SMG POV


What’s Up with KYOSH?



Jami Arnold

Are you aware of what’s been going on with the Kentucky Occupational Safety and Health (KYOSH) Program? Here’s an update with some facts to dissuade some of the rumors. The Federal Occupational Safety and Health Administration (OSHA) has received multiple complaints regarding Kentucky’s OSH investigations of workplace fatalities. OSHA reviewed the complaints and completed a […]


Manufacturing Fatalities on Pace to Set Record High



Jami Arnold

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 […]


TSCA No Longer Issuing NODs for CBI Deficiencies



Sarah Carty, ASP

On January 19, 2017, the Environmental Protection Agency (EPA) announced an interpretation of Section 14 of TSCA relating to non-exempt CBI claims. This interpretation requires manufactures who make or process chemicals covered under TSCA to claim confidential business information (CBI) at the time of submittal. Starting August 15, 2019, the EPA will no longer issue […]


Anticipate the Hurdles – Wetland Delineation



Josiah Frey

Whoever said “what you don’t know won’t hurt you” would be pretty awful at project management.  Often our success as a consultant hinges on the ability to anticipate an environmental permitting hurdle early in the process.  Nobody finishes the race unscathed by blindly barreling through every hurdle in the way.  But just knowing where the […]


WOTUS Rule: Permitting Changes Set Up Busy Spring



Josiah Frey

On February 14, 2018, the US Army Corps of Engineers (USACE) and U.S. EPA  published the latest installment in the Waters of the U.S. (WOTUS) groundhog day saga.  Promising regulatory certainty, the rule is notable for how similar it is to the 1986/1988 WOTUS definition.  However, many in the regulated community will note that the […]

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