Graphic Packaging’s Statement on MDHHS Study & Odor Action Plan

Graphic Packaging International (GPI) continues to place a high priority on the health and safety of employees and community neighbors. As a part of this commitment, GPI has published its ongoing Odor Action Plan, which is a critical part of the company’s continued investment in the Kalamazoo community. Graphic Packaging first began addressing the odor issue voluntarily more than a decade ago, and in February of this year, incorporated its findings and recommendations into a consent agreement with the state of Michigan.  

“We’ve been a part of Kalamazoo for more than 100 years, and we are committed to improving not just the air quality but the quality of life in the community we call home,” said Scott LeBeau, vice president of recycled mills at Graphic Packaging. “We have made progress in recent years, but we know we need to continue to work in lockstep with Kalamazoo’s Water Reclamation Plant (KWRP) to make the impact that we are all striving to achieve. We will relentlessly pursue improved air quality in our community.” 

Graphic Packaging and the Michigan Department of Environment, Great Lakes, and Energy (EGLE) agreed in a February 2023 consent agreement that GPI would investigate any readings exceeding 25 parts per billion (ppb) of H2S over a two-hour period, or 50 ppb over a half hour. The targets are based in part on guidance from the U.S. Agency for Toxic Substances and Disease Registry (ATSDR), which set a minimum level of concern for mid-term exposure (15-364 days) of 20 ppb. Graphic Packaging has consistently complied with the terms put forth in the EGLE consent agreement.  

Odor Action Plan

Graphic Packaging expects to complete its $8 million commitment for odor mitigation equipment by the end of 2023. The company also increased its annual wastewater treatment operating costs to $2 million to further reduce the potential for odors. In addition, Graphic Packaging actively participates in the City’s Odor Task Force, chartered to address odor issues at the Kalamazoo Water Reclamation Plant, the mill and any other potential sources.  

“This is a top priority for our leadership team,” said LeBeau, who works in Graphic Packaging’s Kalamazoo plant. “Every day, we take several actions to help us proactively address odors. Leadership reviews odor observations in our morning meetings. We have staff who conduct daily inspections along a set route through neighboring residential areas, keep a log of their observations and report to the leadership team. We continuously monitor the Envirosuite readings for H2S spikes. These actions provide essential data that we can then use to deploy countermeasures to curb emissions.”  

Some of Graphic Packaging’s most impactful air quality measures to date include:

  • Capping a city-owned sewer vent that was identified as a potential source of nuisance odors in 2009.
  • Optimizing the chemicals used in key processes to reduce the potential to generate odors. 
  • Installing and continuously monitoring 16 Envirosuite odor monitors throughout GPI’s property, with real-time data posted on
  • Conducting independent evaluations to identify the most effective methods to mitigate the potential for nuisance odors. 
  • Investing in discharge water flow control to ensure predictable water flow through the sewer system to KWRP. 
  • Holding daily mill leader team meetings to assess facility odors.

Additional initiatives planned this year are: 

  • Installing a wet scrubber system designed to remove H2S emissions from equipment in the mill wastewater treatment plant. 
  • Replacing the current oxygen rental system with a permanent system. This decision was made after the rental system proved to be highly effective at reducing H2S. 
  • Working with the City of Kalamazoo to reroute discharged water away from a junction chamber that has been identified as a source of nuisance odors. 

“We are dedicated to remaining compliant with all health, safety and environmental regulations,” LeBeau said. “Our commitment runs deeper than checking the box. This is a complex issue. We want to find effective and long-lasting solutions so our community can thrive for years to come.”  

Read the details of Graphic Packaging’s Odor Action Plan.

Health Assessment

A recently released health consultation by the Michigan Department of Health and Human Services (MDHHS) has driven even more urgency around odor mitigation. A key finding from the MDHHS report, issued May 8, cites that continuous long-term exposure to hydrogen sulfide at levels found near KWRP’s sewage treatment center and GPI’s paperboard mill could potentially produce nasal or eye irritation in some people, which could become chronic over a lifetime of exposure.  

GPI has engaged third-party experts to analyze the report and determine any updates to the company’s action plan. The company is also requesting clarification from MDHHS on whether 1.4 ppb is meant to be a new statewide standard for H2S emissions.  

“We appreciate the work that went into the MDHHS assessment,” LeBeau said. “It is very disappointing to learn that any irritant, temporary or chronic, might result from the air surrounding our property and the City’s wastewater facility. It is a positive sign that no correlation was found between H2S presence and asthma or other potentially life-threatening illnesses.” 

“As one of the largest employers in this community, our primary concern will always be the health and wellbeing of our 750 Kalamazoo employees and all of our neighbors,” LeBeau said. “We are optimistic that the actions we are taking in the months ahead with the City’s wastewater reclamation plant will make an even bigger difference for everyone living and working in this area. We are in this for the long haul.”  

For updates on Graphic Packaging’s efforts to invest in the community and tackle odor issues, visit