Before California considers a prohibition that would reshape an entire sector of the construction and remodeling economy, ISFA respectfully requests an opportunity to understand how WOEMA concluded that engineered stone cannot be fabricated safely -- even in shops fully compliant with Cal/OSHA’s existing silica standard. A complete assessment requires:

• Clear separation of product hazard from employer non-compliance
 • Economic impact data on small- and mid-sized fabrication businesses
 • A realistic analysis of workforce consequences
 • Understanding of supply chain and tooling transitions
 • Input from fabricators, manufacturers and worker communities

Additionally, Australia’s policy model is not directly transferable to the U.S. Our regulatory structures, enforcement capacity, market composition and economic environment differ significantly. California must develop solutions based on American conditions -- not assumptions drawn from another country’s framework.

A Ban Is Not the Solution — Enforcement and Licensing Are

“ISFA does not believe a ban is the answer,” stated Laurie Weber, CEO. “The problem is not the material -- the problem is employers ignoring the law and a lack of enforcement resources to ensure compliance. California already prohibits dry cutting. California already requires controls. The issue is compliance, not the material.”

ISFA continues to advocate for -- and is actively developing -- a licensing standard with a verification system that:

• Licenses fabrication shops and installers
 • Verifies required training and compliance before materials are sold
 • Creates a public registry of approved, compliant shops
 • Provides Cal/OSHA and OSHA with stronger, practical enforcement tools

This approach aligns with ISO 45001, OSHA’s General Duty Clause, and evidence-based public health strategies that target unsafe practices without dismantling entire industries.

Recognizing the Responsible Employers

Across California and the U.S., most fabrication businesses have invested heavily in safe operations, including:

• Hundreds of thousands of dollars in engineering controls
 • Professional air monitoring
 • Comprehensive written exposure control plans
 • Regular training and retraining
 • Safety innovations that exceed regulatory requirements

A blanket ban would punish the responsible employers who have done the right thing -- and leave negligent operators as the root problem.

A Ban Would Have Significant Economic Consequences

WOEMA’s petition asserts that a prohibition would carry “no significant economic consequences” for fabrication businesses. ISFA strongly disagrees. The real-world impact would be substantial:

• Hundreds of small businesses may be forced to close
 • Thousands of workers -- many supporting multigenerational families -- could lose their livelihoods
 • Retooling, retraining and restructuring supply chains would impose enormous costs on the fabrication and supply   channels

Does WOEMA have the economic expertise to make definitive claims about the financial impact on fabrication businesses?

“ISFA believes we can protect workers,” Weber said. “Licensing, verified training and stronger enforcement will clean up the industry without wiping out thousands of livelihoods.”

Silicosis is preventable. Safe fabrication is proven and achievable when employers comply with the law and enforcement is adequately supported.

Invitation to Collaborate With WOEMA

ISFA extends an invitation to collaborate with WOEMA membership to expand worker outreach -- particularly to Latino workers who are disproportionately affected by silicosis across construction industries.

ISFA proposes joint efforts to:

• Distribute Spanish-language safety materials and training from ISFA and Cal/OSHA
 • Bring silica safety resources directly into affected communities
 • Support ISFA and Cal/OSHA education through immediate, practical outreach
 • Strengthen trust and communication between medical professionals and fabricators
 • Research and explore new treatments that help stop progression and/or reverse the effects of silicosis
 • Develop a medical surveillance solution that offers valuable data

“WOEMA’s members have access to the workers we are trying to reach. ISFA has access to the employers who need direction and accountability. Working together, we can close gaps – fast -- and give workers and families the protection they deserve.”