What We're Asking For
A Verified Path to COmpliance
ISFA has submitted proposed regulatory language for a new Section 5204.2 of Title 8 that would establish fabrication shop licensing and a Verified Compliance Pathway for countertop and surface materials.
The Proposal
What Would Section 5204.2 Do?
The proposed section would create a state fabrication shop license and a Verified Compliance Pathway. A shop’s eligibility to fabricate covered countertop and surface materials would depend on meeting defined requirements and demonstrating compliance through independent third-party auditing. Existing requirements under Section 5204 and other applicable laws would remain in place.
01
Require a Fabrication Shop LIcense
A California fabrication shop would need a state license to fabricate covered countertop and surface materials.
02
Require Independent Compliance Audits
Eligibility would include a passing independent compliance audit conducted by a Recognized Audit Provider within the required audit period.
03
Verify Workplace Safety Requirements
Audits would examine controls including wet methods, engineering controls, exposure monitoring, respiratory protection, medical surveillance, housekeeping and other workplace requirements.
04
Require Ongoing Medical Surveillance
The proposed language includes medical-surveillance requirements for employees who fabricate covered materials.
05
Create Accountability for Failed Audits
Under the proposal, a shop that does not receive a passing audit result would stop fabricating covered material until correction is verified.
06
Apply Across COuntertop & Surface Materials
The proposed definition of “covered material” is based on its use as a countertop or surface product rather than solely on crystalline silica content.
This is draft regulaotry language
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ISFA is accepting public comment on the proposed language from September 29 through November 13, 2026. Comments will be reviewed, and ISFA states that it will revise the proposed text where comments warrant before submitting a comment summary and responses to the Board.