U.S. EPA Region 5 issued an Administrative Consent Order (ACO) to Cohen Brothers, Inc. (Cohen) to address violations of the Clean Air Act (CAA). On June 28, 2019, EPA issued to Cohen a Finding of Violation (FOV) pertaining to eight of its scrap metal recycling facilities in the Dayton and Cincinnati, Ohio areas. The FOV alleged that Cohen accepted for recycling motor vehicles and small appliances such as refrigerators and room air conditioners that contained or once contained ozone-depleting and substitute refrigerants without either recovering the refrigerant from the items or verifying that the refrigerant had been properly recovered prior to delivery to Cohen, in violation of regulations found at 40 CFR 82.155. The ACO requires Cohen to develop a refrigerant management plan which will include proper refrigerant recovery from intact appliances and motor vehicles, verification of proper refrigerant recovery from such items that arrive at Cohen's facility empty of refrigerant, notification to customers about proper refrigerant recovery, and documentation of compliance. Cohen's refrigerant recovery program is estimated to recover approximately 120 lbs of ozone-depleting and substitute refrigerants per year per participating facility.