Document aDv7Qojo24NyZgx8y308pMezB
ft E A ~ United States
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Environmental Protectlor
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Agency
Region 6 - Enforcement & Compliance Assurance Division
INSPECTION REPORT
Inspection Date(s): Media Program: Regulatory Program(s)
11/4/2025 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:
Border Wholesale, Inc. dba Border Cash & Carry, Inc.
Border Cash & Carry
610 Lanark Drive, #150
San Antonio, Texas 78218
610 Lanark Drive, #150
San Antonio, Texas 78218
Bexar
(210) 257-0933 Sayed H. Nasafi
I I Vice President
Hussein.Nasafi@7starsavings.com
FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC:
N/A N/A N/A 459999 5999
Personnel participating in inspection:
Justin Mullenix
EPA R6 ECAD
Kiera Hancock
EPA R6 ECAD
Sayed H. Nasafi
Border Cash & Carry, Inc.
Inspector Inspector Vice President
EPA Lead Inspector Signature/Date
Supervisor Signature/Date
JU STI N MU LL EN IX Digitally signed by JUSTIN MULLENIX Date: 2025.11.24 12:42:S9 -06'00'
Justin Mullenix
/~/
Gerardo Acosta
Date
Digitally signed by GERARDO ACOSTA Date: 2025.11.24 13:43:37 -06'00'
Date
6ENFORM-019-R9 (02/27/2025)
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Section I - INTRODUCTION
Border Wholesale, Inc. dba Border Cash & Carry, Inc. Inspection Date 11/4/2025
PURPOSE OF THE INSPECTION
This for-cause marketplace inspection was conducted pursuant to the Federal, Insecticide, Fungicide, and Rodenticide Act (FIFRA) Section 8, 7 U.S.C. 136f, and Section 9(a), 7 U.S.C. 136g(a), to evaluate compliance with FIFRA and the regulations thereunder. The inspection occurred for-cause due to suspected distribution or sale of unregistered pesticides.
FACILITY DESCRIPTION
Border Wholesale, Inc. dba Border Cash & Carry, Inc. ("Border Cash & Carry") is a company incorporated and doing business in the state of Texas that specializes in the wholesale distribution or sale of grocery products including those originating from Mexico. Border Cash & Carry is a subsidiary of AK Rashidzada Corporation dba 7 Star Savings ("7 Star Savings"), a company based in New York. Border Cash & Carry operates a warehouse facility located at 610 Lanark Drive, #150, San Antonio, Texas 78218. According to sources available online, Border Cash & Carry generates approximately <$1 million in annual revenue, while its parent company, 7 Star Savings, generates approximately $2.7 million in annual revenue.
Section II - OBSERVATIONS
EPA Inspectors Kiera Hancock and I arrived at Border Cash & Carry on November 4, 2025, at approximately 9:20AM. We entered the facility at approximately 9:30AM. We were met by Mr. Sayad H. Nasafi, Vice President of Border Cash & Carry, and led to a conference room where I presented my inspector credential and a Notice of Inspection (EPA Form 3540-2) to Mr. Nasafi. Mr. Nasafi did not initially sign the Notice of Inspection but later did at the conclusion of the opening conference.
After explaining the scope of the inspection to Mr. Nasafi, I asked a series of questions about the company and its activities, particularly regarding the distribution or sale of any unregistered pesticide cited in the Stop Sale, Use, or Removal Order and Agreement on Consent (SSUROAC) filed in the matter of Border Cash & Carry on August 14, 2025 (EPA Docket No. FIFRA-06-2025-0381). Mr. Nasafi informed us that the unregistered pesticide(s) in question, Fabuloso Ultra Frescura/Frescura Activa (various), was no longer being held for distribution or sale by the company. He further stated that the other products cited in the SSUROAC ("Products Identified on Respondent's Website") have never been held at Border Cash & Carry, explaining that those products may only be present at other 7 Star Savings subsidiaries and/or advertised on the 7 Star Savings website. Mr. Nasafi indicated that all Fabuloso Ultra Frescura/Frescura Activa (various) held at Border Cash & Carry had been returned to its original vender(s).
At the conclusion of the opening conference, Mr. Nasafi offered to show Inspector Hancock and I around the warehouse portion of the facility to review the products in inventory. We followed Mr. Nasafi to the warehouse where we were taken to an area where pesticides and cleaning products were being held. I noted the presence of Fabuloso Multi-Purpose Cleaner which Mr. Nasafi explained was a replacement for Fabuloso Ultra Frescura/Frescura Activa (various). We reviewed other cleaning products as well,
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Border Wholesale, Inc. dba Border Cash & Carry, Inc. Inspection Date 11/4/2025
noting that none appeared to be within the purview of FIFRA due to the lack of pesticidal claims. Products within the purview of FIFRA, such as insect repellents and insecticides, all appeared to be registered and produced in registered establishments in compliance with FIFRA. One product of interest was discovered that did not contain EPA Registration and Establishment Numbers: Bed Bugs No More. This product, which claims a FIFRA Section 25(b) exemption from registration, did not appear to be fully compliant with the Minimum Risk Pesticide exemption standards and was photographed by Inspector Hancock for further review. At the conclusion of the facility walkthrough, Inspector Hancock and I followed Mr. Nasafi back to the conference room. I discussed our findings with Mr. Nasafi and explained next steps including the issuance of an inspection report. I asked Mr. Nasafi about the availability of records pertaining to the distribution or sale of Fabuloso Ultra Frescura/Frescura Activa (various) and/or other products of interest to EPA. Mr. Nasafi stated that he would provide such records upon request but would prefer to do so at a later time. I agreed to follow up with Mr. Nasafi on the records request via email. At the conclusion of the closing conference, I prepared a Receipt for Samples (EPA Form 3540-3) for the photographs taken during the inspection. Inspector Hancock and I also discussed Confidential Business Information and provided an EPA Small Business Resources Information Sheet to Mr. Nasafi. Mr. Nasafi also received courtesy copies of the Notice of Inspection and Receipt for Samples. The inspection concluded at approximately 10:35AM.
Section III - AREAS OF CONCERN An area of concern identified during the inspection is the potential distribution or sale of an unregistered pesticide, Bed Bugs No More, by Border Cash & Carry.
Section IV - FOLLOW UP No additional information has been requested or received by EPA after exiting the facility on November 4, 2025. A records request to Border Cash & Carry is pending.
Section V - LIST OF APPENDICES Appendix 1 - Photo Log Appendix 2 - Notice of Inspection (EPA Form 3540-2) Appendix 3 - Receipt for Samples (EPA Form 3540-3)
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Border Wholesale, Inc. dba Border Cash & Carry, Inc. Inspection Date 11/4/2025
Appendix 1 Photograph Log
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 1
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010001.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Aisle 12 Product Location
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 2
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010002.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Fabuloso Multi-Purpose Cleaner (1)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 3
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010003.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Fabuloso Multi-Purpose Cleaner (2)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 4
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010004.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Aisle 10 Product Location
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 5
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010005.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Aisle 13 Product Location
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 6
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010006.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Aisle 17 Product Location
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 7
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010007.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (1)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 8
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010008.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (2)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 9
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010009.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (3)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 10
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010010.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (4)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 11
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010011.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (5)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 12
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
.BEDBUGS
NO MO/IE;
KIUS EVEN THE rou11HEST BED ~
File Name: P1010012.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (6)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 13
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
I County/Parish: Bexar
I State: Texas 78218
Distributed by: -
Universal Distributf nCenter LLC
' Edison; NJ 08817 ,
File Name: P1010013.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (7)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 14
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010014.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Bed Bugs No More (8)
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Photograph Log
Photo No. 15
Location: Border Cash & Carry - 610 Lanark Dr, #150
City: San Antonio
County/Parish: Bexar
State: Texas 78218
File Name: P1010015.JPG Date: 11/4/2025 Photographer: Kiera Hancock Description: Aisle 18 Product Location
Border Wholesale, Inc. dba Border Cash & Carry, Inc. Inspection Date 11/4/2025
Appendix 2 Notice of Inspection
&EPA United States Environmental Protection Agency
United States
ENVIRONMENTAL PROTECTION AGENCY
Washington, DC 20460
Notice of Inspection
Office of Enforcement and Compliance Assurance
Facility Name
i"r>.," l"'bh -t Utrf Y
{ g,,.-,lc.~ who\t,~ \ i- , 1,\(; .)
Name of Facility Official
5r-tytJ H. >Jl(_~,.f:
Facility Address
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b\O L...i-..rlC pr-. :\'.} l 11
~t,.('I, ""-+""'" 1 T 7\ l\ '1
Title
ve
By my signature, I represent that I am an owner, operator or agent in charge of the facility being inspected, and attest that
the EPA, Designated State or Political Subdivision Employee or Officer identified on this form presented his or her credentials
prior to issuing this Notice of Inspection.
Facility Official's Signature:
Authority for Inspection
~ .......
For the purpose of inspecting and obtain ing samples of any pesticides or devices packaged, labeled and released for shipment,
and samples of any containe rs or labeling for such pesticides or devices, in places where pesticides or devices are held for
distribution or sale [FIFRA 9(a) (7 U.S.C. 1369)]; and for the purpose of inspecting and obtaining copies of those records
specified in FIFRA 8 (7 U.S.C. 136f) and 40 C.F.R. Part 169.
Reasons for Inspections (Check applicable boxes)
Routine Inspection
lx1' For Cause Inspection
Additional Information:
Violation
Suspected: V,<i1(:b"'"1";<il'\)sk1l,. ~
N/A
,,.u,. (~,:~e-rul
fe,S'-h c.i le.~
Name of Inspector "J'"'111.,-'c~,,... M "\ \t-"-iA'
Signature of Inspector ( ) j f t /
Date n )~\ 1'>
Title L.-:-fL Sc.it.p.,h~~
Time 1: ~7 A//\
Tx Address \201 EIM 'i"1, D.. \\.~
71210
Note: The absence of a Facility Officiars signature on this form does not invalidate this Notice of Inspection, or est ablish 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-Inspector Copy 2-Facility Copy
Border Wholesale, Inc. dba Border Cash & Carry, Inc. Inspection Date 11/4/2025
Appendix 3 Receipt for Samples
&EPA United States Environmental Protect ion Agen cy
United States
ENVIRONMENTAL PROTECTION AGENCY
Washington, DC 20460
Receipt for Samples
Office of Enforcement and Compliance Assurance
Facility Name Buf'Jtr Ct.Sh -f 6t~ry
(BorJ.e.r wh~lt:.>"- lt. / TrtC.)
Name of Facility Official
Syu~. H. N1t 51t .t;
Facility Address
blo LAr1rK Or. ::it l'i 0
5"r1 At'\.To.--r;o I Title
Vf
T} 7\ t I?,
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).
\\ol.\lt72.'1 - O\,~o-z;,q_,occ101771, -o,-P,. )5 fno-+ oJ r1teh 1
\..
Duplicate samples .
~uplicate samples IA
.d
mount paI
requested and provided not requested
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 pack~d, labeled and released for shipment.
Facility Official Signature
~~
I Date /V<l V, 'f -. ~ ""l.-
Name of Inspector "S"45+i r1 M" JI UI ,')(
Signature of Inspector ,t ) , ~
Address IZ.o \ 1"" 5i- , OllJIAS , T.X 7S 2 7 P
Title L"-fe, 5l;e,n-J-,~-t1
Date \ \ It>'\ ) 'ZP 21i
EPA Form 3540-3 (Rev. 07/09)
Previous editions may be used until supply is exhausted
1-lnspector Copy 2-Facility Copy