UNITED PARCEL SERVICE - BURLINGTON

United Parcel Service - Burlington (EPA facility ID 110005997234) is a single-node entry within UPS's U.S. package-delivery footprint. It carries zero quarters of formal noncompliance over the trailing 24 months, yet a derived penalty allocation of $2.12 million traces back to multi-state hazardous-waste settlements involving the parent entity [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That number demands context before it can be read as a site-level indictment.

The Burlington record is further complicated by a naming collision. The ECHO entry is coded to Burlington, CO, while Washington State's Pollution Liability Insurance Agency separately managed a UPS cleanup site at 1620 Port Drive, Burlington, WA 98233. PLIA proposed removing that Washington property from the state Hazardous Sites List during a June 1 – July 1, 2023 public comment window [source: https://plia.wa.gov/proposed-delisting-ups-burlington/]. The site now carries "No Further Action" status under Cleanup Site ID 10030 [source: https://apps.ecology.wa.gov/cleanupsearch/site/10030]. Two distinct geographies, one shared name — the distinction matters for any facility-level reading of the data.

Parent-level exposure is materially larger. UPS disclosed $88.7 billion in 2025 revenue and 5.2 billion packages delivered in its Form 10-K filed February 17, 2026 [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. Two federal hazardous-waste settlements anchor the enforcement record. First, a June 2021 EPA Region 6 consent agreement covered 183 facilities across Arkansas, Louisiana, Oklahoma, New Mexico, and Texas, carrying a $3.8 million civil penalty [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. Second, an October 19, 2022 nationwide consent agreement reached 1,160 facilities across 45 states and Puerto Rico [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Those two actions together touched 1,343 facility-level findings. Shareholder pressure on environmental-justice governance then surfaced on November 13, 2025, when As You Sow filed a resolution calling for a third-party EJ audit of UPS operations [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit].

The Burlington facility itself registers no violation quarters over the 24-month ECHO window. The $2.12 million figure carried in the ECHO summary is a pro-rata derivation — specifically, total_5yr × 24/60 — reflecting penalty weight allocated across UPS's corporate enforcement history rather than any site-specific adjudicated fine at Burlington [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. ECHO also shows zero active permits tied to the facility ID and a facility count of one, consistent with a small ground-delivery hub rather than a Title V stationary source [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

A chronological walk through the trailing 24 months starts in mid-2023. Washington State's PLIA opened the public comment period June 1 – July 1, 2023 on removing the UPS Burlington, WA site — TAP #P-NW2351, FSID #64937476 — from the Hazardous Sites List. The site ultimately resolved to "No Further Action" [source: https://plia.wa.gov/proposed-delisting-ups-burlington/] [source: https://apps.ecology.wa.gov/cleanupsearch/site/10030]. That resolution closed a legacy contamination chapter at 1620 Port Drive without any new federal enforcement action tied to the address.

Through 2024 and into 2025, UPS's public environmental reporting centered on its 2024 GRI Report, covering January 1 – December 31, 2024 and released March 20, 2025. That document frames forward commitments on fuel mix, renewable power, and emissions intensity [source: https://about.ups.com/content/dam/upsstories/images/our-impact/reporting/2024-UPS-GRI-Report.pdf]. Then, on November 13, 2025, As You Sow filed a shareholder resolution requesting a third-party environmental-justice audit of UPS operations [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit]. The filing signaled that at least one organized shareholder group views current disclosure as insufficient.

The 10-K filed February 17, 2026 discloses a December 2025 agreement with the United States Postal Service to handle final-mile delivery for a portion of UPS's Ground Saver and Mail Innovations volumes beginning in 2026. It also covers the 2025 acquisitions of Frigo-Trans and Andlauer Healthcare Group, both expanding cold-chain healthcare logistics capacity [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. The most recent 10-Q, filed November 5, 2025 for the quarter ending September 30, 2025, contains no dedicated environmental contingency excerpt in the provided record [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828025049661/ups-20250930.htm]. Separately, a New York Times report dated April 28, 2026 described ongoing litigation by Staten Island residents over UPS's refusal to deliver inside two residential buildings — a service-access matter rather than an environmental one, but relevant to community-impact framing when read alongside the As You Sow EJ resolution [source: https://nytimes.com/2026/04/28/nyregion/ups-staten-island-packages-lines.html].

EPA Region 6 Consent Agreement (announced June 16, 2021): UPS and TForce Freight entered a settlement resolving alleged Resource Conservation and Recovery Act (RCRA) hazardous-waste violations at 183 facilities across Arkansas, Louisiana, Oklahoma, New Mexico, and Texas. Respondents agreed to a $3.8 million civil penalty and a 24-month compliance window [source: https://www.epa.gov/enforcement/united-parcel-service-inc-ups-settlement]. The Consent Agreement and Final Order is archived in EPA's enforcement records [source: https://www.epa.gov/enforcement/consent-agreement-and-final-order-ups].

EPA Nationwide Consent Agreement and Final Order (announced October 19, 2022): EPA resolved alleged RCRA violations at 1,160 UPS facilities across 45 states and the territory of Puerto Rico. Cited conduct included failure to make land disposal determinations and improper on-site management of hazardous waste. The settlement required UPS to implement corporate environmental policies designed to prevent recurrence [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide]. Taken together, the two federal actions covered 1,343 combined facility-level findings — a scale that distinguishes UPS's RCRA enforcement record from most carriers in the NAICS 492110 peer group.

Washington State Cleanup (2023 delisting proposal): Washington's PLIA proposed removing UPS Burlington at 1620 Port Drive, Burlington, WA from the state Hazardous Sites List, with public comment open June 1 – July 1, 2023. The site is now listed as "No Further Action" under Cleanup Site ID 10030 and Facility Site ID 64937476 [source: https://plia.wa.gov/proposed-delisting-ups-burlington/] [source: https://apps.ecology.wa.gov/cleanupsearch/site/10030]. No Clean Water Act or Clean Air Act federal adjudicated actions specific to the Burlington, CO node appear in the data bundle. The ECHO-derived $2.12 million 24-month penalty allocation for this facility ID reflects formula-based apportionment rather than a site-specific monetary judgment [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

UPS Burlington (facility ID 110005997234), Burlington, CO — ECHO records one facility, zero active permits, zero quarters of noncompliance over the 24-month window, and an EJ index average reported as 0.0. In ECHO's exporter schema, a 0.0 EJ index typically indicates either an un-scored or non-major site rather than a community free of environmental exposure [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The facility profile is consistent with a ground-delivery hub that generates no Title V or TRI reporting obligations.

UPS Burlington, WA (1620 Port Drive, Burlington, WA 98233) — Managed by Washington PLIA under TAP #P-NW2351, FSID #64937476, CSID #10030. PLIA proposed delisting from the state Hazardous Sites List during the June 1 – July 1, 2023 comment window [source: https://plia.wa.gov/proposed-delisting-ups-burlington/]. The state cleanup database currently shows "No Further Action" status, with one identified contaminant and seven associated documents in the record [source: https://apps.ecology.wa.gov/cleanupsearch/site/10030]. The site's resolution under PLIA's Heating Oil program lineage closed the legacy petroleum hydrocarbon chapter at that address.

United Parcel Service Inc (parent roll-up, 11 facilities in the NAICS 492110 peer table) — The parent-rollup record shows 8 violation quarters and $10.64 million in 24-month penalty allocation, the largest figure among sibling legal entities tracked in ECHO [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

United Parcel Services (10 facilities, peer record) — Carries 6 violation quarters and $6.42 million in 24-month penalty allocation, placing it second among peer records [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

United Parcel Svc (16 facilities, NAICS 49211) — Records 6 violation quarters and $5.76 million in penalty allocation, with the highest facility count among the listed peer rollups [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. That 16-facility count, combined with the lowest per-facility allocation of the three rollups, suggests a broader but shallower enforcement footprint compared with the parent-rollup string.

The ECHO top-pollutants array for the Burlington facility ID is empty. That absence is consistent with a non-TRI-reporting ground-delivery hub rather than a major emitting stationary source [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The material pollutant signature for UPS under federal enforcement has historically been RCRA-regulated hazardous waste generated through package handling, damaged-goods management, and on-site maintenance streams — precisely the conduct described in the October 2022 nationwide consent agreement, which cited failure to make land disposal determinations and improper on-site hazardous-waste management [source: https://www.epa.gov/newsreleases/ups-settles-epa-correct-alleged-hazardous-waste-violations-nationwide].

A second pollutant exposure flows from mobile-source emissions across UPS's delivery fleet. Diesel particulate matter (PM2.5) and nitrogen oxides (NOx) are the primary compounds of concern. UPS's own 2021 Sustainability Report frames this exposure through alternative-fuel and electrification targets: 40% alternative fuel by 2025, and a 50% CO2 reduction per global small package versus a 2020 baseline by 2035 [source: https://about.ups.com/content/dam/upsstories/assets/social-impact/2021-esg-highlights-brochure/en_en_2021SustainabilityBrochure_V15.pdf.pdf]. The environmental-justice implication of mobile-source PM2.5 and NOx is concentrated near package hubs and routing corridors — communities that often carry elevated pre-existing pollution burdens. As You Sow's November 13, 2025 resolution specifically requested a third-party EJ audit of UPS operations on this exposure surface [source: https://www.asyousow.org/resolutions/2025/11/13-ups-third-party-environmental-justice-audit].

A third pollutant vector is legacy petroleum hydrocarbon contamination. The Washington State cleanup of UPS Burlington, WA proceeded under PLIA's Heating Oil program lineage before reaching its No Further Action determination [source: https://apps.ecology.wa.gov/cleanupsearch/site/10030] [source: https://plia.wa.gov/proposed-delisting-ups-burlington/]. That lineage points to underground storage tank or heating-oil release as the likely source mechanism, a contamination type common to older commercial properties across the Pacific Northwest.

Within NAICS 492110, the three peer rollups are themselves UPS-affiliated legal-name variants in the ECHO exporter rather than independent competitors. The dataset splits a single corporate parent across multiple legal-name strings — an artifact of how facility registrations were submitted over time rather than a reflection of distinct operating companies. Against that backdrop, the Burlington node's derived $2.12 million 24-month penalty allocation and zero violation quarters sit well below the parent UPS rollup's 8 violation quarters and $10.64 million allocation. Burlington is not a primary driver of enforcement exposure relative to the corporate whole [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The 10-K filed February 17, 2026 states that the company "does not undertake any obligation to update forward-looking statements to reflect events, circumstances, changes in expectations or the occurrence of unanticipated events after the date of those statements, except as required by law," and directs investors to the Investor Relations website for material nonpublic information disclosures under Regulation FD. The provided Item 1A excerpt emphasizes strategy execution under the Customer First, People Led, Innovation Driven framework, the December 2025 USPS final-mile agreement, and the 2025 healthcare-logistics acquisitions of Frigo-Trans and Andlauer Healthcare Group. No environmental-contingency passage appears in the excerpt supplied [source: https://www.sec.gov/Archives/edgar/data/1090727/000162828026008432/ups-20251231.htm]. The absence of such a passage, read alongside the As You Sow EJ-audit resolution filed November 13, 2025, leaves open the question of how UPS will address third-party scrutiny of community-level fleet-emission exposure as its delivery network expands through the USPS final-mile arrangement and the newly acquired cold-chain operations.