Document 2qVDrqYY6r4BQ5v5xDzmRM1rb
SENT BY ELECTRONIC MAIL bill.lewis@vetoquinol.com
William Lewis Vetoquinol USA 4250 N Sylvania Ave Fort Worth, Texas 76137
REGION 6
DA LLAS, TX 75270
July 15, 2025
FILED
17 JUL 25 PM 02:57
REGIONAL HEARING CLERK EPA REGION 6
Re: Notice of Warning and Notice of Intent to Terminate Establishment Registration(s) - Immediate Action Required Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) Vetoquinol USA; EPA Establishment No(s). 3134-POL-1, 3134-POL-2 EPA Docket No. FIFRA-06-2025-0383
Dear William Lewis:
Notice of Warning
This Notice of Warning is issued to Vetoquinol USA pursuant to Section 9(c)(3) of FIFRA, 7 U.S.C. 136g(c)(3). The U.S. Environmental Protection Agency is hereby alleging that Vetoquinol USA violated Section 12(a)(2)(L) of FIFRA, 7 U.S.C. 136j(a)(2)(L), by failing to file annual pesticide production reports for its EPA-registered establishment(s) as required by Section 7(c) of FIFRA, 7 U.S.C. 136e(c). Specifically, EPA is alleging that Vetoquinol USA failed to file the Pesticide Report for PesticideProducing Establishments (EPA Form 3540-16) as detailed in the table below.
EPA Est. No. 3134-POL-1
3134-POL-2
Report Year 2020, 2021, 2022,
2023, 2024 2020, 2021, 2022,
2023, 2024
Postmarked Date n/a
n/a
Status Non-reported
Non-reported
Pursuant to 40 C.F.R. 167.85(d), producers operating an active establishment must submit an annual report on or before March 1 of each year covering production during the previous calendar year (the reporting year), even if no pesticide product or device was produced at the establishment for that reporting year. Pursuant to Section 14 of FIFRA, 7 U.S.C. 136l, and 40 C.F.R. Part 19, failure to comply
with this reporting requirement may subject your producing establishment to an administrative civil penalty. Based on a review of Vetoquinol USA's compliance history, EPA has determined this Notice of Warning is an appropriate enforcement response to the alleged violations noted above.
Notice of Intent to Terminate Establishment Registration
In addition, you are hereby notified of EPA's intent to terminate the registration(s) of EPA Establishment Number(s) 3134-POL-1 and 3134-POL-2. Pursuant to 40 C.F.R. 167.20(f), EPA intends to terminate the registration(s) of the establishment(s) if Vetoquinol USA fails to submit the missing annual pesticide production reports indicated above within 30 calendar days from the date of this notification. A copy of the report form is available on the Internet at: https://www.epa.gov/compliance/epa-form-3540-16-pesticide-report-pesticide-producing-and-deviceproducing-establishments.
Termination of the establishment registration(s) will be effective upon the issuance by this office of a Notice of Termination of Establishment Registration. Section 7 of FIFRA prohibits the production of pesticides at any establishment unless that establishment is registered with the EPA. In the event that EPA terminates the establishment registration, any further production at the establishment, including formulation, packaging or labeling, will be in violation of FIFRA and may result in further enforcement action by EPA against Vetoquinol USA. Such enforcement action may include an action to assess penalties as authorized by Section 14 of FIFRA, 7 U.S.C. 136l.
EPA developed an information sheet entitled "U.S. EPA Small Business Resources" to help small businesses understand federal and state environmental laws and right under the Small Business Regulatory Enforcement Fairness Act. The information sheet can be found on the Internet at: https://www.epa.gov/compliance/small-business-resources-information-sheet.
If you have any questions concerning this matter, please contact Justin Mullenix by phone at 214-665-7173 or by email at mullenix.justin@epa.gov.
Sincerely,
JEFFREY YURK
Digitally signed by JEFFREY YURK Date: 2025.07.15 07:04:04 -05'00'
Jeffrey Yurk, Manager Waste and Chemical Enforcement Branch