DODGE CHEMICAL COMPANY

Dodge manufactures embalming chemicals at a facility in Cambridge, MA. In its manufacturing process, Dodge uses formaldehyde, a chemical subject to Clean Air Act Section 112(r)’s Risk Management Plan (“RMP”) regulations. It also uses several flammable alcohols and nitrocellulose. Specifically, EPA has found that (a) Dodge failed to analyze hazards associated with its management of formaldehyde and other extremely hazardous substances, in violation of 40 C.F.R. § 68.67 and the General Duty Clause, 42 U.S.C. § 7412(r)(1); (b) re-submit a Risk Management Plan (“RMP”) for its management of formaldehyde, in violation of 40 C.F.R. §§ 68.190(b); and (c) comply with many of the underlying chemical accident prevention program requirements for “Program 3” processes (40 C.F.R. Part 68, Subpart D). The Notice of Violation, Administrative Order and Reporting Requirement notifies Dodge of the violations; requires Dodge to certify compliance with the RMP regulations; requires Dodge to undertake a hazards analysis pursuant to the General