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The U.S. House Appropriations Committee is urging EPA to back off its proposed ban of
trichloroethylene (TCE) as a spot remover in drycleaning.
The recommendation came in a report accompanying the appropriations committee’s
Department of Interior bill for fiscal year 2018 that sets out next year’s funding for department
which includes EPA and several other federal agencies.
EPA doesn’t have to comply with the committee’s suggestions but they carry weight because
the lawmakers behind them control the agency’s purse. The House bill, approved by the
committee on July 19, funds the EPA at $7.5 billion, a reduction of $528 million from the fiscal
year 2017 level but still $1.9 billion more than the Trump Administration’s request.
The TCE ban was one of the proposals from EPA late last year to ban some uses of certain
chemicals.
The House committee report said that the ruless may not comply with provisions in section 26
of Toxic Substance Control Act regarding risk management activities.
“Rather than continuing with those rulemakings, the committee encourages EPA to consider
those chemical uses as part of the risk evaluation process for the ten priority compounds recently
designated by EPA under TSCA section, which include the chemicals in question,” the committee
report stated.
The rulemaking grew out of revisions to the Toxic Substance Control Act approved last summer
by the U.S. Congress. That legislation required EPA to publish a list of chemicals to evaluate
potential risks to human health and the environment. In December, EPA published its list of 10
chemicals for review, a list that included TCE and perchloroethylene.
Both perc and TCE were identified as “probable human carcinogens” by EPA at that time.
Publication of the list triggered a statutory deadline for EPA to complete risk evaluations for these
chemicals within three years. If an evaluation determines that a chemical presents an
unreasonable risk to humans and the environment, EPA would need to mitigate that risk within
two years.
So far EPA has published only a “scoping document” for perc and action on that chemical could
take a few years. But soon after publishing the list of ten chemicals, EPA announced that it wants
to ban TCE when used as a degreaser and a spot removal agent in drycleaning. That ban could
go into effect in sixth months if EPA gives its final approval.
Other uses would be considered as part of its full review of TCE and the 10 chemicals. The
majority of TCE is used as an intermediate for manufacturing refrigerants. Much of the remainder
— about 15 percent — is used as a solvent for metals degreasing. Only a small portion is used as
a spot remover in drycleaning.
But in announcing its ban in December, EPA said it identified serious risks to workers and
consumers associated with TCE uses in a 2014 assessment that concluded that the chemical can
cause a range of adverse health effects, including cancer, development and neurotoxicological
effects, and toxicity to the liver.
In comments to EPA on the proposed ban, the Halogenated Solvents Industry Alliance said it
“is based on a very deficient risk assessment completed before TSCA was revised.”
HSIA’s position is similar to that of the House committee.
“The better course would be to assess the risks from spot cleaning and aerosol degreasing as
part of the required upcoming TCE assessment,” HSIA said.
HSIA said that EPA had given no notice that its 2014 assessment would address TCE’s use as
spot cleaner in drycleaning, thus there was no participation by drycleaner representatives and no
peer review of the spot cleaning assessment. Nor was there a Small Business Advocacy Review,
even though spot cleaning is done by drycleaners who are virtually all small businesses.
HSIA also questioned EPA’s claim that the rule would have no significant economic impact on
drycleaners.
In proposing the rule, EPA said drycleaners have available a number substitutes that are
comparably priced.
“In general, substitutes are less toxic than TCE,” EPA said. “Thus, considering similar exposure
potentials for substitutes, the overall risk potential for the substitutes will be less than for TCE.”
That has stirred some debate within the drycleaning industry. In comments to EPA, Jon Meijer
of the Drycleaning and Laundry Institute said that while alternatives are available, they aren’t
necessarily equally effective.
“Alternatives to TCE require more time on the spotting board in an attempt to remove the
same stain from the garment,” Meijer said.
Alan Spielvogel of the National Cleaners Association said the ban could negatively effect a
drycleaner’s bottom line. Alternatives to TCE are not as effective, present risks to the garment
that do not exist with TCE and are more time consuming to use in order to achieve similar
results, he said.
“It should be understood,” he wrote in comments to EPA, “that in most mom-and-pop
drycleaning plants the stain removal technician is the highest paid employee. Assuming only 12
garments a day require five additional minutes of stain removal time, using alternatives to TCE
will add one hour a day to the spotter’s labor.”
“Our position is that between labor and utilities, an increased cost as a percentage of gross
sales of between four and five percent of gross sales can be expected if TCE’s use is prohibited as
a spot cleaner in the industry,” Spielvogel concluded.
On the other hand, industry consultant and National Clothesline columnist Dan Eisen told EPA
that “alternative products are not more expensive than TCE-containing products, they do not
take more time to use, and they are more versatile in some cases, actually reducing the overall
time required for spotting/cleaning.”
California, drycleaners can’t use TCE and have successfully replaced it with environmentally
friendly products.
If EPA goes through with its proposal, the first stage would kick in 180 days after final approval
when TCE could no longer be manufactured, processed or distributed for spot cleaning. Then
there would be an additional 90-day period before all commercial use of TCE for spot cleaning in
drycleaning facilities would be halted, giving cleaners time to use up existing stocks.

House committee urges
EPA to go slow on TCE