United States
Environmental Protection
Agency
Pollution Prevention
and Toxics (7406)
EPA 744-F-99-005
May 1999
Design for the Environment
Garment and Textile Care Program Fact Sheet
U.S. EFft
What is Design for
the Environment?
EPA's Design for the Environment
(DfE) Program is a voluntary initia-
tive that forges partnerships with
various stakeholder groups in an
effort to:
Incorporate environmental con-
cerns into the traditional deci-
sion-making parameters of the
business world: 'cost' and 'per-
formance.'
Build incentives for behavior
change to encourage continuous
environmental improvement.
To accomplish these goals, the
program utilizes EPA expertise and
leadership to compare the relative
environmental and human health
risks, performance, and cost
tradeoffs of traditional and newer
technologies. DfE disseminates
information on its work to all
interested parties and also assists
businesses to implement the new
technologies identified through
the program.
The program currently has
cooperative partnerships with:
Industry
Academia
Environmental and Public
Interest Groups
Labor Unions
Research Organizations
Government Purchasing
Agencies
Professional Institutions and
Trade Associations
List of Major Federal
Regulations and
Standards Affecting
Petroleum Cleaners
In general, on a nationwide basis, petroleum drycleaners provide their services primarily to
large industrial, commercial, and institutional customers. Consequently, petroleum drycleaning
establishments tend to be larger operations relative to the drycleaners who cater to a residential
clientele, i.e., the neighborhood cleaners. However, many smaller cleaners are now converting
from perchloroethylene to petroleum processes. Because petroleum drycleaners presently form a
distinct sector (due to size, customer-type, and solvent-type) within the garment and textile care
industry, these operations are subject to special Federal and State regulatory requirements.
This Fact Sheet identifies some of the major Federal environmental, health, and safety require-
ments that apply to petroleum drycleaning operations. The U.S. Environmental Protection Agency
(EPA) administers the Federal environmental protection requirements and the U.S. Occupational
Safety and Health Administration (OSHA) administers the Federal worker health and safety
requirements. The National Institute of Occupational Safety and Health (NIOSH) has established
operational recommendations in the form of guidance documents. NIOSH is a Federal institute
that provides research and technical support to OSHA and other Federal agencies. Other Federal
Agencies may have regulations that apply to petroleum solvent cleaners and they are not covered
in this Fact Sheet.
Compliance with State-Level Requirements. Most States have adopted the Federal
regulations and standards into their State-level regulatory codes and are therefore authorized
to carry out primary implementation and enforcement responsibilities for the Federal EPA
and OSHA requirements. For example, the States responsible for implementing Federal
OSHA requirements are called "State Plan States." Beyond the Federal requirements, many
State environmental control and public health agencies have adopted regulations and
standards that are stricter than the Federal requirements. This document does not address specific
State requirements for petroleum drycleaners. Petroleum drycleaners must be knowledgeable
of, and in compliance with, the regulations and standards of individual States.
Federal Environmental Protection
Regulations and Standards
EPA regulations apply to petroleum drycleaners with respect to: 1) hazardous waste handling and
disposal; 2) ozone and volatile organic compound (VOC) air emissions; and 3) spill prevention
and control. The EPA regulations outlined below, and related guidance documents, can be
accessed on specific EPA web sites as indicated.
DISCLAIMER - This document provides a listing and brief description of only the current
MAJOR federal environmental and -worker safety regulations that affect petroleum dryclean-
ing operations. It is not intended to be an inclusive listing of every U.S. EPA or U.S. OSHA
regulation that may apply to petroleum drycleaning establishments. Further, many States
have developed additional regulatory requirements that may apply to petroleum drycleaning
operations. Federal and State regulatory requirements may change over time. Petroleum
drycleaners must comply -with all currently applicable Federal and State regulations
and standards. To stay abreast of changes in regulations and standards, and to precisely
determine -which requirements apply to your specific operation, you should contact
your regional EPA and OSHA office (listed at the end of this document) and officials of
your state environmental control or public health agency.
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Hazardous Waste Handling and Disposal - Under the Fed-
eral Resource Conservation and Recover}' Act (RCRA). a petroleum
drycleaner must comply with various hazardous waste regulations if
the particular solvent used is "ignitable." A solvent is ignitable if its
flashpoint is lower than 140 degrees Fahrenheit (60 degrees Centi-
grade). If the solvent is ignitable, then the extent of hazardous
waste regulation is dependent upon the amount of hazardous waste
that a drycleaner generates. The EPA hazardous waste regulations
are located in Title 40 of the Code of Federal Regulations (CFR),
Part 260 through Part 279. In general, these regulations govern the fol-
lowing aspects of hazardous waste management: use of the off-site
waste shipment manifest form; packaging and labeling; on-site storage;
recycling and reuse; off-site waste transport requirements; and recy-
cling/disposal facility selection. Materials that commonly qualify as
hazardous petroleum drycleaning wastes include, but are not limited
to: filter casings; still bottoms; separator water; partially empty solvent
containers or drums; and spotting board residues. Regulatory, guidance,
and other information pertaining to hazardous waste management can
be accessed on the EPA web site at: www.epa. gov/epaoswer/osw/
hazwaste.htm.
New Source Performance Standards (NSPS) - Established
pursuant to the Federal Clean Air Act (CAA), the NSPS standards
serve to ensure that new sources of air pollution meet minimum per-
formance requirements pertaining to equipment and work practices.
The NSPS for petroleum dryclcancrs serves to minimize VOC emis-
sions through application of best demonstrated technologies. A petro-
leum drycleaner must comply with new source performance standards
if the operation has a total manufacturer-rated dryer capacity that is
equal to or greater than 84 pounds (38 kilograms) AND the equipment
was installed after December 14, 1982. The EPA new source emission
standards for petroleum drycleaners are located in Title 40 CFR Part
60, Subpart JJJ (40 CFR Sections 60.620 through 60.625). In general,
these standards specify: allowable dryer types; allowable solvent
filters; allowable solvent recovery flow rates; recordkeeping require-
ments; information posting requirements; and performance testing
procedures. Regulator)', guidance, and other information pertaining
to NSPS requirements can be accessed on the following EPA web
sites: www.epa.gov/oar/oaqps and www.epa.gov/ttn/uatw. Also, the
NSPS requirement can be accessed on the EPA web site at:
www.cpa.gov/docs/cpacfr40/chapt-I.info/subch-C/40P0060.
Oil Pollution Prevention Regulation - Pursuant to the Federal
Clean Water Act (CWA) and the Oil Pollution Act (OPA), EPA devel-
oped the Oil Pollution Prevention Regulation. The regulation is located
at Title 40 CFR Part 112 and forms the basis of EPA's Oil Spill Pre-
vention, Control, and Countermeasures (SPCC) Program. The goal of
the SPCC Program is to prevent oil spills from certain aboveground
and underground storage tanks.
A petroleum drycleaner must comply with the Oil Pollution Prevention
Regulation if the facility meets the following criteria:
a) has an aboveground petroleum solvent storage capacity
of more man 660 gallons in a single tank, an aggregate above-
ground storage capacity of more than 1,320 gallons, OR a total
underground storage capacity of 42,000 gallons;
AND;
b) could reasonably be expected to discharge oil product
in harmful quantities into navigable waters of the
United States.
Petroleum drycleaners who meet the above criteria must prepare a
SPCC Plan. The Plan is required to address the facility's design, opera-
tion, and maintenance procedures established to prevent spills from
occurring, as well as countermeasures to control, contain, clean up, and
mitigate the effects of an oil spill that could affect navigable waters.
Regulator}', guidance, and other information pertaining to the Oil Pol-
lution Prevention Regulation and the SPCC Program can be accessed
on the EPA web site at: www. epa. gov/oilspill/opprover.htm.
Further, under the CWA, petroleum solvents with a flashpoint of less
than 140 degrees Farhenheit (60 degrees Centigrade) may be prohib-
ited from discharge into a public sewer system. A petroleum drycleaner
must contact the State environmental control agency for specific
requirements governing discharges into public sewer systems.
Control Techniques Guidelines - Unlike perchloroethylene
(PCE or perc), petroleum solvents are volatile organic compounds
(VOCs). As a result, a Control Techniques Guideline (CTG) was devel-
oped by EPA for States and local pollution control agencies to use for
regulating solvent emissions from various petroleum drycleaning
establishments. The petroleum CTG applies only to petroleum
drycleaning operations that use more than 32,500 gallons (123,000
liters) of solvent per year. Petroleum drycleaners that exceed that
threshold may need to install a petroleum recover}' dryer and adhere to
other requirements for filtration and leaks.
A CTG is not mandatory in all situations, nor does it serve as absolute
minimum or maximum requirement. In determining how closely to
adhere to the EPA CTG guideline, each Slate or local air pollution con-
trol agency evaluates the severity of ozone pollution in a local or
regional area and the amount of control necessary to alleviate the prob-
lem. A petroleum drycleaner must contact the State environmental con-
trol agency or local air pollution control agency to determine exactly
how this requirement applies to his/her operation.
The EPA CTG guidance for petroleum solvent is title Control of
Volatile Organic Compound Emissions front Large Petroleum
Drycleaners (EPA 450/3-82-009). This document can be ordered by
contacting the National Technical Information Service (NTIS) at the
following toll-free number: (800) 553-NTIS.
Underground Storage Tank Regulations Under RCRA. a
petroleum drycleaner that stores solvent in underground storage tanks
(USTs) must comply with Federal and State UST regulations. The
Federal UST regulations are located at Title 40 CFR Part 280 and
require that USTs be protected from corrosion, equipped with devices
that prevent spills and overfills, and periodically monitored for leaks.
Regulatory, guidance, and other information pertaining to UST
requirements can be accessed on the following EPA web site:
http://www.cpa.gov/swcrustl.
Maximum Achievable Control Technology (MACT)
Standard - In the near future, as already exists for perchloroethylene
drycleaners, EPA may establish a MACT standard for petroleum
drycleaners pursuant to authority granted to the EPA under the CAA.
The puipose of a MACT standard is to ensure that state-of-the-art tech-
nologies are used to control listed hazardous air pollutants (HAPs).
This regulation would be more comprehensive and more stringent than
the Subpart JJJ NSPS standard discussed above. Regulatory, guidance,
and other information pertaining to NSPS requirements can be
accessed on the following EPA web sites: www.epa.gov/oar/oaqps and
www.epa.gov/ttn/uatw.
Worker
Pursuant to the Federal Occupational Safety and Health Act, in addi-
tion to the Federal OSHA standards that apply to a broad range of
industry types, petroleum drycleaners must also comply with OSHA
standards that are specific to those industries that use petroleum sol-
vents. These particular OSHA standards address the following aspects
of petroleum drycleaning operations: worker exposure; fire safety; and
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protection against bloodborne pathogens. For some petroleum
drycleaners, OSHA hazard communication standards may also
apply. The OSHA standards outlined below, and related guidance
documents, can be accessed on the OSHA web site at: www.osha-
slc.gov/SLTC/drycleaning. NOTE: For a petroleum dry cleaning
facility located in a State Plan State, there may be additional require-
ments. A list of State Plan States and contacts is located on the OSHA
web site at: www.osha.gov/oshdir/states.
Worker Exposure - Those petroleum drycleaners that use Stod-
dard solvent must comply with the OSHA Permissible Exposure Limit
(PEL) for Stoddard solvent listed under petroleum distillates. The PEL
for Stoddard solvent was established to protect workers from the health
effects resulting from exposure to that substance. The PEL- for Stod-
dard solvent is 500 parts per million (ppm) of contaminated air or
2,000 milligrams per cubic meter (mg/cu-m) of air, as measured by an
eight-hour Time-Weighted Average (TWA). The PEL standard applica-
ble to petroleum drycleaners is located at 29 CFR Section 1910.1000,
Table Z-l.
Fire Safety - Petroleum drycleaners must comply with the OSHA
standards for flammable and combustible liquids located at 29 CFR
Section 1910.106. The OSHA standards for fire protection that may
also apply are located at 29 CFR Part 1910, Subpart L. OSHA's expert
systems, titled Hazard Awareness Advisor and Fire Safety1 Advisor,
provide guidance for determining which OSHA standards apply your
specific establishments). These expert systems can be accessed on the
OSHA web site at: www.osha.gov/oshasoft.
Also, as specified in 29 CFR Section 1910.106, OSHA requires com-
pliance with National Fire Protection Association (NFPA) Standard
No. 32 (Standard for Drycleaning Plants). This guidance document is
available on the NFPA web site at: www.nfpa.org. Further, NIOSH has
developed non-regulatory guidance addressing the control of fire haz-
ards specific to petroleum dry cleaning operations. This guidance docu-
ment is titled Control of Fire Hazards in Commercial Drycleaning
Shops 'Using Petroleum-Based Solvents (Hazard Control Guidance No.
21). This NIOSH guidance document can be accessed on the OSHA
web site at: www.osha-slc.gov/SLTC/drycleaning.
Bloodborne Pathogens - Those petroleum drycleaners that pro-
vide services to health care facilities, police departments, and fire
departments must comply with the OSHA standards for control of
bloodborne pathogens. These standards are located at 29 CFR Section
1910.1030 and set forth requirements for work practice controls, per-
sonal protection equipment, housekeeping procedures and techniques,
and establishing and implementing an Exposure Control Plan.
Hazard Communication - If a petroleum drycleaner-in addition
to being a purchaser and user of petroleum solventis also a distribu-
tor, importer, or manufacturer of petroleum solvent, the drycleaner
must comply with the OSHA standards for hazard communication.
These standards are located at 29 CFR Section 1910.1200 and set forth
requirements For: establishing and implementing a workplace hazard
communication plan; labeling of containers; training employees; and
maintaining Material Safety Data Sheets (MSDSs).
For
EPA EPA officials, located at the Agency's Regional Offices, are
available to answer questions pertaining to drycleaning regulatory
compliance. You may contact the official in your region as listed
below:
Region 1 [Connecticut, Maine, Massachusetts,
New Hampshire, Khode Island, Vermont]
1 Congress Street 1100 (SEA)
Boston, MA 02203-2211
Doug Koopman, Compliance
(617) 918-1747, fax: (617) 918-1809
koopman.douglas@epa.gov
Region 2 [New Jersey, New York, Puerto Mico,
Virgin Islands]
290 Broadway (see floors and mail codes below for each)
New York, NY 10007-1866
Diane Buxbaum, Drycleaning Project/Compliance Assistance
(2DECA-CAPS) 21st Floor
(212) 637-3919, fax: (212) 637-4035
Carl Plossl, Engineer, RCRA Compliance
(2DECA-RCB) 22nd Floor
(212) 637-4137; fax: (212) 637-4949
Venkata Rao, Air Compliance
(2DECA-ACB)21stFloor
(212) 637-4053, fax: (212) 637-3998
Region 3 [Delaware, District of Columbia, Maryland,
Pennsylvania, Virginia, West Virginia]
1650 Arch Street (see mail codes below For each)
Philadelphia, PA 19103-2029
Richard Segrave-Daly, Compliance and Drycleaning
Pollution Prevention Business Assistance Center (3RA20)
(800) 228-8711 or (215) 814-5535
Fax: (215)814-2783
daley.richard@epa.gov
Artra B. Cooper, Enforcement (3AP22)
(215) 814-2096, fax: (215) 814-2114
Region 4 [Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee]
61 Forsyth Street, SW.
Atlanta, GA 30303-3415
Rosalyn Hughes, Compliance
(404) 562-9206, fax: (404) 562-9164
Region 5 [Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin]
77 West Jackson Boulevard
Chicago, IL 60604-3590
John Kelly, Compliance (AR-18J)
(312) 886-4882, fax: (312) 886-5824
kelly.johnj@cpa.gov
Region 6 [Arkansas, Louisiana, New Mexico,
Oklahoma, Texas]
1445 Ross Avenue (6EN-AA)
Dallas, TX 75202-2733
Mary K. Marasak, Compliance and Enforcement
(214) 665-7598, (214) 665-7446
Region 7 [Iowa, Kansas, Missouri, Nebraska]
726 Minnesota Avenue
Kansas City, KS 66101-2798
Alma Moreno-Lahm, Compliance, Drycleaning Sector Team
(ENSV/ARCM)
(913) 551-5232, Fax: (913) 551-5287
Gary Schlicht, Compliance (MACT air rale)
(ARTD/APCO)
(913) 551-7097, fax: (913) 551-7065
E-mail: schlicht.gary@epa.gov
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Region 8 [Colorado, Montana, North Dakota, South Dakota,
Utah, Wyoming]
999 18th Street
Denver Place, Suite 500
Denver, CO 80202-2045
Tami Thomas-Burton, Enforcement/Compliance
(8ENF-T)
(303) 312-6581, fax: (303) 312-6409
Region 9 [Arizona, California, Hawaii, Nevada,
American Samoa, Guam]
75 Hawthorne Street
San Francisco, CA 94105
Angela Baranco, Air Division, Compliance Assistance Program
(AIR-6)
(415) 744-H96, fax: (415) 744-1073
Region 10 [Alaska, Idaho, Oregon, Washington]
1200 Sixth Avenue
Seattle, WA 98101
Dan Meyer, Drycleaning Project
(OAQ-107)
(206) 553-4150, fax: (206) 553-0110
OSHA OSHA officials, located at the Administration's Regional
Offices, are available to answer questions pertaining to compliance
with worker protection and fire safety requirements. You may contact
your regional OSHA office as listed below:
Region 1 [Connecticut, Massachusetts, Maine,
New Hampshire, Rhode Island, Vermont]
JFK Federal Building, Room E340
Boston, MA 02203
(617) 565-9860
Region 2 [New Jersey, New York, Puerto Rico,
Virgin Islands]
201 Varick Street, Room 6701
New York, NY 10014
(212) 337-2378
Region 3 [District of Columbia, Delaware, Maryland,
Pennsylvania, Virginia, West Virginia]
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215)596-1201
Region 4 [Alabama, Florida, Georgia, Kentucky, Mississippi,
North Carolina, South Carolina, Tennessee]
61 Forsyth Steet, SW
Atlanta, GA 30303
(404) 562-2300
Region 5 [Illinois, Indiana, Michigan, Minnesota, Ohio,
Wisconsin]
230 South Dearborn Street, Room 3244
Chicago, IL 60604
(312)353-2220
Region 6 [Arkansas, Louisiana, New Mexico, Oklahoma,
Texas]
525 Griffin Street, Room 602
Dallas, TX
(214)767-4731
Region 7 [Iowa, Kansas, Missouri, Nebraska]
City Center Square
1100 Main Street, Suite 800
Kansas City, MO 64105
(816) 426-5861
Region 8 [Colorado, Montana, North Dakota,
South Dakota, Utah, Wyoming]
1999 Broadway, Suite 1690
Denver, CO 80202-5716
(303) 844-1600
Region 9 [Arizona, California, Guam, Hawaii, Nevada]
71 Stevenson Street, Room 420
San Francisco, CA 94105
(415) 975-4310
Region 10 [Alaska, Idaho, Oregon, Washington]
111 Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 553-5930
How Can I Get More
Information?
Contact EPA's Pollution Prevention Informa-
tion Center to receive an information packet
about EPA's DfE Program, or the Garment and
Textile Care Program (GTCP), or to request
single copies of DfE documents. A revised DfE Publications List
along with these recent GTCP publications are now available:
Cleaner Technologies Substitutes Assessment for
Professional Fabricare Processes
(EPA 744-B-98-001)
Cleaner Technologies Substitutes Assessment for
Professional Fabricare Processes: SUMMARY
(EPA 744-S-98-001)
Cleaner Technologies Substitutes Assessment for
Professional Fabricare Processes: Fact Sheet
(EPA744-F-98-011)
Frequently Asked Questions About Drycleaning
(EPA 744-K-98-002)
Garment and Textile Care Resource Guide
(EPA 744-K-98-005)
Pollution Prevention Information Clearinghous
U.S. Environmental Protection Agency
401 M Street, SW (7409)
Washington, DC 20460
Phone: (202)260-1023
Fax: (202) 260-4659
Email address: ppic@epa.gov
DfE Garment and Textile Care Program Web Site:
http: //www. ep a. gov/dfe/garment/garment. html
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