Document X7OJYR2EXeMe9kaJvv6NBLDxx

ft E A ~ United States ~., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 06/26/2024 Pesticides FIFRA Company Name: Facility Name: Facility Physical Location: (city, state, zip code) Mailing address: (city, state, zip code) County/Parish: Facility Phone Number Facility Contact: 3PL Fulfillment & Prep LLC 3PL Fulfillment & Prep 11094 Grader St Dallas, TX 75238 533 Highland Fairway Ln Wylie, TX 75098-5553 Dallas (469) 927-6177 Mohammed Kamran info@3plfulfillmentprep.com I I Owner FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: n/a n/a n/a 4931 4225 Personnel participating in inspection: Justin Mullenix EPA-ECDST Kiera Hancock EPA-ECDST Sidrah Khan EPA-LCRPP Stephen Angle EPA-LCRPP Mohammed Kamran 3PL Fulfillment & Prep Fuadd M. Siddiqui 3PL Fulfillment & Prep Lead Inspector Inspector Subject Matter Expert Subject Matter Expert Owner Warehouse Manager EPA Lead Inspector Signature/Date JUSTIN MULLENIX Date: 2024.08.21 11:51:49 -05'00' Digitally signed by JUSTIN MULLENIX Justin Mullenix Date Supervisor Signature/Date H STUCKEY Digitally signed by H STUCKEY Date: 2024.08.22 11:31:12 -05'00' H. Troy Stuckey, PhD Date 6ENFORM-019-R8.2 (02/12/2020) 1 Section I - INTRODUCTION 3PL Fulfillment & Prep LLC / 3PL Fulfillment & Prep Inspection Date 06/26/2024 PURPOSE OF THE INSPECTION This for-cause scheme marketplace establishment inspection was conducted pursuant to the Federal, Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 9(a), 7 U.S.C. 136g(a), to evaluate compliance with FIFRA and the regulations thereunder. The inspection occurred for-cause for suspected distribution or sale of a counterfeit (misbranded) pesticidal device, Sub-Zero Water Filter, that was subject to an import Notice of Refusal by EPA Region 9. 3PL Fulfillment & Prep LLC was identified as the consignee of this import. FACILITY DESCRIPTION 3PL Fulfillment & Prep LLC is a company incorporated and operating a single facility in Dallas, Texas, that specializes in the warehousing, packaging, and distribution of general merchandise for third-party retailers operating online. The size of the business is unknown. Section II - OBSERVATIONS I, EPA Region 6 Inspector Justin Mullenix, along with Inspector Kiera Hancock, and pesticide import subject matter experts Sidrah Khan and Stephen Angle, arrived at 3PL Fulfillment & Prep LLC on June 26, 2024, at approximately 9:55 AM. Upon entering the facility, we met Fuaad M. Siddiqui, warehouse manager of 3PL Fulfillment & Prep LLC. Inspectors Hancock and I presented Mr. Siddiqui our EPA inspector credentials and explained the purpose of our visit. We asked Mr. Siddiqui if an office or conference room was available, and we were led to a conference room. I then presented Mr. Siddiqui a Notice of Inspection (EPA Form 3540-2) which he and I signed (Appendix 1). I informed Mr. Siddiqui of the EPA Region 9 Notice of Refusal associated with the Sub-Zero Water Filter pesticidal device and inquired if 3PL Fulfillment & Prep LLC was in possession of the product. Mr. Siddiqui stated that he was unaware of the product but explained that several brands of water filters have been distributed by the company and offered to search the warehouse for the product. We obliged Mr. Siddiqui to perform a search, which he left the conference room to do. After a short while, Mr. Siddiqui returned to the conference room with four different models of water filters; however, none were confirmed to be the Sub-Zero Water Filter. We were then joined by Mohammed Kamran, the owner of 3PL Fulfillment & Prep LLC. While the other EPA staff members evaluated the water filters for compliance, I asked Mr. Kamran about 3PL Fulfillment & Prep LLC and how it operates. Mr. Kamran explained that the company operates as a warehousing and packaging facility on behalf of third-party online retailers. He explained that as orders come in, the company retrieves and packages products to then be sent to customers, and that products held in inventory vary over time. 2 3PL Fulfillment & Prep LLC / 3PL Fulfillment & Prep Inspection Date 06/26/2024 After concluding the opening meeting, I asked Mr. Kamran if the EPA staff members and I could walk through the facility to evaluate products for compliance with FIFRA. Mr. Kamran agreed, so the EPA staff members and I began at the front of the facility where a variety of products were on display. We reviewed and photographed several products before making our way to the warehouse section of the facility. We walked through the aisles of the warehouse reviewing and photographing additional products before making our way back to the conference room. Upon returning to the conference room, I asked Mr. Siddiqui some follow up questions regarding certain products. I then prepared a Receipt for Samples (EPA Form 3540-3) which Mr. Siddiqui and I signed (Appendix 2). Mr. Siddiqui was then provided a copy of the Notice of Inspection and Receipt for Samples, along with an EPA Small Business Resources information sheet. The inspection concluded at approximately 11:12 AM. Section III - AREAS OF CONCERN The areas of concern identified during the inspection included potential distribution or sale of unregistered or misbranded pesticides or pesticidal devices. Section IV - FOLLOW UP No additional information was received by EPA after exiting the facility on June 26, 2024. Section V - LIST OF APPENDICES Appendix 1 - Notice of Inspection (EPA Form 3540-2) Appendix 2 - Receipt for Samples (EPA Form 3540-3) Appendix 3 - Photograph Log - 35 photographs taken on June 26, 2024 3 3PL Fulfillment & Prep LLC / 3PL Fulfillment & Prep Inspection Date 06/26/2024 Appendix 1 Notice of Inspection &EPA United States Environ mental Protection Agen cy United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Notice of Inspection Office of Enforcement and Compliance Assurance Facility Name i f L. f: ) ~ \) J. p (A. J ~e--1'\-r 10, rr. r Facility Address }) o1 '-\ G"r.-tAer5i. , vd ))Ar, )Xl,2"3~ Name of Facility Official fuAkO tV\ . <;2 ~ vQ U) Title w /1-t fV'\ /.\Y'JAGr ~ By my signature, I represent that I am an owner, operator or agent in charge of the facility being inspected, and attest that the EPA, Designated State or Political Subdivision Employee or Officer identified on this form presented his or her credentials oA\J\ .. - / ~ prior to issuing this Notice of Inspection. - Facility Official's Signature: / Authority for Inspection L..... ?~ i For the purpose of inspecting and obtaining samples of any pe icides 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. 136g)); 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 ~ For Cause Inspection Violation Suspected : lo i-.1o1'1(. r1' if- Additional Information: e1l ,, ;h.tl Ve1t.; ,,e_ Name of Inspector Jt/rt: ="' MM I)U'. ,< Signature of Inspector Q1 ~1 t , ~ . , /~ Title L.ft.. 5L.l e.l"tt1f Address EPA Region 6, 1201 Elm St, D allas, TX 75270 Date b)1b/2.'t Time 9~) 7 AA!l Note: The absence of a Facility Official's signature on this form does not invalidate this Notice of Inspection, or establish that consent to the inspection was not provided or t hat t he proper procedures were not followed. EPA Form 3540-2 (Rev. 07/09) Previous ed itions may be used until supply is exhausted 1-lnspector Copy 2-Facility Copy 3PL Fulfillment & Prep LLC / 3PL Fulfillment & Prep Inspection Date 06/26/2024 Appendix 2 Receipt for Samples &EPA United States Environment.al Protectio n Agency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples Office of Enforcement and Compliance Assurance Facility Address lloql-\ f,-Aer 5--t . 1 Va))a~, T,x7f2~i Name of Facility Official f l,(ttaA M. ~;J) : (Y ; Title vJ} J-1 MM"'jer 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). bb'l'72P:J..."1 - 01:>7~o71Jl\~Oo0101.77)~ -0) -o]; 3~ fhv+ojr"fhf, ( O Cash O Credit Card WNo 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 Date 6 ~) Name of Inspector Signature of Inspector Date b}J._b / z.l\ Address I].. C I 1,.,.. ?-I EPA Form 3540-3 (Rev. 07/09) 7o Previous editions may be used until supply is exhausted 1-lnspector Copy 2-Facility Copy 3PL Fulfillment & Prep LLC / 3PL Fulfillment & Prep Inspection Date 06/26/2024 Appendix 3 Photograph Log UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 1 I County/Parish: Dallas I State: TX Photo File Name: P6260121.jpg Date of Photo: 06/26/2024 Time of Photo: 10:20 AM Photographer: Kiera Hancock Description: LG Water Filter side 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 2 I County/Parish: Dallas I State: TX Photo File Name: P6260123.jpg Date of Photo: 06/26/2024 Time of Photo: 10:20 AM Photographer: Kiera Hancock Description: LG Water Filter side 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 3 County/Parish: Dallas State: TX Photo File Name: P6260125.jpg Date of Photo: 06/26/2024 Time of Photo: 10:20 AM Photographer: Kiera Hancock Description: LG Water Filter side 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 4 County/Parish: Dallas State: TX Photo File Name: P6260129.jpg Date of Photo: 06/26/2024 Time of Photo: 10:22 AM Photographer: Kiera Hancock Description: LG Water Filter side 4 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 5 County/Parish: Dallas State: TX Photo File Name: P6260130.jpg Date of Photo: 06/26/2024 Time of Photo: 10:22 AM Photographer: Kiera Hancock Description: LG Water Filter side 4 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 6 County/Parish: Dallas State: TX Photo File Name: P6260131.jpg Date of Photo: 06/26/2024 Time of Photo: 10:22 AM Photographer: Kiera Hancock Description: LG Water Filter side 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 7 County/Parish: Dallas State: TX Photo File Name: P6260132.jpg Date of Photo: 06/26/2024 Time of Photo: 10:22 AM Photographer: Kiera Hancock Description: LG Water Filter side 5 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 8 I County/Parish: Dallas I State: TX ],N1 SYST[M/C Rose& Flower Photo File Name: P6260136.jpg Date of Photo: 06/26/2024 Time of Photo: 10:28 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 9 County/Parish: Dallas State: TX roof ction Photo File Name: P6260137.jpg Date of Photo: 06/26/2024 Time of Photo: 10:28 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 1 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 10 I County/Parish: Dallas I State: TX KILLS FEEDS USEON AMOUNT TO USE WHEN TO USE ff Aph1ds,LaceBugs,leafbeetlL .,leafho Leafminers,MealWorms,andotherhst 696Fertilizer Roses,Flowers&Shrubs Established Roses: 1/2cupper9sq.ft.(3'X3l :~~:~;~:2~~3,1~prro~;;/hqf!i~f;~rub height When plants have about 1inch of new growth il'I the spring and reapply every6weeks For questions or comments, call1011-free1-877229-3724 Photo File Name: P6260138.jpg Date of Photo: 06/26/2024 Time of Photo: 10:28 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 11 County/Parish: Dallas State: TX Photo File Name: P6260139.jpg Date of Photo: 06/26/2024 Time of Photo: 10:28 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 2 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 12 County/Parish: Dallas State: TX Photo File Name: P6260140.jpg Date of Photo: 06/26/2024 Time of Photo: 10:28 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 2 (3) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 13 I County/Parish: Dallas I State: TX Photo File Name: P6260141.jpg Date of Photo: 06/26/2024 Time of Photo: 10:29 AM Photographer: Kiera Hancock Description: Bioadvanced Rose & Flower Care side 2 (4) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 14 I County/Parish: Dallas I State: TX Photo File Name: P6260142.jpg Date of Photo: 06/26/2024 Time of Photo: 10:30 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 15 I County/Parish: Dallas I State: TX Photo File Name: P6260143.jpg Date of Photo: 06/26/2024 Time of Photo: 10:30 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 16 I County/Parish: Dallas I State: TX Partials & dentures need special care Polident 4 in 1 Oeaning System is age tle &. noo-at>rasive fo ulation that lls odor-a using bacteria hdps rel'IXl'tt stains and eeps ur partial denture ctean & fr1!StL Photo File Name: P6260144.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 17 I County/Parish: Dallas I State: TX INGREDIENTS: sodi um bicarbonate, citric acid, potassium monopersul_fa te, sodium carbonate, sodium carbonate peroxide, TAED, sodium benzoate PEG- 180, sodium lauryl sulfat e, VP/VA copolymer ' flavo r, cellu lose gum, FD&C blue 2, blue 1lake, yell~w 5 yellow 5 lake ' Do not store above 25"( (77F). Questions or comments? 1-866- 844- 2796. Keep tablets outofreach of children and those at risk of accidentally swallowing the tablet or solution Do not place tablets or solution in mouth Do not drink cleansing solution or use it as mouthwash Rinse well Do not use ifyou are sensitive to any of the ingredients. May produce allergic reaction. If irritation occurs, discontinue use and get medical advice and/or attention. IF SWALLOWED: Call a Poison Control Center or doctor. Do not touch mouth or eyes after handling tablets or solution. Wash hands thoroughly after handUng tablet or solution. Causes serious eye irritation. IF IN EYES: rinse cautiously with water for several minutes. If eye irritation persists, get medical advice and/or attention. Tamper evident inner unit. Do not use if sealed Polident packs are torn or broken. "Soaking on ly, in laboratory tests. Photo File Name: P6260145.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 4 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 18 County/Parish: Dallas State: TX Photo File Name: P6260146.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 4 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 19 I County/Parish: Dallas I State: TX Of l k ~ to the GSK aroup of Comp,nitS COMUIM" HNl,theln. n s or lK nsor Photo File Name: P6260147.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 20 County/Parish: Dallas State: TX Photo File Name: P6260149.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 21 County/Parish: Dallas State: TX Photo File Name: P6260150.jpg Date of Photo: 06/26/2024 Time of Photo: 10:31 AM Photographer: Kiera Hancock Description: Polident Antibacterial Denture Cleanser side 1 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 22 County/Parish: Dallas State: TX Photo File Name: P6260151.jpg Date of Photo: 06/26/2024 Time of Photo: 10:38 AM Photographer: Kiera Hancock Description: 3PL Fulfillment & Prep warehouse UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 23 County/Parish: Dallas State: TX Photo File Name: P6260152.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 24 County/Parish: Dallas State: TX Photo File Name: P6260153.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 1 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 25 County/Parish: Dallas State: TX Photo File Name: P6260154.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 26 I County/Parish: Dallas I State: TX PUSH TO COMPRESS Photo File Name: P6260155.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 2 (2) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 27 County/Parish: Dallas State: TX Photo File Name: P6260156.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 2 (3) UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 28 County/Parish: Dallas State: TX Photo File Name: P6260157.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 3 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 29 I County/Parish: Dallas I State: TX Photo File Name: P6260158.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 4 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 30 County/Parish: Dallas State: TX Photo File Name: P6260159.jpg Date of Photo: 06/26/2024 Time of Photo: 10:42 AM Photographer: Kiera Hancock Description: BugZooka side 5 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 31 County/Parish: Dallas State: TX Photo File Name: P6260160.jpg Date of Photo: 06/26/2024 Time of Photo: 10:43 AM Photographer: Kiera Hancock Description: BugZooka side 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 32 County/Parish: Dallas State: TX ThifU gZ0;ik:i Part No: WB100 Qty: 16 set N. W. 26.4 LBS - - - G.W. 32.8 LBS CUFT: 18.5 "X 16.6 "X 22.8" www.bugzooka.com E C Photo File Name: P6260161.jpg Date of Photo: 06/26/2024 Time of Photo: 10:43 AM Photographer: Kiera Hancock Description: BugZooka box label UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 33 I County/Parish: Dallas I State: TX Photo File Name: P6260162.jpg Date of Photo: 06/26/2024 Time of Photo: 10:48 AM Photographer: Kiera Hancock Description: Advantage 20X Citrus Multi-Purpose Cleaner side 1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 34 County/Parish: Dallas State: TX ,ng - carpet stains, Ots, food spill,~ concentrated Photo File Name: P6260163.jpg Date of Photo: 06/26/2024 Time of Photo: 10:48 AM Photographer: Kiera Hancock Description: Advantage 20X Citrus Multi-Purpose Cleaner side 2 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Location: 11094 Grader St City: Dallas Photo No. 35 County/Parish: Dallas State: TX Photo File Name: P6260165.jpg Date of Photo: 06/26/2024 Time of Photo: 10:50 AM Photographer: Kiera Hancock Description: LG Water Filter box