Comment from American Public Health Association
American Public Health AssociationSupportAdvocacy
Summary: The American Public Health Association, representing public health experts, supports the proposed action of exempting recycled or crushed glass quartz surface products (QSPs) containing less than 1% silica from tariff-rate quotas. They argue that this exemption is necessary to prevent job losses and price increases while addressing a public health emergency of silicosis caused by high-silica engineered stone.
Attached please find comments regarding the Administration’s actions following the U.S. International Trade Commission’s determination of import injury with regard to Quartz Surface Products (QSPs). In this comment, we address very recent regulatory developments that could have significant impacts on the markets for QSPs, directly affecting both jobs and consumer prices. These developments relate to efforts to control control the rapidly growing epidemic of silicosis among workers who fabricate countertops manufactured from QSPs containing more than 1% crystalline silica.
Last week, the California Occupational Safety and Health Standards Board unanimously voted to request the California Division of Occupational Safety and Health (DOSH) to “prepare the required finding of emergency to support expedited rulemaking under California’s emergency regulatory process" that would prohibit the fabrication and installation of artificial stone products containing more than 1% crystalline silica.
In our comment, we explain that failure to carve out QSPs that less than 1% silica from any remedy will result in deleterious impacts on jobs, prices, and consumer choice, as well as on the health of thousands of fabrication workers.