regulators cannot be everywhere at once and that proving violations requires a detailed, time-consuming investigation. This transforms the regulatory code from a shield that protects the public into a smokescreen that can hide corporate misconduct, allowing companies to profit from the system’s inherent limitations.
Modular Commentary: This Is the System Working as Intended
It is tempting to view the case of Custom Foods of America as a failure of the system. In truth, it is a textbook example of the system working exactly as it was designed to. A corporation was able to allegedly ignore critical safety rules for years, increasing its profitability by cutting corners on maintenance and oversight. When finally caught, it was not forced to admit wrongdoing and was subjected to a financial penalty that represents a fraction of the profits likely gained from its years of non-compliance.
The system successfully protected the corporation from significant liability and shielded its decision-makers from personal responsibility. It prioritized the financial interests of Custom Foods of America over the physical well-being of its workers and the surrounding community. From the perspective of neoliberal capitalism, which views regulation as a burden and fines as a business cost, this is not a failure; it is a feature.
Conclusion: The High Cost of a Low Penalty
In the end, this is a story about 20 tons of hazardous ammonia, corroded pipes, a missing safety shower, and years of neglected oversight. It is about a company that allegedly failed to prepare for the worst, neglecting to coordinate with the very first responders who would be tasked with saving lives in a disaster. And it is about a settlement that resolves these grave dangers with a penalty of $135,279 and no admission of guilt.
This outcome is not an anomaly. It is the quiet, routine business of a system that has become adept at managing corporate harm rather than preventing it. The human and societal cost of this model is immense, measured in the risks borne by ordinary people every day. The legal battle may be over, but the case of Custom Foods of America serves as a chilling reminder of a deeper failure in how modern economies protect corporate entities over the communities they operate in. Justice was not served here; it was settled.
Frivolous or Serious Lawsuit?
This was not a private lawsuit but a formal enforcement action brought by the United States Environmental Protection Agency, and it was unequivocally serious. The legitimacy of the government’s action is grounded in the direct, physical evidence gathered by federal investigators during their on-site inspection of the facility. The EPA’s allegations were not based on trivial matters or procedural technicalities.
They documented extensive and “heavy” corrosion on pipes carrying a highly toxic chemical, a fundamental failure of mechanical integrity.
They noted the absence of legally required, life-saving safety equipment for workers and a multi-year failure to conduct mandatory safety audits and coordinate with local emergency services. These are not minor infractions; they are precisely the types of dangerous conditions that chemical safety laws were written to prevent. The government’s action was a legitimate and necessary intervention to address a significant and ongoing threat to public health and safety.
Please click on this link to read the file on the EPA’s website: https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/A535CCCD53216F5885258C8A0082A93F/$File/Custom%20Foods%20of%20America%20Incorporated%20CAFO%205-14-25%20CAA-04-2025-0300(b).pdf
This evil corporation faced a different EPA fine in 2018 for doing illegal androgenous ammonia releases : https://yosemite.epa.gov/oa/rhc/epaadmin.nsf/Filings/513FC459B17322FC85258288001BC70A/$File/CAFO.pdf
Custom Foods Of America can be reached by calling (865) 525-0401 and by emailing sales@customfoods.net
đź’ˇ Explore Corporate Misconduct by Category
Corporations harm people every day — from wage theft to pollution. Learn more by exploring key areas of injustice.
- 💀 Product Safety Violations — When companies risk lives for profit.
- 🌿 Environmental Violations — Pollution, ecological collapse, and unchecked greed.
- 💼 Labor Exploitation — Wage theft, worker abuse, and unsafe conditions.
- 🛡️ Data Breaches & Privacy Abuses — Misuse and mishandling of personal information.
- 💵 Financial Fraud & Corruption — Lies, scams, and executive impunity.
NOTE:
This website is facing massive amounts of headwind trying to procure the lawsuits relating to corporate misconduct. We are being pimp-slapped by a quadruple whammy:
- The Trump regime's reversal of the laws & regulations meant to protect us is making it so victims are no longer filing lawsuits for shit which was previously illegal.
- Donald Trump's defunding of regulatory agencies led to the frequency of enforcement actions severely decreasing. What's more, the quality of the enforcement actions has also plummeted.
- The GOP's insistence on cutting the healthcare funding for millions of Americans in order to give their billionaire donors additional tax cuts has recently shut the government down. This government shut down has also impacted the aforementioned defunded agencies capabilities to crack down on evil-doers. Donald Trump has since threatened to make these agency shutdowns permanent on account of them being "democrat agencies".
- My access to the LexisNexis legal research platform got revoked. This isn't related to Trump or anything, but it still hurt as I'm being forced to scrounge around public sources to find legal documents now. Sadge.
All four of these factors are severely limiting my ability to access stories of corporate misconduct.
Due to this, I have temporarily decreased the amount of articles published everyday from 5 down to 3, and I will also be publishing articles from previous years as I was fortunate enough to download a butt load of EPA documents back in 2022 and 2023 to make YouTube videos with.... This also means that you'll be seeing many more environmental violation stories going forward :3
Thank you for your attention to this matter,
Aleeia (owner and publisher of www.evilcorporations.com)
Also, can we talk about how ICE has a $170 billion annual budget, while the EPA-- which protects the air we breathe and water we drink-- barely clocks $4 billion? Just something to think about....
