The following is a press release from the Neighborhood Cleaners Association-International in response to EPA's release of the Cleaner Technologies Substitutes Assessment (CTSA)
The Drycleaning Industry Is Under Attack Again
U.S. EPA's Cleaner Technologies Substitute Assessment (CTSA) Report Is Biased, Inaccurate, and Dangerous to the Industry
BY WILLIAM SEITZ
EXECUTIVE DIRECTORThe long awaited "Cleaners Technologies Substitute Assessment" (CTSA) report was received by NCA-I and was reported In the Federal Register on September 4, 1998.
Despite the fact that the intent of this report was to be 'a resource for the small cleaner who has limited time and resources to collect and analyze the large amount of detailed Information themselves, it consists of many technical reports, charts and graphs that confuse and confound the reader. Much of the information on the carcinogenicity of perc (PCE) is based on animal data, and Is inconsistent with over 50 years of industry experience with the solvent. If not read carefully, it may leave the reader with the mistaken impression that there is a serious and present danger with perc (PCE) in the workplace, apartments above drycleaners, adjoining stores and even to people wearing clothes that have been drycleaned. In many instances the reports are followed by disclaimers of uncertainties regarding scientifically inconclusive or unproven data. Unfortunately, the damage has been done by giving the environmental hard-liners an opportunity to quote the charts and graphs conveniently, leaving out the disclaimers.
We are appalled at US EPA's obviously intended omission of New York Slate's Department of Environmental Conservation's regulation Part 232, which went into effect May 1997 and addresses all of the suggestions EPA offers as solutions to the potential problems.
During 1993 and 1994 "stakeholders" from the New York State Department of Environmental Conservation (DEC), the New York State Department of Health (DOH) and the New York City Department of Environmental Protection (DEP), environmental groups and the drycleaning industry sat down together to craft a statewide regulation to control drycleaning perchloroethylene (perc) emissions. The product of this negotiation was "Part 232," the toughest and most comprehensive regulation In the nation, perhaps the world. Its goal is to ensure that drycleaning operations meet DOH guidelines (also the most stringent in the nation) for air quality in adjoining spaces. That is what it was designed to do and that is what it will do.
What Does Part 232 Do For Mixed Use Residential And Commercial Locations?
As of May 1997, every new drycleaning plant must open and operate with the following Part 232 requirements In place:1. All cleaning equipment enclosed In a vapor barrier (air tight room)
2. State Of the art (4th generation) drycleaning equipment only (maximum available control technology)
3. Spill containment tanks to safeguard against accidental spill.
4. Ventilation
5. Self monitoring with leak detection equipment
6. Independent 3rd party inspections by licensed professionals to ensure compliance
7. Certified operators
8. By September 1998 existing transfer (first generation) machines in residential settings are outlawed
9. By November 15 of this year all existing third-generation (non-venting dry-to-dry) machines) must be In a vapor barrier enclosure
Wetcleaning
The U.S. EPA's continued insistence on wetcleaning as an alternative to drycleaning is specious and counter productive to the positive objective of encouraging more drycleaners to embrace wetcleaning as adjunct to drycleaning. NCA-I has been in the forefront of recommending more wetcleaning. We have been and continue to teach wetcleaning in our courses at the New York School of Drycleaning. We have given seminars, workshops and mini-courses In wetcleaning. We strongly believe that wetcleaning Is good for a quality product, as well as an environmentally desirable option for 40 to 45 percent of the garments we process. EPA's insistence on all or nothing has been a negative factor In gaining a more widespread acceptance of Increased wetcleaning.The Ecomat franchises, one of EPA's pet projects, is In deep financial trouble. Three franchisees are closed or will be closing soon. New openings are literally non-existent. NCA-I's position of offering the public both wet and dry cleaning services has proved to be viable and acceptable in the marketplace while contributing to the objective of reducing perc consumption.
In Conclusion
NCA-I feels betrayed and deceived by the EPA's CTSA Report. We have, shown by our actions, our commitment to a cleaner and a safer environment. The results (a 70% reduction In perc usage) speak for themselves. EPA has rewarded us with a bogus and dangerous report that will give the hard-line environmental activists, who will only settle for the elimination of perc, the tools to further incite and scare the public. I sincerely believe we deserved better.
Home