Silica-Free Surface Due Diligence Checklist for Architects and Specifiers
If you specify surface materials — countertops, cladding, flooring — for commercial, institutional, or multi-family residential projects, silica compliance is now part of your professional responsibility. Specifying a product that turns out to contain crystalline silica when the project required a silica-free surface exposes you, your firm, and your client to regulatory, legal, and reputational risk. This checklist covers what architects and specifiers need to verify.
Phase 1: During Product Selection
- Define the silica requirement. Is the project in a jurisdiction with a silica ban (Australia) or active regulation (California, some EU member states)? Even if not, does the client’s sustainability or wellness policy require silica-free materials? Write the requirement into the specification.
- Request documentation at the spec stage. Don’t wait until submittals. Request SDS, TDS, and silica content certification during product evaluation. If a manufacturer can’t provide these, cross them off the list.
- Verify “silica-free” claims. Look for “crystalline silica: 0%” or “quartz (SiO2): not present” on the SDS Section 3. Request the XRD report. Verify the lab is ISO 17025 accredited.
- Check for cristobalite and tridymite. Some manufacturing processes convert quartz to cristobalite (more hazardous). Ensure the XRD report tests for all three polymorphs.
Phase 2: During Submittals
- Review submittal documentation. Does the submittal include current SDS, TDS, and silica content certification? If not, reject it. “We’ll provide it later” is not acceptable.
- Verify batch traceability. The documentation should reference the specific product name, colour, and batch that will be supplied. Generic documentation that doesn’t link to the order is not valid.
- Check documentation dates. All documentation should be dated within 12 months of the submittal date.
Phase 3: During Construction
- Verify delivered product matches submittal. Check slab labels against the submittal documentation. If the delivered product name or colour code doesn’t match, stop and investigate.
- Require COA for delivered batch. The supplier should provide a Certificate of Analysis for the specific batch delivered. This is the final verification before installation.
- Document everything in the closeout package. Include all SDS, TDS, COA, and silica content certifications in the project closeout documents. Future building owners, tenants, and renovators may need this information.
Liability Considerations
If a project specifies “silica-free surfaces” and a contractor installs a product containing crystalline silica, liability can flow in multiple directions:
- The contractor for installing a non-compliant product
- The supplier for misrepresenting their product
- The specifier (you) for not verifying documentation
- The owner/developer for not enforcing specification requirements
The best protection is documentation. We’ve seen project disputes resolved entirely by the presence (or absence) of a documented submittal review. If you can show that you requested silica-free documentation, reviewed it, and approved it based on the supplier’s representations, your professional liability exposure is significantly reduced — even if the product later proves non-compliant. If you can’t show any documentation review, you’re exposed.
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