National Clothesline

EPA engaged in a lot of guesswork in developing its proposed new clean-air rules for drycleaners who use perc. Some of the wildest guessing occurred in developing the part of the proposal the has become the most controversial — regulations for co-residential drycleaners. Leaving aside the very good question raised by industry associations concerning EPA’s authority to regulate in this area, the proposal has too many unanswered questions.

To begin with, EPA really has no idea how many cleaners operate in buildings that also have residential units. Actual data on co-residential facilities is available for only four states — California, New York, Rhode Island, Maine and Delaware. In those four states, the count is 1,094 co-residential cleaners. For all other states, EPA just figured that one percent of the cleaners would be co-residential. That’s a curious assumption considering that in those areas where actual numbers are available, the percentage is much higher. We suspect that there are far more co-residential cleaners in the country than EPA’s estimate of just over 1,300.

Even when dealing with data from the known co-residential cleaners, EPA is unsure of its numbers, admitting that its estimate of risk posed by such cleaners is likely limited because it does not know if a small sample of 16 New York City drycleaners is representative of all co-residential cleaners in the country. As EPA itself said in its Federal Register notice, “We base our exposure and risk estimate on snapshot data available…”

“Snapshot data” may be OK for some government work, but it should not be used to develop a regulation that will burden an unknown number of cleaners with new and costly regulations that may or may not be necessary to protect the public health from an unquantified risk.

In Romeo and Juliet, Shakespeare wrote: “A rose by any other name would smell as sweet.” Basically, he was suggesting that a thing is what it is, and not necessarily what it is called. In other words, you can’t judge a book by its cover. Of course, there is truth in that cliché, but that doesn’t stop us from doing precisely that. Regardless of how sound a product is, marketing makes it look inviting and irresistible. It all begins with the “cover” of your business. You, like any other consumer, will make assumptions about a company based on its name, decor and signage. We are all guilty of it, perhaps because sometimes we simply have nothing else on which to base the decision.

Names are important. If you have “discount” in your business name, it will attract the interest of a different type of consumer than, say, “quality” will. Yet, consumers are smart enough to realize that business owners name their own companies, so there is less credence in such titles. However, even the most cynical consumers recognize names which are brought in from an outside source. A book cover might seem impressive, but the celebrity testimonials on the back offer more tangible validation. Many people will buy a book just because somebody they respect or like had good things to say about it.

The same is true of your drycleaning businesses. A few “celebrity testimonials” can make a big impact. Here are a few examples: Award of Excellence; Member of the Better Business Bureau; Voted Best Drycleaner of 2005; Preferred Drycleaner of the (fill-in-the-blank here), etc. A potential customer may have no preconceived notions about your business, but will immediately trust such credentials because they carry extra weight. If a leading drycleaning association recognizes the validity of a particular company, then why shouldn’t the consumer? If a local newspaper voted So-And-So Cleaners as the best in the region, why not trust them? Or, even better, if the cleaner performs work for one of your favorite major league baseball teams or theater companies, then why wouldn’t you want to give them your garments as well?

While it certainly pays to advertise, sometimes the best publicity comes from something you didn’t buy, but earned. If you have received an award or accreditation, if you belong to a group or organization, then, by all means, proudly display it for all to see. Your current customers will be happy to have more justification to put their faith in you and new ones will have a valid reason to trust you. After all, sometimes it’s simply who you know that counts the most.