The Non-Financial Ledger

What the Fine Doesn’t Cover: The Human Cost of Routine Neglect

Nobody died in this story. No river caught fire. The EPA documents don’t describe a catastrophe. They describe something arguably more insidious: the slow, daily accumulation of neglect inside an ordinary industrial building in a suburb of Minneapolis, carried out by people who knew the rules and chose not to follow them.

For over two years, workers at the Meyers Printing facility in Brooklyn Park went about their shifts cleaning printing press equipment with solvents like isopropyl alcohol, ethyl acetate, and 2-phenoxyethyl ester of acrylic acid. These aren’t exotic chemicals. They’re the unglamorous backbone of commercial printing. But when they’re used to clean industrial equipment and collect in 55-gallon drums alongside silver residue from the printing process, they become legally and physically dangerous materials. The EPA classifies Meyers’ waste under codes D001 (ignitable), D002 (corrosive), D011 (silver), and F003 (spent solvents). These codes exist because these materials can contaminate groundwater, corrode infrastructure, and cause acute harm to anyone who breathes or touches them in sufficient quantity.

The workers handling those drums — loading them, moving them through staging areas, working near containers that sat open — had no way of knowing whether the container next to their workstation met regulatory storage standards. An unlabeled drum of used oil looks identical to a labeled one. A hazardous waste container sitting open in a staging area is indistinguishable from one that’s properly sealed, unless you already know the rules and happen to check. The regulatory labels and sealed containers that Meyers repeatedly failed to maintain aren’t bureaucratic theater. They are the system by which workers know what they are standing next to and what to do if something goes wrong.

The facility had been generating and managing hazardous waste since at least November 19, 1980 — four and a half decades. These requirements were not new. The company’s own waste characterization records show it knew it was producing D001, D002, D011, and F003 hazardous waste. It classified the waste correctly. It just chose not to tell regulators when it crossed into higher-volume territory, and chose not to maintain the container discipline that the law requires.

The neighborhood around 7277 Boone Ave. N. is a working-class suburb. The people living nearest to that facility are not hedge fund managers. They are the kind of people who rely on public information systems, regulatory inspections, and legally mandated labels to know what is happening in the industrial buildings near their homes, parks, and water tables. When those systems break down quietly, inside ordinary-looking warehouses, the people who absorb the risk are never the executives who sign the settlement agreements.

Christopher Dillon, CEO of The Meyers Printing Companies, Inc., signed this consent agreement. The company paid $18,441. No individual faced criminal liability. No one was required to apologize to anyone. The violations simply stopped — officially — on the day the ink dried.

Legal Receipts

From the EPA’s Own Files: Five Violations, One Inspection, Zero Excuses

The following quotes come directly from the Consent Agreement and Final Order filed with the EPA Region 5 Regional Hearing Clerk on April 25, 2025 (Docket No. RCRA-05-2025-0002). These are not paraphrases. This is what the federal record says.

• This confirms that Meyers Printing operated for a minimum of 28 months without filing the legally required notification that it had crossed into Large Quantity Generator status in certain months. Large Quantity Generator status triggers a stricter set of federal requirements specifically because higher waste volumes pose greater risks to workers and the surrounding environment.
• The company only corrected this violation on March 11, 2024 — the same day it finally filed its overdue 2021 Biennial Report, and notably after the EPA’s January 2024 inspection had already flagged the problem. The timing is difficult to read as anything other than damage control.

• The Biennial Report is the primary mechanism by which regulators track how much hazardous waste a facility is producing and how it is being disposed of. It is not an optional administrative task; it is the foundation of the entire oversight system. Meyers missed the 2022 deadline by over two years.
• Without this report, the Minnesota Pollution Control Agency had no accurate picture of the waste volumes Meyers was generating in 2021 — a year when the company generated 1,000 kilograms or more of hazardous waste in at least one month. Regulators were, in effect, flying blind.

• Under Minnesota and federal law, a hazardous waste generator can avoid the permit requirement only if it follows every applicable condition. One open container in one staging area is enough to void that exemption entirely. That is exactly what happened here: a single unclosed container triggered the legal reclassification of the entire facility as an unpermitted hazardous waste treatment, storage, and disposal facility (TSDF).
• This is the most legally severe violation in the document. Operating as an unpermitted TSDF carries the highest penalties under RCRA. The fact that it was resolved for $18,441 total across all five counts tells you everything about how regulators value corporate compliance over community protection.

• The labeling requirement for used oil exists so that anyone handling the containers, including workers, emergency responders, and waste haulers, knows immediately what the substance is and how to handle it safely. “Oil Filters” and “Used Oil Filters” are not legally equivalent terms.
• The presence of multiple mislabeled and unlabeled containers in a facility that has been managing hazardous and regulated waste since 1980 is not an oversight. It is a pattern.

• Fluorescent lamps contain mercury. Batteries contain lead, cadmium, and other heavy metals. These are not hypothetically dangerous materials. The universal waste rules exist because improper storage and disposal of these items has documented, measurable environmental consequences.
• Six open boxes of lamps and three unlabeled battery containers in a facility with a dedicated 90-day hazardous waste storage room — a room that exists specifically because the company knows it generates regulated waste — represents a complete failure to apply the most basic storage discipline.

Societal Impact Mapping

Who Actually Pays When a Printing Company Ignores Hazardous Waste Law

Environmental Degradation

The waste streams at this facility include materials specifically regulated because of their documented capacity to harm soil, groundwater, and aquatic ecosystems.

• Meyers’ waste includes hazardous code F003, which covers spent non-halogenated solvents including ethyl acetate, isopropyl alcohol, and related compounds. These solvents are persistent in soil and groundwater and are classified as hazardous precisely because improper disposal can contaminate drinking water sources for communities near industrial facilities.
• Silver waste (hazardous code D011) is a heavy metal contaminant. Silver compounds in groundwater are toxic to aquatic organisms at low concentrations and are not easily remediated once they enter a water table. The Minneapolis-Saint Paul metro area sits above glacial aquifer systems that serve as regional water sources.
• Six open boxes of fluorescent lamps in an unsecured storage room represent a mercury release risk. Mercury from broken fluorescent lamps can volatilize into air (acute inhalation hazard) or leach into soil and water if improperly disposed of. The closed-container requirement exists specifically to contain both risks.
• Unlabeled battery containers holding lead-acid or cadmium-bearing batteries, stored in a 90-day hazardous waste room, represent an untracked quantity of heavy metals without the accountability chain that labeling and reporting requirements are designed to create.

Public Health

The workers inside this facility and the residents of Brooklyn Park, Minnesota, bore the uncompensated risk of these violations for the duration of the misconduct.

• Workers cleaning printing presses with the solvents described in this case — including 2-phenoxyethyl ester of acrylic acid (a skin and respiratory irritant) and isopropyl alcohol (a central nervous system depressant at high concentrations) — depend on proper container management and labeling to understand what they are handling and what to do in an accident. An open, unlabeled drum removes that protection entirely.
• The ignitable waste classification (D001) means containers held materials with a flash point below 60 degrees Celsius. An unclosed container of ignitable waste in a production staging area is a fire and explosion risk to everyone in the building, including workers with no knowledge of or responsibility for the hazardous waste compliance failures.
• The facility’s two years of unreported Large Quantity Generator status means that Minnesota regulators had incomplete information about the actual volume of hazardous materials being stored and transported through Brooklyn Park during those months. That gap in data directly limits the ability of emergency responders to plan for chemical incidents at the site.
• The absence of required “Used Oil” and “Used Oil Filters” labels means any worker, contractor, or emergency responder encountering those containers during the inspection period had no guaranteed way to know the contents or the appropriate handling procedures.

Economic Inequality

The financial structure of this settlement concentrates risk in working-class communities while distributing the cost of non-compliance across the public.

• The $18,441 penalty is, by any reasonable measure, a cost of doing business rather than a deterrent. For a commercial printing company generating 1,000 kilograms or more of hazardous waste per month in peak periods, the legal, logistical, and compliance costs saved by not filing reports, not labeling containers, and not obtaining permits likely exceeded the penalty amount many times over.
• Brooklyn Park, Minnesota, is a working-class suburb with significant immigrant and refugee populations. Environmental justice research consistently documents that industrial facilities with poor compliance records are disproportionately located in or adjacent to lower-income communities. The residents nearest to 7277 Boone Ave. N. had no seat at the table when this settlement was negotiated.
• When hazardous waste incidents occur at improperly managed facilities, the costs of remediation, medical care, and property devaluation are externalized onto local governments, public health systems, and individual residents. The $18,441 penalty does nothing to compensate or prepare for those downstream costs.
• The company’s attorneys (on record as lremakel@fredlaw.com and ddriscoll@fredlaw.com, representing Fredrikson and Byron, P.A.) negotiated a consent agreement that waived Meyers’ right to a hearing, waived its right to contest the allegations, and waived its right to appeal — in exchange for the lowest possible penalty. Workers and neighbors had no equivalent legal representation in this process.

The “Cost of a Life” Metric

The Arithmetic of Impunity

The EPA has a legal ceiling on what it can charge per violation per day. Here is what Meyers Printing actually paid, and what that number means in context.

What Now?

Who to Pressure and How to Protect Your Community

The Meyers Printing case is closed on paper, but the structural conditions that made it possible — weak penalty enforcement, minimal public notification, and a settlement process that excludes affected communities — remain fully intact. Here is where accountability actually lives and what you can do about it.

Who Signed This Agreement

• Christopher Dillon, CEO, The Meyers Printing Companies, Inc. — signed the consent agreement on behalf of the company.
• Michael D. Harris, Division Director, Enforcement and Compliance Assurance Division, EPA Region 5 — signed on behalf of the EPA, digitally on April 24, 2025.
• Ann L. Coyle, Regional Judicial Officer, EPA Region 5 — issued the Final Order on April 25, 2025.

Regulatory Watchlist

• U.S. EPA Region 5 (Chicago): The regional office with jurisdiction over Minnesota. They conducted this inspection and negotiated this settlement. Contact them to request public disclosure of the full compliance history for Meyers Printing’s facility, EPA ID for this site, and any prior enforcement actions. R5LECAB@epa.gov is the public enforcement contact on record.
• Minnesota Pollution Control Agency (MPCA): The state agency authorized under RCRA to administer Minnesota’s hazardous waste program. The MPCA received the overdue 2021 Biennial Report and the LQG notification in March 2024. Request their compliance file for the facility at 7277 Boone Ave. N., Brooklyn Park, MN 55428.
• EPA’s RCRA Enforcement Program: Submit a tip or complaint about hazardous waste violations at any facility through EPA’s online enforcement portal. Citizen complaints have historically triggered inspections that formal oversight missed.
• EPA Office of Inspector General (OIG): If you believe the penalty assessed in this case was inadequate or that the settlement process was mishandled, the OIG accepts public complaints about EPA enforcement actions.

Mutual Aid, Local Organizing, and Grassroots Resistance

• Request the full RCRA inspection report: Under the Freedom of Information Act (FOIA), you can request the complete Compliance Evaluation Inspection report from EPA Region 5. The CAFO is a summary; the full inspection file contains site photographs, sample results, and inspector notes that were not published in this settlement document.
• Connect with Brooklyn Park neighbors: Contact the Brooklyn Park Environmental Commission and Hennepin County’s Environmental Services division to ask whether the community was formally notified of the violations at 7277 Boone Ave. N. and whether any soil or groundwater monitoring was conducted near the facility.
• Support environmental justice organizations in the Twin Cities metro: Organizations like the Minnesota Environmental Justice Table and the Center for Earth, Energy and Democracy work specifically on industrial pollution accountability in communities of color and working-class neighborhoods in the Minneapolis-Saint Paul area. Direct financial support and volunteer time amplify their capacity to monitor facilities like this one.
• Push for stiffer penalties at the state level: Contact your Minnesota state legislators to demand that hazardous waste penalty structures be reviewed for deterrence. The current federal ceiling of $124,426 per day is only a ceiling; what gets assessed is a negotiated outcome. Legislative pressure can shift that negotiation.
• If you work at this facility or a similar one: You have whistleblower protections under Section 11(c) of RCRA (42 U.S.C. § 6971) if you report hazardous waste violations to federal or state authorities. The EPA’s Office of Environmental Justice and External Civil Rights can provide guidance on your rights.

The Record vs. The Reality

What Meyers Told Regulators vs. What EPA Found