9. Safe work practices must continue while alternative non-crystalline silica products are used in fabrication shops. Data are limited regarding the health risks associated with amorphous silica exposure as a result of processing benchtops, panels and slabs, with some studies suggesting that there may be significant lung inflammatory response in animal studies. 18 There may also be an increase in the use of acrylic-based solid surfaces containing aluminum hydroxide, with two case reports of lung fibrosis linked to a similar product. 19 It is also likely that many fabrication shops will continue to fabricate countertops containing crystalline silica( for example, marble, granite, and quartzite). Therefore, it is essential that Cal / OSHA continues to enforce the provisions of 8 CCR § 5204 while the Board takes action to prohibit the fabrication of engineered stone containing more than 1 % crystalline silica.
In summary, silicosis is a devastating, deadly, and thoroughly preventable disease. In light of the scientific evidence and the emergence of silicosis among hundreds of California stone fabrication workers, WOEMA is hereby petitioning the Standards Board to initiate expedited rulemaking to implement revisions to § 5204( Occupational Exposures to Respirable Crystalline Silica) that will prohibit all fabrication and installation tasks on engineered stone that contains more than 1 % crystalline silica. We stand ready to assist the Division and the Standards Board to clarify our request and answer any questions. Please do not hesitate to contact me or our legislative staff expert, Mr. Don Schinske( 415-497-5716), if you have questions or need more information.
Sincerely, _
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. lwCct,0c��, � /4,,), Rosalie Banasiak, MD, F ACOEM President WOEMA
18
Ramkissoon C, Pavan C, Petriglieri JR, Fimiani M, Pisaniello D, Gaskin S, Turci F. Physico-chemical features and membranolytic activity of dust fi · om low or no crystalline silica engineered stone with implications for toxicological assessment. Sci Rep. 2025 Jul 15; 15( 1): 25451; Ramkissoon, Chandnee; Gaskin, Sharyn( 2025). Engineered stone is now banned. How safe are new-generation low and no-silica stone materials? The University of Adelaide. Journal contribution. https:// doi. org / I0.25909 / 29916743. vl
19
Raghu G, Collins BF, Xia D, Schmidt R, Abraham JL. Pulmonaty.f ibrosis associated with aluminum trihydrate( Corian) dust. N Engl J Med. 2014 May 29; 370( 22): 2154-6; Corwin C, Waterhouse H, Abraham JL, Sanyal S, Crawford JA, Caddell M, Hodgson MJ. Interstitial pulmonary disease and aluminum trihydrate exposure: A single case report and detailed workplace analysis. Am J Ind Med. 2024 Mar; 67( 3): 274-286.
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