If you sell environmental services, ECHO can feel like a fire hose. ECHO is EPA's public website for compliance and enforcement records. The name is short for Enforcement and Compliance History Online. It lists inspections, violations, and enforcement actions for more than a million places that EPA and the states regulate.
Two words show up again and again: informal and formal. They sound alike. They are not the same signal. This note uses fresh numbers to show the difference. Then it gives a simple order for what to check first.
This note is educational. It is not legal advice and not EPA guidance. Record of Sale, LLC operates SNCAlert. Questions go to publisher@noticenearby.com.
Two kinds of enforcement, in plain words
An enforcement action is a step a regulator takes when it thinks a facility broke a rule. The facility might be a factory, a water treatment plant, or a shop that handles hazardous waste.
An informal action is a warning. Think of a notice of violation or a warning letter. It says, "We found a problem. Fix it." It usually has no fine and no court.
A formal action is stronger. It can be an order, a signed agreement with the regulator, or a court case. It often comes with a fine, called a penalty. It may also require the facility to do certain work by a set date.
So informal is the yellow card. Formal is the red card.
Fresh numbers from ECHO (pulled October 5, 2026)
On Monday, October 5, 2026, at about 9:15 AM Pacific time, we ran searches on EPA's public ECHO web services. We used the "all data" facility search and kept only active facilities. Here is what came back:
| Search (active facilities, nationwide) | Facilities | Now flagged SNC/HPV | Penalties in ECHO's summary |
|---|---|---|---|
| Formal action in the past 1 year | 9,800 | 1,320 | $761,872,713 |
| Informal action in the past 1 year | 40,770 | 5,092 | $653,599,750 |
| Informal action in the past 1 year, but no formal action in 5 years | 33,552 | 3,649 | $0 |
Two terms in that table need a quick explanation.
- SNC means Significant Noncompliance. EPA uses it for the most serious or long-lasting problems under water, hazardous-waste, and drinking-water rules.
- HPV means High Priority Violation. It is the air version of the same idea, under the Clean Air Act.
ECHO groups SNC and HPV together as "significant violators." That is the "now flagged" column.
Here is what jumps out:
- Informal actions are about four times as common as formal ones. It was 40,770 versus 9,800 over the same one-year window.
- Most warnings have not turned into formal action. 33,552 facilities got a warning in the past year and had no formal action in five years.
- 3,649 of those warned-only facilities are already flagged SNC or HPV. That is the group to watch closely. They have a serious flag and a warning, but no order or fine on record.
We also ran the same searches for Oregon, where Record of Sale, LLC is based:
| Search (active facilities, Oregon) | Facilities | Now flagged SNC/HPV | Penalties in ECHO's summary |
|---|---|---|---|
| Formal action in the past 1 year | 112 | 19 | $7,415,308 |
| Informal action in the past 1 year | 224 | 50 | $3,231,854 |
| Informal in the past year, no formal in 5 years | 152 | 33 | $0 |
| Formal action in the past 5 years | 555 | 81 | $91,989,192 |
Oregon's ratio is closer, about two warnings for every formal action. Every state is different. That is one reason a nationwide average can fool you.
What to check first
Here is a simple order. It is not the only right order. It is a good start for a small team.
1. SNC or HPV plus a recent formal action
Start here. A formal action means the regulator has put the problem in writing, with teeth. There may be a deadline. There may be a fine. The facility often needs outside help fast: testing, engineering, permits, or cleanup. Nationwide, that was 1,320 facilities on October 5. In Oregon, it was 19.
Before you reach out, open the facility's Detailed Facility Report, or DFR. That is the ECHO summary page for a single site. Check the action date, the law involved, and whether a penalty amount is listed. Our formal action and penalty note walks through that check.
2. SNC or HPV plus a warning, with no formal action yet
This is the "watch closely" group. Nationwide, it was 3,649. In Oregon, 33. The regulator has flagged a serious problem and sent a warning. A formal step may come next. Or the facility may fix things first. A helpful, low-pressure note can land well here. Do not tell the facility it is about to be fined. You do not know that.
3. A warning with no SNC or HPV flag
This is the biggest group by far. Many of these are smaller issues, like a late report, a missed sample, or a paperwork gap. They can still be good leads, but they are lower priority. Batch them. Do not let them crowd out groups 1 and 2.
4. Old formal actions
A formal action from four or five years ago may already be closed. Check the DFR before you mention it. Our return-to-compliance note covers what it means when a flag clears.
Why penalty dollars are not the whole story
The tables show big penalty totals. Be careful with them. A penalty is not the full cost to the owner. It does not include repair work, testing, or legal fees. Also, one large case can make a group total look huge. The nationwide formal-action group shows about $762 million in ECHO's summary. That is a total for thousands of facilities, not a typical fine.
Use penalty dollars as a hint, not a headline. If you want to frame what a penalty might mean for a facility, the free penalty exposure tool gives a rough range. It is an estimate, not a forecast.
Common mix-ups
- Informal does not mean "not serious." A warning can come right before a formal order. That is why group 2 matters.
- Formal does not mean "guilty." Many formal actions end in a settlement. That means the owner agrees to terms, often without admitting fault.
- SNC and HPV are not the same word. HPV is air. SNC is water, waste, or drinking water. Our SNC vs HPV tool is a quick check.
- ECHO lags. EPA says new records can take from about a week to three months to show up in ECHO. A new action may not be there yet. An old one may already be fixed.
How SNCAlert fits in
SNCAlert watches EPA's weekly ECHO Exporter file. That is the big bulk download of facility data. Each week we compare the new file to the last one. We flag facilities that newly turn SNC or HPV, and facilities with a new formal action or penalty date. That is our own comparison of a public file. It is not EPA's ECHO Notify email service. Our Exporter vs Notify note explains the difference.
Starter covers three states. Pro covers the whole country. See pricing for details. The free tools, including the watch ROI tool, help you decide if a watch is worth your time.
How we pulled these numbers
All counts come from EPA's public ECHO web service (echo_rest_services.get_facilities), queried October 5, 2026, around 9:15 AM PT. We used p_act=Y to keep active facilities only. The formal and informal time windows used the p_fea/p_feay and p_iea/p_ieay filters. "Now flagged SNC/HPV" is ECHO's SVRows count. Penalties are ECHO's TotalPenalties value for each result. Example: formal action in the past year, nationwide. If you run the same search on a later day, your numbers may be a little different.
Limits
ECHO is a snapshot, and it can be incomplete. A count is not a list of confirmed violations. SNCAlert is not EPA and is not endorsed by EPA. This note is not a Phase I Environmental Site Assessment. Always confirm on the facility's own DFR before you reach out.
Record of Sale, LLC operates SNCAlert from Oregon. Contact publisher@noticenearby.com.