The following is a press release from the International Fabricare Institute in response to EPA's release of the Cleaner Technologies Substitutes Assessment (CTSA)
IFI Issues Advisory On U.S. EPA CTSA Report
Although a just-released U.S. EPA report, "Cleaner Technologies Substitutes Assessment," seeks to perform a comparative analysis of various fabricare industry technologies, the report relies on theoretical "models" that do not accurately characterize the relationship between perchloroethylene (perc) and human health.
The CTSA report, produced by the agency's "Design for the Environment" program, represents an effort to combine, in one report, available information on the cleaning industry's existing and emerging chemicals, processes, and technologies. But the report is not designed to serve as a rigorous risk assessment of the chemicals used In the fabricare industry. Consequently, consumers cannot reliably determine their absolute level of risk associated with any particular cleaning process. Given the generalized nature of the information collected for this report, the data about perc and other chemicals cannot be extrapolated to specific populations or individuals. The report's authors also state that much of the information on the health effects of these chemicals are inconclusive and do not reflect the official position of the U.S. EPA.
IFI has considerable, and justifiable, concerns about how the report's findings will be interpreted. For example, a cursory review of the CTSA might indicate that the authors identify an established link between perc and human cancer. In fact, the risk information provided in the CTSA does not attempt to determine whether perc is likely to be a human carcinogen. Rather, the assessment uses the most conservative (worst case) assumptions to develop maximum theoretical cancer risk estimates for exposure to perc. These estimates are used by EPA to help establish regulatory priorities; they do not mean that perc actually causes human cancer. In developing these types of estimates, EPA states that the cancer risk may, in fact, be zero.
The report also alludes to consumers' concerns about wearing drycleaned clothes. Garments that are properly drycleaned do not pose a threat to human health. Any suggestion to the contrary is based on two flawed, unproven assumptions: (1) that perc is a human carcinogen and (2) that cancer risk is based on the preceding premise.
Another CTSA issue involves perc contamination of businesses and residences near drycleaning plants. Such contamination is quite limited, and generally can be resolved with minimal effort by the drycleaner. The location of cleaners in close proximity to residential apartments in generally unique to New York City. Measurements of high perc concentrations in a few of NYC's apartment buildings are not typical of conditions nationwide and represent isolated instances of poor equipment maintenance. The cleaning industry, in fact, actively participated in the development of regulations by New York State to minimize perc contamination in mixed-use buildings.
The cleaning industry, particularly IFI, has aggressively championed the virtues of reducing perc emissions. In the past seven years, the industry has reduced its overall consumption of perc by 30 percent. IFI has urged its members to properly maintain and, when appropriate, install the most modern drycleaning equipment. Such equipment, currently used by two-thirds of the industry, is approximately five times more efficient. The replacement of the remaining stock of older equipment, expected in the next few years, will achieve significant additional reductions in emissions.
IFI has also been involved in efforts to further reduce atmospheric emissions of perc. These include participation in EPA programs to investigate alternatives to perc and the development of industry certification programs to ensure that drycleaners are properly trained.
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