Four Violations. One Inspection. A Fine That Fits in a Wallet.

On February 19, 2025, EPA Region 7 inspectors walked through Siegwerk USA’s facility at 3535 SW 56th Street in Des Moines, Iowa. What they found was a facility operating in violation of the Resource Conservation and Recovery Act (RCRA), the federal law that governs how hazardous waste must be stored, labeled, and reported. The inspection triggered a federal enforcement action that ended with four documented violations.

Siegwerk USA is a subsidiary of Siegwerk Druckfarben AG, a global commercial printing ink manufacturer. The Des Moines facility is an industrial operation producing inks that contain solvents, pigments, and chemical byproducts that federal law classifies as hazardous secondary materials. These are not minor housekeeping infractions. These rules exist because unlabeled, improperly stored hazardous waste injures and kills workers and contaminates communities.

The EPA and Siegwerk agreed to resolve the case through an Expedited Settlement Agreement. The total civil penalty: $5,500 ($5,500 — about what a minimum wage worker in Iowa earns in three months of full-time labor). The agreement was signed and filed on November 17, 2025.

Violation 1: They Never Told the EPA They Were Even Doing This

Federal law under 40 C.F.R. § 261.4(a)(23)(ii)(c) requires any facility managing hazardous secondary materials to notify the EPA before it starts doing so, and then again every two years. This rule exists so regulators know where hazardous materials are being handled. Siegwerk did not submit that notification. The EPA did not know this facility was managing these materials until inspectors physically walked through the door.

This is the kind of violation that makes every other rule meaningless. If the agency does not know a facility exists in the hazardous waste management system, it cannot inspect it, cannot track what materials move in and out, and cannot protect the workers or the surrounding neighborhood from contamination. Siegwerk’s failure to file that notification kept them off the radar.

Violation 2 and 3: An Unlabeled Container of Unknown Hazards

Federal rules under 40 C.F.R. § 262.15(a)(5)(i) and (ii) require that any satellite container holding hazardous waste be labeled with the words “Hazardous Waste” and with a description of the specific hazard: ignitable, corrosive, reactive, or toxic. Inspectors found one container at the Siegwerk facility that had neither label. No words. No hazard identification. Nothing.

A worker walking past that container had no federally required warning that the contents could catch fire, eat through skin, or poison them if inhaled. That is the entire purpose of these labeling laws: to give the person nearest the container a fighting chance to react correctly in an emergency. Siegwerk stripped that information away.

Violation 4: Stockpiling Mercury-Containing Lamps Past the Deadline

Universal waste lamps — fluorescent tubes and other lighting that contains mercury — are classified as universal waste because mercury is a potent neurotoxin. Federal rules under 40 C.F.R. § 273.15(a) require these lamps to leave the facility within one year of generation. Siegwerk held onto them past that deadline. The source document does not specify by how long, but the violation was confirmed and documented during the February 2025 inspection.

Mercury does not disappear. It accumulates. A broken lamp stored past its legal deadline in an industrial facility releases mercury vapor into the air that workers breathe every day. The one-year rule is a hard limit for a reason, and Siegwerk ignored it.

The Non-Financial Ledger: What the $5,500 Does Not Cover

The EPA’s settlement agreement is a legal document. It lists violations, calculates a penalty, and closes a file. What it cannot do is account for what it felt like to work a shift on the floor of that facility, walking past a container holding an unknown hazard with no label telling you to stay back, wear gloves, or call for help if something spills. That is the cost that does not appear on any government form.

Hazardous waste labeling laws are written in the language of bureaucratic regulation, but they exist because of real events: workers burned by unlabeled corrosives, workers who inhaled ignitable vapors and triggered fires, workers who went home sick and did not know why. Every label law on the books traces back to an injury. When Siegwerk left that satellite container unlabeled, the company removed the one piece of information that stands between a worker and a preventable emergency. Workers at that facility had no way of knowing — from that container — whether they were standing next to something that could kill them.

The mercury lamp situation deserves its own accounting. Mercury is a neurological poison. Chronic low-level mercury vapor exposure causes tremors, memory loss, and cognitive impairment. The symptoms are slow and insidious; they do not announce themselves the way a burn or a cut does. A worker exposed to mercury vapor from improperly stored lamps may not connect their symptoms to their workplace for months or years, if ever. Siegwerk stored those lamps past the federally mandated deadline, and the source document does not tell us how long they sat there or how many lamps were involved.

Then there is the community dimension. The Siegwerk facility sits at 3535 SW 56th Street in Des Moines, Iowa — a working-class industrial zone. The people who live nearest to industrial facilities are disproportionately lower-income families and communities of color, who bear a higher cumulative burden of industrial pollution while having the least political power to demand accountability. When a company operates without notifying the EPA that it is managing hazardous materials, the surrounding neighborhood loses the oversight layer that is supposed to protect them. The EPA cannot track what is happening at a facility it does not know is operating under hazardous material rules. That gap in the regulatory record falls entirely on the community that lives downwind.

Legal Receipts: The Documents Speak

These are direct quotes and citations from the EPA’s Expedited Settlement Agreement and Final Order filed November 17, 2025. Every word below comes from official federal records.

“The facility did not submit notification to the EPA prior to managing hazardous secondary materials.”

EPA Region 7 Expedited Settlement Agreement, Paragraph 3(a) — Violation of 40 C.F.R. § 261.4(a)(23)(ii)(c)

“The facility did not label one satellite container with the words hazardous waste.” / “The facility did not label one satellite container with the nature of the hazard.”

EPA Region 7 Expedited Settlement Agreement, Paragraphs 3(b) and 3(c) — Violations of 40 C.F.R. § 262.15(a)(5)(i) and (ii)

“The facility did not send off Universal Waste lamps before one year from the date of generation.”

EPA Region 7 Expedited Settlement Agreement, Paragraph 3(d) — Violation of 40 C.F.R. § 273.15(a)

“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.”

EPA Region 7 Expedited Settlement Agreement, Paragraph 7 — Respondent’s Admissions and Consents

“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.”

EPA Region 7 Expedited Settlement Agreement, Paragraph 11 — Scope of Resolution

Societal Impact Mapping: Who Pays the Real Price

Public Health: Workers in the Dark, Mercury in the Air

The most direct public health consequence documented in this case is the unlabeled hazardous waste container. RCRA’s labeling requirements exist entirely to protect human health. The law mandates labels for ignitable, corrosive, reactive, and toxic wastes because each category carries a distinct injury profile: ignitables cause fires and burns; corrosives destroy tissue on contact; reactives can explode; toxics poison organs, nerves, and blood. Without a label specifying which hazard is present, a worker, a janitor, or a first responder cannot make an informed decision about how to handle an emergency. Siegwerk removed that protection.

The mercury lamp violation compounds the public health picture. Mercury vapor is odorless and colorless. Workers cannot detect it without instruments. The EPA’s universal waste regulations impose strict time limits on lamp storage precisely because the risk of breakage and vapor release increases the longer lamps sit in storage. Siegwerk held those lamps past the one-year federal limit. The source material does not disclose the duration of the overage or the number of lamps involved, which means the full scope of potential worker mercury exposure remains unknown.

Chronic mercury exposure at industrial levels produces neurological symptoms that workers may attribute to aging, stress, or unrelated health conditions. The connection between workplace exposure and health decline often goes undocumented, unmeasured, and uncompensated. The families of those workers absorb those costs invisibly, in medical bills, lost income, and diminished quality of life that never appears in any EPA enforcement ledger.

Economic Inequality: Who Bears the Cost of Corporate Non-Compliance

The $5,500 ($5,500 — equivalent to about 18 days of pay for the average American full-time worker) penalty Siegwerk agreed to pay represents a rounding error in the operational budget of a global printing ink manufacturer. Siegwerk Druckfarben AG operates manufacturing facilities across multiple continents and serves major consumer goods brands worldwide. A $5,500 fine creates zero financial deterrent. It does not fund community health monitoring, worker medical screening, or environmental testing near the facility.

Meanwhile, the workers at the Des Moines facility who labored near unlabeled hazardous waste or breathed mercury vapor from improperly stored lamps bear the health costs on their own. Most industrial workers do not have the resources to pursue independent environmental testing, legal action, or long-term health monitoring. The regulatory system that is supposed to protect them settled the case in nine months, collected a fine smaller than most people’s security deposits, and closed the file. The workers never appeared in the document at all.

The surrounding Des Moines community also receives nothing from this settlement. The $5,500 penalty does not fund neighborhood air quality monitoring, does not go toward a community health fund, and does not require Siegwerk to report its past compliance failures to the people who live near the facility. The penalty flows directly to the federal government, not to the people most exposed to the risk.

The Cost of a Life: By the Numbers

What Now: Who to Watch, Where to Push

Corporate Role The settlement agreement was signed by Siegwerk USA’s HSE Manager, Gary Klukow (gary.klukow@siegwerk.com), who is listed as the company’s designated representative for this enforcement action. The parent company is Siegwerk Druckfarben AG, a global printing ink manufacturer.

Regulatory Watchlist

• EPA Region 7 — The agency that conducted this investigation. Monitor their public enforcement actions database for any future Siegwerk violations or follow-up inspections.
• Iowa Department of Natural Resources (IDNR) — The state agency notified of these violations. Contact: Environmental Services Division Administrator Ed Tormey (ed.tormey@dnr.iowa.gov) and Section Supervisor Mike Sullivan (michael.sullivan@dnr.iowa.gov). Iowa DNR received a copy of this settlement and has independent authority to act.
• OSHA (Occupational Safety and Health Administration) — RCRA violations involving unlabeled hazardous waste containers overlap directly with OSHA’s Hazard Communication Standard (HazCom). Workers at this facility have the right to file a confidential complaint with OSHA if they believe their workplace safety was compromised.
• EPA’s ECHO Database — Search “Siegwerk USA” in the EPA’s Enforcement and Compliance History Online (ECHO) database at echo.epa.gov to track all past and future compliance records for this facility.

The $5,500 Settlement Expires the Problem. Your Pressure Keeps It Alive.

Federal settlements like this one are designed to close files, not fix cultures. Siegwerk paid $5,500 ($5,500 — less than a single OSHA workers’ comp claim), signed a document saying the violations are corrected, and walked away with no admission of wrongdoing. The workers at 3535 SW 56th Street in Des Moines are still showing up every day. If you live near this facility, connect with local environmental justice organizations in the Des Moines area. If you work at this facility, you have federally protected whistleblower rights under RCRA Section 7001 and the right to request your workplace’s hazardous material records. Mutual aid and grassroots pressure are the only forces that turn a $5,500 fine into genuine accountability.