December 12, 2025
To: Joseph Alioto Chair, Occupational Safety and Health Standards Board
Re:
Petition to Revise 8 CCR § 5204( Occupational Exposures to Respirable Crystalline Silica) to prohibit all fabrication and installation tasks on engineered stone that contains more than 1 % crystalline silica
Dear Mr. Alioto and Board Members:
We are submitting this petition to the California Occupational Safety and Health Standards Board( Board) to initiate expedited rulemaking to implement revisions to § 5204( Occupational Exposures to Respirable Crystalline Silica) that will prohibit all fabrication and installation tasks( cutting, grinding, polishing, etc) on engineered stone that contains more than 1 % crystalline silica. This action is necessary in light of the continuing epidemic of silicosis that is causing disabling disease and death among California fabrication workers as a result of their workplace exposure to silica dust from engineered stone containing crystalline silica.
The Western Occupational and Environmental Medicine Association( WOEMA) is a professional non-profit association representing over 600 occupational medicine physicians and other experts in occupational and environmental health and safety, in seven western states( Arizona, California, Hawaii, Nevada, Utah, Colorado, and New Mexico). In February 2023, WOEMA requested that the Standards Board adopt an Emergency Temporary Standard( ETS) to control the hazards of airborne silica dust in shops that fabricate engineered stone. After the Board approved the Cal / OSHA ETS, the Board adopted permanent updates to § 5204 on December 19, 2024. The permanent standard continued the requirements of the ETS and introduced new protections for workers engaged in high-exposure trigger tasks( cutting, grinding, polishing, clean up, etc.) on engineered stone containing more 0.1 % crystalline silica, or other silica containing products, including natural stone containing more than 10 % crystalline silica. Among other requirements, employers must ensure that workers who perform high-exposure trigger tasks use effective wet methods; do not dry cut or sweep; perform high-exposure trigger tasks within regulated areas; use a full-face, tight-fitting, powered air-purifying respirator( PAPR); and are offered medical testing at no cost to the exposed worker, including a low-dose chest CT scan and a breathing test.