Elementis Chromium, Inc. (“Elementis”) appeals an Initial Decision the Chief Administrative Law Judge (“ALJ”) issued assessing a $2,571,800 administrative civil penalty against it for violating section 8(e) of the Toxic Substances Control Act (“TSCA”), 15 U.S.C. § 2607(e). The ALJ concluded that Elementis failed to report to the Environmental Protection Agency information contained in an occupational epidemiology study on hexavalent chromium.

U.S. Environmental Protection Agency Region 5 appeals from an Administrative Law Judge’s initial decision in an enforcement matter arising under EPA’s residential lead-based paint disclosure rule (“Disclosure Rule”), promulgated under the authority of section 1018 of the Residential Lead-Based Paint Hazard Reduction Act, 42 U.S.C. § 4852d, and sections 16(a) and 409 of the Toxic Substances Control Act, 15 U.S.C. §§ 2615(a), 2689. In that decision, the Administrative Law Judge (“ALJ”) dismissed ten violations of the Disclosure Rule, codified at 40 C.F.R.