(Two Kipp Workers, photo by John Hart, Madison.com). According to a recent letter from Kipp to the DNR, Kipp has been excavating inside the factory, and finding PCBs in concrete floors hundreds of times above the residual contact levels (levels considered safe for direct contact) in some places. This is not surprising, given that up to 20,000 ppm PCBs have been found beneath the factory floor, as we reported in our previous post. All of these PCB contaminated materials are also very likely contaminated with dioxins—among the most toxic chemicals ever studied (significantly more toxic than PCBs).
This raises more questions for our “Unanswered Questions: Madison-Kipp Unbound” series: What is being done right now to protect Kipp’s non-unionized workers as these highly PCB contaminated materials are being excavated? What machines (referred to in the letter) are being installed? Who is doing the excavation? What is being done—and has been done in the past—to protect workers from the myriad toxic contaminants used at Kipp, emitted into factory air, and sloshed around on the floor? Are tetrachloroethylene (PCE) and other toxic vapors seeping into the plant from the giant contaminant plume below the floor? Has anyone measured? What about the workers who clean Kipp? Are they and other workers aware of the polychlorinated biphenyls (PCBs) and other toxins in floors, walls, and air? Do they have adequate protective gear? What are Kipp Corporation and the relevant government agencies doing to assure that workers are not exposed to toxic contaminants?
Are Kipp Worker Exposures Even on Radar Screen of Government Agencies…?
Madison Kipp’s non-unionized workers—which include many minorities, as well as some ex-offenders—are among the most exposed to the factory’s toxic pollution. Kipp also hires a number of low-wage LTEs (limited term employees) during busy times, and at times employs homeless people.Various companies are contracted to clean Kipp and remove wastes; cleaning Kipp and removing wastes likely involve exposures to a stew of toxic contaminants.
Yet even as PCE, PCB, TCE (trichloroethylene), PAHs (polycyclic aromatic hydrocarbons), vinyl chloride, dioxins, heavy metals, and myriad other contaminants have been measured in soils and groundwater under Kipp, and/or emitted into factory air and from stacks, local and state government agencies and elected officials apparently are not very concerned about the health and safety of the manufacturing workers at the plant. In our reviews of thousands of pages of documents and communications from local and state agencies, we have not seen anything about assessing exposures to Kipp factory workers, assuring that they are protected, or communicating with them about potential exposures in and around the plant. Even public health agencies don’t seem to be concerned about workers’ health and well-being at all—or if they are, it is not evident anywhere.
What about the U.S. Occupational Safety and Health Administration (OSHA), which has an office in Madison? It’s our understanding that OSHA doesn’t investigate workplace exposures unless there is a formal complaint. While OSHA has been in Kipp several times in the last 10-15 years to investigate a number of serious worker accidents, and has issued numerous citations for significant safety violations (see next story), we have found no evidence that OSHA staff have ever investigated worker exposures to PCEs, PCBs, or any of the other highly toxic contaminants found at Kipp in recent years—nor has OSHA been involved in helping to develop strategies to protect workers from harmful exposures to these contaminants .
When MEJO met with four DNR managers on Jan. 29 2014, we asked whether they had ever contacted OSHA and they said “no”—but “they will.” Shouldn’t the DNR and its city/county and state health agency collaborators have contacted OSHA many years ago, especially as the enormous plume of toxic compounds was documented under the plant, with a high potential for vapor intrusion into the factory (however, see footnote #3)? Why haven’t they contacted OSHA to get guidance on assessing worker exposures and ways to best protect workers as toxic materials are excavated all around the plant? Do DNR staff have training in assessing workplace exposures to dusts and particulates, vapors, VOCs, PCBs? Are they industrial hygienists? Is the EPA, involved with the PCB portion of the Kipp investigation, assuring that workers are protected from PCB exposures?
Of course, Kipp’s non-unionized manufacturing workers are very unlikely to complain to OSHA or anyone, for a number of reasons. Most are unaware of the toxins around them and/or serious implications for their health and their children’s health (if they are women of childbearing age). Even if they are aware, they are very unlikely to complain to superiors or say anything publicly, because they do not want to jeopardize their jobs. Not being unionized, they have no organization to protect and represent them in complaints against their employer. They are probably very grateful to have a job—any job. Some, like homeless people and ex-offenders, have few other choices.
Sadly, this scenario fits a classic pattern of environmental injustice: the most vulnerable people—also the least privileged, least likely to have the capacities and resources to protect themselves, and with fewer alternatives available to them as far as work—are ignored by government and other powers-that-be.
Why have government agencies, public officials, media, and even neighborhood groups not raised questions about the health and safety of Kipp’s workers? With jobs and economic growth currently the top priority on all sides of the political spectrum, public officials on the left and right are reluctant to do or say anything that might threaten jobs.
MEJO does not want Kipp workers to lose their means of supporting themselves and their families. But they deserve safe and healthy work that will not increase their (or their children’s) risks for serious health problems—problems that will likely create even more socioeconomic challenges for them in the future.
Again: What are Madison Kipp, responsible government agencies, and elected officials doing to assure that Kipp workers are protected from toxic exposures?
To be continued in next post…
People out there–comments, answers, questions, corrections? Please send to: email@example.com. THANKS!!!
 MEJO members know people who worked at Kipp while homeless (though they are still homeless, they no longer work there). Sadly, one said he couldn’t keep the job because he kept falling asleep at work. Another recalled sloppy practices in the plant. See the next post…
 MEJO members have talked to people who cleaned at Kipp and suffered health effects while there.
 Ironically, a recent Kipp consultant report revealed that Kipp would be assessing vapor intrusion only in the office portions of the plant. Why not the manufacturing portions? Are they concerned about Kipp’s managers and administrative staff but not the manufacturing workers, cleaning contractors, and other temporary workers?
 In 2011, OSHA did a very limited one-time assessment of aluminum dust.