EPA v. TOX PATH SPECIALISTS, LLC

Case summary

On December 26, 2018, EPA Region III filed a Consent Agreement and Final Order, simultaneously commencing and concluding an administrative action proceeding against Tox Path Specialists, LLC ( TPS ), of 8420 Gas House Pike, Frederick, MD 21701, for seven alleged violations of the authorized Code of Maryland Regulations ( COMAR ). TPS, a large quantity generator of hazardous and acute hazardous waste, is a laboratory specializing in neurohistology and neuropathology evaluations and consultations in addition to being a full-service histopathology provider. The violations in the Consent Agreement and Final Order included the following: I) owning and/or operating a hazardous waste treatment, storage or disposal facility without a permit or interim status; 2) failure to make a hazardous waste determination; 3) failure to provide job descriptions relating to hazardous waste handling; 4) failure to provide adequate initial and annual training to personnel handling hazardous waste; and 5) failure to perform weekly inspections of the hazardous waste storage area; 6) failure to submit biennial reports; and 7) storage of hazardous waste for greater than 90-days. Per the terms of the Consent Agreement, Respondent will pay a civil penalty in the amount of $29,425.00.

Defendants (1)

• TOX PATH SPECIALISTS, LLCNamed in complaintNamed in settlement

Facilities (2)

• TOX PATH SPECIALISTS, LLC

  8420 GAS HOUSE PIKE, FREDERICK, MD, 21701

  Registry ID: 110045545594

• TOX PATH SPECIALISTS, LLC

  8420 GAS HOUSE PIKE, STE G, FREDERICK, MD, 21701

  Registry ID: 110045545594

Statutes cited

• RCRA 3002 — Standards Applicable to Generators of Hazardous Waste

Enforcement conclusions (1)

• TOX PATH SPECIALISTS, LLCentered 2018-12-26

  Primary law: RCRA

  Federal penalty: $29,425

Timeline (4 milestones)

• 2018-12-26Complaint Filed/Proposed Order
• 2018-12-26Final Order Issued
• 2019-01-29Enforcement Action Closed
• 2019-02-01Enforcement Action Data Entered