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Violation Tracker User Guide
Violation Tracker 2.0, produced by the Corporate Research Project of Good Jobs First, brings together enforcement data obtained from 39 federal regulatory agencies with responsibility for banking, consumer protection, environmental, health and safety, workplace discrimination and other matters. We also collect information from the Justice Department on cases referred to it by these agencies as well as cases it initiated on offenses such as price-fixing, foreign bribery, false claims, civil rights abuses and tax evasion. A list of the agencies and the online locations of their data can be found here.
We have put all the information into a standardized set of categories to allow the user to search across many states and programs at the same time. The companies named in the violations are linked to 2,310 parent companies.
Violation Tracker was created with the invaluable help of Rich Puchalsky of Grassroots Connection. Rich created the system that generates the parent-subsidiary matches (which we also check manually); he built the underlying databases; and he programmed and designed the search pages.
A report entitled The $160 Billion Bank Fee summarizing what the database shows about the largest bank cases is linked on the Violation Tracker homepage, as is BP and Its Brethren, a report on the biggest environmental, health and safety violators.
Details of the Data
The basic violation data was obtained from the websites of the agencies and the Justice Department. In some cases the data for a particular agency could be downloaded all at once. In other cases we had to “scrape” the information from website tables or extract the information from official press releases posted on those sites. In all cases we gathered data going back to the beginning of 2010. The data is current as of early 2017.
For all agencies we use revised penalty amounts rather than those initially proposed, in order to account for cases in which companies were able to negotiate reductions in the penalties or those in which regulators decided on their own to adjust the amounts.
We eliminate entries with penalty amounts below $5,000 as well as those with no dollar penalties at all. The latter is frequently the case for agencies such as the Food and Drug Administration, which generally does not use dollar penalties but instead compels companies to suspend sales of dangerous products. (The FDA, however, does refer serious cases to the Justice Department, which may negotiate settlements or obtain verdicts involving financial penalties. We include those.) For OSHA we include only those penalties designated as willful, repeat or serious.
We also eliminate entries, regardless of the penalty amount, brought against government agencies or publicly owned entities such as municipal power authorities (some of these cases from the large datasets remain in Violation Tracker but are not included in the parent-subsidiary matching). Also excluded are cases against individual executives unless the firm was also a defendant. Lawsuits brought by individual plaintiffs, including class actions, are outside the scope of our project. We include criminal as well as civil cases brought by the agencies and DOJ.
In addition to the agency enforcement records, we collected information on settlements negotiated by the agencies or DOJ and announced in press releases. The company totals are adjusted to avoid double-counting of penalty amounts reported both in agency enforcement records and in settlement announcements. They are also adjusted to account for the fact that in numerous EPA cases involving multiple facilities owned by a single company, an overall penalty or settlement amount covering all the facilities is reported in the individual records for each facility.
For cases brought by the EPA or referred by that agency to the Justice Department, we include both civil or criminal penalties paid to the federal government and those penalties the company was required to pay to state or local government agencies. In addition, our penalty amounts include the stated costs of supplementary environmental projects companies are frequently required to undertake as part of the settlement of environmental cases. We exclude Superfund cases, most of which are clean-up agreements and often involve parties that do not own the sites, unless the company was also being charged with violations. Numerous bank settlements include amounts designated for consumer relief.
Following the practice adopted for Subsidy Tracker, we match entities to their current parent, even if they were part of a different corporate “family” at the time the penalty was imposed. An acquiring company typically takes on the liabilities and responsibilities of a purchased business. In Violation Tracker we have numerous cases in which a parent company was required to pay a penalty for actions that occurred before an acquisition took place. We think it is also appropriate to list penalties paid before an acquisition on the current parent's summary page. The allows us to display a full summary of the regulatory and legal track record of all the entities associated with the parent company.
Joint ventures are treated like subsidiaries when one of the owners has a stake of more than 50 percent; those in which no owner has a majority interest are treated like independent companies. Portfolio companies of private equity firms are treated the same way.
Accessing the Data
Option 1. Summary Pages
The first way to access Violation Tracker data is by viewing various summary pages that are linked in dropdown menus at the top of the search form.
Parent Summary Pages. The largest of these menus contains the 2,165 pages we have created to summarize information about the parents to which we link about 30,000 individual entries accounting for 95 percent of the penalty dollars in the Violation Tracker dataset. The parent universe is a mixture of large companies (regardless of penalty amount) and smaller companies with large penalties.
The parent pages include the following features:
- Basic information on the company: ownership status, headquarters location and industry.
- Penalty total. The total value of the penalties in the dataset linked to the parent after making the adjustments described above.
- Number of records. This is not the same as the number of violations or penalties, mainly because the data we obtained from the Environmental Protection Agency’s Enforcement and Compliance History Online (ECHO) system aggregates penalty amounts for a given establishment during the most recent a five-year period.
- Offense Types. A breakdown of cases associated with the parent according to type. We have tagged every entry in Violation Tracker with a primary offense type drawn from a list of 49 categories such as price-fixing, mortgage abuses and discriminary practices.
- Associated Names. A list of the names of the units and subsidiaries involved in the violations that went into the parent's penalty total. In some cases these lists have to be truncated.
- Links. Links to several other useful sources of information on the parent company. Depending on availability, these include links to: the parent's Corporate Rap Sheet (produced by the Corporate Research Project of Good Jobs First on 75 major violators); the parent's summary page on Subsidy Tracker; the parent's Citizen for Tax Justice-Institute on Taxation and Economic Policy tax dodger page; information from a Sunlight Foundation report called Fixed Fortunes on how the company's spending on federal political influence compares to its federal subsidies and contractors; and information from Maplight on how the company's political spending relates to its position on proposed legislation.
- Individual Violation Records. A list of all the individual Violation Tracker entries associated with the company. The default setting for the table is to show the individual penalties ranked by dollar amount, but it can be resorted by company name, facility state (which is not always the same as headquarters state), year or agency.
Top 100 Parents. Next to the parent dropdown menu is a link to a page showing the 100 companies with the largest amount of total penalties.
Coverage. Below the parent dropdown is a link to a page detailing the extent of the parent matching we have completed.
Industry Summary Pages. The second dropdown menu provides access to summary pages for 50 industry groups into which we have divided the 1,956 parent companies based on their major field of operation. These pages show aggregate penalty amounts for the parents assigned to that industry as well as a list of the ten parents in the group with the most penalties, with the amounts adjusted as described above. There is also a list of the individual records connected to all the parents in the industry. The default setting for the table is to show the individual penalties ranked by dollar amount, but it can be resorted by company name, parent name, facility state, year or agency.
Top Industries. Next to the industry dropdown menu is a link to a page showing the penalty totals for each of the 50 industry groups into which we have divided the parent companies.
Offense Type Summary Pages. The third dropdown menu provides access to summary pages for each of the 49 categories into which cases have been divided.These pages show aggreate penalty amounts for cases tagged with the category Unlike the parent and industry summary pages, the amounts here include all entries in Violation Tracker, not only those linked to a parent company. There is also a list of the ten parents with the most penalties in the category as well as a list of the individual records with that tag. The default setting for the table is to show the individual penalties ranked by dollar amount, but it can be resorted by company name, parent name, parent industry, year or agency.
Top Offense Types. Next to the agency dropdown menu is a link to a page showing the penalty totals for each of the primary offense types included in Violation Tracker.
Agency Summary Pages. The fourth dropdown menu provides access to summary pages for each of the regulatory agencies covered in Violation Tracker as well as for cases we link to the Justice Department because they involved much than one agency. These pages show aggregate penalty amounts for cases originating with the agencies, including those referred to the Justice Department. Like the offense type pages, the amounts here include all entries in Violation Tracker, not only those linked to a parent company. There is also a list of the ten parents with the most penalties stemming from cases brought by the agency as well as a list of the individual records connected to the agency. The default setting for the table is to show the individual penalties ranked by dollar amount, but it can be resorted by company name, parent name, facility state, or year.
Top Agencies. Next to the agency dropdown menu is a link to a page showing the penalty totals for each of the regulatory agencies (and the Justice Department) that originated the cases included in Violation Tracker.
Headquarters Summary Pages. The fifth dropdown menu provides access to summary pages for each state (for U.S. firms) or country (for non-U.S. firms) in which Violation Tracker parents are headquartered. (Entries relating to parents that have reincorporated abroad for tax reasons are listed separately.) These pages show aggregate penalty amounts for the parents headquartered in each place as well as a list of the ten parents with the most penalties, adjusted as described above. There is also a list of the individual records connected to all the parents based in the place. The default setting for the table is to show the individual penalties ranked by dollar amount, but it can be resorted by company name, parent name, facility state, year or agency.
Top States and Top Countries. Next to the headquarters dropdown menu are links to pages showing the penalty totals for parents headquartered in each state, territory or country.
Option 2. Searching by Company Name or Other Variables
This option allows the user to enter a single variable or multiple ones in searching for penalties. The variables are as follows:
- Company: This field can be used whether or not the target company is on our list of parents. The name can be searched in five different ways: Starting with the letters or words entered; Is equal to (exactly matches) the letters or words entered; Contains any one of the words entered; Contains all of the words entered; or Ends with the value entered.
- Industry: This field allows searching by the 50 industry groups we have assigned to parent companies (and thus their units and subsidiaries). It will not yield results related to entries for firms not matched to a parent. Choosing one of these industries alone will display the same summary page from the industry dropdown menu in Option 1. Use CTRL-click to choose more than one option from the dropdown.
- Offense Type: This field allows searching by an offense type. The dropdown includes both the primary ones summarized in Option 1 and secondary types added to some entries.
- Penalty Amount: results can be restricted to particular value ranges by choosing one of the following: Is greater than, Is greater than or equal to, Is equal to, or Is less than or equal to. Note that amounts must be entered as plain digits with no dollar signs or commas; e.g. enter $1 million as 1000000.
- Agency: This field allows searching by the regulatory agencies (and Justice Department) for which Violation Tracker contains data. This field covers all entries in the database, not only those matched to a parent. Choosing one of these agencies alone will display the same summary page from the agency dropdown menu in Option 1. Use CTRL-click to choose more than one option from the dropdown.
- Year: use the dropdown to limit search results to those reported for a given year. The years are those provided by agency records. Use CTRL-click to choose more than one option from the dropdown.
- Text: free-text search for words or phrases contained in any of the data fields in individual records, including the notes.
- Case Type: use the dropdown to limit the search to civil cases, to criminal cases or to criminal cases that were resolved with a deferred prosecution or non-prosecution agreement.
- Parent Ownership Structure: This field allows searching limited to cases linked to parent companies in one or more of the following ownership categories: cooperative, employee-owned, government-owned, joint venture, mutual, non-profit, out of business, privately held or publicly traded. It will not yield results related to entries for firms not matched to a parent.
- Headquarters State or Country: This field allows searching by the state (for U.S. firms) or country (for non-U.S. firms) in which the parent is headquartered. It will not yield results related to entries for firms not matched to a parent. Choosing one of these places alone will display the same summary page from the headquarters dropdown menu in Option 1.
- Facility State: This field allows searching by the state or U.S. territory in which the penalized facility is physically located. Not all agency records have facility locations, so this search covers only a portion of the Violation Tracker universe but it includes records not matched to a parent as well as those that are.
- City: When a facility state is chosen in the field above, a dropdown menu is generated here listing the localities for which entries are available, thus allowing more targeted searching. But note that even those records that contain a facility state may not include a city.
Intermediate Search Results
After choices have been made from the categories above and the search button has been pressed, the site will display an intermediate search results page with a limited set of fields:
- Company Name
- Parent Company Name (if the recipient has been matched to a parent)
- Parent Industry (if the recipient has been matched to a parent)
- Primary Offense Type
- Penalty Amount
The company name is hyperlinked to the individual entry for the award, which contains additional information (see below). If a parent name appears, it is linked to the summary page for the parent company. The table can be sorted by any of the columns.
Some penalty entries are partial or complete duplicates of other penalty records, either because a Justice Department settlement duplicates an agency record or because EPA listed the full penalty for a company in the records for each of the firm's relevant facilities. Penalty amounts marked with an asterisk have been identified by us as duplicating other penalty amounts. Company penalty totals are adjusted to account for these duplicates.
Data Fields for Individual Entries
There is no standard set of data fields used by all regulatory agencies in their violation reporting. We thus had to re-arrange and re-label the data we collected in order to conform to a standard set of fields we chose. Penalty records usually not provide data for every one of our fields. Individual entries display only those fields for which we have data.
The following is the full set of data fields that may appear for any given individual entry:
Company: The name of the company as it appears in the original agency records, with some obvious typos corrected.
Parent Company: The ultimate owner of the recipient firm, as derived from research using outside sources such as the Croctail compilation of the subsidiary lists that publicly traded companies are required to include in their 10-K filings with the Securities and Exchange Commission. These entries are hyperlinked to the summary page for that parent. More details on parent company coverage can be found here.
Facility State, Facility City, Facility Address and Facility Zip: These relate to where the facility is physically located. This information is not available for many entries.
Facility NAICS: Some agency records include the facility's industry grouping, using the federal government's North American Industry Classification System (NAICS).
Penalty: The dollar amount of the penalty as reported in the agency or Justice Department source. For all agencies we use revised penalty amounts rather than those initially proposed, in order to account for cases in which companies were able to negotiate reductions in the penalties or those in which regulators decided on their own to adjust the amounts.
Primary Offense Type: Each entry has been tagged with an offense type from a list of 49 categories.
Secondary Offense Type: Some cases that overlap categories have been tagged with a secondary offense type from a list of 35 categories, seven of which do not appear on the list of primary offense types.
Violation Description: An explanation of the nature of the violation, if the information is included in the data source. Entries derived from press releases (which include all Justice Department cases) contain excerpts from the release in this field.
Year. The year contained in the agency record.
Date: The precise date, if available, contained in the agency record. We include this to allow the user to distinguish between entries in situations where a given company may have more than one penalty for the same dollar amount in a given year.
Agency: The regulatory agency that originated the case, even when the case was referred to the Justice Department. DOJ cases involving more than one agency display "Justice Department" in this field.
Civil or Criminal Case: An indication of whether the case was brought as a civil or criminal matter.
Prosecution Agreement: Indicates whether a criminal case with resolved with a deferred prosecution or non-prosecution agreement.
HQ Country of Parent: The country in which the parent company is headquartered.
HQ State of Parent: The state in which the parent company is headquartered (U.S.-based firms only).
Ownership Structure of Parent. One of the following list of ownership categories in which we have grouped our universe of parent companies: cooperative, employee-owned, government-owned, joint venture, mutual, non-profit, out of business, privately held or publicly traded.
Major Industry of Parent: One of the 50 industries into which we have grouped our universe of parent companies.
Source of Data: A link showing where the violation data was obtained. For those entries whose information was taken from individual documents or webpages, there is also a link to an archived copy preserved on our server.
Notes: Explanatory information about this entry only or a larger set of entries to which this entry belongs.
Source Notes: This is a standard insertion for each individual entry noting that in instances in which the online data source above is not working, the user should check the Violation Tracker data source page, which will be updated more frequently than all the individual entries.
Link to ECHO: For entries obtained from the EPA's Enforcement and Compliance History Online (ECHO) database, there is a direct link to the facility's summary page on that site.
Link to OSHA Inspection records: For OSHA records there is a link to the page on the OSHA website with the inspection record relating to the case.
Other fields: The EPA, MSHA and OSHA records contain fields with other identifying information about the facility.
Search results can be downloaded to a CSV file for use in a spreadsheet or as an XML file. Because of its large size, the entire database cannot be downloaded. If you wish to request a full spreadsheet for non-commercial purposes, contact Philip Mattera of the Corporate Research Project of Good Jobs First at email@example.com.
Last updated February 20, 2017