EPA BECAME AWARE OF FULLER'S OPERATION IN NOV 2002, WHEN EPA DISCOVERED THAT FULLER WAS IMPORTING AN EXTREMELY DANGEROUS UNREGISTERED PESTICIDE. FULLER WAS USING THE CHEMICAL TO MANUFACTURE INSECTICIDE SMOKE BOMBS. UPON EPA'S DISCOVERY, THE U.S. REFUSED TO ALLOW THE DELIVERY OF THE PESTICIDE, AND RETURNED IT TO ITS COUNTRY OF ORGIN, IRELAND. ON JANUARY 15, 2003, EPA INSPECTORS CONDUCTED AN INSPECTION OF FULLER'S FACILTY AND FOUND FULLER FAILED TO MANAGE HAZARDOUS WASTE IN ACCORDANCE WITH STATE AND FEDERAL REGULATIONS, INCLUDING FAILURE TO NOTIFY, AND OBTAIN AN EPA ID#. FAILURE TO CONDUCT HAZARDOUS WASTE DETERMINATIONS, FAILURE TO IMPLEMENT HAZARDOUS WASTE MANAGEMENT MEASURES, FAILURE TO OBTAIN A STORAGE FACILITY LICENSE, FAILURE TO DEVELOP PERSONNEL TRAINING PLANS, AND FAILURE TO DEVELOP CONTINGENCY PLANS.