TFORCE FREIGHT

TForce Freight, Inc. — the less-than-truckload carrier spun from UPS Freight in April 2021 and now operating as a TFI International subsidiary — carries a compliance profile shaped almost entirely by one system-wide hazardous waste matter rather than a scattered pattern of air or water permit exceedances. EPA ECHO data as of May 4, 2026 shows 37 linked facilities, 77 quarters-with-noncompliance instances across a rolling 24-month window, and a derived penalty total of $16,691,520, with zero active permits of record and a latest permit date of December 17, 2015 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That penalty figure traces directly to the December 2022 RCRA Section 3008 consent agreement and final order entered in EPA Docket No. RCRA-HQ-2022-0943, which resolved alleged hazardous waste noncompliance across 39 states [source: https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/a32958a86c47d3d485256fc70049e837/2274217517a48ca6852589120072d36f!OpenDocument].

No active SEC filings exist for TForce Freight itself. The entity is private. Its parent TFI International reports at the consolidated level, where the U.S. LTL segment housing TForce posted an adjusted Q4 operating ratio of 95.3% and an 11% revenue decline [source: https://ng.investing.com/news/earnings/tfi-international-faces-earnings-test-amid-freight-market-struggles-93CH-2463551]. Public-facing ESG disclosure from the company is limited to a brief ESG update page maintained by affiliated TForce Logistics and an emissions estimate hosted by a third party [source: https://www.tforcelogistics.com/esg-update/] [source: https://ditchcarbon.com/organizations/tforce-freight-inc]. A 39-state RCRA settlement on one side, a near-empty sustainability disclosure surface on the other — that gap is the defining ESG feature of this issuer.

TForce Freight's regulatory footprint is unusual for a motor carrier in NAICS 484122. The company does not operate heavy manufacturing or chemical process units. Environmental exposure arises instead from terminal operations — parts washers, used oil, aerosol cans, spent solvents, damaged freight containing listed wastes, and fluorescent lamps — distributed across a national terminal network. EPA ECHO lists 37 regulated facilities tied to the TForce Freight registrant, with a 24-month violation count of 77 and a derived 24-month penalty of $16.69 million based on the exporter's standard 5-year-to-24-month proration [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO records show no active permits and a last permit date of December 17, 2015, consistent with RCRA small- or large-quantity-generator status rather than Title V or NPDES major-source permitting [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The chronological spine of the past 24 months begins with the April 2021 closing of UPS's divestiture of UPS Freight to TFI International and the rebrand to TForce Freight [source: https://en.wikipedia.org/wiki/TForce_Freight]. On December 5, 2022, EPA filed a consent agreement in Docket No. RCRA-HQ-2022-0943. The Environmental Appeals Board entered the Final Order three days later, on December 8, and EPA publicly announced the settlement on December 13, 2022 [source: https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/a32958a86c47d3d485256fc70049e837/2274217517a48ca6852589120072d36f!OpenDocument] [source: https://epa.gov/newsreleases/epa-announces-settlement-tforce-correct-hazardous-waste-violations-39-states]. Bloomberg Law's coverage of the same action characterizes it as resolving alleged noncompliance with hazardous waste regulations across 39 states [source: https://news.bloomberglaw.com/environment-and-energy/tforce-freight-settles-hazardous-waste-violations-in-39-states].

Throughout 2023 and 2024, trade press attention shifted from enforcement to cost structure. In October 2023, Trucking Dive reported TFI International's plan to reduce costs at TForce terminals, with executives publicly describing the acquired operation as carrying excess overhead [source: https://www.truckingdive.com/news/tfi-international-tforce-freight-yellow-corp-cost-reduction/722698/]. FreightWaves separately reported Teamsters allegations that TForce Freight reduced truck governed speeds from 68 to 65 mph in a manner the union argued violated federal law — a labor matter rather than an environmental one, but relevant to any reading of operator conduct [source: https://www.freightwaves.com/news/tag/tfi-international]. By Q1 2026, TFI reported softer earnings attributed partly to higher accident-related costs, though LTL operating ratio trended favorably [source: https://www.trucknews.com/business-management/tfi-sees-improving-freight-market-despite-softer-q1-earnings/1003213919/] [source: https://www.ttnews.com/articles/tfi-earnings-q1-2026]. No new EPA enforcement actions against TForce Freight have surfaced in the research bundle since the December 2022 consent order, meaning the ECHO penalty figure reflects amortization of that single settlement rather than fresh violations.

Primary action: EPA Docket No. RCRA-HQ-2022-0943, Appeal No. RCRA 3008 22-03C, captioned In re TForce Freight, Inc. Statute: Resource Conservation and Recovery Act, Section 3008. Type: Penalty. File date: December 5, 2022. Decision date: December 8, 2022. Result: Final Order, Consent Agreement (unpublished) [source: https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/a32958a86c47d3d485256fc70049e837/2274217517a48ca6852589120072d36f!OpenDocument]. EPA's December 13, 2022 press release states the settlement resolved alleged hazardous waste noncompliance across 39 states, placing it among the broader multi-state RCRA administrative actions against a motor carrier on record [source: https://epa.gov/newsreleases/epa-announces-settlement-tforce-correct-hazardous-waste-violations-39-states] [source: https://news.bloomberglaw.com/environment-and-energy/tforce-freight-settles-hazardous-waste-violations-in-39-states]. Program: RCRA Subtitle C generator and transporter standards applicable to terminal operations handling universal waste, used oil, and damaged shipments containing listed or characteristic wastes. Facilities implicated: the action references conduct across 39 states; ECHO links 37 registered facility IDs to the TForce Freight registrant, spanning terminals in Ohio, Virginia, Texas, Washington, and other states [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Dollar outcome: ECHO's derived 24-month penalty allocation is $16,691,520 against a 5-year total implied by the exporter's proration formula of approximately $41.7 million. The underlying consent order is filed as unpublished in the EAB docket, and the precise civil penalty amount does not appear in the research bundle [source: https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/a32958a86c47d3d485256fc70049e837/2274217517a48ca6852589120072d36f!OpenDocument]. Secondary CWA/CAA actions: none disclosed in the research bundle. No NPDES effluent, Title V air, or TSCA actions against TForce Freight in the 24-month window are present in the provided sources.

Shelby, Ohio (HQ-linked terminal): Ohio corporate records list TForce Freight, Inc. as an active foreign corporation originally filed October 3, 1973 under predecessor names, with registered agent Corporation Service Company at 50 West Broad Street, Columbus [source: https://ohio-corp.com/co/ups-ground-freight-inc]. ECHO links multiple Ohio facility IDs among the 37 registrants, and the Shelby location serves as the operational anchor for Midwest LTL flows described in TFI's investor commentary [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Richmond/Henrico, Virginia: the registrant's corporate address of record on the UPGF 102-S tariff effective November 10, 2025 is P.O. Box 1216, Richmond, VA 23218-1216 [source: https://www.tforcefreight.com/downloads/UPGF-102-S-20251110.pdf]. Dun & Bradstreet confirms the Henrico, Virginia profile for TForce Freight, Inc. [source: https://www.dnb.com/business-directory/company-profiles.tforce_freight_inc.deb995d2277f1e0b29761fc2addf8d18.html]. This address is the nexus for administrative RCRA reporting obligations.

Fort Worth, Texas (service center): TForce operates a dispatch and service center in Fort Worth [source: https://talents.vaia.com/companies/tforce-freight/fort-worth/freight-dispatch-service-center-specialist-74821614]. Texas is among the 39 states covered by the December 2022 RCRA consent order [source: https://epa.gov/newsreleases/epa-announces-settlement-tforce-correct-hazardous-waste-violations-39-states].

Kansas City (road driver domicile terminal): TForce Logistics lists an active Kansas City road operation, consistent with ECHO-registered Missouri/Kansas terminal IDs in the facility list [source: https://talents.vaia.com/companies/tforce-logistics/kansas-city/road-driver-tforce-freight-74810993/] [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Spokane, Washington corridor: trade press imagery documents TForce double-combination equipment operating on Interstate 90 west of Spokane, confirming an active Pacific Northwest terminal presence within the 37-facility ECHO set [source: https://www.truckingdive.com/news/tfi-internationals-ltl-shipments-get-big-boost-in-recent-months/818635/]. ECHO's EJ index average across the registered facilities is reported as 0.0 in the exporter snapshot. That figure reflects missing EJScreen joins for motor-carrier terminals rather than a confirmed absence of overburdened-community exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

ECHO's top_pollutants field is empty for TForce Freight, consistent with a RCRA generator/transporter compliance profile rather than a TRI or NPDES discharge profile [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The waste streams implicit in the 2022 RCRA Section 3008 action are those typical of LTL terminals: used oil and oil-contaminated absorbents from tractor maintenance; spent solvents and aerosol cans handled as universal or hazardous waste; and damaged freight containing listed or characteristic hazardous materials that become the carrier's generator responsibility upon breakage in transit [source: https://epa.gov/newsreleases/epa-announces-settlement-tforce-correct-hazardous-waste-violations-39-states].

Toxicity profile: spent halogenated and non-halogenated solvents — F-listed wastes under 40 CFR 261.31 — carry neurotoxic and hepatotoxic endpoints. Used oil is regulated under 40 CFR Part 279 primarily for PAH and metals content. Damaged-freight streams vary widely. They can include corrosives, flammables, and pesticides that trigger D-list characteristics. Exposure pathways at terminal sites are dominated by soil and stormwater migration from loading-dock spills rather than stack emissions, which is why terminals typically lack Title V permits and carry no active permits in ECHO [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

EJ implications: ECHO reports an EJ index average of 0.0 across the 37 facilities, which the exporter methodology treats as missing data rather than a measured zero. Community-exposure conclusions cannot be drawn directly from that field. EPA's December 2022 release framed the TForce settlement in national compliance terms rather than as an environmental-justice action, and no NGO litigation surface appears in the research bundle [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip] [source: https://epa.gov/newsreleases/epa-announces-settlement-tforce-correct-hazardous-waste-violations-39-states].

The research bundle returns an empty NAICS 484122 peer set, so quantitative benchmarking against direct LTL peers is not possible from the provided data [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Contextually, the TFI International portfolio includes multiple LTL and truckload brands whose operating metrics are reported at the parent level. Q1 2026 commentary references accident-cost pressure and an 11% U.S. LTL revenue decline, with adjusted operating ratio improvement to 95.3% [source: https://ng.investing.com/news/earnings/tfi-international-faces-earnings-test-amid-freight-market-struggles-93CH-2463551] [source: https://www.ttnews.com/articles/tfi-earnings-q1-2026]. Trade press references to ArcBest and Saia as comparable LTL operators exist but carry no EPA penalty figures in this bundle [source: https://www.truckingdive.com/news/tfi-international-tforce-freight-yellow-corp-cost-reduction/722698/]. Readers requiring sector benchmarking should pull ECHO registrant-level data for those peers directly.

TForce Freight is a private subsidiary and does not file its own 10-K. The research bundle returns no SEC filings for the entity and no Item 1A text [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Parent TFI International's investor communications in the bundle reference acquisition-driven integration risk at TForce, density and operating-ratio targets in U.S. LTL, and accident-related cost exposure as the primary forward-looking operational factors. None of those factors are framed as environmental risk items in the provided excerpts [source: https://ainvest.com/news/tfi-international-acquisition-driven-growth-north-american-freight-2604] [source: https://www.trucknews.com/business-management/tfi-sees-improving-freight-market-despite-softer-q1-earnings/1003213919/]. Without a standalone SEC filing, forward environmental risk for TForce Freight is most reliably inferred from two sources: the December 2022 RCRA consent order's corrective-action obligations, and the company's ongoing RCRA generator status across 37 active terminals [source: https://yosemite.epa.gov/oa/EAB_Web_Docket.nsf/a32958a86c47d3d485256fc70049e837/2274217517a48ca6852589120072d36f!OpenDocument]. Those two data points, taken together, define the environmental compliance baseline against which any future EPA activity would be measured.