How Chem Tech’s Systemic Neglect Turned a Factory into a Ticking Time Bomb

Workers at Chem Tech’s Bristol, Indiana factory showed up every day to a building packed with tens of thousands of pounds of explosive gas, a fire suppression system that had not been checked since 2018, exit doors blocked by stacked product, and zero documented safety training — and management filed paperwork saying everything was fine.

A Factory Running on Fumes and Paperwork

C3E, LLC, which operates under the name Chem Tech, runs an aerosol adhesive manufacturing facility at 501 Bloomingdale Drive in Bristol, Indiana. The process involves butane and propane, two substances the federal government classifies as regulated flammable substances under the Clean Air Act specifically because an accidental release could cause mass casualties. Chem Tech’s own Risk Management Plan, submitted in 2019, confirmed the facility held quantities of both chemicals exceeding the 10,000-pound threshold that triggers the highest level of federal safety oversight.

That threshold triggers what the law calls Program 3 requirements: the most rigorous category of chemical accident prevention, demanding exhaustive safety documentation, regular hazard analysis, trained workers, functioning emergency systems, and inspected equipment. Chem Tech was legally subject to Program 3 requirements since at least 2017. The EPA showed up on August 31, 2022, and found a facility that had treated those requirements as optional.

The hazard assessment in Chem Tech’s own Risk Management Plan documents stated clearly that a public receptor, meaning nearby residents or community members, sat within the flammable endpoint of a potential release. In plain terms: if their chemicals had caught fire or exploded, people outside the factory walls would have been in the kill zone.

The Fire System Hadn’t Been Checked in Four Years

Federal regulations and the National Fire Protection Association’s own standards require annual inspection of fire sprinkler systems in facilities like this. When EPA inspectors examined the fire suppression system at the Chem Tech facility in August 2022, the inspection tag on the system showed the last completed inspection was in 2018. Four years. Four years of explosive chemicals, production shifts, and employees clocking in, all protected by a fire system no one had verified still worked.

This was a facility where, by Chem Tech’s own admission in its RMP documents, a catastrophic release could reach the surrounding public. The fire suppression system is the last line of defense if something goes wrong on the production floor. Chem Tech let that system go uninspected for four consecutive years without interruption.

The Exit Was Blocked. Literally.

Federal regulations require that in high-hazard facilities, means of egress must be free from obstructions. NFPA standards define high-hazard contents as those “likely to burn with extreme rapidity or from which explosions are likely.” Chem Tech’s production floor, filled with butane and propane, met that definition completely. When inspectors walked through the main production area, they found finished product staged directly in front of the main egress point, reducing visibility of the exit.

The production floor is larger than 200 square feet and was occupied by more than three people, which means federal law required at minimum two functional means of egress. Only the main exit had panic hardware on the doors. The secondary exits did not. In a fire or explosion scenario in that room, workers would have been funneling toward a single, partially obstructed exit — in a room full of explosive gas.

The Non-Financial Ledger

The Workers Who Signed Nothing, Were Taught Nothing, and Were Told Nothing

Picture what it means to go to work in a building where you handle explosive chemicals and nobody has ever formally told you what to do if something goes wrong. The EPA found that Chem Tech provided zero documentation of initial safety training for any employee involved in operating the covered process. Not thin records. Not partial records. Nothing. Federal law requires that every worker receives training before touching a covered process, with emphasis specifically on emergency operations, including how to shut the process down, and safe work practices for their exact job tasks.

These were not abstract regulations dreamed up by bureaucrats. They exist because propane and butane, when released in large quantities and ignited, produce fireballs. The training requirement exists so that workers know what they’re working with, know what the warning signs of a leak look like, know how to shut down, and know where to run. Chem Tech never gave its workers that information in any documented form, for initial training or for the three-year refresher training cycles required by law. The company also never kept any record confirming that any worker had understood any training at all. The workers were on their own.

Maintenance workers who kept the equipment running were similarly left without documented training in the hazards of the process they maintained. Federal rules require that employees maintaining process equipment receive training in both the hazards of that process and the specific procedures for their job tasks, so they can perform the work safely. Chem Tech produced no evidence this happened either. Maintenance workers tightened fittings, checked equipment, and serviced systems on a process containing tens of thousands of pounds of flammable gas without any verified understanding of what that gas could do to them.

The Door That Could Have Killed Everyone in the Room

The blocked exit was documented by EPA inspectors during their physical walkthrough of the facility. Finished product, boxes of Chem Tech’s own manufactured output, sat staged in front of the main egress point of the production floor. The inspectors noted this reduced the visibility of the exit. In a fire or explosion scenario on a production floor containing explosive gas, seconds are the difference between life and death. A blocked exit that is harder to see in smoke or panic is a blocked exit that kills people.

Federal law and NFPA standards, both recognized as the engineering standard of care for facilities like this, required that exit paths be clear and unobstructed. Those same standards required that high-hazard areas with more than five occupants have panic hardware on all required exit doors, not just one. Chem Tech met neither requirement. The production floor was larger than 200 square feet and held more than three workers, which under the law required a minimum of two clear, hardware-equipped exits. The workers in that room had one, and it was partially blocked by their employer’s own product.

A 2018 Hazard Analysis That Nobody Acted On

In 2018, Chem Tech completed a Process Hazard Analysis, the structured review of what could go wrong with their covered process and how serious the consequences would be. That PHA produced five specific recommendations. Federal regulations require facilities to establish a documented system to track PHA recommendations, assign schedules for resolving them, and complete the recommended actions as soon as possible. When EPA inspectors arrived four years later in August 2022, the 2018 PHA’s five recommendations had no documented resolution schedule and no documented completion record. Four years. Five recommendations about safety in a room full of explosive gas. Zero documented follow-through.

Operating Procedures That Left Out the Part About Danger

The written operating procedures that Chem Tech provided to the EPA during the inspection covered the covered process but omitted safety and health considerations entirely. Federal law is specific about what those procedures must include: the properties and hazards of the chemicals being used, the precautions necessary to prevent exposure, what engineering and administrative controls to use, what personal protective equipment is required, what to do if physical contact or airborne exposure occurs, and any special or unique hazards of the process. Chem Tech’s procedures addressed how to operate the process. They said nothing about what would happen to a worker’s body if it went wrong, and nothing about what that worker should do to prevent it.

Legal Receipts: The Documents They Signed

These are direct citations from the EPA’s Consent Agreement and Final Order. Every word below comes from the official government document.

“The fire suppression system inspection tag denoted that the fire suppression system inspection was last completed in 2018.” EPA Inspection Findings, August 31, 2022 — Stipulated Fact 63(a)

“Respondent did not provide any documentation of initial training for employees involved in operating a process either during or following the Inspection.” EPA Allegations — Paragraph 77

“The 2018 PHA included five recommendations but had no documentation at the time of the Inspection of a proposed schedule to resolve and implement recommendations from the PHA in a timely manner.” EPA Allegations — Paragraph 71

“Written operating procedures for the covered process reviewed by the inspectors during the Inspection did not include safety and health considerations.” EPA Allegations — Paragraph 74

“Finished product was staged in front of the main egress point and reduced visibility of the exit.” EPA Inspection Observations — Paragraph 63(c)

“Respondent’s covered process at the Facility has had regulated substances present in more than threshold quantities as determined under § 68.115 since at least 2017.” Stipulated Fact — Paragraph 55

Societal Impact Mapping

Public Health: The Blast Zone Was Real, and the Public Was In It

Chem Tech’s own Risk Management Plan, a document the company submitted to the EPA in 2019, contained a hazard assessment that confirmed a public receptor sat within the flammable endpoint of a potential release. This is the government’s language for: if the chemicals at this facility ignite, the danger zone extends to where people live and work outside the factory fence. The company knew this. It filed the document that said this. And then it ran a factory where the fire suppression system went uninspected for four years and workers had no documented emergency training.

The Clean Air Act’s Chemical Accident Prevention Provisions exist because Congress, in 1990, recognized that certain chemical facilities pose a lethal risk to surrounding communities. The law specifically identifies the goal as “preventing the accidental release and minimizing the consequences of any such release” of substances that “are known to cause or may reasonably be anticipated to cause death, injury, or serious adverse effects to human health or the environment.” Butane and propane qualify. Chem Tech’s facility qualified. The surrounding community of Bristol, Indiana qualifies as people who could have been hurt. Every day Chem Tech operated out of compliance was another day the community bore that risk without knowing it.

Workers inside the facility faced a compounded risk. Without formal safety training, they may not have recognized early warning signs of a gas leak. Without a functioning fire suppression system confirmed by inspection, any ignition source in a production area running explosive chemicals would have encountered a system of unknown reliability. Without clear, unobstructed exits, evacuation would have been slower. These are the conditions that turn industrial accidents into mass casualty events.

Economic Inequality: Who Pays When Corporations Cut Corners on Safety

The penalty Chem Tech agreed to pay is $100,000 (roughly the annual salary of a median American household, meaning a single family’s entire year of work). This is the total financial consequence for years of documented violations involving chemicals capable of causing explosions large enough to injure people outside the building. The settlement covers nine separate violations of federal law across five distinct regulatory categories: safety information, hazard analysis, operating procedures, training, and mechanical integrity.

The workers in that factory are the people who absorbed the actual risk that Chem Tech’s compliance failures created. They handled the chemicals, ran the equipment, and worked inside the building with the blocked exits. They received no documented safety training, and no documented emergency procedure guidance. If something had gone wrong, the company’s financial exposure was capped at a penalty that a mid-size business can pay in thirty days. The workers’ exposure was their lives.

Community members living near the facility in Bristol, Indiana had no knowledge that a hazard assessment had already identified them as being within the blast range of a potential chemical release, and no way to know that the facility’s safety systems were operating out of compliance with federal law for years. This is how the burden of industrial risk falls: corporations hold the information, communities absorb the danger, and when the regulatory system catches up, the penalty is a number the company negotiates down to something it can absorb.

What Now?

Chem Tech neither admitted nor denied the violations in the settlement. The company agreed to pay $100,000 (roughly what the median American household earns in a year) and waived its right to appeal. The administrative compliance order issued concurrently with the settlement means regulators will monitor Chem Tech’s ongoing compliance. Here is who to watch, who has authority, and what you can do.

Regulatory Watchlist

• EPA Region 5 (Chicago) — filed this enforcement action and holds ongoing oversight authority over the facility’s Risk Management Plan compliance.
• EPA Air Enforcement and Compliance Assurance Branch, Region 5 — the team that conducted the inspection and manages the settlement.
• OSHA — Chem Tech’s process is also subject to OSHA’s Process Safety Management standard (29 C.F.R. § 1910.119), which means OSHA has independent authority to inspect and enforce at this facility.
• Department of Justice — retains authority to bring civil action if Chem Tech fails to pay or comply with the terms of the Final Order.
• EPA RMP Database — Risk Management Plans are public records. You can look up any facility in your area at the EPA’s RMP database to see what hazardous chemicals they store and whether a public receptor sits within their danger zone.

Corporate Roles Named in the Settlement

• C3E, LLC d/b/a Chem Tech — Respondent; operating entity responsible for all violations.
• Contact identified in settlement: cam.erekson@chemtechadhesives.com (Chem Tech’s designated representative for this proceeding).

What You Can Do Right Now

• If you work at a facility with hazardous chemicals: You have the right to request your facility’s Risk Management Plan. Ask your employer for your documented safety training records. If they don’t exist, OSHA’s whistleblower protection program can protect you while you report it.
• If you live near a chemical facility: Search the EPA’s RMP database for your zip code. Find out if your neighbors are running a covered process, and whether the public is within their danger zone.
• Organize locally: Local emergency planning committees (LEPCs) exist in every community under federal law. They are required to coordinate with facilities like Chem Tech on emergency response. Attend LEPC meetings. Demand to know which facilities in your area have open hazard assessment findings and what the community evacuation plan actually is.

The system that let Chem Tech run a chemical factory with blocked exits and an unverified fire suppression system for years is the same system that settled those violations for a fee a mid-size business can pay in a month. Pressure on regulatory agencies to conduct more unannounced inspections, sustained contact with your local LEPC, and solidarity with workers inside facilities like this one are the tools that close the gap between what the law says and what actually happens on the factory floor.