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Despite declining rates in recent years, Kentucky has had an unusually high number of manufacturing fatalities thus far in fiscal year 2019.  According to the Kentucky Labor Cabinet, manufacturing is the 5th most fatal industry in Kentucky and has consistently ranked in the top 5 since 2014. We are on pace to set a new record high for occupational fatalities in 2019 if the trend continues.

The good news for Kentucky is that 2018 saw a year of continued growth with manufacturing and logistics leading the way. The outlook for 2019 is shaping up the same way.  The Commonwealth’s economy is growing and expanding into various advanced manufacturing sectors. “Kentucky has moved to the forefront of national influence, steadily gaining recognition as America’s center for engineering and manufacturing excellence,” according to Governor Bevin (Lane Report, 2019). De-regulation and the passage of pro-business legislation contribute to attracting new manufacturing opportunities to Kentucky, as well as expansion projects of existing manufacturing facilities. As of June 2019, the number of manufacturing facilities had grown to 2,461 with over 258,00 full-time employees. However, this growth hasn’t come without a cost as we have seen with the increased number of manufacturing fatalities. In response to the unfavorable forecast of work-related fatalities, the Labor Cabinet established a Fatality Prevention Task Force to promote and emphasize workplace safety.

Nonfatal occupational injury and illness rates in Kentucky have also declined in recent years, but Kentucky is still higher than the national rate. This isn’t good for Kentucky workers or business owners. In today’s competitive marketplace, Kentucky businesses need to attract and retain a skilled workforce. Focusing on workplace safety will not only protect workers but can also increase a company’s bottom line.

There are many costs associated with fatal and nonfatal injuries. Direct costs include workers’ comp claims, medical expenses, increased insurance premiums, and legal fees. Indirect costs include lost productivity, time and resources to train replacement employees, conduct accident investigations, and repair damaged equipment/property. Other costs include employee morale, absenteeism, turnover rates, and the negative publicity that can damage a company’s reputation. By creating a positive safety culture, workers are healthier and happier which translates into lower incident rates which means more $$$ in the bank.

SMG offers a wide variety of health and safety consulting services. If you need assistance with OSHA compliance, reducing violations, identifying and controlling hazards, re-thinking and updating existing training programs, IH testing and sampling, or going beyond compliance to build a positive safety culture, we can help.

Jami Arnold is a health and safety consultant at Smith Management Group. Jami can be reached at jamia@smithmanage.com .

August 1, 2019

TSCA No Longer Issuing NODs for CBI Deficiencies

June 19, 2019

Anticipate the Hurdles – Wetland Delineation

March 5, 2019

WOTUS Rule: Permitting Changes Set Up Busy Spring




A permitted manufacturing facility in Kentucky had stopped using equipment and wanted to make operational changes which were not reflected on their air permit. Large old boilers which had not been used for several years were still active on the site’s air permit. Additionally, the facility wanted to increase operating hours for certain affected facilities.
The old boilers were the reason that the site had federally enforceable limits for sulfur dioxide in their permit and were subject to the National Emission Standard for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources. This status resulted in additional requirements, higher monitoring and reporting costs, and higher fees to the regulatory agency. Changes to operations required a reevaluation of the site’s potential emissions.


Smith Management Group evaluated the permit requirements and operational data. SMG calculated the potential to emit without the large boilers and with the expanded hours. SMG’s assisted the facility in updating the correspondence and permit with the regulatory authority to change the facility status to minor source.


SMG helped the source update their air permit to represent current site conditions and allow for expanded operations. The source fully decommissioned the large oil boilers in place, successfully transitioned from a permit with federal limits (FEDOOP/FESOP) to a minor source permit and updated their potential-to-emit calculations to represent new operating parameters. These changes saved the facility money in monitoring, reporting, and fees and also allowed for expanded operations in compliance with air regulations.