The week of August 19, 2024, Region 6 issued a Consent Agreement and Final Order ( CAFO ) to Sherwin-Williams to resolve RCRA violations at its Shiloh Rd and Miller Rd facilities. The violations were identified during an onsite inspection of the Shiloh Rd facility in April 2022 and the Miller Rd facility in August 2022. Region 6 determined that Sherwin-Williams failed to comply with notification requirements (RCRA Section 3010(a)), failed to make accurate hazardous waste determinations (262.11), failed to have an adequate contingency plan (262.17(a)(6), failed to manage containers of hazardous waste properly (262.17(a)(5)(ii)), failed to comply with RCRA air emission standards (265 Subparts BB and CC), failed to keep certain employee training records (262.17(a)(7)(iv)), and failed to operate the Shiloh Rd facility in accordance with the General Duty Clause (262.251). The settlement requires Sherwin-Williams to pay a $270,000 penalty and:
A. Respondent shall certify that it has assessed all its solid waste streams at the Shiloh Road
Facility to determine the accurate waste codes and has developed and implemented
standard operating procedures ( SOPs ) to ensure that Respondent is operating the Shiloh
Road Facility in compliance with RCRA and the regulations promulgated thereunder,
including, but not limited to, procedures for: (a) making hazardous waste determinations;
(b) managing hazardous wastes; (c) reporting, transporting, and disposing of hazardous
waste; (d) pre