What the Lawyers Can’t Put a Number On

Fannie and Albert Tartt have lived in Rockdale County since 2007. Their home at 1849 Kings Row sits 1.3 miles from the Bio-Lab plant. On the morning of September 29, 2024, they woke up to a fire. By afternoon, a wall of chemical smoke was rolling toward their neighborhood and they had a choice: evacuate, or stay and shelter in place. They couldn’t evacuate. So they shut the doors, turned off the HVAC, and sat inside their own home like it was a bunker.

Albert Tartt had a physical therapy appointment that day. He missed it. That sounds small until you understand what it means to be trapped in a sealed house, possibly in pain, unable to call for help, unable to leave, surrounded by air that government officials are telling you not to breathe. The Tartts’ home, a place they’ve built their lives in for seventeen years, became a holding cell because a corporation 1.3 miles away couldn’t be bothered to fix a sprinkler system or store its chemicals safely.

Think about what the shelter-in-place order actually meant for 77,000 people. It meant parents couldn’t reach children at school. It meant people ran out of medication with no ability to get more. It meant nobody could tell their families where they were because communication devices had been left behind. It meant elderly residents and people with mobility problems had to decide between breathable air and the physical risk of an evacuation they weren’t equipped to make. It meant Sunday church services were cancelled mid-prayer across Rockdale County, from Rockbridge to Northside.

Piedmont Rockdale Hospital, the facility that exists to catch people when everything goes wrong, evacuated its own patients. It went on diversion. Anyone who needed emergency care that afternoon, a heart attack, a car accident, a child’s injury, was redirected somewhere farther away. Bio-Lab’s fire did not just damage property. It severed the local emergency medical net at exactly the moment people were most likely to need it.

Children in Newton County Schools spent Monday, September 30th at home instead of in classrooms. Georgia Piedmont Technical College closed both campuses. Students lost instruction time. Workers lost wages. Business owners lost revenue they will never recover. Some of those businesses are small and local, with no insurance buffer and no corporate parent to absorb the hit. When Rockdale County’s courthouse, tax office, elections office, water resources department, and animal shelter all shut down on the same day because of a chemical cloud from a private pool supply company, that is a government forced off the field by corporate negligence.

The residents who came home to smoke and ash on their porches, on their lawns, on their children’s outdoor toys, are still waiting for answers about what exactly was in that plume. The chlorine was confirmed. The full chemical composition, as of the filing of this lawsuit, had not been publicly disclosed. People are sleeping in homes coated with the byproducts of a chemical inferno and still do not know everything that landed on them. That is the ledger that no settlement figure ever fully closes.

What the Lawsuit Actually Says: Verbatim

These are direct quotes from the class action complaint filed September 30, 2024, in the U.S. District Court for the Northern District of Georgia (Case No. 1:24-cv-04407-SEG). Nothing below is paraphrased.

The Full Scale of What This Fire Did to Real People

Environmental Degradation

The Conyers Plant fire released a documented chemical plume that contaminated outdoor and indoor environments across multiple counties. The following environmental harms are documented in the complaint and referenced state and federal agency records.

• Air quality surveys by the Georgia Environmental Protection Division and the EPA on September 29 and 30 confirmed “the harmful irritant chlorine” emitting from the Conyers Plant in the post-fire plume. Wind patterns caused the toxic chlorine pollution to follow an “unpredictable path” across the region.
• Residents living near the Conyers Plant observed smoke and ash debris deposited on their property and around their homes. Toxic and harmful substances, particulate matter, and other pollutants were physically deposited on residential, commercial, and public properties without consent.
• The complaint alleges that Defendants are aware that toxic materials landed on class members’ properties but have failed to remove them, meaning the contamination remained present as of the filing date, September 30, 2024.
• In the 2020 predecessor incident at the same plant, chlorine levels at nearby business property hit 12 times the federal permissible exposure limit, establishing the facility’s documented capacity for environmental overload. The 2024 fire was larger in scale.
• The plume was visible from at least 30 miles away, indicating the volume of airborne chemical particulates released was extraordinary. Adjacent counties, including Newton and Walton, deployed emergency management resources and issued their own public advisories about outdoor air quality.

Public Health

The public health consequences of the September 29, 2024, fire extended far beyond the immediate blast radius. The following documented harms come directly from the complaint and linked government and news sources.

• 77,000 Rockdale County residents were ordered to shelter in place, required to seal their homes, turn off air conditioning, and close all windows and doors from 7:45 p.m. into September 30. This order was extended.
• Piedmont Rockdale Hospital evacuated patients and announced it was on medical diversion. People seeking emergency care during the event were redirected to more distant facilities, introducing potentially life-threatening delays.
• More than 17,000 residents under the evacuation alert could not return home, leaving people without medication, medical devices, and the ability to communicate with family about their safety.
• Plaintiff Albert Tartt was unable to attend a scheduled physical therapy session. While one missed appointment sounds minor, it represents a documented pattern: when a toxic chemical event locks 77,000 people inside, every medical need, appointment, and prescription pickup in the county is simultaneously disrupted.
• Churches across Rockdale County and surrounding areas were asked to cancel or immediately end Sunday services on September 29, cutting off community support networks that many residents depend on for mental and physical wellbeing.
• Walton County officials advised residents to bring outside animals indoors. The chlorine plume posed documented respiratory risks to both humans and animals across a multi-county area.
• The full chemical composition of the plume had not been publicly disclosed as of the complaint filing. Residents were living in potentially contaminated homes without complete information about what they had been exposed to.

Economic Inequality

The financial damage from this fire fell hardest on people who had the least ability to absorb it. The following documented economic harms come from the complaint.

• All businesses in Rockdale County were asked to close operations while the shelter-in-place order was in effect. Small business owners, hourly workers, and gig workers lost income they cannot recover through a corporate expense account.
• Newton County Schools, Georgia Piedmont Technical College (both Newton and Rockdale campuses), and the City of Conyers closed through October 2. Working parents without backup childcare faced an immediate economic crisis: miss work or leave children unsupervised.
• All major Rockdale County government offices, including the tax commissioner, elections office, water resources, and courthouse, closed on September 30. Property owners needing permits, residents needing government services, and legal matters requiring courthouse access were all delayed at no fault of their own.
• The complaint seeks property remediation, independent third-party property damage assessments, and alternative housing for displaced residents, because property damage and diminished values are expected to be widespread. Renters and homeowners in a 93,000-person county are facing costs they did not create and cannot individually afford to address.
• Rockdale County’s Emergency Management Agency, the Georgia Environmental Protection Division, the Georgia Department of Transportation, the EPA, FEMA, the American Red Cross, and DeKalb County Emergency Management were all deployed to respond. The cost of that public emergency response, paid for by taxpayers, is a direct economic transfer from the public to the private company whose negligence caused the emergency.
• The 2004 fire at the same plant resulted in a $7 million settlement. The 2020 incident caused $1,007,000 in documented property damage. The 2024 fire caused a complete building collapse and displaced tens of thousands of people; the financial scale is orders of magnitude larger and has not yet been fully calculated.

What the Prior Settlement Actually Bought

Where the Power Is and How to Use It

The people accountable for what happened to Rockdale County hold specific titles at specific corporations, and specific regulatory agencies have jurisdiction over their conduct. Here is the current picture.

Who Is Named in the Lawsuit

• Defendant: Bio-Lab, Inc., a Delaware corporation headquartered at 1725 N. Brown Rd., Lawrenceville, Georgia 30043. Registered agent: CT Corporation System, 289 S. Culver St., Lawrenceville, Georgia 30046.
• Defendant: KIK Consumer Products Inc., a foreign corporation with principal offices in Canada. KIK acquired Bio-Lab to expand its pool and spa treatment business and directly owned and operated the Conyers Plant.
• Named plaintiffs: Fannie and Albert Tartt, Rockdale County residents since 2007, located 1.3 miles from the Conyers Plant at 1849 Kings Row, Conyers, GA 30012.
• Plaintiff’s counsel: DiCello Levitt LLP; Stewart Miller Simmons Trial Attorneys; Miner, Barnhill & Galland, P.C.; and Collins Law Environmental & Personal Injury Lawyers. These firms specialize in environmental and toxic tort class actions.

Watchlist: Regulatory Bodies With Jurisdiction

• EPA (U.S. Environmental Protection Agency): Deployed to the Conyers Plant site on September 29-30 for air quality monitoring. Has authority to investigate chemical plant safety under RCRA and the Clean Air Act’s Risk Management Program (RMP). Submit complaints at epa.gov/tips.
• Georgia EPD (Environmental Protection Division): Conducted on-site air quality surveys after the fire. Has state-level regulatory authority over chemical facilities in Georgia. File complaints at epd.georgia.gov.
• OSHA (Occupational Safety and Health Administration): Has jurisdiction over Process Safety Management (PSM) compliance at chemical facilities storing highly hazardous chemicals including trichloroisocyanuric acid at covered thresholds. Contact OSHA at 1-800-321-OSHA.
• FEMA (Federal Emergency Management Agency): Was deployed to assist in the emergency response. Tracks disaster declarations that can trigger federal relief funding for affected residents.
• U.S. Chemical Safety and Hazard Investigation Board (CSB): Previously investigated the 2020 Bio-Lab water leak incident and produced a published report cited in the complaint. Has the authority to investigate the 2024 fire independently. CSB reports are public; the 2020 report is linked in the complaint at csb.gov.
• DOJ (U.S. Department of Justice): In cases involving documented criminal recklessness at chemical facilities, the DOJ Environment and Natural Resources Division can pursue criminal charges independent of the civil class action.

Mutual Aid and Grassroots Resistance: Specific Steps

• If you are a Rockdale County property owner or renter: Contact the class action counsel directly. DiCello Levitt LLP (alevitt@dicellolevitt.com), Stewart Miller Simmons (cstewart@smstrial.com), or Barnes Law Group (roy@barneslawgroup.com). The class is defined as all owners and lessees of real property subject to the evacuation and shelter-in-place orders. If you qualify, you have standing.
• Document everything now: Photograph ash, debris, or residue on your property. Keep all medical records for respiratory symptoms, skin irritation, or other health effects experienced after September 29. Keep receipts for any cleanup costs, alternative housing, or lost business income. This documentation strengthens the class claims.
• Demand Bio-Lab’s public disclosures: The complaint specifically requests that Defendants “immediately and publicly disclose all information regarding the toxins and other compounds that comprised the plume.” Contact the Rockdale County Board of Commissioners and your Georgia state representatives to demand that this disclosure happen on a legally binding timeline.
• Organize with neighbors on property testing: The complaint requests independent third-party assessment of property damage and air and groundwater testing. Connect with neighborhood associations and mutual aid networks in Rockdale County to coordinate collective pressure on both the company and county government to fund independent testing that does not rely on Bio-Lab’s own assessments.
• Submit formal comments to the CSB: The CSB’s 2020 Bio-Lab investigation report is public. Residents and community organizations can submit public comments to CSB’s ongoing work and formally request a new investigation into the 2024 fire. CSB investigations produce legally significant findings that support regulatory enforcement and litigation.
• Support the local emergency infrastructure that was damaged: Piedmont Rockdale Hospital went on diversion. Local firefighters from Rockdale County Fire Rescue responded to a hazmat inferno they were not adequately equipped for. Support local fundraising for better protective equipment and hazmat response capacity that the county should never have had to improvise.