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f t E A ~ United States ._.,,.., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 01/12/2026 Pesticides FIFRA 12(a)(1) Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: RectorSeal Corporation RectorSeal 2601 Spenwick Dr. Houston, TX 77055 2601 Spenwick Dr. Houston, TX 77055 Harris (713) 929-4286 Scott Kern Scott.kerns@RectorSeal.com I I Environmental Health & Safety Manager FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A N/A R06-2025-1035 424410 5141 Personnel participating in inspection: Scott Kern RectorSeal Lee McMillan EPA Region 6 - Pesticides Enforcement (6ECDST) EHS Manager Lead Inspector EPA Lead Inspector Signature/Date Supervisor Signature/Date ~JJ{t~ Lee V. McMillan /~/ Gerardo Acosta Digitally signed by LEE MCMILLAN Date: 2026.03.0~ 10:34:28 -06'00' Date Digitally signed by <;ERARDO ACOSTA Date: 2026.03.03 1 ):46:27 -06'00' Date 6ENFORM-019-8 (10/31/2019) 1 Section I - INTRODUCTION Rectorseal Corporation Inspection Date 1/12/2026 PURPOSE OF THE INSPECTION I, EPA Region 6 inspector Lee McMillan accompanied by inspector Justin Mullenix began an investigation based on a follow-up to a tip and complaint submitted to the agency. I arrived at the RectorSeal at 1:15 PM on January 12, 2026, for an unannounced inspection. I used the company's automated system to contact the Environmental Health and Safety Manger, Scott Kerns. When Mr. Kerns arrived in the lobby area, I presented my credentials and informed him that I was there to conduct an EPA inspection to determine compliance with the Federal Insecticide Fungicide Rodenticide Act (FIFRA). The scope of the inspection would be to review documents and any pesticide products for evaluation of the compliance with FIFRA (40 CFR Subpart 169.3 - Inspections). More specifically, I let Mr. Kerns know that I would be more specifically focused on a product of the company called Actabs (Reg. No. 51219-7). I was informed at that time that the product known as Actabs had been discontinued and is no longer in production. FACILITY DESCRIPTION RectorSeal Corporation is a wholly owned subsidiary of CSW Industrials, Inc (CSWI). Based in Dallas, Texas, CSW Industrials is a diversified industrial growth company that acquired RectorSeal in 2015. Founded in 1937, RectorSeal operates within CSWI's Contractor Solutions segment, offering HVAC/R, plumbing, and electrical chemical products. The company has 250 employees. CSWI's annual revenue is approximately $800 million. Section II - OBSERVATIONS On January 12, 2026, I sat with Mr. Scott Kerns and discussed the company's products. Although Actabs is no longer produced by the company, it has other FIFRA regulated supplementally registered products produced by ChemOne, Quest, and Lonza. At approximately 1:50 PM, I toured and inspected the RectorSeal facility. During the investigation I viewed the Manufacturing Area where its product Fire Stop is produced, Receiving Area, Material Storage Area, Distribution Area, and Maintenance Area. No photos were taken during the inspection. Section III - AREAS OF CONCERN I conducted a closing conference with Mr. Kerns at 2:04 PM on January 12, 2026. There were no areas of concern found during the inspection. I received the cancellation notification documents for Actabs before leaving the facility. I concluded the inspection and exited the facility at 2:07 PM. 2 6ENFORM-019-8 (10/31/2019) Section IV - FOLLOW UP Rectorseal Corporation Inspection Date 1/12/2026 On January 12, 2026, I received labels for the RectorSeal products Coil-Cure and Root Destroyer for review. No additional concerns were found, and no additional information was requested. Section V - LIST OF APPENDICES Appendix 1 - Notice of Inspection Appendix 2 - Receipt for Samples 3 6ENFORM-019-8 (10/31/2019) APPENDIX 1 NOTICE OF INSPECTION oEPA United States Environmental Protection Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance Facility Name Facility Address Rectorseal Corporation 2601 Spenwick Drive Houston, TX 77055 Name of Facility Official ~fl KevtS n11 Ef/S/Re~rl"lory jp.fd,',7 ~LA.._t:<.f=j <.-V By my signature, I represent that I am an owner, operator or agent in charge of the facility being inspected, and attest tnat the EPA, Designated State or Political Subdivision Employee or Officer identified on this form presented his or her credentials prior to issuing this Notice of lnsp~tion. ~ Facility Official's Signature: ~~ ~ Authority for Inspection For the purpose of inspecting and obtaining samples of any pesticides or devices packaged, labeled and released for shipment, and samples of any containers or labeling for such pesticides or devices, in places where pesticides or devices are held for distribution or sale [FIFRA 9(a) (7 U.S.C. 1369)]; and for the purpose of inspecting and obtaining copies of those records specified in FIFRA 8 (7 U.S.C. 136f) and 40 C.F.R. Part 169. Reasons for Inspections (Check applicable boxes) Routine Inspection [BJ For Cause Inspection Violation Suspect ed: FlFRA Sect1on l 2(a)(I) - Misbranding Additional Information: Name of Inspector LeeM~ illan 1-t i : / ~ ~ Signature of Inspector Title Sr. Inspector"' t/ Address EPA Region 6, 1201 Elm Street, Dallas, TX 75270-2162 Date 1/;z/z~ Time / / Z:5 //,11 Note: The absence of a Facility Official's signature on this form does not invalidate this Notice of Inspection, orestablish that consent to the inspection was not provided or that the proper procedures were not followed. EPA Form 3540-2 (Rev. 07/09) Previous editions may be used until supply is exhausted 1-lnspector Copy 2-Facility Copy ---------------------------- APPENDIX 2 RECEIPT FOR SAMPLE oEPA United States Environmental Protection Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples Office of Enforcement and Compliance Assurance ~ Faciz'<- r'3eP--/ Name of Facility Official So-0-ff }1efl"S Facility Address V/!Ol ~wt'c#- Pr.1 l-t,u6h1 7}.,)14/tYa!:J Title E 1/!!!J MaVt 4.~ -d' Samples Collected (Assign sample number and describe fully (e.g. , product name, size, quantity, registration , establishment, lot, batch , model and/or serial numbers, etc.)) The following samples were collected by or on behalf of the U.S. Environmental Protection Agency and receipt is hereby acknowledged pursuant to Section 9(a) of the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136g). wf~e 1t! &,{ ~..eI/J, ~ n - ~1~ O I,~ -{)()t) I 17197Io - tJ 2-tJ I ' I Duplicate samples Duplicate samples Amount paI"d D requested and provided not requested j!f I Cash D Credit Card ~ No Charge Acknowledgement of Samples Collected: The undersigned acknowledges that the samples shown above were obtained from pesticides or devices that were packaged, labeled and released for shipment. Facility Official Signature /fLYJ! Name of Inspector Lee V . McMillan - Signature of Inspector Vfi / (L ' ~ Address EPA Region 6, 1201 Elm St., Ste. 500, Dallas, TX 75270 !Date 11!1/u Title Sr. Ins!ector I Date t/;ez/4r, f ' EPA Form 3540-3 (Rev. 07/09) Previous editions may be used until supply is exhausted 1-lnspector Copy 2-Facility Copy