On September 26, 2017, the Regional Judicial Officer ratified a combined Complaint and Consent Agreement (CAFO) between EPA Region III and Clean-Flo International, LLC of West Chester, Pennsylvania for alleged violations of FIFRA statutory and regulatory requirements governing establishment registration, sales and distributions of pesticides, and of associated recordkeeping/reporting. EPA's investigation yielded evidence sufficient to allege that in calendar years 2012 and 2013 Clean-Flo International, LLC: (1) produced five (5) pesticidal products (i.e., the pesticides Lake Care, Lake Cleanser Special, Clean & Clear Concentrated Enzymes and Lake Clear) and a device known as the Clean-Flo Laminar System, at an unregistered establishment in West Chester, Pennsylvania; (2) made numerous distributions and/or sales of unregistered pesticides produced at that establishment; and (3) twice failed to comply with applicable FIFRA annual recordkeeping/reporting regulatory requirements. These activities constitute violations of Sections 3(a) and 7(a) of FIFRA, 7 U.S.C. Section 136a(a) and 136e(a), and unlawful acts under FIFRA Sections 12(a)(1)(A) and 12(a)(2)(L), 7 U.S.C. Section 136j(a)(1)(A) and 136j(a)(2)(L) for which penalties may be assessed pursuant to Section 14(a) of FIFRA, 7 U.S.C.Section 136l(a).
Representatives of Clean-Flo International, LLC cooperated fully with EPA during the inspection and investigation and have now certified that the Company currently is in compli