Sherwin-Williams Breaks Environmental Laws… EPA Responds With a Slap on the Wrist

Sherwin-Williams Fined $10,000 After Hazardous Waste Violations in Iowa
Corporate Misconduct Accountability Project

Sherwin-Williams Fined $10,000 After Hazardous Waste Violations in Iowa

EPA inspectors found unlabeled hazardous waste drums, open containers of flammable solvents, and no emergency coordination at Cedar Rapids paint store Branch 3527. The company paid a penalty equal to minutes of global revenue.

HIGH SEVERITY
TL;DR

On July 11, 2023, EPA inspectors discovered eight serious hazardous waste violations at a Sherwin-Williams paint store in Cedar Rapids, Iowa. The facility left drums of flammable paint solvents unsealed and unlabeled, failed to mark waste with required hazardous codes, and never coordinated with local emergency responders. Nearly two years later, the EPA settled for a $10,000 penalty against a company that reported over $23 billion in annual sales.

This case shows how multinational corporations treat safety violations as minor business expenses while communities bear the risk of chemical fires and toxic exposure.

$10,000
Total EPA civil penalty assessed
$23.1B
Sherwin-Williams 2024 annual revenue
8
Separate RCRA violations documented
21 months
Delay between inspection and final order

The Allegations: A Breakdown

โš ๏ธ
Core Allegations
What They Did · 8 points
01 Sherwin-Williams failed to label its shop rag container with the required words ‘Excluded Solvent Contaminated Wipes,’ violating 40 C.F.R. section 262.4(b)(18)(i). Proper labels alert workers and waste haulers that solvent-soaked rags can spontaneously combust if mishandled. high
02 The facility prepared a full container of hazardous waste paint and solvent for transport but never marked it with applicable EPA hazardous waste codes, violating 40 C.F.R. section 262.11(g). These codes trigger specialized handling, transport, and disposal safeguards required by law. high
03 Inspectors found a one-third full container of hazardous waste paint and solvent sitting open due to an unsealed bung hole and unlatched funnel, violating 40 C.F.R. section 262.16(b)(2)(iii)(A). Open containers allow toxic vapors to escape into the workplace and create fire hazards. high
04 Two separate containers of hazardous waste paint and solvent lacked any indication of the nature of the hazard, violating 40 C.F.R. section 262.16(b)(5)(i)(B). Workers cannot protect themselves from dangers they cannot see or identify. high
05 The facility failed to mark two containers of hazardous waste with accumulation start dates as required by 40 C.F.R. section 262.16(b)(1)(C). Without these dates, regulators cannot verify whether waste exceeded legal storage time limits. medium
06 Sherwin-Williams had never made arrangements with local emergency authorities, violating 40 C.F.R. section 262.16(b)(8)(vi)(A)(2). Emergency responders arrived at inspections with no knowledge of facility layout, waste types, or evacuation routes. high
07 The company never familiarized coordinating agencies with facility layout, waste types, access points, evacuation routes, and likely casualty types as required by 40 C.F.R. section 262.16(b)(8)(vi)(A)(2). First responders would arrive blind to critical safety information during an emergency. high
08 The facility failed to maintain any records documenting arrangements with response agencies, violating 40 C.F.R. section 262.16(b)(8)(vi)(B). This recordkeeping failure made it impossible to verify whether emergency coordination had ever occurred. medium
๐Ÿ“‹
Regulatory Failures
How Oversight Broke Down · 6 points
01 EPA inspectors identified all eight violations during a single inspection on July 11, 2023, but the final order was not filed until April 14, 2025. This 21-month delay left the Cedar Rapids community exposed to ongoing risk while bureaucratic processes ground forward. high
02 The EPA authorized this settlement under the expedited settlement agreement process in 40 C.F.R. section 22.13(b), allowing rapid resolution without full administrative hearings. This streamlined approach favors quick closure over thorough public accountability. medium
03 The settlement permits Sherwin-Williams to ‘neither admit nor deny’ the factual allegations while simultaneously certifying that violations have been corrected. This legal posture allows the company to avoid public admission of wrongdoing despite documented evidence. medium
04 The agreement resolves only federal civil penalties for the specific violations alleged, explicitly reserving EPA’s right to pursue any other past, present, or future violations. The settlement creates no incentive for comprehensive safety improvements beyond the eight items caught. high
05 Each party agreed to bear its own costs and fees, meaning taxpayers absorbed the expense of investigating and documenting violations while Sherwin-Williams paid only the $10,000 penalty. The company faced no reimbursement obligation for public enforcement resources. medium
06 The penalty amount represents approximately 0.00004 percent of Sherwin-Williams’ $23.1 billion in 2024 annual sales. At this scale, the fine functions as a trivial cost of doing business rather than a meaningful deterrent. high
๐Ÿ’ฐ
Profit Over People
Corporate Cost-Cutting at Public Expense · 5 points
01 Sherwin-Williams skipped basic safety steps including proper labeling, container closure, and emergency coordination. Every minute saved on compliance translates to faster throughput and incrementally higher quarterly earnings. high
02 The company certified that the penalty ‘shall not be deductible for purposes of Federal, State and local taxes,’ but it retains numerous levers to recoup the cost. Small price increases across thousands of products can recover $10,000 in a single business day. medium
03 Branch 3527’s legal structure as a separately identified facility creates a liability firewall that shields the parent corporation’s billions. If an explosion or toxic release occurred, financial exposure could be corralled within this single location. high
04 The settlement required Sherwin-Williams to certify present compliance with all RCRA requirements but imposed no ongoing monitoring, third-party audits, or public reporting. The company fixed only what inspectors caught, nothing more. medium
05 Sherwin-Williams operates thousands of retail locations nationwide, yet this Cedar Rapids case appears as an isolated incident in public records. The lack of pattern evidence may reflect limited inspection resources rather than genuine corporate safety culture. medium
๐Ÿฅ
Public Health and Safety
Risks Imposed on Workers and Community · 6 points
01 Inspectors found an open container of hazardous paint waste and solvent with an unsealed bung hole and unlatched funnel. Open solvent drums release volatile organic compound vapors that create combustible atmospheres and cause respiratory illness. high
02 The facility’s failure to coordinate with local emergency authorities meant firefighters and medics had no knowledge of chemical inventories, facility layout, or evacuation routes. First responders arriving at a chemical fire would face life-threatening unknowns. high
03 Missing hazard labels on two waste containers forced workers to guess at toxicity and flammability levels of materials they handled daily. Employees cannot protect themselves from dangers that remain invisible and unidentified. high
04 Unlabeled shop rags contaminated with solvents pose spontaneous combustion risk when improperly stored or transported. The facility’s failure to mark these containers ‘Excluded Solvent Contaminated Wipes’ increased fire danger for workers and waste haulers. medium
05 Paint solvents contain volatile organic compounds that contribute to ground-level ozone formation and smog. The open drum accelerated VOC evaporation inside a retail storefront where customers and employees breathed contaminated air. medium
06 The facility sits at 3501 J Street SW in Cedar Rapids, a mixed residential and industrial corridor less than three miles from downtown. An ignition event could spread vapors and firefighting runoff into the nearby Cedar River floodplain. high
๐Ÿ‘ท
Worker Exploitation
Employees Bear the Greatest Risk · 4 points
01 Sherwin-Williams employees handled hazardous waste paint and solvents in containers missing required hazard warnings. Workers were denied basic information needed to protect themselves from chemical burns, inhalation injuries, and fire risk. high
02 The open drum with unsealed bung hole and unlatched funnel sat in the workspace where employees breathed solvent vapors linked to neurological damage. Frontline staff absorbed toxic exposure while managers prioritized production speed over safety. high
03 Lack of documented emergency coordination meant Branch 3527 workers had no drills, no evacuation maps, and no clear response protocols if a chemical fire erupted. Employees closest to the company’s profit engine faced the greatest unmitigated danger. high
04 The facility never familiarized local emergency responders with site layout or waste types, leaving workers dependent on outside help that would arrive unprepared. In the critical first minutes of a chemical emergency, employees would face life-or-death decisions alone. high
๐Ÿ˜๏ธ
Community Impact
Cedar Rapids Residents Left at Risk · 5 points
01 Branch 3527 operates on J Street SW in a mixed residential and industrial area where neighbors drive past the paint store daily. An ignition event involving unsealed solvent drums would not remain contained within warehouse walls. high
02 The 21-month gap between the July 2023 inspection and April 2025 final order left Cedar Rapids residents in regulatory limbo. During this period, the community had no public assurance that hazards were abated while Sherwin-Williams continued normal operations. high
03 Local fire departments and emergency medical services must now draft contingency plans and purchase specialized equipment to respond to chemical incidents at the facility. These preparedness costs fall on Cedar Rapids taxpayers, not the corporation that created the risk. medium
04 Even rumored chemical safety issues can depress property values in industrial corridors, eroding household wealth for homeowners near Branch 3527. The settlement provides zero compensation or monitoring funds to affected community members. medium
05 EPA notified the State of Iowa about the RCRA violations as required by Section 3008(a)(2), but the settlement document provides no evidence that state regulators imposed additional penalties or oversight. Federal enforcement appears to be the sole consequence. low
โš–๏ธ
Corporate Accountability Failures
Loopholes That Let Companies Off Easy · 6 points
01 The settlement resolves only civil liability for the eight specific violations documented during the July 2023 inspection. Criminal charges, personal liability for executives, and future violations remain entirely unaddressed. high
02 Sherwin-Williams waived its right to a jury trial and any challenge to the lawfulness of the final order by signing the expedited settlement agreement. The company traded full legal process for rapid case closure and minimal publicity. medium
03 By certifying ‘neither admits nor denies the factual allegations,’ Sherwin-Williams avoided any public acknowledgment that it left hazardous waste drums open, unlabeled, and undated. The legal formula converts documented violations into procedural ambiguity. medium
04 The agreement requires no community restitution, no mandatory environmental monitoring, and no third-party safety audits. Full payment of the $10,000 penalty extinguishes all federal civil liability for the documented misconduct. high
05 The settlement became binding and effective on the date the Regional Judicial Officer filed the final order, April 14, 2025. Sherwin-Williams faced a 30-day payment deadline but no ongoing compliance verification beyond self-certification. medium
06 The document states that the penalty ‘is in the public interest’ after EPA considered factors specified in RCRA Section 3008. No breakdown of those factors appears in the public settlement, leaving penalty calculation opaque. low
โณ
Exploiting Delay
How Time Itself Becomes a Weapon · 4 points
01 EPA inspectors documented all eight RCRA violations during a single site visit on July 11, 2023. The expedited settlement agreement was not signed by Sherwin-Williams until December 12, 2024, and the final order was not filed until April 14, 2025. high
02 During the 21 months between inspection and final order, Sherwin-Williams continued selling paint, investors collected dividends, and the Cedar Rapids community absorbed ongoing risk. Delay reduced the net present cost of the penalty while diffusing public attention. high
03 The company certified that violations ‘have been corrected’ and that it is ‘presently in compliance’ as of the agreement signing date. This language implies the hazards persisted for nearly two years after EPA discovered them. high
04 The 30-day payment deadline following the April 14, 2025 effective date pushes final financial consequence to mid-May 2025. From initial violation discovery to closed enforcement case spans roughly two years, allowing ample time for public interest to fade. medium
๐Ÿ“ข
The PR Machine
Corporate Spin Tactics in Action · 4 points
01 Sherwin-Williams secured language stating it ‘neither admits nor denies the factual allegations contained herein’ while simultaneously certifying that violations have been corrected. This careful phrasing allows corporate communications to emphasize compliance without acknowledging wrongdoing. medium
02 The company certified under penalty of making false statements that ‘the alleged violations have been corrected’ and that it is ‘presently in compliance with all requirements of RCRA.’ These self-reported claims carry no independent verification or ongoing monitoring requirement. medium
03 The settlement agreement includes a clause requiring each party to ‘bear its own costs and fees.’ This language creates equivalence between a global paint corporation and federal regulators, obscuring the fact that taxpayers funded the investigation. low
04 Sherwin-Williams consented to electronic service of the filed settlement at SW3527@sherwin.com and acknowledged that ‘the ESA will become publicly available upon filing.’ The company accepted public disclosure only after securing favorable ‘neither admit nor deny’ language. low
๐Ÿ’ธ
Wealth Disparity
Who Profits, Who Pays · 5 points
01 Sherwin-Williams reported $23.1 billion in consolidated net sales for 2024. The $10,000 EPA penalty represents approximately 0.00004 percent of annual revenue, or roughly one minute of global sales. high
02 When fines represent trivial fractions of corporate revenue, misconduct migrates from business risk to business model. The settlement confirms that hazardous waste violations can be resolved for less than the cost of a single executive bonus. high
03 Cedar Rapids taxpayers funded the EPA inspection, investigation, and enforcement action through federal appropriations, but the settlement directs the $10,000 penalty to the United States Treasury. No funds flow back to the community that bore the risk. medium
04 Local emergency services must now invest in hazmat equipment, training, and contingency planning to prepare for potential incidents at Branch 3527. These ongoing preparedness costs accumulate in city budgets while corporate profits remain untouched. medium
05 The settlement allows Sherwin-Williams to continue operations immediately upon payment, with no financial reserves, bonds, or insurance requirements to cover potential future incidents. All residual risk remains externalized to the community. medium
๐ŸŽฏ
The Bottom Line
What This Case Reveals About Corporate Power · 5 points
01 A multinational paint corporation with over $23 billion in annual sales resolved eight serious hazardous waste violations for a penalty equal to minutes of revenue. The financial consequence was too small to change corporate behavior or deter future misconduct. high
02 For 21 months after EPA inspectors documented open solvent drums and missing emergency coordination, Cedar Rapids residents lived with unabated risk while bureaucratic settlement processes unfolded. Delay itself became a tool that benefited the corporation at community expense. high
03 The settlement imposed no ongoing monitoring, no community restitution, no mandatory safety audits, and no personal liability for executives. Accountability was reduced to a modest check payable to the U.S. Treasury with no direct benefit to those at risk. high
04 Sherwin-Williams certified present compliance without admitting past wrongdoing, transforming documented violations into procedural closure. This legal formula allows corporations to move forward without reputational damage or lessons learned. medium
05 The case demonstrates how regulatory systems designed to protect public health can be reduced to cost-benefit calculations where companies weigh trivial fines against the expense of comprehensive safety programs. When penalties are this low, prevention loses every time. high

Timeline of Events

July 11, 2023
EPA inspectors conduct compliance inspection at Sherwin-Williams Branch 3527 in Cedar Rapids and discover eight RCRA violations including open solvent drums and missing emergency coordination
December 12, 2024
Sherwin-Williams signs the Expedited Settlement Agreement, certifying that violations have been corrected and the facility is now in compliance
April 11, 2025
David Cozad, Director of EPA Enforcement and Compliance Assurance Division, and Christopher Muehlberger, EPA Attorney, digitally sign approval of the settlement
April 14, 2025
Regional Judicial Officer Karina Borromeo files the Final Order at 7:16 AM, making the settlement effective and starting the 30-day payment clock
May 14, 2025
Payment deadline: Sherwin-Williams must deliver $10,000 penalty to U.S. Treasury via certified check or electronic payment

Direct Quotes from the Legal Record

QUOTE 1 Open Solvent Container Violation allegations
“40 C.F.R ยง 262.16(b)(2)(iii)(A) requires that a generator keep containers of hazardous waste closed during accumulation, except when it is necessary to add or remove waste. At the time of the EPA inspection, a container of hazardous waste paint and waste solvent, approximately one-third full, was not closed due to an open bung hole and an unlatched funnel.”

๐Ÿ’ก Open containers allow toxic vapors to escape and create fire hazards in the workplace and retail environment

QUOTE 2 Missing Emergency Coordination health
“40 C.F.R ยง 262.16(b)(8)(vi)(A)(2) requires that a generator makes arrangements with local emergency authorities. It was determined during the EPA inspection that the facility had not previously made arrangements with local emergency authorities.”

๐Ÿ’ก Firefighters and medics would arrive at a chemical emergency with no knowledge of facility layout, waste types, or evacuation routes

QUOTE 3 Missing Hazard Labels workers
“40 C.F.R ยง 262.16(b)(5)(i)(B) requires that a generator labels containers of hazardous waste with an indication of the nature of the hazard. At the time of the EPA inspection, two containers of hazardous waste paint and waste solvent were not labeled with indications of the nature of the hazard.”

๐Ÿ’ก Workers cannot protect themselves from chemical dangers they cannot identify or see marked on containers

QUOTE 4 Neither Admits Nor Denies pr_machine
“In signing this Agreement, Respondent: (a) admits that Respondent is subject to RCRA and its implementing regulations; (b) admits that EPA has jurisdiction over Respondent and Respondent’s conduct as alleged herein, (c) neither admits nor denies the factual allegations contained herein; (d) consents to the assessment of this penalty”

๐Ÿ’ก This legal language allows the company to settle without publicly acknowledging the documented violations

QUOTE 5 Self-Certification of Compliance accountability
“By its signature below Respondent certifies, subject to civil and criminal penalties for making a false submission to the United States Government, that: (a) the alleged violations have been corrected, and (b) it is presently in compliance with all requirements of RCRA, 42 U.S.C. ยง 6901 et. seq., its implementing regulations, and any permit issued pursuant to RCRA.”

๐Ÿ’ก The company self-reports compliance with no requirement for independent verification or ongoing monitoring

QUOTE 6 Penalty Not Tax Deductible wealth
“The penalty specified herein shall represent civil penalties assessed by EPA and shall not be deductible for purposes of Federal, State and local taxes.”

๐Ÿ’ก While the penalty cannot be written off as a business expense, it represents only 0.00004% of annual revenue

QUOTE 7 Each Party Bears Own Costs regulatory
“Each party shall bear its own costs and fees, if any.”

๐Ÿ’ก Taxpayers funded the investigation and enforcement action, but no costs are recovered from the violating corporation

QUOTE 8 Limited Scope of Settlement accountability
“Full payment of the civil penalty shall only resolve Respondent’s liability for federal civil penalties for the violations alleged herein. The EPA reserves the right to take any enforcement action with respect to any other past, present, or future violations of RCRA or any other applicable law.”

๐Ÿ’ก The settlement resolves only these eight specific violations with no broader accountability for corporate safety practices

QUOTE 9 Waiver of Legal Rights accountability
“By signing this Agreement, Respondent waives any rights or defenses that Respondent has or may have for this matter to be resolved in federal court, including, but not limited to any right to a jury trial, and waives any right to challenge the lawfulness of the final order accompanying the Expedited Settlement Agreement.”

๐Ÿ’ก The company traded full legal process for rapid case closure and minimal public scrutiny

QUOTE 10 Penalty Determination Factors regulatory
“In determining the amount of the penalty to be assessed, EPA has taken into account the factors specified in Section 3008 of RCRA, 42 U.S.C. ยง 6928. After considering these factors, EPA has determined and Respondent agrees that settlement of this matter for a civil penalty of ten thousand dollars ($10,000.00) is in the public interest.”

๐Ÿ’ก EPA concluded that a penalty equal to minutes of corporate revenue serves the public interest despite serious safety violations

QUOTE 11 Missing Accumulation Start Dates allegations
“40 C.F.R ยง 262.16(b)(i)(C) requires that a generator marks accumulating containers of hazardous waste with an accumulation start date. At the time of the EPA inspection, two containers of hazardous waste paint and waste solvent were not marked with accumulation start dates.”

๐Ÿ’ก Without dates, regulators cannot verify whether waste exceeded legal storage time limits

QUOTE 12 Missing Hazardous Waste Codes allegations
“40 C.F.R ยง 262.11(g) requires that a facility marks its containers with applicable EPA hazardous waste codes prior to shipping waste off site. At the time of the EPA inspection, a container of hazardous waste paint and waste solvent was full and prepared for transport but was not labeled with the applicable EPA hazardous waste codes.”

๐Ÿ’ก These codes trigger specialized handling and disposal safeguards required to protect workers and the public

QUOTE 13 No Emergency Familiarization community
“40 C.F.R ยง 262.16(b)(8)(vi)(A)(2) requires that a generator familiarizes coordinating agencies with facility layout, waste types, access points, evacuation routes, and likely casualty types. It was determined during the EPA inspection that the facility had not familiarized coordinating agencies with the facility.”

๐Ÿ’ก First responders would arrive at a chemical emergency without critical information needed to save lives

QUOTE 14 No Records of Emergency Coordination allegations
“40 C.F.R ยง 262.16(b)(8)(vi)(B) requires that a generator maintain records documenting arrangements with response agencies. It was determined during the EPA inspection that the facility had not documented relevant arrangements with response agencies.”

๐Ÿ’ก The complete absence of records suggests emergency coordination had never occurred

QUOTE 15 State Notification Requirement community
“The EPA has provided the State of Iowa with notice of the referenced violations of Subtitle C of RCRA as required by Section 3008(a)(2).”

๐Ÿ’ก Federal law requires state notification but the settlement shows no evidence of additional state enforcement action

Frequently Asked Questions

โ“What exactly did Sherwin-Williams do wrong at the Cedar Rapids facility?
EPA inspectors found eight separate violations during a July 2023 inspection. The company left hazardous waste containers open and unsealed, failed to label drums with required hazard warnings and waste codes, did not mark containers with accumulation start dates, and never coordinated with local fire departments or emergency responders. These failures created fire hazards and left first responders unprepared for a potential chemical emergency.
โ“How much was the penalty and how does it compare to company revenue?
Sherwin-Williams paid a $10,000 civil penalty. The company reported $23.1 billion in annual sales for 2024, meaning the fine represents approximately 0.00004 percent of yearly revenue or roughly one minute of global sales. At this scale, the penalty functions as a trivial business expense rather than a meaningful deterrent.
โ“How long did it take EPA to resolve this case after finding the violations?
EPA inspectors documented all eight violations on July 11, 2023. The company did not sign the settlement agreement until December 12, 2024, and the final order was not filed until April 14, 2025. This 21-month delay left the Cedar Rapids community in regulatory limbo while the violations were supposedly being corrected.
โ“Did Sherwin-Williams admit to the violations?
No. The settlement allows the company to ‘neither admit nor deny the factual allegations’ while simultaneously certifying that violations have been corrected and the facility is now in compliance. This legal language lets executives issue statements about safety commitments without ever publicly acknowledging the documented misconduct.
โ“What were the risks to workers and the community?
Open containers of paint solvent release toxic vapors that cause respiratory illness and create combustible atmospheres. Missing hazard labels meant workers could not identify dangers. The complete failure to coordinate with emergency responders meant firefighters would arrive at a chemical fire with no knowledge of facility layout, waste types, or evacuation routes. The facility sits in a mixed residential and industrial area less than three miles from downtown Cedar Rapids.
โ“Will the community receive any compensation or ongoing monitoring?
No. The $10,000 penalty goes to the United States Treasury. The settlement requires no community restitution, no mandatory environmental monitoring, no third-party safety audits, and no funds for local emergency preparedness. Cedar Rapids taxpayers funded the investigation but receive no direct benefit from the settlement.
โ“Could Sherwin-Williams face criminal charges or additional penalties?
The settlement resolves only federal civil penalties for the eight specific violations documented in July 2023. EPA explicitly reserved the right to pursue any other past, present, or future violations. However, the agreement contains no criminal charges and no personal liability for corporate executives.
โ“How does EPA verify that Sherwin-Williams actually fixed the problems?
The company certified under penalty of making false statements that violations have been corrected and it is presently in compliance. The settlement requires no independent verification, no ongoing monitoring, and no follow-up inspections. Compliance is self-reported by the same company that committed the original violations.
โ“Why did Sherwin-Williams agree to this settlement?
By signing the expedited settlement agreement, the company avoided full administrative hearings, waived its right to a jury trial, and closed the case quickly with minimal publicity. The modest penalty and favorable legal language allowing it to ‘neither admit nor deny’ wrongdoing made settlement far more attractive than prolonged litigation.
โ“What can concerned citizens do about corporate hazardous waste violations?
Request public records from EPA and state environmental agencies about facilities in your community. Attend local emergency planning committee meetings where hazardous materials coordination is discussed. Support legislation that indexes corporate penalties to revenue rather than flat dollar amounts. File Freedom of Information Act requests to track whether cited violations have been corrected. Contact elected representatives to demand stronger enforcement and community restitution requirements in environmental settlements.
Post ID: 3717  ยท  Slug: sherwin-williams-epa-hazardous-waste-fine  ยท  Original: 2025-05-12  ยท  Rebuilt: 2026-03-20

Please visit this link for a different article on Sherwin-Williams’ rampant pollution: https://evilcorporations.com/sherwin-williams-toxic-scandal-epa-public-health-impact/

I also did this article here about one of their subsidiaries in California: https://evilcorporations.com/engineered-polymer-solutions-sherwin-williams-hazardous-waste-rcra-california-epa-fine/

You can read this expedited settlement agreement between the EPA and Sherwin-Williams on the EPA’s website: https://yosemite.epa.gov/OA/RHC/EPAAdmin.nsf/Filings/3D5085CA8217EF2785258C6C004D19F8/$File/Sherwin-Williams%20Branch%203527%20Expedited%20Settlement%20Agreement%20and%20Final%20Order.pdf

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