EPA v. SHIELD PACKAGING

Case summary

On November 21, 2023, EPA issued an administrative compliance order (AO) under the Clean Air Act (CAA) to Shield Packaging Co., a company that manufactures aerosol products at its facility in Dudley, Massachusetts. Shield Packaging Co. is subject to risk management planning (RMP) regulations and the General Duty Clause (GDC) promulgated pursuant to Section 112(r) of the Clean Air Act because the company uses and stores large quantities of flammable chemicals in its manufacturing process. An EPA inspection of the facility found, among other things, that the company failed to update its Process Hazard Analysis, to complete an RMP compliance audit, to maintain a written plan to maintain the mechanical integrity of its process equipment, ignored the recommendations for mechanical integrity documented by inspections conducted pursuant to applicable standards, and failed to follow recommendations and requirements of applicable standards for flammable liquid storage tanks. The AO requires the company to develop and implement a work plan to address the RMP and GDC violations found at the facility. CAA Section 112(r) requirements are not delegated to the Commonwealth of Massachusetts, but EPA will share a copy of the AO with the Commonwealth.

Defendants (1)

• Shield Packaging Co.Named in complaintNamed in settlement

Facilities (1)

• SHIELD PACKAGING COMPANY INC

  50 OXFORD AVENUE, DUDLEY, MA, 01571

  Registry ID: 110020059675

Statutes cited

• CAA 112R — General Duty/Accidental Release
• CAA 112[R][7] — Prevention of Accidental Release/Risk Management Plans (RMPs)

Enforcement conclusions (1)

• SHIELD PACKAGINGentered 2023-11-21

  Primary law: CAA

Timeline (3 milestones)

• 2023-11-21Complaint Filed/Proposed Order
• 2023-11-21Final Order Issued
• 2023-12-14Enforcement Action Data Entered