Sherwin-Williams, a company that earned over $23 billion in revenue in 2023, stored drums of arsenic, lead, cadmium, benzene, and chromium waste in an open warehouse in Winter Haven, Florida — and the federal government’s response was a fine of $213,750 ($213,750, roughly what a single American nurse earns over four years of full-time work).

What Happened Inside That Warehouse

On March 21, 2023, EPA inspectors and the Florida Department of Environmental Protection walked into Sherwin-Williams’ warehouse and distribution center at 400 Bert Schulz Boulevard in Winter Haven, Florida. What they found was a textbook study in corporate negligence: open containers of toxic waste, unlabeled drums of hazardous material, leaking batteries left on the floor, and a disaster response plan that listed a contact person who had not worked at the facility since the summer of 2022.

The facility operates as a large-scale distribution center supplying Sherwin-Williams retail stores and other markets with latex, traffic, automotive, and marine paints. By law, any facility generating more than 1,000 kilograms of hazardous waste per month qualifies as a “Large Quantity Generator” and faces a strict set of federal and state rules about how that waste must be stored, labeled, and tracked. Sherwin-Williams’ Winter Haven warehouse hit that threshold — and then ignored most of the rules that came with it.

Inspectors documented twelve separate categories of violations in a single day. The EPA emailed its findings to Sherwin-Williams on May 11, 2023, revised those findings after the company submitted additional information, and issued a final revised report on November 14, 2023. The settlement order was signed and filed with the Regional Hearing Clerk on May 21, 2025 — more than two years after inspectors first walked through the door.

The Chemicals They Left Sitting in Open Drums

The hazardous waste codes documented at the facility read like a who’s-who of public health nightmares. Inspectors found waste classified under codes for ignitability (D001), corrosivity (D002), arsenic (D004), barium (D005), cadmium (D006), chromium (D007), lead (D008), benzene (D018), o-cresol (D023), methyl ethyl ketone (D035), and spent solvent mixtures containing acetone/xylene (F003) and methyl ethyl ketone/toluene (F005). That is eleven distinct hazardous waste designations found at a single paint warehouse.

Benzene alone — classified under waste code D018 — is a confirmed human carcinogen linked to leukemia and other blood cancers. Lead, classified under D008, causes irreversible neurological damage, particularly in children. Cadmium, classified under D006, damages the kidneys and lungs with repeated exposure. These are chemicals that the federal government mandates be handled with precision documentation, sealed containers, and trained personnel. Sherwin-Williams stored them in open, unlabeled drums.

The company also accumulated more than 5,000 kilograms of universal waste — including batteries and lamps — which triggered an additional layer of regulatory requirements it also failed to meet. Inspectors found 28 “NexSys” batteries, 4 “GEL” batteries, and 6 small security batteries in the Central Accumulation Area, plus 2 more “GEL” batteries in the Trailer Maintenance Shop — none of them properly labeled, and none with documentation proving how long they had been sitting there.

Leaking Batteries Left on the Floor — For How Long, Nobody Knows

Three lead-acid batteries found in two separate equipment battery areas were visibly not in good condition and were actively leaking. Federal law requires immediate action the moment a container begins to leak: transfer the waste, fix the problem, document everything. Sherwin-Williams did none of those things. The batteries sat there, leaking acid onto the warehouse floor, until federal inspectors arrived and pointed it out.

The Non-Financial Ledger

The human cost that no settlement check can cover.

Start with the chemicals. The EPA documented eleven distinct categories of hazardous waste at the Winter Haven facility. These are categories assigned by federal regulators specifically because the substances inside them can kill, maim, and sicken human beings. Arsenic causes cancer. Lead destroys developing brains. Benzene causes leukemia. Cadmium shreds kidneys. Chromium damages the lungs. These are not abstractions or regulatory technicalities. They are the documented, peer-reviewed, scientifically established health consequences of exposure to the exact substances Sherwin-Williams left sitting in open and unlabeled drums inside a working warehouse.

The people most at risk in this scenario are the warehouse workers who showed up to their jobs every single day inside that building. They were not chemists or hazmat technicians. They were distribution center employees loading paint products for Sherwin-Williams stores. The EPA found that workers filling positions related to hazardous waste management had no documented training. Sherwin-Williams could not produce records proving employees had completed any required program — classroom, online, or on-the-job — for handling hazardous waste safely. These workers may have had no idea what was sitting open in those drums, because the company had also failed to label the containers with the hazard information required by law.

Now consider the emergency preparedness failure on top of that. If a fire had broken out, or if those open drums had spilled, or if those leaking lead-acid batteries had ignited — what would have happened? The company’s own emergency response plan listed a coordinator who had not worked at the facility since the summer of 2022. First responders — firefighters, paramedics, hazmat teams — who responded to an emergency call would have been working from a plan referencing a contact who no longer existed, with no map showing where the hazardous waste was stored. The quick reference guide given to local emergency responders contained no such map. Sherwin-Williams had also failed to even confirm that local fire departments, hospitals, and emergency response teams had received a copy of the plan at all.

The 57 drums of hazardous paint waste shipped off-site without the required federal Uniform Hazardous Waste Manifest represent a specific category of institutional failure that extends beyond Winter Haven. A manifest is the legal paper trail that follows hazardous waste from the moment it leaves a facility to the moment it reaches a licensed treatment or disposal site. Without it, regulators cannot verify where the waste went, who handled it, or whether it was properly disposed of. Sherwin-Williams shipped 57 drums — each holding up to 55 gallons — containing lead, cadmium, chromium, and flammable solvents, without that paper trail. The company only produced the manifest after the EPA asked about it during the inspection, and the land disposal restriction notice only followed after that. The question of where that waste traveled and what condition those drums arrived in is one the EPA document does not answer.

The penalty itself is its own kind of insult. Sherwin-Williams reported net revenues of approximately $23.05 billion in 2023. The $213,750 ($213,750 — enough to cover one year of tuition, room, and board for roughly 4 college students at a private university) fine represents approximately 0.00093% of that annual revenue. For context: if an average American worker earning $55,000 a year committed a comparable proportional financial penalty, they would owe about 51 cents. The company settled without admitting a single violation occurred.

Legal Receipts: Straight From the Documents

Every quote below comes directly from the EPA Consent Agreement and Final Order.

“The inspectors observed one open 55-gallon container of hazardous waste paint liquid (D001, D005, D035, F003) in one of the Repour Room SAAs. The Respondent was not actively adding, removing, or consolidating waste in the open container.” — EPA Findings of Fact, Paragraph 65

“The inspectors observed one lead-acid battery, which was not in good condition and was leaking, in the Sit-down Equipment Battery Area near the Central Accumulation Area and two lead-acid batteries, which were not in good condition and were leaking, in the Sit-down Equipment Battery Area near the Facility Maintenance Shop. The batteries had not been immediately transferred to a container that was in good condition, or immediately managed in some other way that complies with the conditions of the LQG Permit Exemption.” — EPA Findings of Fact, Paragraph 68

“The individual who was identified in the contingency plan as the Emergency Coordinator had not been employed at the Facility since the summer of calendar year 2022, and the Respondent had not amended the contingency plan when the list of emergency coordinators changed as a result of the identified Emergency Coordinator’s departure from the Facility.” — EPA Findings of Fact, Paragraph 73

“The inspectors determined that the Respondent offered 57 55-gallon containers of hazardous waste paint related material (D001, D005, D006, D007, F003, F005) for transport for offsite treatment, storage, or disposal without a Manifest (OMB Control Number 2050–0039) on EPA Form 8700–22.” — EPA Alleged Violations, Paragraph 99

“The Respondent neither admits nor denies the factual allegations set forth in Section IV (Findings of Facts) of this CAFO… consents to the assessment of a civil penalty… [and] waives any right to contest the allegations set forth in Section V (Alleged Violations).” — Stipulations, Paragraph 106 (b), (c), (e)

“The inspectors observed 20 55-gallon containers stored in the Central Accumulation Area without adequate aisle space to allow for inspection of the condition and labels of the individual containers.” — EPA Findings of Fact, Paragraph 83

Societal Impact Mapping

Environmental Degradation: Chemicals With No Paper Trail

The 57 drums of hazardous paint material shipped without a federal manifest represent a direct environmental accountability gap. The Uniform Hazardous Waste Manifest system exists for one reason: to ensure that when toxic materials leave a facility, every link in the chain — the transporter, the receiving facility, the regulator — knows exactly what was moved, by whom, and where it ended up. Without that manifest, a regulator has no legal mechanism to verify the waste was handled lawfully at any point after it left the loading dock. Sherwin-Williams generated this gap. The company shipped the material first, and only produced the paperwork after EPA inspectors asked questions.

The specific waste codes in those 57 drums included D001 (ignitable), D005 (barium), D006 (cadmium), D007 (chromium), F003 (acetone/xylene solvent mixtures), and F005 (methyl ethyl ketone/toluene solvent mixtures). These are flammable, toxic, and persistent contaminants. When hazardous waste reaches a disposal site without proper documentation, the receiving facility may not apply the correct treatment protocols — particularly the land disposal restrictions Sherwin-Williams also failed to notify the facility about. Improper land disposal of these substances can result in groundwater contamination that persists for decades.

The open containers in the warehouse represent an additional and more immediate environmental risk. Volatile organic compounds, including solvents like xylene and toluene found in the F003 and F005 waste codes, evaporate readily from open containers and contribute to indoor and local air pollution. Inspectors found these containers open in a working facility where employees circulated daily. An open 55-gallon drum of ignitable solvent waste also represents a fire risk capable of releasing combustion byproducts — including toxic smoke and runoff — into the surrounding Winter Haven community.

Public Health: Workers First, Community Second

The warehouse workers at 400 Bert Schulz Boulevard were the population at greatest immediate risk. EPA regulations requiring closed containers, hazard labeling, adequate aisle space, and trained personnel exist specifically to protect the human beings who spend eight or more hours a day working near these substances. Sherwin-Williams failed every one of those protective requirements simultaneously. Workers had no training documentation on file. The containers around them lacked hazard labels. The aisle space between 20 drums of toxic waste was insufficient for a person to physically move through to inspect them. Three lead-acid batteries were actively leaking on the floor.

Benzene exposure is worth isolating as a specific public health concern. Benzene is classified by the International Agency for Research on Cancer as a Group 1 carcinogen — meaning the evidence that it causes cancer in humans is unequivocal. Even short-term, high-level exposure causes dizziness, headaches, rapid heart rate, tremors, and unconsciousness. Long-term exposure at lower levels causes bone marrow damage and leukemia. The waste code D018 — benzene — appears in the documented inventory at the Winter Haven facility. Workers interacting with unlabeled open containers of this material may have had no knowledge of what they were breathing or touching.

Economic Inequality: The Penalty That Means Nothing to Them

Sherwin-Williams is a Fortune 500 company. Its 2023 annual report listed net revenues of approximately $23 billion. The $213,750 ($213,750 — less than the annual salary of many of the company’s own senior corporate attorneys) penalty the EPA imposed for twelve categories of violations at one warehouse represents a rounding error in any meaningful financial analysis of this company. It is the kind of number that does not appear in quarterly earnings calls. It does not affect shareholder returns. It does not change executive compensation structures.

The workers inside that warehouse, by contrast, earn wages calibrated to the distribution and logistics sector — jobs that typically pay between $35,000 and $55,000 per year. The people who faced the actual physical risk of the violations documented in this case are the people least equipped to absorb the health consequences of those violations. Leukemia treatment costs hundreds of thousands of dollars. Kidney disease from cadmium exposure requires ongoing dialysis. Lead-induced neurological damage in any children of exposed workers is permanent and irreversible. The company risked those outcomes to save on operational compliance costs that — for a $23 billion corporation — are effectively zero. Sherwin-Williams settled the entire matter for the equivalent of less than one year of pay for a single mid-level manager, with no admission that any of it ever happened.

The “Cost of a Life” Metric

What Now? Who to Watch and What to Demand

Corporate Roles to Hold Accountable

The EPA’s settlement documents identify one Sherwin-Williams corporate contact in the Certificate of Service:

• Jason Perdion, VP and Associate General Counsel, Corporate Legal Services — the attorney who received the settlement on behalf of Sherwin-Williams
• The Vice President of Operations / Facility Management responsible for the Winter Haven distribution center [REDACTED – Not in Source]
• The Environmental Health and Safety Director responsible for RCRA compliance at Large Quantity Generator facilities [REDACTED – Not in Source]

Regulatory Watchlist

• EPA Region 4 (Southeast): The agency that conducted this inspection and issued the settlement. Track their public enforcement actions at epa.gov/enforcement.
• Florida Department of Environmental Protection (FDEP): Co-conducted the inspection. Florida has independent authority to enforce its own hazardous waste program against this facility.
• OSHA: Worker safety at hazardous waste facilities falls under OSHA’s jurisdiction. An EPA RCRA violation of this scale, involving untrained workers and unlabeled containers, warrants an independent OSHA investigation of worker health and safety records at the Winter Haven facility.
• The EPA’s ECHO database (echo.epa.gov): A public tool that tracks compliance and enforcement history for facilities like this one — searchable by EPA ID No. FLD984242453.

What You Can Do Right Now

If you work at, or know someone who works at, a Sherwin-Williams distribution facility, contact OSHA at 1-800-321-OSHA to report unsafe hazardous waste handling conditions. OSHA complaints can be filed anonymously.

Environmental justice organizing is already happening in communities near industrial facilities throughout Florida and the Southeast. Organizations like Earthjustice, the Center for Biological Diversity, and local environmental justice coalitions track corporate polluters and push for stronger penalties and criminal — not just civil — enforcement. Joining or donating to those organizations puts structural pressure on regulators who currently let corporations like Sherwin-Williams settle for fractions of a percent of their annual earnings.

Demand your elected representatives in the Florida state legislature and in Congress push for penalty reform that ties RCRA civil penalties to a percentage of the offending company’s annual revenue — not to flat statutory maximums that were last seriously updated decades ago. A $213,750 fine for a $23 billion company is not accountability. It is a business expense.