U.S. EPA issued an FOV to Mule-Hide on March 29, 2004, citing them for violations of the Architectural Coatings Standards at 40 C.F.R. Part 59, Subpart D. Specifically, the alleged violations included Mule-Hide's failure to submit an initial notification report by Sept. 13, 1999, failure to provide a statement of its recommendation on thinning on its containers of architectural coatings, and failure to provide the VOC content on its containers of architectural coatings.
During a 113 conference held on May 17, 2004, Mule-Hide provided U.S. EPA with an initial notification report dated April 28, 2004 and updated labels, both of which were required for compliance.