{"id":6895,"date":"2026-03-26T23:22:39","date_gmt":"2026-03-26T23:22:39","guid":{"rendered":"https:\/\/blogs.luc.edu\/compliance\/?p=6895"},"modified":"2026-03-31T15:48:42","modified_gmt":"2026-03-31T15:48:42","slug":"green-waters-gray-areas-chicagos-st-patricks-day-tradition-and-environmental-regulations","status":"publish","type":"post","link":"https:\/\/blogs.luc.edu\/compliance\/?p=6895","title":{"rendered":"Green Waters, Gray Areas: Chicago\u2019s St. Patrick\u2019s Day Tradition and Environmental Regulations"},"content":{"rendered":"

Kendall Henry<\/em><\/p>\n

Associate Editor<\/em><\/p>\n

Loyola University Chicago School of Law, JD 2027<\/em><\/p>\n

\u00a0<\/em>Every March, Chicago\u2019s St. Patrick\u2019s Day<\/a> celebration involves one of the most recognizable traditions in the country: dyeing the Chicago River shamrock green. To Chicago residents and tourists alike, it is a prelude to the spring season, but beyond the bright green surface is quite a story. The annual tradition<\/a> of dyeing the Chicago River originated in 1962. The tradition grew out of city cleanup efforts. It later evolved into a holiday celebration once the Chicago Plumbers Union Local 130 and former Chicago mayor Richard J. Daley joined forces to create a yearly event. However, in the decades since the tradition began, environmental law in the United States has expanded significantly, raising questions about how it aligns with modern regulatory frameworks.<\/p>\n

The Clean Water Act<\/strong><\/p>\n

The Clean Water Act<\/a>\u00a0 (CWA), originally enacted in 1948 and amended in 1972, is regulated and enforced by the Environmental Protection Agency<\/a> (EPA). The 1972 amendments marked a major shift in federal water regulation as they established new water quality standards. To date, the CWA prohibits the discharge of pollutants through a point source into the \u201cWaters of the United States\u201d<\/a> (WOTUS), which encompasses bodies of water such as major rivers, including the Chicago River. One of the central regulatory frameworks under the CWA is the National Pollutant Discharge Elimination System<\/a> (NPDES) permitting program. Under this system, it is unlawful to discharge any pollutant into the covered bodies of water without obtaining a permit. The NPDES defines \u201cpoint source\u201d and \u201cpollutant\u201d broadly.<\/a> A point source can include a floating craft, container, channel and pollutant can include chemical wastes, industrial substances, and agricultural waste.<\/p>\n

At first glance, releasing dye into a river appears to fit squarely within the definition of \u201cdischarge of a pollutant.\u201d However, the continued practice reveals a regulatory grey area attributed partly to the secrecy of the dye itself. The Chicago Plumbers Union Local 130 has kept the formula is a closely guarded secret. This secrecy is justified as preventing replication (though it has already occurred), but in turn, it limits environmental transparency. Despite this, an EPA aquatic toxicologist, the dye used today is an orange powdery, non-toxic compound<\/a> made from vegetables. Therefore, regulators have treated the substance as outside the scope of harmful pollutants requiring formal permitting under the NPDES program.<\/p>\n

Illinois Environmental Protection Agency<\/strong><\/p>\n

Even if this tradition avoids regulation on the federal level, state level regulation and oversight still exist. The Illinois Environmental Protection Agency<\/a> (IEPA) is responsible for protecting Illinois water quality and compliance with environmental regulations. Yet, like the US EPA, the IEPA has never required a NPDES permit for the river dyeing due to its non-toxic classification. Existing statutes, such as Illinois Administrative Code \u00a7302.203<\/a>, specify other prohibited conditions in Illinois waters, including color. However, this color is acceptable as long as it is from a natural origin. It is likely that the tradition gets around this prohibition because of the powder\u2019s vegetable-based composition.<\/p>\n

Some environmental advocacy groups, such as Friends of the Chicago River<\/a> and the Sierra Club<\/a>, argue that discharging dye into the Chicago River, regardless of its claimed non-toxicity, is harmful. Specifically, these groups have called out the US and Illinois EPAs for failing to enforce NPDES permits. The lack of transparency in its composition and the absence of any regulatory guardrails sends a loose message about the discharge of substances into any WOTUS. In fact, cities such as Tampa, Indianapolis, and San Antonio have already taken inspiration from Chicago\u2019s long-running St. Patrick\u2019s river-dyeing tradition. San Antonio describes its dye as eco-friendly<\/a>, though similar concerns remain about the vagueness of the description and the lack of compliance certification. Notably, Tampa<\/a> has adopted a similar practice by dyeing the Hillsborough River, but with a more transparent regulatory standpoint. Tampa utilizes a Bright Dyes product that is EPA certified food grade dye<\/a> and compliant under Occupational Safety and Health Administration<\/a> (OSHA) standards such that it is permissible. Unlike Chicago, where the dye\u2019s formula remains a secret, Tampa\u2019s transparency allows for public trust and regulatory evaluation.<\/p>\n

Meeting in the middle <\/strong><\/p>\n

There is no doubt that this annual tradition is inconsistent with federal pollution laws, regulatory frameworks, and state law. This conversation seems appropriate during the climate of deregulation by the current administration and, simultaneously, regulatory shifts to address environmental protections. The decades-long tradition of dyeing the Chicago River may appear harmless on the surface, but the lack of public disclosures regarding the makeup of the compounds, the issuance of any permits, or explicit statements about compliance raises valid concerns about oversight. However, the tradition’s cultural significance and impact cannot be ignored. Perhaps a more balanced approach involving increased transparency of the process and formal regulatory acknowledgement from the EPA on both the federal and state levels could be helpful. In this way, a message is sent that the tradition operates within regulatory guardrails, deterring other cities or citizens from engaging in unpermitted or non-compliant dyeing of WOTUS. Ultimately, making it clear that the tradition coincides with regulatory compliance is the effective way for environmental integrity and civic pride to co-exist.<\/p>\n","protected":false},"excerpt":{"rendered":"

Kendall Henry Associate Editor Loyola University Chicago School of Law, JD 2027 \u00a0Every March, Chicago\u2019s St. Patrick\u2019s Day celebration involves one of the most recognizable traditions in the country: dyeing the Chicago River shamrock green. To Chicago residents and tourists alike, it is a prelude to the spring season, but beyond the bright green surface …
Read more<\/a><\/p>\n","protected":false},"author":180,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[21],"tags":[],"class_list":["post-6895","post","type-post","status-publish","format-standard","hentry","category-epa"],"_links":{"self":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts\/6895","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/users\/180"}],"replies":[{"embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=6895"}],"version-history":[{"count":1,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts\/6895\/revisions"}],"predecessor-version":[{"id":6896,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=\/wp\/v2\/posts\/6895\/revisions\/6896"}],"wp:attachment":[{"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=6895"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=6895"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/blogs.luc.edu\/compliance\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=6895"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}