The Warehouse Where Safety Warnings Vanished for Four Years

When Federal Inspectors Found What Workers Saw Every Day

On April 22, 2025, an EPA inspector arrived at 7422 Ranco Road in Richmond, Virginia. The address houses a Performance Foodservice distribution facility responsible for moving thousands of pounds of food product through the mid-Atlantic supply chain every single day. The inspector was there to assess compliance with Section 112(r) of the Clean Air Act, the federal statute governing Risk Management Programs for facilities handling toxic substances above threshold quantities.

What the inspector documented that day was not an accident. It was not a sudden failure. It was the physical record of 1,400 consecutive days of deferred maintenance, missing safety protocols, and regulatory violations spanning from August 3, 2021 to the day of the inspection.

The facility uses an industrial ammonia refrigeration system to keep perishable goods cold during storage and distribution. Anhydrous ammonia is not a minor irritant. It is a federally regulated toxic substance under 40 C.F.R. § 68.130 with a threshold quantity of 10,000 pounds. Performance Foodservice-Virginia handles more than that threshold, triggering mandatory compliance with Risk Management Program regulations designed to prevent catastrophic releases that can injure or kill workers, emergency responders, and nearby communities.

The violations the inspector found were not obscure technicalities. They were failures of basic, industry-standard safety practices recognized by the International Institute of Ammonia Refrigeration (IIAR) and the American National Standards Institute (ANSI). These are the guidelines that exist because people have died when ammonia systems fail.

Missing valve identification tags mean that in an emergency, a worker or firefighter attempting to isolate a leak or shut down the system cannot quickly identify which valve controls which part of the system. Seconds matter when ammonia is released. IIAR Bulletin No. 114 exists specifically to ensure “clear and consistent identification of valves and system components to facilitate safe operation and effective emergency response.”

Performance Foodservice-Virginia failed to maintain those tags from at least August 3, 2021 until the inspection on April 22, 2025.

The Door That Said Nothing

The primary entrance to the ammonia machinery room had no ammonia hazard warning labels. It had no National Fire Protection Association (NFPA) hazard placard. ANSI/IIAR Standard 2, Section 6.6.2, is explicit: entrances to ammonia machinery rooms must be “clearly marked to notify personnel and emergency responders of the presence of ammonia hazards.”

Imagine a fire. Imagine first responders rushing into a building to evacuate workers or contain a release. The door tells them nothing. They have no warning that opening it exposes them to a space containing thousands of pounds of a chemical that causes severe respiratory burns, blindness, and death at high concentrations.

This was not a label that fell off yesterday. EPA documented that the labels were missing for the same 1,400-day period as the other violations: August 3, 2021 to April 22, 2025.

The Ice and the Corrosion

The inspector also documented excessive ice accumulation on the low-temperature recirculator and corrosion on multiple piping components, flanges, and metal-to-metal contact supports throughout the ammonia refrigeration system.

Ice accumulation on refrigeration equipment is not cosmetic. IIAR Bulletin No. 110, Section 5, identifies such conditions as indicators of “potential insulation deficiencies, system inefficiencies, or leaks that require inspection and corrective maintenance.” Ice means something is wrong. It means the system is not operating as designed. It means there is a pathway for a release.

Corrosion is structural degradation. ANSI/IIAR Standard 2, Section 5.3, requires that system components be maintained in a condition that “preserves structural integrity and minimizes the risk of ammonia releases.” Corroded pipes are weakened pipes. Corroded flanges are points of failure. In an ammonia system operating under pressure, corrosion is a countdown to catastrophic release.

Both conditions existed from at least August 3, 2021 until the EPA inspection in April 2025.

The Non-Financial Ledger

This case does not involve deaths. It does not involve a mass casualty release. That is not a reason to minimize it. It is evidence of extraordinary luck.

The real toll here is measured in the daily indignity and risk imposed on the workers who entered that facility every shift for four years. The people who walked past the unmarked door. The people who operated equipment surrounded by corroded components and unexplained ice. The people who had no quick visual reference for which valve controlled which part of the system if something went wrong.

Every single one of those workers was placed at unnecessary risk because Performance Foodservice-Virginia failed to comply with basic, industry-standard safety practices for 1,400 consecutive days.

Emergency responders in Richmond were placed at risk because they had no way to know, from the outside, that opening a certain door meant entering a space with thousands of pounds of pressurized toxic gas.

The surrounding community was placed at risk because a corroded, improperly maintained ammonia system is a potential source of a toxic release that does not respect property lines.

None of these people consented to that risk. None of them were compensated for bearing it. And none of them will see a dollar of the $1,500 penalty EPA assessed.

Legal Receipts

Societal Impact Mapping

Environmental Degradation

Ammonia is not just a workplace hazard. It is an environmental contaminant. An uncontrolled release can contaminate soil and groundwater. Ammonia in water bodies causes fish kills and disrupts aquatic ecosystems. The EPA regulates ammonia refrigeration systems under the Clean Air Act precisely because the consequences of failure extend far beyond the property line.

The corroded piping and ice accumulation documented at the Performance Foodservice facility represent degraded barriers between thousands of pounds of pressurized ammonia and the surrounding environment. Every day those conditions persisted was a day the risk of environmental contamination increased.

Public Health

Anhydrous ammonia is acutely toxic. Exposure causes severe respiratory distress, chemical burns to the eyes and skin, and pulmonary edema. At concentrations above 300 parts per million, ammonia is immediately dangerous to life and health. A major release from an industrial refrigeration system can create a toxic vapor cloud that travels downwind, affecting everyone in its path.

Performance Foodservice-Virginia is located in an industrial area of Richmond. Workers at neighboring facilities, truck drivers making deliveries, and residents in nearby communities were all within the potential impact zone of a release. The failure to maintain proper safety labeling and equipment integrity increased the probability of such a release for four consecutive years.

Economic Inequality

The workers in this facility are not executives. They are warehouse staff, forklift operators, and maintenance personnel. They do not set corporate safety budgets. They do not decide whether to replace corroded piping or defer maintenance to next quarter.

They simply show up, perform physically demanding labor in industrial refrigeration environments, and trust that their employer is maintaining the equipment in accordance with federal safety standards. That trust was violated for 1,400 days.

Meanwhile, Performance Foodservice is a subsidiary of Performance Food Group, a publicly traded corporation with annual revenues exceeding $50 billion. The cost to bring the Richmond facility into compliance was $290,379.55, according to the company’s own certification in the settlement agreement. That is 0.0006% of annual corporate revenue. It is a rounding error.

The decision to defer that spending for four years was a decision to transfer risk from the corporation’s balance sheet onto the bodies of its workers and the surrounding community.

The “Cost of a Life” Metric

What Now?

Performance Foodservice-Virginia is a facility-level respondent in this settlement. The corporate parent is Performance Food Group Company, a publicly traded entity (NYSE: PFGC) headquartered in Richmond, Virginia. The Director of Facilities and Safety who signed the settlement agreement is Steve Fasulka.

The regulatory bodies with jurisdiction over industrial ammonia refrigeration safety include:

• EPA Region 3 (Mid-Atlantic): Enforcement of Clean Air Act Section 112(r) Risk Management Program regulations for chemical accident prevention.
• OSHA (Occupational Safety and Health Administration): Enforcement of Process Safety Management standards under 29 CFR 1910.119, which apply to facilities with more than 10,000 pounds of anhydrous ammonia.
• Virginia Department of Environmental Quality (DEQ): State-level environmental compliance and enforcement.
• Virginia Department of Labor and Industry (DOLI): State-level workplace safety enforcement under Virginia Occupational Safety and Health (VOSH) program.

If you work in a facility with an industrial ammonia refrigeration system, you have the right to request inspection records, maintenance logs, and Risk Management Plans. You have the right to know what chemicals are present at your workplace and what safety measures are in place. You have the right to refuse unsafe work.

If you are a community member living near an industrial refrigeration facility, you have the right to access the facility’s Risk Management Plan through EPA’s RMP*Info database. You have the right to know what worst-case release scenarios have been modeled and whether your address falls within the potential impact zone.

Organize. Demand transparency. Demand enforcement. A $1,500 fine for four years of violations is not deterrence. It is permission.