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Why “safe” levels of toxic chemicals may not be safe

Why “safe” levels of toxic chemicals may not be safe

“There’s no problem; toxic exposure is too low to cause any harm” is a common response by pubic officials when citizens raise concerns about toxins in the environment, such a PCBs or atrazine.

MEJO board member Kristine Mattis explains why this assurance may not be accurate in this article published at Counterpunch Online:

Toxic Curve Ball: Why Outdated Assumptions to Determine “Safe Levels” of To…

By now, a large number of consumers are aware of the hazards of the synthetic compound bisphenol-A (BPA). Effect… [MORE]

 

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PCB Excavation Along Bike Path next to Madison Kipp–Enjoy Photos!

PCB Excavation Along Bike Path next to Madison Kipp–Enjoy Photos!

A previous post shared details about the excavation of soils contaminated with high levels of PCBs, from October 6-9, 2015, along the bike path between Madison Kipp Corporation and the Goodman Center.

Here’s what the excavation looked like…enjoy! (sorry about the strange sizes, we had some formatting problems…)

Excavation begins, October 6, on the east end of the raingarden…

Earth First Advanced Waste drops off a PCB dumpster across from the splash pad…(Yes, Earth First came to Kipp!!) 

The bike path is a busy place! Neighbors sit at the splash pad bench and enjoy the show…

Children pick vegetables near the excavation (red PCB dumpster behind them)…

A neighborhood mom whose children are playing at Goodman tells Earth First Advanced Waste they are “killing the earth” and does a ritual to “take the land back” and “release the bad energy”

A dust monitor is in place (good step in the right direction….but is this monitor to assess dust exposures to the excavation workers? Or people on the bike path? Either way, it seems to be the wrong kind of monitor and in the wrong place….).

Dust barriers put up on 2nd day of excavation (Good, finally!! But won’t some fine dust go up and over them? )

A “Best Waste Solutions” truck behind the excavation spews smoke (oops!)…

Are there really no PCBs on the right side of this fence, next to the bike path?? This area has not been tested. Hmmm…..

Yellow “caution” tape was put up around dust barriers on October 8

The dust monitor concentration on the outside of the excavation dust fence read 19 µg/m3 at 10 am on October 8 (time-weighted average of 12 µg/m3)…

Soils with the highest PCB levels, along about an 80 foot stretch across from splash pad, were excavated right to the edge of the bike path, including the jogging path…

A couple hotspots in the raingarden, excavated on October 6, were re-seeded and covered with hay…

A PCB hotspot in the grassy area along the far eastern end of the bike path was “capped” with a few inches of clean soil (and later fenced off)…

 

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International Federation of Gynecology and Obstetrics (FIGO) opinion on reproductive health impacts of exposure to toxic environmental chemicals

International Federation of Gynecology and Obstetrics (FIGO) opinion on reproductive health impacts of exposure to toxic environmental chemicals

On October 1, 2015, the International Federation of Gynecology & Obstetrics (FIGO) published an Opinion in the International Journal of Gynecology and Obstetrics stating that dramatic increases in exposure to toxic chemicals in the last four decades is threatening human reproduction and our planetary health.

See more here

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Links between health problems and endocrine-disrupting chemicals now stronger

Links between health problems and endocrine-disrupting chemicals now stronger
[PCBs, known endocrine disruptors, excavated next to Madison-Kipp]

 

By

“The list of health problems that scientists can confidently link to exposure to hormone-disrupting chemicals has grown to include diabetes, cardiovascular disease, and obesity, a new scientific statement suggests. The statement, released today by the Endocrine Society, also adds support to the somewhat controversial idea that even minute doses of these chemicals can interfere with the activity of natural hormones, which play a major role in regulating physiology and behavior.”

See full article from ScienceInsider here.

 

 

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Madison-Kipp Clean Air Act violations: MEJO response to Kipp CEO

Madison-Kipp Clean Air Act violations: MEJO response to Kipp CEO

Madison-Kipp Corp President/CEO Tony Koblinski responded to our post regarding the EPA consent decree for his company’s Clean Air Act violations. Here is our response:

Dear Mr. Koblinski: We offer the following responses to your comments in hopes of providing some clarity as to why we are dissatisfied with the resolution of the EPA’s Notice of Violation (NOV) to Madison-Kipp Corp.

Koblinski: “This NOV is not a new matter.  It was issued to us September 12, 2012.”  

MEJO Response: Right—these violations are not new. They go back many years. For more on Kipp’s air pollution issues since 1990, and the community’s struggle to address them, see here and here.

The EPA violations occurred from 2007 (and before) through at least 2013. Kipp’s lawyers negotiated with EPA for 2.5 years after the initial violation was sent to them on Sept. 12, 2012.

In 2008, a DNR air pollution compliance engineer notified Kipp that they were using the wrong emissions factors, underestimating the stack discharges and violating their permit. However, after this engineer passed away and another one was assigned, the DNR continued to allow Kipp to use the wrong emissions factors for years, even after the 2012 NOV from EPA was issued. In 2013, DNR found Kipp in full compliance with air regulations, even while the company was still using the wrong emissions factors. DNR South Central Air Management Supervisor Tom Roushar explained in fall 2013 (about a year after the EPA NOV was issued) that it was acceptable that Kipp continued to use the 2001 emissions factors through 2013 even though their permit specified that they should use the higher 2007 emissions factors. He felt that EPA’s allegations were unsubstantiated (though oddly, he claimed not to have seen the NOV).

Koblinski: “It does not allege that we violated our emissions limits, but rather that we did not have adequate controls on our data recording, emissions factors, record keeping, calibration and plant signage.  These are technical issues which we have taken very seriously, but at no time have we exceeded our permitted emissions limits.”  

MEJO Response: Kipp’s estimated levels of air emissions, a key basis on which agencies assess regulatory compliance, are almost entirely based on the company’s own data recording, records keeping, and/or the emission factors they use. Because Kipp kept bad (or no) records on important processes that affect emission levels, and/or used old, incorrect emissions factors, inaccurate emission estimates were reported to the DNR, EPA, and the public for over five years. These are not just minor “administrative” or “technical” issues.

In 2012, Representative Chris Taylor asked the DNR to require Kipp to measure the actual emissions from its stacks. The DNR responded by saying that the extensive recordkeeping required of Kipp was superior to testing emissions. Shortly thereafter, the EPA issued its notice of violation because Kipp was neither conducting its required recordkeeping nor filing correct reports.

Here’s one example of the consequences of using an incorrect emissions factor. Because Kipp used a 2001 emissions factor for chlorine that was 5.8 times lower than its 2007 permit required it to use, chlorine wasn’t reported at all on several air emissions inventories between 2007 and 2012 even though it should have been; incorrect chlorine emissions factors produced inaccurate chlorine emissions estimates that were lower than DNR reporting thresholds. Stack tests done in 2014 as part of the recent NOV showed that Kipp was emitting almost 12 times more chlorine than the 2001 emissions factor they used from 2007 to 2013 predicted they would emit.

Kipp also used 2001 emissions factors for dioxins through at least 2012, even though a more appropriate stack test in 2007 showed dioxin/furan emission levels orders of magnitude above the levels found in 2001 tests. Dioxins (and closely related compounds, called furans) are highly toxic at extremely minute levels—much, much more toxic than chlorine and even the tetrachoroethylene (PCE) Kipp workers dumped onto the ground for years. Even though Kipp stack tests in 2001, 2003, and 2007 showed that Kipp emitted dioxins/furans (and emissions factors increased with each test), none of Kipp’s air inventories have ever reported dioxin/furan emission levels, because using the old emissions factor kept the estimated emission levels under the DNR’s reporting limit. DNR was either oblivious to Kipp’s method of keeping their emission off the public air inventories, or decided that this was acceptable.

Kipp was also found in violation by EPA for not maintaining accurate records of its “Hazardous Air Pollutant” (HAP) emissions, which include a number of other highly toxic chemicals emitted from the factory.

Again, these record-keeping and reporting issues are not minor technical matters. Given the decades of community concerns about dioxins, chlorine, and other hazardous air pollutant emissions from Kipp, and hundreds of complaints to government agencies about strong chemical odors and health effects in the neighborhood, these reporting issues are very problematic, whether or not emission levels exceeded regulatory limits (which studies show, for many of the contaminants emitted Kipp, are too high to adequately protect public health).

Considering the discovery of extremely high levels of contaminants in soil and groundwater at Kipp, is it any surprise that Kipp did not maintain the records needed to show it complied with air pollution control laws? Pollutant levels reported to the DNR for air inventories are the only way citizens have to know what hazardous pollutants Kipp is emitting and at what levels. Kipp knows that and has worked hard to keep these chemicals off air inventories, in part, by using incorrect emissions factors. According to DNR, in 2007/2008, industries lobbied hard to not be required to report emissions below reporting limits (as they had been before). DNR allowed this.

Violations led to increases in actual emissions

Some of Kipp’s violations likely led to actual higher emissions of hazardous air pollutants, not just incorrect emissions estimates. The lubricant used to make aluminum castings is evaporated and partially burned, then exhausted through the roof. Rather than actually capturing and controlling the die lubricant emissions, diluting the die lubricant is the method required by DNR for reducing emissions from the die casting process. One of the EPA violations against Kipp was not diluting the die lubricants as much as required in its permit, resulting in higher VOC and other toxic emissions from die casting.

Other violations included not recording how much they diluted the die lubricant and/or not calibrating their die lubricant mixing equipment correctly—in other words, not following the emissions control method they are required by the permit to follow. These die casting violations are not minor technical issues. The “waxy/oily/burnt” and “metallic” smells neighbors have complained of for years are primarily die casting emissions. According to EPA, the top eight Toxic Release Inventory (TRI) air releases reported from aluminum die casting industries in the U.S. are: aluminum (fume or dust), trichloroethylene, tetrachloroethylene, zinc (fume or dust), copper, hexachloroethane, glycol ethers, and zinc compounds.

Actual emissions from Kipp’s die casting processes have been measured only sporadically and incompletely over the years inside the plant—and not for many years. In 1994, an OSHA inspector measured “oil mists” and “release agents” from die casting processes made up of metals and numerous organic compounds, including: aliphatic hydrocarbons, aliphatic alcohols, acetic acid, organic acids, butyrated hydroxyl toluene, long chain aromatic compounds, fatty acid methyl esters, propylene glycol, hydroxytriethylamine, methyl styrene, 1-2-2—methoxy-1-methyl-ethoxy-1-methylethoxy-2- propanol, and several “unidentified compounds.” The “condensate of mold release agent” contained “50% gray metallic flakes” made up of lead, aluminum, zinc, copper, and iron as well as “small particles, oily or greasy substances” and “brown particles.”

The 2001 “Madison Kipp Corp Exposure Assessment,” done by the Madison Public Health Department listed the following emissions measured above Kipp’s die casting machines in 1998: 1, 1, 1 trichloroethane, benzene, toluene, 1, 2 butadiene, hexane, ethanol, acetone, and several “unknown alkanes or alkenes.” Other reports and studies indicate that aluminum die casting emissions may also contain other very toxic chlorinated compounds such as chlorinated paraffins, PCBs, and dioxins/furans (as far as we know, these compounds have never been tested for in Kipp’s die casting emissions, inside the plant or from the stacks/vents).

During the 2011 inspection by EPA, the inspector noted “hazy air” in the die casting areas in both the Atwood and Fair Oaks facilities. This “haze” is the “oil mist” or die cast emissions, made up of many of the hazardous air pollutants listed above. Workers inhale this mist. It goes out open doors and windows and into roof vents and stacks uncontrolled. That’s why the odors are so strong in the neighborhood on some days. Again, Kipp has never characterized the chemical components of their die cast stack emissions or reported them to the DNR, nor has DNR required them to do so.

Prior to 1995, the “oily mist” from die casting was primarily vented through the doors and windows into adjacent backyards. At that time, after hundreds of neighborhood complaints, Kipp installed many roof vents sending the die casting fumes and the waxy odor further through the neighborhood. Only in 2007 did DNR recognize that Kipp was violating the 1971 air quality standards and required taller stacks rather than simple roof vents, in order to disperse the die casting emissions higher and further away. Current emissions factors for die casting are based on stack tests done in 1994 (that did not assess chemical components of the emissions).

Die casting emissions deposit on Kipp’s side walls and roofs, are washed off during rain/snow, and go into the storm drain system and eventually to the raingarden and/or Starkweather Creek and then Lake Monona. Kipp doesn’t test the chemicals in its stormwater runoff, so we don’t know what contaminants are going into the raingarden and the already highly impaired Starkweather Creek and Lake Monona.

Koblinski: “Under the direction of the EPA we completed new stack testing in May of 2014 and further verified that we operate within a fraction of our allowable emissions levels.”

MEJO Response: In the May 2014 EPA tests, the Atwood aluminum furnace stack emissions were tested for chlorine, hydrochloric acid, PM (particulate matter) and PM-10 (particulate matter ten microns or less in size). The Fair Oaks stacks were tested only for PM/PM-10. The smaller, more toxic components of particulate matter (PM 2.5) were not assessed at stacks from either facility. Dioxins/furans were not tested. Aluminum salts were not tested. No other hazardous pollutants were tested. Die casting emissions were not tested. Therefore, we have no idea whether Kipp was “within a fraction of allowable emission levels” for small particulates and many of the other hazardous air pollutants they emit.

The allowable emissions levels in Kipp’s expired air pollution permit are no basis to judge if the surrounding neighborhood is safe. The discharge limits were established to meet the old air quality standards. All the stacks on Kipp’s roof were designed to comply with the 1971 air standard for PM. The DNR’s own analysis shows current permit limits are not sufficient to comply with modern air quality standards for fine particles or PM2.5. Die casting emissions factors are over two decades old.

The community has asked repeatedly over the years that Kipp more completely characterize die casting emissions and update die casting emissions factors. Given that several of Kipp’s EPA violations had to do with issues that would affect die casting emissions, it is problematic that die casting emissions were not part of the stack testing done for the NOV. We don’t know why, but Kipp’s lawyers likely negotiated them out of the agreement if they were ever on the table for consideration. Further, originally the EPA planned to test dioxins/furans to resolve this Notice of Violation. However, Kipp’s legal team talked them out of doing dioxin/furan tests some time in 2014 (based on MEJO communications with EPA).

Koblinski: “I approached the Goodman Center to see if they had an energy efficiency project that I could help them with and ultimately agreed to pay $80,000 towards their needed chiller upgrade…”  

MEJO Response: We think improving energy efficiency is very important, but this Goodman Supplemental Environmental Project (SEP) does nothing to reduce exposures to Kipp’s toxic pollution (as described above) among the children who play at Goodman just feet from the factory. Also, it makes it even more likely that Goodman leaders will not raise any questions about Kipp’s pollution. Madison-Kipp, its wealthy owner Reed Coleman, and/or the several foundations to which Mr. Coleman funnels his wealth, have supported the Goodman Community Center with funding and other types of support since it was located next to Kipp and before that when it was the Atwood Community Center. This is one reason the Goodman Center leaders do not raise concerns about Kipp’s pollution, and dismiss or ridicule those in the community who do raise these concerns. The Goodman SEP is, in effect, more hush money to Goodman. What a boon for Kipp—congratulations!

Meanwhile, the SEPs Kipp agreed to didn’t consider in any way the concerns and suggestions of many people in the Kipp neighborhood for over two decades. Since the 1990s, hundreds of Kipp neighbors have asked for more monitoring, better emissions and noise controls, and a variety of other actions to reduce or eliminate the noise, odors, and toxic pollution from Kipp. In most cases, their concerns have been dismissed or ignored by Kipp (and DNR).  

Koblinski: “The violations indicated in the NOV did not “expose residents and children at the center to harmful pollutants” as they were administrative in nature and we have always operated well within the limits of our permits (in fact less than 4% of our total allowable).

MEJO Response: As outlined above, the violations were much more than just “administrative” and likely did result in higher emissions of some hazardous air pollutants, which continue to be emitted from the factory at unknown levels. Close neighbors of Kipp, including many children, and children playing at the Goodman Center, are among the most exposed and the most vulnerable to these hazardous pollutants released from stacks and vents just feet away from where they live and play.  

Koblinski: “The EPA did not make a “surprise, unannounced visit to our facility,” rather the inaccuracies in our reporting were discovered through the standard annual reporting that we do to the EPA and subsequent information exchanges throughout 2012.”

MEJO Response: This EPA document about the Jan. 12, 2011 inspection of Kipp describes the inspection as “unannounced.”  We don’t think EPA would lie about this.  

Koblinski: Lastly, I would use this opportunity to indicate that we are progressing well on a number of fronts as we take responsibility for the unintended environmental impacts caused over previous decades.  

I won’t list all of the actions taken and completed as those are documented through various reports submitted to the WDNR and posted to their site.  Work still ahead of us includes:

– Some additional soil remediation (removal) work remains to be done in the storm water ‘bio-basin’ (Rain Garden) and adjacent bike path.  

– We will be bringing the Ground water Extraction and Treatment System GETS on line later this month to pump and filter PCE impacted groundwater.

– We are working with WDNR and EPA to resolve remaining PCB issues under our plant.  

We will, of course, continue to regularly monitor and verify our network of wells and probes to ensure there is no risk to public health.  

MEJO Response: Please share with the neighborhood and public the most recent documents about these activities—especially those regarding the continued removal of PCB contamination from the raingarden/bike path and also under the factory. What work remains to be done and why? Please share any available data.

A representative from the Madison/Dane Co Board of Health recently reported to the Madison Committee on the Environment that all the PCBs at Kipp have been remediated. Obviously, this is incorrect. Recent documents about these activities are not posted on the DNR website. People in the neighborhood, and the public officials who serve them, need to know about ongoing remediation of highly toxic soils going on right in the middle of where they live, work, and play (children are playing at a splash pad just feet from these PCB remediations!).

Sincerely,  

Tony Koblinski

President/CEO

Madison-Kipp Corp.

tkoblinski@madison-kipp.com

MEJO Response: Thanks, Mr. Koblinski! Drop us an email any time if you have further questions or comments.

Sincerely,

MEJO

info@mejo.us


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A “Healthy and Safe Place” for “Good Clean Fun”?

A “Healthy and Safe Place” for “Good Clean Fun”?

Is this a safe place for children to frolic in a splash pad? Here are some of the toxic contaminants and safety risks not visible in the above photo…

A post in today’s Cap Times online raises important questions about whether the children’s splash pad planned at the Goodman Community Center will be a “healthy and safe place” for “good clean fun,” as the center’s Executive Director Becky Steinhoff assured us it will be in the May/June issue of the Eastside News.

Adding to questions raised in previous posts, there is a glaring omission in considerations about the safety of this location for a splash pad. Trucks carrying chlorine, toxic chemicals, and hazardous wastes to and from Kipp—and spewing hazardous diesel fumes—will rumble just feet past the children’s splash pad many times a day, every day.

Aluminum die casting is inherently toxic and dangerous, and Kipp has a lousy health and safety record. As we outlined in a previous post, between 1998 and Feb. 2014, the Madison Fire Department/EMS (emergency medical services) made 172 calls to Kipp for fires, explosions, accidents, and/or worker health problems and injuries.[1]

Kipp uses, stores, and transports chlorine, in addition to numerous other highly toxic chemicals. Chlorine is a highly toxic gas that can cause severe health problems (including death) to people exposed to high enough levels. Severe health effects from chlorine inhalation can occur within minutes—well before HazMat teams can get to the scene. The highest potential for such a release near Kipp is during the transport of chlorine; for details, see Kipp’s “Hazardous Materials Incident Initial Response Guidelines.” . With all the trucks going in and out of Kipp for well installation, remediation, etc., the chances of such an accident have likely increased in recent years.[2]

What will happen if there is a chlorine truck accident involving a chlorine release next to the splash pad while children are playing there? What plan does Goodman Community Center have in place for such an incident at its facility? Not long ago, community members asked Goodman Center staff this question and they had never heard of such a plan; they were clearly unprepared. How will the center staff handle such a chlorine or other toxic material accident next to a crowded splash pad? How will kids at an outdoor splash pad “shelter-in-place” if a chlorine spill happens 50 feet away?

[1] The actual number of fires, accidents and injuries is probably higher than this, since Kipp likely tries to avoid calling the Fire Department unless the accidents reach a certain severity level.

[2] Emergency Planning and Community-Right-To-Know (EPCRA)

MKC uses, stores, transports, and releases many highly hazardous chemicals, and is required to follow Emergency Planning and Community-Right-To-Know laws—see here for federal regulations and here for Dane County. Hazardous chemicals at Kipp include chlorine, propane, sodium hydroxide, nitrogen, fluorides, molten aluminum, fuel oils, lubricants and many more. The use, storage, and transport of chlorine are among the most potentially dangerous situations at and around Kipp. According to the “Hazardous Materials Incident Initial Response Guidelines” for Madison Kipp, “the worst-case scenario would involve chlorine being released directly to the outside of the facility during transport.”

Chlorine’s health effects: Permissible Exposure Level–1 ppm; detectable odor threshold–over 1 ppm; 3-5 ppm–slight irritation of the nose and upper respiratory tract; 5-8 ppm–irritation of the respiratory tract and eyes; 10 ppm– immediately dangerous to life and health; 15-20 ppm–immediate severe irritation of the respiratory tract, intense coughing and choking; 30 ppm–shortness of breath, chest pain, possibly nausea and vomiting; 40-60 ppm–development of chemical bronchitis and fluid in the lungs, chemical pneumonia. Prolonged exposure over 50 ppm will cause unconsciousness and death.

Two types of “vulnerability zones” for chlorine accidents at Kipp were modeled in Kipp’s Haz Mat Guideline document. One is the area in which chlorine levels could reach 1/10 of the IDLH (immediately dangerous to life and health)—or the level that “poses a threat of exposure to airborne contaminants when that exposure is likely to cause death or immediate or delayed permanent adverse health effects or prevent escape from such an environment.” The 1/10 factor is added to protect especially vulnerable people, such as those with respiratory disease or illness. The IDLH for chlorine is 10ppm so the 1/10 IDLH is 1ppm. An alternative vulnerability zone based on ERPG-2 (Emergency Response Planning Guidelines), or “the maximum airborne concentration below which it is believed that nearly all individuals could be exposed for up to one hour without experiencing or developing irreversible or other serious health effects or symptoms which could impair an individual’s ability to take protective action.” The ERPG-2 for chlorine is 3 ppm.

Vulnerability zones for chlorine releases are: 3.1 miles at 1 ppm (1/10 IDLH), 1.9 miles at 3 ppm (ERPG-2) “in the worst case scenario, dangerous or deadly levels of chlorine contamination may reach a distance of between .1 and .25 miles downwind of the source within a matter of minutes following the initial release.” Later, the document states that “The lead time for a HAZMAT incident could be from 15-40 minutes. As a result, this short time may not allow for a safe evacuation…An evacuation under these circumstances may expose the population to dangerous toxic chemicals and the decision may be made to shelter-in-place.” The document then lists 11 “shelter-in-place” recommended instructions.

**********

Do you live in the Kipp Neighborhood? If there is a chlorine accident at Kipp or an accident involving a chlorine truck on a street in the neighborhood:

-How will you know? Is there any system in place to immediately notify you and others in the neighborhood?

-Do you/your family know what the “shelter-in-place” steps are? Do staff at Goodman Community Center/Lowell School?

-Is the community prepared? Are people near Kipp even aware that the potential exists for such an accident?

If you live in the Kipp neighborhood, contact your elected officials, public health agencies, Madison Fire Department and OSHA, with questions. Ask them to look into whether Kipp is following EPCRA laws. Ask them to initiate a public meeting to help prepare residents, schools, and community centers for a chlorine and/or other hazardous chemical accident at or around Kipp. Always include your street address when contacting your political representatives.

Madison Alder Marsha Rummel: 608-772-4555, district6@cityofmadison.com

Senator Fred Risser: (608)266-1627, sen.risser@legis.wisconsin.gov

Representative Chris Taylor: (608) 266-5342, Rep.Taylor@legis.wisconsin.gov

John Hausbeck (Epidemiologist, Madison Dane County Public Health): 608.243.0331, JHausbeck@publichealthmdc.com

Henry Nehls-Lowe (Epidemiologist, Department of Health Services): 608-266-3479, Henry.NehlsLowe@dhs.wisconsin.gov

Dave Bursack, Dane County Local Emergency Planning Committee: 608-266-9051,

Madison Fire Department: 608-266-4420, fire@cityofmadison.com

Occupational Safety and Health Administration (Madison Office): (608) 441-5388

 

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Madison Kipp: Making a Beautiful Difference?

Madison Kipp: Making a Beautiful Difference?

See the beautiful difference: Kipp Raingarden to Kipp Sludgegarden.

Previous story about the Kipp raingarden here. A raingarden was built by middle school children in 2006 next to Madison-Kipp Corporation. High levels of PCBs, PCE and other contaminants were found there in August 2012, AFTER it was excavated the first time to create the garden! Another excavation occurred in early 2014 to remove the PCBs found in the first excavation.

These pictures were taken on Earth Day 2014 after the 2nd excavation. NOTE: The open pit–full of toxins–is right next to the Goodman Community Center, directly across from the compost pile area.

Kipp raingarden photo gallery is here.

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Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

Is Kipp A Safe Place to Work? Cleaning Employee Fired by Contractor for Asking

(Madison-Kipp Worker Pouring Molten Aluminum)

–Madison Kipp Corporation’s non-unionized manufacturing workers, and contractors brought in to clean and do other work at the factory, are at ground zero for exposures to myriad toxic chemicals emitted in aluminum die casting processes, vapors from the giant plume of toxic volatile organic compounds (VOCs) beneath the plant, and polychlorinated biphenyls (PCBs) contaminated soils being excavated all over the site. See previous posts for more background.

Yet Kipp’s CEO Tony Koblinski assured people in a community presentation on March 19 2014 that Kipp has “good people and good jobs” and is “a company in control.” [1] Further, he asserted “people like working at Kipp, they always have.”

Kipp workers we have talked to over the years do indeed seem like good people, but the stories they told us about working there are not about “good jobs” in a factory that is “in control.” Those we have talked to—usually after they quit—not only did not like working at Kipp, but they did not feel safe or healthy there.

Our review of records, in fact, shows that Kipp’s manufacturing workers and contractors have very legitimate reasons to be concerned about their health and safety. Madison Fire Department (MFD) and Occupational Safety and Health Administration (OSHA) records on Kipp from 1990 to the present indicate that the place is anything but safe for workers. From 1998 through Feb. 2014, Madison Fire Department/Emergency Medical Services (EMS) paid approximately 172 visits to the Kipp facilities on Waubesa and Atwood Ave.[2] [3] Disturbingly, well over half of these calls—we counted 113—were “emergency medical service” (EMS) calls for worker injuries and/or health problems. Some reasons for EMS calls:  chest pains, difficulty breathing, dizziness, possible heart attacks or seizures, passing out from heat, low blood pressure/fainting, lacerations/loss of blood, finger amputations, fingers caught in machines, molten metal burns, burns from propane explosion, worker hit or pinned by forklift, hit over the head, falls, sprains, and more. The first two—chest pains and breathing problems—were listed many times. Either Kipp workers are not very healthy people to begin with, or something in the facility is causing these frequent health problems—or both.[4]

Since 1990, the facility has had numerous molten metal spills, explosions, and fires—most caused by ignition of highly combustible metal dusts and filings. In addition to being obvious immediate threats to worker safety, smoke and fumes from fires and materials used to extinguish fires are often toxic and associated with respiratory problems, cancer and other long-term health problems.[5]  Kipp’s MFD and OSHA records also raise serious questions about how prepared residents near the factory, and staff at Goodman Community Center and Lowell School, are for a chlorine or other chemical accident at Kipp (or an accident involving a truck transporting chemicals to/from there on roads in the neighborhood). For more info, see here.

Cleaning worker is fired for asking if Kipp is safe, requesting not to work there

In February 2014, a worker with existing respiratory problems, who had cleaned for the company Environment Control for five years, contacted MEJO about having headaches and respiratory problems when cleaning at Kipp (which he had recently been assigned to). Several employees of this company who had cleaned at Kipp before him had already quit because they did not want to work in the foundry. He asked his managers that he be transferred to another cleaning job, but they said he would have to prove that the factory was not safe before they would take him off the Kipp job (how could a worker possibly do this?). They told him if he had a health evaluation by a doctor, validating his respiratory problems and connecting them to exposures at Kipp, they might transfer him. Not having health insurance, he could not afford to see a doctor.

He began to search for information about the kinds of toxic contaminants he might be exposed to at Kipp, and sent documents he found (including some written by top scientific experts on the kinds of contaminants found at Kipp) to his managers. Unwilling to read or believe the information he provided, they continued to refute his concerns and demand that he continue cleaning at Kipp (several hours a night, five nights a week).

Frustrated, he eventually contacted MEJO with questions. He suspected that what he was breathing in Kipp was aggravating his lungs and causing headaches. Also, he recalled that for 2-3 weeks in Jan/Feb., while PCB contaminated concrete and soils (again, see this story) were being excavated to install new machines, piles of dirt were sitting all over on the factory floor.[6] Was anything done to reduce/eliminate PCB dust levels in factory air, to protect all workers in the plant? Were workers informed of the contamination? Did they have protective gear?[7]  According to the worker, no, no, and no.[8]

He said practices in the factory seemed very sloppy.  One day while cleaning he noticed a sign in the factory that said “number of days since last accident.” The number there that day was “10.” Factory workers told him 10 days without an accident “is pretty good for Kipp.” This is a factory that is “in control”? Hmmm….

When queried, Kipp assured managers at Environment Control that the factory was perfectly safe. Kipp presented the company with a document (apparently written by Kipp’s insurance company) stating that Kipp is safe.[9]  Rather than showing concern for their employee’s health, and considering the legitimate evidence he brought forward, Environment Control managers chose to believe whatever evidence Kipp and their insurance company gave them.[10]

Sadly, in late March, after continuing to request that he not work at Kipp, the cleaning worker was fired. Apparently Environmental Control considers its employees expendable.

Kipp workers, neighbors, and others have complained of health problems for decades

Many former Kipp workers have shared stories of disturbing health and safety problems in the factory over the years. In 1996, a person who worked at Kipp through 1989 (but believed that the conditions there remained unsafe or got worse after that) wrote a summary of some of the unhealthy conditions in the factory and environmental problems. Another former worker said that there were cases in which workers collapsed from fumes.

Kipp workers aren’t the only ones who have experienced health problems at Kipp. In July 1994, a DNR employee, investigating an odor complaint submitted by a neighbor, smelled a “metallic, solvent-like odor.” Her official statement about this incident says that within five minutes of leaving the plant after the investigation: “I experienced a dizzy, woozy feeling. My face and fingers felt numb and tingly, my heart was pounding, and I found my breathing rapid and shallow. My proprioreception was disrupted and I did not believe I could safely drive.”

In the last few years, there have been similar odd cases of people suddenly suffering health effects near Kipp.  In 2009, the Fire Department responded to situation in which a 10-year old child walking back from a school field trip felt faint and laid down on the grass on Atwood Avenue in front of the Kipp factory (it is unclear whether this incident was connected to any Kipp emissions—but it raises questions). In 2012, a bicyclist was riding on the bike path behind the Atwood plant, smelled a noxious odor that he connected with Kipp, and became nauseous.

Hundreds of reports have been submitted to local agencies over the last two decades by residents in the neighborhood about noxious smells from Kipp—especially the smell of chlorine and/or a “waxy/oily/burnt” smell. According to a 2001 report, “Evaluation of Community Exposure to Emissions from Madison Kipp Corporation,” people “identified both of these odors as the cause of acute illness including asthma attacks, sore throat, nausea vomiting etc.” and goes on to say “it is reasonable to assume that reports of chlorine odors originate from the aluminum melting and drossing process” and “emission of chlorine from this process is the most likely source of these odor complaints.” It also notes that “waxy/oily/burnt” smell in the neighborhood is from the die casting process but that “the chemical composition of this odor is unknown.”

Odor complaints have continued in recent years.[11] In early 2013, a resident on S. Marquette St., next to Kipp, emailed public health agency staff saying that 5 or 6 times in the last several years, he and his wife had “noticed the strong smell of burning rubber or plastic emitting from the basement stairs in our home,” particularly after heavy rainstorms or large snow melt-off events.” He noted that the smell “is not dissimilar to one of the odors that we occasionally smell outdoors and that the neighborhood generally associates with MKC.” He recalled a day in late 2012 in which “several in our neighborhood reported smelling a chlorine smell coming from the MKC property,” and he personally detected a “fairly strong burning rubber smell outdoors.”

Despite all of these worker and neighborhood complaints over the years, public health agencies have insisted many times that there are no harmful exposures in the neighborhood around Kipp—even while admitting many times in the 2001 report that there is not enough data to make this determination. As we described in previous articles (see here and here), a group of citizens from the community worked with government health agencies for nearly two years to develop a health study in the Kipp area, but the study was eventually dropped, for reasons that are unclear. Many suspect that Kipp played a role in shutting the study down.

Meanwhile, none of the DNR or public health agency reports, documents, or communications to date (we have reviewed thousands of pages of them) have even mentioned, let alone expressed concern about, potential exposures to workers inside the plant. Apparently manufacturing workers, most of whom are citizens of Madison and Dane County, are not included in their definition of “public health.”

Many respiratory irritants and toxins emitted in aluminum die casting facilities…

The fired cleaning worker’s aggravated respiratory symptoms and headaches in the factory parallel Madison Fire Department visits to the factory to attend to workers with chest pains, breathing problems, dizziness, and related symptoms. Moreover, Kipp’s terrible worker health, safety and OSHA records indicate that Kipp is doing far from an adequate job inside the factory protecting their workers from exposures to harmful chemicals, regardless of whether or not they meet standards (which is unknown, due to lack of adequate data). Many existing workplace health standards, heavily influenced by industry lobbying, are known to be far too lax and not adequate to protect workers’ health.

What are Kipp’s workers exposed to?  Releases from Kipp’s stacks aren’t all the same as what’s in factory air, but can tell us something about what chemicals the facility uses and emits into factory air.

As of 2004, EPA’s Toxics Release Inventory (TRI) listed the following as top air releases in aluminum die casting industries all over the U.S: aluminum (fume or dust), trichloroethylene, tetrachloroethylene, zinc (fume or dust), zinc compounds, copper, hexachloroethane, glycol ethers.[12] Unfortunately, it is increasingly difficult to find out what comes out of Madison-Kipp stacks in particular—in part due to industry’s political lobbying to keep this information out of the public realm, inadequate monitoring and lax regulatory approaches [13] .  Madison-Kipp’s 2012 DNR Air Emissions Inventory Report lists the following emissions: carbon monoxide, nitrogen oxides, particulate matter, hydrogen chloride, and “reactive organic gas” or ROG (otherwise known as volatile organic chemicals or VOCs). Many of Kipp’s most toxic emissions, however, are not reported on Kipp’s air inventories—or were in the past but are no longer .[14] [15] [16]  For instance, Kipp also emits dioxins and furans (among the most toxic compounds ever studied), aluminum salts, fluorides, fluorinated compounds, chlorine, chlorinated and chlorofluorinated compounds, numerous metals, polycyclic aromatic hydrocarbons (PAHs), and several other toxic compounds that are not listed on the inventories.

Just as problematically, the chemical composition of emissions from Kipp’s die casting processes—which include reactive organic gases (ROGs), polycyclic aromatic hydrocarbons (PAHs), small particulates, metals, and a mix of other contaminants found in oil mists associated with metalworking fluids used as die lubricants (discussed in more detail later)—have never been assessed.[17] The “emissions factors” used to assess the levels of ROGs and particulates emitted from the die casters are old and inadequate (based on tests done in the mid-90s), and Kipp has added many more die cast machines since the time they were developed. So the estimated levels of ROGs and particulates on inventories are likely too low. (Several years ago, Kipp raised its stacks higher in order to disperse these compounds, associated with the “waxy/oily/burnt” smell nearby residents have complained about for years, further out into the community. Given this, it defies common sense (and science) to assert–as Mr. Koblinski did on March 19–that none of the PAHs and other contaminants found in nearby residential soils are from the facility. The elaborate (but problematic) statistical analyses by Kipp’s consultants, and comparisons to background samples obtained by government agencies (which certainly included some of Kipp’s PAHs, dispersed widely around the community via taller stacks) do not prove that none of the PAHs and other contaminants found in soils offsite came from Kipp).

As a result of inadequate reporting and data gaps, it is difficult for citizens or workers to track what Kipp is really emitting outside or inside the plant. Efforts by the Madison Department of Public Health (now called Public Health Madison Dane County, PHMDC) to assess exposures in the Kipp neighborhood were aborted because of limited or no air monitoring. Ultimately the agency concluded in its 2001 report that there were too many data gaps to draw any conclusions, and recommended more air monitoring. Unfortunately, 13 years after this report was written, no further air monitoring around Kipp has been done.

What are workers breathing inside Kipp?

Many of the compounds emitted from Kipp’s stacks are likely found to some degree inside the factory, where workers are exposed to a number of them at the same time. Unfortunately, even less information is publicly available about chemical exposures inside Kipp than is available about outdoor emissions.[18] Regardless, several of the compounds listed above and known to be emitted from, and found inside, aluminum die casting facilities, can aggravate respiratory problems and a range of other health effects. Kipp workers have also been breathing unknown levels of toxic vapors from beneath the plant, which include tetrachloroethylene (PCE), trichloroethylene (TCE), vinyl chloride (VC), and other VOCs known to aggravate respiratory problems and headaches. Most of these chemicals are also associated in scientific studies with a number of serious long-term health problems, including cancer.

Next we discuss some of the above compounds that are most likely aggravating respiratory and other acute problems among workers. We discuss the sparse data available from monitoring inside of Kipp, what it can (or cannot) tell us about exposures to Kipp workers, and government agency actions (or lack thereof) related to Kipp workers’ health and safety.

If you have read this far, and are interested in learning more about what we have learned, please email us at info@mejo.us.



[1] The talk was most likely written by Kipp’s law firm, Michael Best & Friederich

[2] These numbers are approximate (possibly underestimated) due to gaps in records; they also don’t include Fire/EMS calls to the Sun Prairie facility.

[3] While some of these recorded calls were false alarms, we have heard that many times there are close calls (near-miss accidents and fires, etc) for which nobody ever calls the Fire Department, in part because management wants to keep the official fire call record as low as possible. Consequently, the official number of calls in records is likely an underestimate of the actual number of accidents, fires, and worker illnesses.

[4] Kipp’s lowest-end manufacturing workers, contractor cleaning employees, and temporary workers include ex-offenders, homeless people, and a significant proportion of minorities. Sadly, statistics show that these groups are likely to be much less healthy than more privileged people—making them even more vulnerable to health problems from exposures to contaminants in Kipp. Many also lack health insurance. This is a significant environmental justice issue that has been completely ignored by Kipp and the government agencies responsible for protecting public health in Madison/Dane Co. and Wisconsin.

[5] A fire on August 1, 1992 sent four firefighters to the hospital after they inhaled noxious fumes. The Aug. 2 1992 Madison newspaper article on this fire, titled “Molten Flames,” says that the building filled with smoke and noxious fumes.

[6]  He only found out about it after coming across it on the MEJO website.

[7] Some of the precautions EPA recommends when excavating contaminated soil: “Handling contaminated soil requires precautions to ensure safety. Site workers are trained to follow safety procedures while excavating soil to avoid contact with contaminants…Site workers typically wear protective clothing such as rubber gloves, boots, hard hats, and coveralls. These items are either washed or disposed of before leaving the site to keep workers from carrying contaminated soil offsite on their shoes and clothing…Workers monitor the air to make sure dust and contaminant vapors are not present at levels that may pose a breathing risk, and monitors may be placed around the site to ensure that dust or vapors are not leaving it. Site workers close to the excavation may need to wear “respirators,” which are face masks equipped with filters that remove dust and contaminants from the air…

[8] Now the new machinery is installed, the dirt was hauled away, and the floors cleaned up. The area was re-painted and is clean and shiny.

[9] From what we understand (not having seen this document), the last inspection in Kipp for insurance purposes was 3 years ago.

[10] Mr. Koblinski said in his March 19 presentation that the company’s current priorities include “managing health risks to employees” and “communicating openly with the neighborhood.” If this is the case, the company should openly share the health and safety assessments done inside the factory by insurance companies and other third parties. If they are unwilling to share these assessments, what are they hiding?  On the other hand, if the assessments are comprehensive and state of the art, and show that the factory is safe, that would be reassuring to workers and the neighborhood. So why won’t Kipp share them?

[11] In the weeks just before this article was written, residents near Kipp have reported increased odors from the plant, including a particularly acrid smell that seems new to them.

[12] Dalquist and Gutkowski, 2004

[13] Again, see previous articles

[14] In Wisconsin, industry (likely including MKC) lobbied to not report certain emissions on public inventories at all unless they were modeled at over NR 438 levels. See previous article describing some of these issues, particularly as they relate to dioxins and chlorinated compounds, among Kipp’s most toxic emissions.

[15] Given that Kipp purportedly no longer uses tetrachoroethylene (PCE) (and it is not clear whether they still use trichloroethylene, TCE), it is unknown whether Kipp has or still does emit these compounds from its stacks; PCE, TCE, and their breakdown product, vinyl chloride, have never been tested for in Kipp’ air stack emissions. They are being emitted (and monitored) from soil vapor extraction (SVE) systems on the site. It’s unknown what compounds Kipp used to replace PCE—and what kinds of emissions might be associated with these replacement chemicals

[16] MEJO has asked government agencies several times what Kipp replaced PCE/TCE and PCBs with, but have never received answers.

[17] Levels of ROGs listed on Kipp’s inventories have increased significantly in recent years, from 17.4 tons in 2008  to just over 26  tons in 2012 (2013 and 2014 levels are not available yet). Of course, these levels do not include VOCs being emitted from vapor extraction systems all over the site.

[18] Air monitoring in aluminum die casting facilities has been relatively scant—in part due to die-cast industry’s competitiveness, success in withholding proprietary information about the chemicals they use, and resistance to any monitoring in their plants.

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Medical researchers say brain disorders tied to industrial chemicals

Medical researchers say brain disorders tied to industrial chemicals

“Children worldwide are being exposed to unrecognized toxic chemicals that are silently eroding intelligence, disrupting behaviours, truncating future achievements and damaging societies” according to a new Lancet Neurology article. Also read more here.

In other words, toxins emitted from Kipp and other industries have significant long-term and irreversible effects on our children, our educational system, and our whole society. Here’s the abstract from the Lancet Neurology article by Dr. Grandjean and Dr. Landrigan:

“Neurodevelopmental disabilities, including autism, attention-deficit hyperactivity disorder, dyslexia, and other cognitive impairments, affect millions of children worldwide, and some diagnoses seem to be increasing in frequency. Industrial chemicals that injure the developing brain are among the known causes for this rise in prevalence. In 2006, we did a systematic review and identified five industrial chemicals as developmental neurotoxicants: lead, methylmercury, polychlorinated biphenyls, arsenic, and toluene. Since 2006, epidemiological studies have documented six additional developmental neurotoxicants—manganese, fluoride, chlorpyrifos, dichlorodiphenyltrichloroethane, tetrachloroethylene, and the polybrominated diphenyl ethers. We postulate that even more neurotoxicants remain undiscovered. To control the pandemic of developmental neurotoxicity, we propose a global prevention strategy. Untested chemicals should not be presumed to be safe to brain development, and chemicals in existing use and all new chemicals must therefore be tested for developmental neurotoxicity. To coordinate these efforts and to accelerate translation of science into prevention, we propose the urgent formation of a new international clearinghouse.”

EIGHT of the chemicals highlighted as the most damaging to the developing brain are known to be emitted from Madison Kipp Corporation and/or have been found in soils, groundwater and/or air at the site. This factory is just feet away from homes, schools, daycare centers, and a community center that focuses on programs for low income and minority children.

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High Levels of PCBs Being Excavated from Kipp’s Floors—Are Workers Protected?

High Levels of PCBs Being Excavated from Kipp’s Floors—Are Workers Protected?

(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.[1]Various companies are contracted to clean Kipp and remove wastes; cleaning Kipp and removing wastes likely involve exposures to a stew of toxic contaminants.[2]

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.[3]  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 .[4]

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: info@mejo.us. THANKS!!!


[1] 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…

[2] MEJO members have talked to people who cleaned at Kipp and suffered health effects while there.

[3] 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?

[4] In 2011, OSHA did a very limited one-time assessment of aluminum dust.

 

 

 

 

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