As a first step, the EPO collected the information during an inspection of the AFCO branch in Chambersburg, Pennsylvania, on 20 June 2016. The transaction also concerns infringements of a Stop Sale, Use or Removal Or (SSURO) order issued by the EPO afCO on 13 July 2018 and obliges AFCO to immediately cease all sales and distribution of the 12 products. CAFO asserts that AFCO made sales and sales that violated this order by selling or distributing the products from at least January 1, 2015 to August 8, 2019 or August 9, 2019. Since then, AFCO has suspended the sale of all affected products, with the exception of one registered product for which the EPO issued an Amendment order letter on 4 March 2019 which allows it to cease the sale. © Mitchell, Williams, Selig, Gates &Woodyard, P.L.L.C. | Advertising of lawyers 2. certify that it has accurately and appropriately complied with the RCRA Section 3010 message for ease and within the prescribed time frame; Kelly N. Garson is a partner at Bergeson & Campbell, P.C (B&C®). Ms. Garson assists clients with Toxic Substances Control Act (TSCA), Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) and other federal and government regulatory matters. researches and creates white papers, briefings and regulatory memoranda to provide insights and strategies to B&C clients, address regulatory challenges and seize competitive opportunities; and increases the timely and efficient delivery of exceptional customer services. 5) certification of environmental benefits (reduction of waste generation or reduction of waste toxicity). CAFO finds that the EPA found that OHC produced the hazardous waste streams referred to in paragraph 14 in quantities exceeding the threshold of 1 kilogram of acute hazardous waste and qualified as large generators of hazardous waste in accordance with LAC 33: V.108 [40 C.F.R.

Part 262] for the periods during which these wastes remained on site. CAFO provides more information on alleged violations in Region 3. CAFO`s claims indicate that AFCO sold and distributed 10 unregistered pesticide products on at least 1,031 different occasions, in violation of Fifra Section 12(a)(1)(A). CAFO also asserts that AFCO sold and distributed, on at least five different occasions, a product that went beyond the claims authorized by its FIFRA registration. In addition, it is alleged that AFCO sold or distributed a mislabeled pesticide on 41 different occasions. (d) prepare its manifests; (e) meet soil disposal requirements; DISCLAIMER: Given the overall quality of this update, the information contained in this update may not apply in all situations and should not be implemented without specific legal advice based on certain situations. . . .