ISFA Response to WOEMA Petition | Page 2

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?