What the EPA Found Inside Pfizer’s Kalamazoo Plant

EPA Region 5 sent three authorized inspectors to 7000 Portage Road, Kalamazoo, Michigan, between January 22 and 25, 2024. What they documented was a federal pharmaceutical operation handling some of the most dangerous chemicals in industrial chemistry without the basic paperwork and training the law requires.

• The facility runs at least three regulated chemical processes: HF Process 1, HF Process 2, and TMA Process 3. All three involve chemicals classified as “regulated substances” under 40 C.F.R. Part 68, the federal rule implementing Chemical Accident Prevention requirements.
• Hydrogen fluoride was present in two forms: compressed gas cylinders and 70% HF solution drums. The 70% concentration is classified as highly corrosive and acutely toxic. It penetrates skin without immediate pain, absorbs into the bloodstream, and can cause fatal cardiac arrest hours after exposure by stripping calcium from the body.
• Trimethylamine is a flammable, compressed toxic gas with an immediately dangerous to life or health (IDLH) concentration of 2,000 ppm. It is also a precursor chemical in pharmaceutical synthesis.
• The inspectors found that written procedures for safely transporting these materials within the facility did not exist, in violation of 40 C.F.R. § 68.69(a)(1)(ii).
• Inspectors also found that employees assigned to operate these processes had not received required overview training on the processes and their operating procedures, in violation of 40 C.F.R. § 68.71(a)(1).
• The violations were confirmed using documentation submitted by Pharmacia & Upjohn itself to the EPA, alongside the inspection findings. The company’s own records helped build the case against it.

What a Worker Without Training Faces When the Drum Tips Over

Imagine you’ve been assigned to move a drum of 70% hydrogen fluoride solution across a plant floor. You do not have a written procedure telling you what to do if something goes wrong. You have not been trained on what the process you’re working in actually does or what the hazards are. You are just moving the drum because that is your job today.

Hydrogen fluoride at 70% concentration is not an abstract regulatory category. It is a liquid that penetrates skin without immediately triggering pain. The deceiving part is how it works: you may not feel the burn right away. By the time you realize something went wrong, the fluoride ions are already migrating through your tissue toward your bones. The mechanism of fatal exposure is hypocalcemia: the fluoride binds to calcium in your blood, your heart loses what it needs to maintain rhythm, and you go into cardiac arrest. People have died from palm-sized skin exposures to high-concentration HF. Without rapid, specific medical intervention involving calcium gluconate, the outcome can be permanent injury or death.

Trimethylamine is not gentler. It is flammable, it is toxic, and it has a deeply penetrating odor at low concentrations that provides a warning, but above its immediately dangerous threshold, it attacks the respiratory tract. It is also heavier than air in certain conditions, which means a leak in a low area of a facility can accumulate silently.

The workers at 7000 Portage Road in Kalamazoo, Michigan, were operating in the presence of these chemicals without the law’s most basic protections: the written step-by-step procedures that tell you what to do in every scenario, and the formal training that makes sure you know what you are handling before you handle it. These are not bureaucratic requirements. They exist because people died in industrial accidents before them. They were written in blood decades before Pharmacia & Upjohn was ever formed.

The settlement does not tell us how long the violations existed before the January 2024 inspection. It does not tell us how many workers rotated through those processes untrained. It does not tell us whether anyone was injured. The ESA structure resolves the legal liability while leaving those answers permanently off the record. The workers at that facility will likely never know their employer was fined by the federal government for failing to train them on the chemicals they were breathing next to every day.

The Words They Signed. What They Prove.

Every quote below is reproduced verbatim from the signed Expedited Settlement Agreement, Docket No. CAA-05-2024-0030. Nothing is paraphrased.

“The EPA and Respondent (jointly ‘the Parties’) have agreed that settling this action without the filing of a complaint or the adjudication of any issue of fact or law is in their interest and in the public interest.”

• This sentence establishes that the case was designed to end before it officially began. No complaint was filed, which means no public docket entry forcing Pharmacia & Upjohn to respond to specific factual allegations in a formal enforcement proceeding.
• The phrase “in the public interest” appears in a document that simultaneously prevents the public from seeing a formal complaint describing the severity, duration, or human impact of the violations.

“Respondent waives its right to contest the specific factual allegations contained herein, and neither admits nor denies these specific factual allegations.”

• This is the standard corporate legal shield. Pharmacia & Upjohn paid $8,100 to close a federal chemical safety case without ever going on record as having done anything wrong. The violations are documented; the admission is not.
• This structure means workers, community members, and journalists cannot use this settlement as legal evidence of admitted wrongdoing in any subsequent proceeding. The misconduct is confirmed by the company’s own documents but legally sealed behind a denial.

“Respondent certifies, subject to civil and criminal penalties for making a false submission to the United States Government, that Respondent has corrected the violations set forth in this ESA.”

• This certification means Pharmacia & Upjohn self-reported that it fixed the violations. There is no mention in the document of an independent post-correction inspection to verify the claim. The EPA accepts the company’s word under penalty of law.
• The correction standard is entirely unverified in the public record. We know the company said it complied. We do not know whether a federal inspector confirmed it.

“In consideration of Respondent’s size of business, its full compliance history, its good faith efforts to comply, other factors as justice may require, and upon consideration of the entire record, the parties enter into this ESA in order to resolve any civil penalties for these alleged violations for the total penalty amount of $8,100.”

• The phrase “full compliance history” was used to justify an $8,100 fine for violations involving hydrogen fluoride, a chemical with a known history of industrial fatalities. This language directly reduced the penalty amount.
• “Good faith efforts to comply” is credited in a settlement for a facility that was found to have no written safety procedures and no confirmed employee training. The law does not require good intentions; it requires procedures and training to exist before workers handle acutely hazardous chemicals.

Who Pays When Corporations Cut Corners on Chemical Safety

Public Health

Hydrogen fluoride and trimethylamine are not low-risk industrial chemicals. The regulatory framework around them exists because of documented mass casualty events, not hypothetical scenarios.

• A release of hydrogen fluoride at industrial concentrations can trigger an emergency evacuation radius of miles, not feet. The 1994 Texas City HF release injured 4,700 residents and prompted national regulatory debate about whether HF should be replaced in industrial processes entirely. The Kalamazoo facility operated without written transport procedures for this same chemical.
• Workers operating processes without formal training are statistically more likely to make procedural errors during abnormal conditions, exactly the circumstances where most chemical accidents occur. The absence of written procedures compounds this risk by removing the reference document workers need when something unexpected happens.
• 70% hydrogen fluoride solution exposure to a small patch of skin can require immediate emergency hospital intervention. Without trained co-workers who know what the chemical is and how it works, the delay between exposure and appropriate treatment lengthens. That delay is the difference between recovery and permanent injury.
• Trimethylamine releases in enclosed spaces create immediate respiratory hazards. Workers not trained on the process would not have known the facility’s specific emergency response protocol for a TMA leak, including evacuation routes, shut-off points, and communication procedures.

Economic Inequality

The financial math of this case makes visible a structural truth about how chemical safety law functions when the defendant is a subsidiary of a trillion-dollar corporation.

• The $8,100 penalty represents a fraction of a fraction of Pfizer’s revenue. Pfizer reported approximately $58.5 billion in revenue for 2023. The fine is the equivalent of a person earning $58,500 per year paying roughly $0.008, less than a single penny, as a penalty for a safety violation at work.
• Workers at chemical facilities in the United States are disproportionately employed from lower-income demographics. Production and maintenance workers at pharmaceutical manufacturing plants typically earn between $40,000 and $70,000 annually. These workers bear the full physical risk of chemical exposure while corporate shareholders bear zero personal exposure.
• The Expedited Settlement Agreement structure, which resolves violations before a formal complaint is filed, is legally available to all respondents but practically useful primarily to corporations with legal resources to negotiate quickly and quietly. Smaller employers without legal departments rarely resolve EPA enforcement actions in this format.
• The fine was not ordered as a corrective investment back into worker safety. The $8,100 went to the U.S. Treasury. The workers who operated these processes without adequate training received no compensation, no formal notification, and no legally mandated acknowledgment that the company had failed its obligations to them.

The Number That Says Everything About How This System Works

What Now: Accountability Does Not End With an $8,100 Check

The settlement closed this specific federal civil penalty action. It did not close the broader question of whether Pfizer’s subsidiary network is consistently meeting chemical accident prevention requirements across its facilities, and it explicitly did not waive EPA’s right to pursue further enforcement for any other violations.

Corporate Roles Named in This Document

• Michael D. Harris, Director, Enforcement and Compliance Assurance Division, EPA Region 5: signed as Complainant on behalf of the EPA.
• Ann L. Coyle, Regional Judicial Officer, EPA Region 5: issued the Final Order ratifying the settlement on June 5, 2024.
• Carolyn Persoon, EPA Region 5: signed the ESA on May 30, 2024 on behalf of the Complainant.
• [REDACTED – Not in Source]: The name of the Pharmacia & Upjohn or Pfizer executive who signed the settlement on behalf of the Respondent was not included in the source document provided for this investigation.

Watchlist: Who Has Jurisdiction

• U.S. EPA Region 5 (Chicago): The direct enforcement authority for Clean Air Act violations at this facility. The ESA explicitly preserved EPA’s right to pursue further enforcement for any other CAA violation or violation of any other statute. Contact: r5airenforcement@epa.gov
• U.S. EPA Office of Inspector General: Handles complaints about whether EPA enforcement actions adequately protect workers and communities. Can investigate whether the Expedited Settlement Agreement process is being used to systematically under-penalize large corporations.
• U.S. Occupational Safety and Health Administration (OSHA): OSHA’s Process Safety Management (PSM) standard, 29 C.F.R. § 1910.119, covers many of the same chemicals and facilities covered by EPA’s Risk Management Program. An OSHA complaint can trigger a parallel workplace safety inspection.
• Michigan Department of Environment, Great Lakes, and Energy (EGLE): State-level authority with jurisdiction over chemical facility operations in Michigan. State agencies can pursue enforcement independent of federal ESA terms.
• U.S. Department of Justice (DOJ), Environment and Natural Resources Division: The ESA explicitly preserved EPA’s right to pursue criminal sanctions. The DOJ is the pathway for that escalation if new evidence emerges of knowing or willful violations.

What You Can Do Right Now

• If you work at 7000 Portage Road in Kalamazoo or know someone who does: contact the National Council for Occupational Safety and Health (National COSH) at coshnetwork.org to connect with worker safety advocates who operate independently of employer HR systems.
• Submit a formal complaint to OSHA’s online complaint portal (osha.gov/workers/file-complaint) requesting an inspection of Pharmacia & Upjohn’s PSM compliance at the Kalamazoo facility. Complaints can be filed anonymously.
• Contact Michigan EGLE’s Air Quality Division to request public disclosure of any state-level inspection records for this facility that are not captured in the federal EPA docket.
• Support the United Steelworkers (USW) Chemical Workers program and the Paper, Allied-Industrial, Chemical and Energy Workers International Union (PACE) legacy networks, which advocate for chemical process worker safety at exactly the type of facility described in this investigation.
• Share this article with anyone in Kalamazoo County. The community surrounding a facility handling hydrogen fluoride at industrial scale has a right to know whether its neighbor is following federal chemical accident prevention law.