Science Feedback
Show Us the Science
California is weighing whether engineered stone can be fabricated safely at all. That question deserves the best evidence available — from every direction. ISFA is collecting scientific data, studies, and field experience and will submit what we receive, unaltered, along with a summary, to support the Cal/OSHA advisory process.
The Ask
To The Scientific & Safety Community
To physicians, epidemiologists, industrial hygienists, toxicologists, engineers, safety professionals, and researchers:
The Cal/OSHA process is weighing the health effects of engineered stone and whether worker exposures can be controlled. ISFA continues to ask when a dedicated science review will be convened. In the meantime, we are helping gather the evidence in one place so the Cal/OSHA Standards Board and the Division of Occupational Safety and Health can weigh all of it.
We are asking you to share what you know, including evidence that challenges our position.
ISFA’s position is that engineered stone can be fabricated safely when Title 8, Section 5204 is fully followed, and that the cases reported in California reflect failures of compliance and enforcement. That position is the basis of ISFA’s draft regulatory language, now open for public comment, which proposes the Verified Compliance Pathway as an alternative to a ban. If the evidence says otherwise, the Board needs to see it, and so do we. Workers are best served by an honest answer, not a convenient one.
Please submit peer-reviewed studies, exposure monitoring data, engineering-control performance data, de-identified case information and expert opinion through the form below.
Sincerely,
Laurie Weber
Chief Executive Officer
International Surface Fabricators Association
Our Process
How ISFA Handles Submissions
“ISFA is not a scientific body and does not claim to settle the science. Its role is to collect the evidence and deliver it, unaltered, to the Board and the Division.”
What ISFA Asks of Each Submitter
01
An Answer to one or more of the questions identified.
03
A statement of whether the submission is individual opinion or evidence that has gone through the review process recognized in the submitter's field, and the name of that process.
02
The Submitter's view of what the board should consider.
ISFA does not decide which label applies. It records the submitter’s own description and reports that label next to the submission in the neutral summary, so the Board and the Division can weigh it.
Categories of Evidence
The list below is ISFA’s current understanding of the categories of evidence and the process each one normally goes through. It is a working guide, not a ruling on what counts as science.
Peer-Reviewed Research
Studies published in a journal that uses independent peer review, or government reports that have been externally peer reviewed.
Formal Evidence Reviews
Systematic reviews or hazard assessments that follow a published method, such as GRADE, the National Toxicology Program’s OHAT approach, or the IARC Monographs Preamble.
Measured Exposure Data
Air-monitoring results collected by or under the direction of a qualified person, as defined in proposed Section 5204.2(b)(6). The samples must be analyzed by a laboratory accredited to ISO/IEC 17025, such as through the AIHA Laboratory Accreditation Programs, using a recognized method such as NIOSH 7500, NIOSH 7602 or OSHA ID-142. Submitters are asked to state the sampling method, laboratory and dates.
Agency and Consensus Positions
Published positions of government agencies, such as NIOSH, OSHA, Cal/OSHA or CDPH, and of recognized standards or guidance bodies, adopted through those bodies’ own procedures.
Clinical and Case Data
Case series, surveillance data or clinical observations, published or unpublished. Submitters are asked to state whether the data has been reviewed outside their own organization. All case information must be de-identified.
Individual Professional Opinion and Field Experience
The views of physicians, industrial hygienists, engineers, safety professionals, researchers, shop owners and workers, based on their own experience. ISFA values this input and forwards it in full. It is labeled as individual opinion so it is not mistaken for reviewed evidence.
Conflict-of-Interest Disclosure
Each submitter is asked to complete a conflict-of-interest disclosure modeled on the ICMJE form used by medical journals. It covers funding, employment, consulting and financial interests related to engineered stone, natural stone or any other surface material.
How this framework will change
Each submitter is asked to complete a conflict-of-interest disclosure modeled on the ICMJE form used by medical journals. It covers funding, employment, consulting and financial interests related to engineered stone, natural stone or any other surface material.
Disclaimer
ISFA is a trade association representing fabrication shops, and its position on engineered stone is stated above. ISFA is not a scientific, medical or regulatory body. Collecting and forwarding a submission does not mean ISFA endorses, verifies or agrees with it. The neutral summary organizes submissions. It does not evaluate their scientific merit, which is for the Board, the Division and the scientific community to judge. Submissions filed with the Board may become part of the public rulemaking record. Do not submit individually identifiable health information. Nothing on this page is medical, legal or safety advice.
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01
Review the Questions
Review the questions ISFA is asking the scientific and safety community to address.
02
Submit Science Feedback
Share scientific evidence, data, studies, or expert opinion through the submission form.