Document pmYK6ez97Qzj2eG0p0xK9QLQd

ft E A ~ United States ._.,,.., Environmental Protectior , Agency Region 6 - Enforcement & Compliance Assurance Division INSPECTION REPORT Inspection Date(s): Media Program: Regulatory Program(s) 11/05/2025 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: AK Wholesale LLC AK Wholesale LLC 8774 Fawn Trail Conroe, Texas, 77385 8774 Fawn Trail Conroe, Texas, 77385 Montgomery 936-827-5080 Razwan Khan akwholesalellc@gmail.com FRS Number: Identification/Permit Number: Media Identifier Number: NAICS: SIC: N/A N/A N/A 424410 50 Personnel participating in inspection: Kiera Hancock EPA-ECDST Justin Mullenix EPA-ECDST Razwan Khan AK Wholesale LLC I I Manager Inspector Inspector Manager EPA Lead Inspector Signature/Date Supervisor Signature/Date Kl ERA HAN Coe K Digitally signed by KIERA HANCOCK Date: 2025.12.18 10:16:22 -06'00' Kiera Hancock Date /~/ Gerardo Acosta Digitally signed by GERARDO ACOSTA Date: 2025.12.18 10:37:46 -06'00' Date 6ENFORM-019-R8.2 (02/12/2020) 1 AK Wholesale LLC Inspection Date 11/05/2025 2 Section I - INTRODUCTION AK Wholesale LLC Inspection Date 11/05/2025 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. This inspection occurred for-cause for suspected sale and/or distribution of unregistered pesticides as identified through their website, https://akwholesaletx.com/. FACILITY DESCRIPTION AK Wholesale LLC is a wholesale warehouse that specializes in household products, medicines, personal care, and school supplies. Household products included disinfectants, sanitizers, and insecticides. AK Wholesale LLC is incorporated in Texas and is estimated to be a Category II size of business. Section II - OBSERVATIONS I, EPA Region 6 inspector, Kiera Hancock, and inspector Justin Mullenix, arrived at AK Wholesale LLC, on November 5, 2025, at approximately 11:55AM. I entered the facility and spoke with an employee who directed us to the manager of AK Wholesale LLC. I identified myself and my colleague as inspectors with the EPA and explained the purpose of our visit. The manager identified himself as Razwan Khan. I requested to move to an office to review and provide documentation. Inspector Mullenix and I presented our federal inspector's credentials, and I provided a Notice of Inspection (EPA Form 3540-2) to Mr. Khan for review and signature (Appendix 1). After the Notice of Inspection was signed, inspector Mullenix and I asked questions about the store and its activities. Mr. Khan informed us that AK Wholesale LLC does not import products but buys from companies within the United States. I provided a list of products observed to be potentially an area of concern on AK Wholesale's website (URL: https://akwholesaletx.com/). We then informed Mr. Khan that we would look around and review the pesticidal products being offered for sale at the store. Mr. Khan, Inspector Mullenix, and I entered the warehouse and observed a small assortment of FIFRAregulated products being held for sale and distribution. Pesticidal products were reviewed, and Inspector Mullenix took photographs of the product's labels (Appendix 3). Following our review of the pesticidal products, Inspector Mullenix and I reapproached Mr. Khan to discuss the findings of the inspection. We then re-entered the office. I informed Mr. Khan that there were four products of concern that included Fabuloso Ultra Frescura, Ariel Matic, Clorox Ropa, and Clorox (Spanish label). Mr. Khan confirmed that he will set the products aside and not sell or distribute them. I explained the FIFRA regulations and provided him with a Small Business Resource Information Sheet, the Confidential Business Information (CBI) Sheet, and the CBI Notice Questions and Answers. I requested him to provide 3 AK Wholesale LLC Inspection Date 11/05/2025 three years of sale/distribution and invoices for the products, and he stated he will need some time but will provide them. I informed Mr. Khan that a copy of the EPA inspection report would be provided to him via email within sixty days. I then provided a Receipt for Samples (EPA Form 3540-3) for the photographs taken for his review and signature. Mr. Khan signed the Receipt for Samples (Appendix 2). A copy of the Receipt for Samples and Notice of Inspection was provided to Mr. Khan. The inspection concluded at approximately 12:35PM. Section III - AREAS OF CONCERN Four pesticidal products were observed to be areas of concern. The products include: 1. Fabuloso Ultra Frescura - Mar Fresco (500mL) 2. Ariel Matic 3. Clorox Ropa (930mL) 4. Clorox - Spanish Label (1.89L, 930mL, and 500mL) All four products labels indicated they are used as pesticides and were not registered within the United States at the time of the inspection. Labeling for the products included, but was not limited to the following claims: 1. Fabuloso Ultra Frescura - Mar Fresco (500mL) a. "Neutraliza Malos Olores, Virus y Bacterias" (Neutralizes bad odors, viruses and bacteria) b. "Antibacterial y Antiviral" (Antibacterial and Antiviral) c. "...elimina virus y bacterias y deja una duradera fragancia" (Eliminates viruses and bacteria and leaves a long-lasting fragrance) 2. Ariel Matic a. "Antibac" (Antibacterial) b. "khng khuan" (Antibacterial) 3. Clorox Ropa (930mL) a. "Quita Manchas y Desinfecta" (Removes stains and disinfects) 4. Clorox - Spanish Label (1.89L, 930mL, and 500mL) a. "48 Horas Prevencion Contra Bacterias" (48 Hours Prevention Against Bacteria) Section IV - FOLLOW UP The following information was requested through email by EPA on November 11, 2025, after exiting the Facility on November 5, 2025: 1. Last three years of sale/distribution records for Fabuloso Ultra Frescura, Ariel Matic, Clorox Ropa, and Clorox (Spanish Label). 2. Last three years of invoices for Fabuloso Ultra Frescura, Ariel Matic, Clorox Ropa, and Clorox (Spanish Label). 4 Section V - LIST OF APPENDICES AK Wholesale LLC Inspection Date 11/05/2025 Appendix 1 - Notice of Inspection (Form 3540-2) Appendix 2 - Receipt for Samples (Form 3540-3) Appendix 3 - Photograph Log - 5 photographs taken on November 5, 2025 5 AK Wholesale LLC Inspection Date 11/05/2025 Appendix 1 Notice of Inspection (Form 3540-2) 6 &EPA United States Environm ental Protection Ag ency United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 N<:>tice of Inspection Office of Enforcement and Compliance Assurance Facility Name A-1(. vJhol~(~ L.Le, Name of Facility Official Facility Address '%77'-1 Fe,,1,,-?Vl Cu~roec-, TX Title r~:, 773f?S /Lh~V\ I (le."\... I.,,./Ci V\ ;Vl0-VtL- ~ 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: l(~ 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 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 obtain ing 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 Violat ion Suspected: <;c,\'C. j f) ;~ti",L....-1fhft c! Additional Information: (,.{ v1 n , ; :::. 1--c..rv( ) - r s J d- A Name of Inspector /L-ii 0c Signature of Inspector ~ J-J-c:,,;/l lvc---lL... .... Title -:r:,'1 </)YL--ft>rv Date // / 5/ J-<.JJ..._S Time I ';)_ '. <YOtJt Address 1)..01 Elm. <;+rz__e + , }:)4]It. I , TK 7->:J- 7o 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 that the proper procedures were not followed. EPA Form 3540-2 (Rev. 07/09) Previous editions may be used unt il supply is exhausted 1-lnspector Copy 2-Facility Copy AK Wholesale LLC Inspection Date 11/05/2025 Appendix 2 Receipt for Samples (Form 3540-3) 7 oEPA United States Environmental Protection Age ncy United States ENVIRONMENTAL PROTECTION AGENCY Washington, DC 20460 Receipt for Samples Office of Enforcement and Compliance Assurance Facility Name A-I" Wn.,l~e-.\~ l.,LC Name of Facility Official Facility Address 37rt ~vvV\_ T'R.i\ l uY1 f?>..(_ I I X 77 3,J > Title )2,. C\ 2..-W 4 I'\ JL, heiV\ ~k(./' 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). /JOSJ..o'J.-.>- 0oJ5O7- J..';)...'i1 - /Joc..X>fll~t'I -o:t.-01- 5 ph ii toj a~ No Duplicate samples . D Duplicate samples IA .d mount paI requested and provided not requested I Cash D Credit Card D 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 '(t\lYV\ A Name of Inspector Jliie_ry_ l+c.r1c,..x--L - Signature of Inspector ~ Address I ?...01 G/W\._ StCl.et I lJ4/l~;. , 7 X JS')...70 IDate // / 5 / "J-,YJ.-5 Title T'rutJYvtv-r Date II Is; I )-.._C} ;).J" EPA Form 3540-3 (Rev. 07/09) Previous editions may be used until supply is exhausted 1-lnspector Copy 2-Facility Copy AK Wholesale LLC Inspection Date 11/05/2025 Appendix 3 Photograph Log - 5 photographs taken on November 5, 2025 8 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 1 Location: AK Wholesale LLC - 8774 Fawn Trail City: Conroe County/Parish: Montgomery State: Texas Photo File Name: P1010035.jpg Date of Photo: 11/05/2025 Time of Photo: 12:05M Photographer: Justin Mullenix Description: Front and back label of Fabuloso Ultra Frescura Antibacterial Y Antiviral - Mar Fresco (500mL). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 2 Location: AK Wholesale LLC - 8774 Fawn Trail City: Conroe I County/Parish: Montgomery IState: Texas Photo File Name: P1010036.jpg Date of Photo: 11/05/2025 Time of Photo: 12:08PM Photographer: Justin Mullenix Description: Front label of Ariel Matic. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 3 Location: AK Wholesale LLC - 8774 Fawn Trail City: Conroe I County/Parish: Montgomery IState: Texas Photo File Name: P1010037.jpg Date of Photo: 11/05/2025 Time of Photo: 12:09PM Photographer: Justin Mullenix Description: Back label of Ariel Matic. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 4 Location: AK Wholesale LLC - 8774 Fawn Trail City: Conroe County/Parish: Montgomery State: Texas Photo File Name: P1010038.jpg Date of Photo: 11/05/2025 Time of Photo: 12:11PM Photographer: Justin Mullenix Description: Front label of Clorox (Spanish Label). UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Photograph Log Photo No. 5 Location: AK Wholesale LLC - 8774 Fawn Trail City: Conroe I County/Parish: Montgomery IState: Texas Photo File Name: P1010039.jpg Date of Photo: 11/05/2025 Time of Photo: 12:13PM Photographer: Justin Mullenix Description: Front label of Clorox Ropa.