United States
           Environmental Protection
                 Office of Pollution
                 Prevention and Toxics
                 (7406)  ;
June 1998
           Garment and I^He Gare
           An Eye to the Future
         Fiber Production
                                 Textile Production
                            Garment Design
                            and Manufacture
                   , Distributio'n & Sales
                                         Garment Cleaning


                                           EPA 744-R-98-006
                                             June 1998
Garment and Textile Care Program:
         An Eye to the Future
    1998  Conference Proceedings
            U.S Environmental Protection Agency
           Office of Pollution Prevention and Toxics
       Economics, Exposure and Technology Division (7406)
                 401 M Street, SW
               Washington, DC 20460

This document has been reviewed by the U.S. Environmental Protection Agency (USEPA) and approved
for publication.  It is based on the experiences and opinions of EPA's Design for the Environment partners
from industry, public interest groups, and research/educational institutions.

The information in this document reflects the opinions of the individual conference speakers.  Mention of
trade names, products, or services by those speakers who  are not USEPA officials does not convey, and
should not be interpreted as conveying official USEPA approval, endorsement, or recommendation.

Further, any information  on product usage, performance, cost, and sales  provided by those individual
conference speakers, who are not USEPA officials, was not independently corroborated by USEPA.

       This publication was produced by the Garment and Textile Care Program staff of the U.S.
Environmental Protection Agency (EPA). The overall Program Manager is Cindy Stroup.

       We appreciate the efforts of all of the contributing conference speakers. We especially want to
thank the members of the Conference Planning Committee: David DeRosa, Sylvia Ewing, Bill Fisher,
Bill Seitz, Anthony Star, Mary Ellen Weber, and Manfred Wentz.

       A special thanks is extended to EPA interns, Ian Perm and Denise Dickenson for their invaluable
assistance during the conference, as well as the staff of Westat, Inc., and Tascon, Inc.

       This document was prepared under EPA Contract number 68-D7-0025 by Westat, Inc., of
Rockville, MD, under the direction of Karen Delia Torre and Kurt Patrizi.  The EPA Work Assignment
Manager is Cindy Stroup.

 To obtain a copy of this or other EPA/Design for the Environment Program (DfE) publications, contact:

                   EPA's Pollution Prevention Information Clearinghouse (PPIC)
                                   401M Street SW (3404)
                                    Washington, DC 20460
                                     fax: 202-260-4659

          To leam more about The Garment and Textile Care Program, visit our website at:

           Any questions or comments regarding this document should be addressed to:

                                        Cindy Stroup
                      Economics, Exposure and Technology Division (7406)
                                      U.S. EPA/OPPT
                                      401M Street SW
                                    Washington, DC 20460

       The DfE Garment and Textile Care Program (GTCP) was initiated after a 1992 international
roundtable on drycleaning in which industry leaders and EPA agreed that health and environmental issues
surrounding the drycleaning industry could be addressed effectively through DfE's voluntary, proactive
approach. The project partnership was established to encourage the development and incorporation of
environmentally-preferable cleaning methods which professional cleaners can offer  to their customers,
while maintaining or increasing economic viability. Initial efforts focused on the development and
evaluation of new cleaning methods, the development of technical and training materials, and the
publication of information. In 1996, at the DfE Apparel Care Conference, it was recognized that
decisions made in related industries affect the cleanability of garments, and ultimately the decisions made
by drycleaners.

       Representatives of industries such as garment and textile designers, manufacturers, fiber
producers, drycleaners, and retailers along with the U.S. Environmental Protection Agency, gathered in
Washington, D.C. on March 31-April 2,1998, for "Garment and Textile Program: An Eye to the Future."
Participants shared a common goal: To explore how decisions made by other industries affect the
incorporation of environmentally-preferable methods into professional cleaning operations.  The
conference was the first step in the evolvement of the GTCP to incorporate a life cycle approach to
identify upstream industrial issues that impact garment care.

                              Table of Contents
           Mary Ellen Weber, Ph.D., Director, Economics, Exposure and
                 Technology Division, U.S. EPA Office of Pollution
                 Prevention and Toxics	    4

           Manfred Wentz, Ph.D. American Association of Textile Chemists
                 andColorists	;	    10

           Judith Schreiber, Ph.D., New York State Department of Health	    15

           Norma Keyes, American Association of Textile Chemists and Colorists	    20

           David DeRosa, Greenpeace	    24

           Joseph J. Breen, Ph.D., Green Chemistry Institute	    29

           Buster Bell, Bell Laundry and Cleaners	    33

          Ed Boorstein, Prestige Cleaners	    35

          Debra Davis, Cleaner by Nature	    39

          Ken Adamson, Canadian Fabricare Association	   42

          Max Oh, Federation of Korean Drycleaners Association of
                Greater Washington	    47

          Vic Vandermolen, Canadian Fabricare Association	,	    49

          Dave Wintz, Indiana Department of Environmental Management	    55

          Joseph J. Nilsen, U.S. Department of Defense	    60

          Sylvia Ewing-Hoover, Center for Neighborhood Technology	    63

          Robert Gottlieb, Ph.D., Occidental College/UCLA	    66

          Braden R. Allenby, Ph.D., Vice President for Environment,
                Health and Safety, AT&T	    73

          Jack Belluscio, President, Global Technologies	    80

          Perry Grady, Ph.D., College of Textiles, North Carolina State University	    84
          Charles L. Riggs, Ph.D., Texas Woman's University	    86
          Gary Mock, Ph.D., North Carolina State University, College of Textiles	    90

          Stephen P. Bates, Ph.D., Rynex Holdings, Ltd	    93

          Craig M.V. Taylor, Ph.D., Los Alamos National Laboratory	    97

          Jim McClain, Ph.D., MiCELL Technologies	    101

          Connie Vecellio, Federal Trade Commission	    105

          Jackie Stephens, International Fabricare Institute	    110

          Kay M. Villa, American Textile Manufacturer Association	    112

          Nancy L. Cassill, Ph.D., UNC School of Human Environmental Studies	    116

         Barbara Warren, Chair	
         Sylvia Ewing-Hoover, Chair	
         Kay Villa, Chair	
         Manfred Wentz, Chair	
         Bill Seitz, Chair	







               Garment and Textile Care:  An Eye to the Future...
                                    Opening Remarks

                                    Mary Ellen Weber, Ph.D.
                      Director, Economics, Exposure and Technology Division
                        U.S. EPA Office of Pollution Prevention and Toxics

       Dr. Mary Ellen Weber is the Director of the  Economics, Exposure and Technology
       Division (EETD) in the Office of Pollution Prevention and Toxics (OPPT).  EETD is
       responsible for all economic, industrial chemistry, chemical engineering, environmental
       fate and transport, and consumer and occupational exposure analyses for OPPT.  In
       addition, she is co-founder of the EPA Design for the Environment Program and the EPA
       Green Chemistry Program, both housed in EETD.
       The Economics, Exposure and Technology Division of EPA's Office of Pollution Prevention and
Toxics is the home for EPA's Design for the Environment Program, called DfE. The DfE Garment and
Textile Care Program is sponsoring this conference in order to look beyond drycleaning and to involve
upstream industries on relevant environmental issues. But first, here is some background on the overall
DfE Program itself.

       The Design for the Environment Program is a voluntary program based on partnerships with
individual industrial sectors, usually sectors predominated by small businesses. The program was created
in 1991 to promote the conscious incorporation of relevant environmental issues into business decisions,
thereby increasing opportunities for pollution prevention and reducing risk.  The DfE Program works
through voluntary partnerships comprised of a variety of stakeholders from industry, professional
associations, state and local governments, other federal agencies, the public, environmental organizations,
labor unions, and community groups. DfE partnerships develop and share information, and create
incentives for environmentally preferable behaviors and practices.  Through DfE, the Agency works with
stakeholders to find safer ways to do business.

       EPA realizes businesses use certain chemicals because those chemicals perform a desired service,
not because they are toxic. If a business can be profitable and maintain their market share while using
safer chemicals, or by using smaller quantities of toxic chemicals, that is the preferable alternative. The
"bottom line" of the DfE Program is to work in a team with project partners to identify and implement
environmentally-preferable alternatives that can be successfully incorporated into the particular industry.

       The DfE Program has three overall goals:

       •     To encourage voluntary reduction of the use of specific hazardous chemicals by
             businesses, governments, and other organizations through actual design or redesign of
             products, processes, and technical and management systems.

       •     To change the way businesses, governments and other organizations view and manage for
             environmental protection by demonstrating the benefits of incorporating environmental

               considerations into the up-front design and redesign of products, processes, and technical
               and management systems.

               To develop effective voluntary partnerships with businesses, labor organizations,
               government agencies, and environmental/community groups in order to implement DfE
               projects and other pollution prevention activities.
         EPA has undertaken a wide variety of DfE partnership projects to date.  Examples include
 fabricate; auto refinishing; printed wiring board and circuit board manufacturing; flat panel display screen
 manufacturing; and several printing industry sectors.  Small businesses such as these typically do not
 possess the capital to conduct their own independent technology and process evaluations. In addition, it is
 difficult for small businesses to absorb the financial risks associated with investing in new technologies
 that are not yet fully proven. Often small businesses are unaware they are using chemicals that pose
 human health and environmental concerns. Accordingly, the DfE Program, through its industrial
 partnerships, develops and disseminates information that businesses find useful for adopting pollution
 prevention measures while maintaining profitability and financial viability.

         Each DfE partnership project is custom-designed for a specific industrial sector, or for a subset
 within the industrial sector; for example, flexographers as a subset of the printing industry.  Due to the
 nature of information development and dissemination, and the incorporation of industry-wide pollution
 prevention measures, DfE partnership projects are long-term initiatives. The first step in a DfE project is
 to identify project partners and other interested parties. The second step is to form a core team with the
 mission of identifying project goals, ascertaining the scope of the project, and  determining an approach
 and activities necessary to attain the goals. In these first two steps, the team does not attempt to address
 all relevant issues and solve all problems. Rather, the focus is  on resolving the problems with the most
 likelihood of having a feasible and successful solution.

        Project workgroups are then created to address in detail the partnership's activities. Generally
 speaking, these workgroup activities encompass  five primary elements:  1) the "Cleaner Technologies
 Substitutes Assessment;" 2) training development and delivery; 3) development of incentives; 4) public
 outreach; and 5) evaluation of the partnership project.

        Central to each DfE partnership project is the development of a technical document called the
 "Cleaner Technologies Substitutes Assessment" or "CTSA." This document is an important  compendium
 and analysis of technical information pertaining to pollution prevention opportunities in each particular
 industrial sector. The various pollution prevention options for that industry are examined in terms of their
 relative merits, risks, and impacts with respect to protection of the environment and human health. To be
 more specific, the CTSA addresses both existing and new technologies and discusses the cost,
performance, and relative human health and environmental concerns associated with each technology or
process option. Technology options are examined on a comparative basis only. These comparative or
relative assessments are intended to inform the owners and operators  of small businesses. The purpose is
to provide small business decision makers with the information needed to take environmental issues into
consideration, along with traditional parameters of cost and performance, when choosing among different
technology, product design, and production process options.

       In the production of the CTSA, what the DfE Program specifically brings to the partnership is
EPA's unique set of tools for risk analysis and risk management decision-making. EPA possesses a range
of professional skills and technical expertise in critical areas, and over the years has developed methods to

 compile, assess, and present information on relative chemical risks. For example, EPA can assist in
 designing models to predict chemical transport and fate, perform relative risk assessments, or conduct
 economic and financial analyses of the impacts of technology, process, and management options. It is
 critical to point out that in conducting these analyses for a DfE project, EPA relies heavily on the industry
 partners for industry-specific knowledge.

        In addition to the development and dissemination of CTSA documents, DfE partnership projects
 involve activities designed to directly assist small businesses with implementing environmentally-friendly
 and economically-viable alternatives. For example, the projects involve both demonstration initiatives
 and the design, development, and delivery of training programs. EPA has sponsored such opportunities
 within many industrial sectors. Examples in the garment care area include the development of an
 excellent curriculum on wetcleaning, the many wetcleaning seminars held for drycleaners and other
 interested parties, and the work of the Small Business Development Centers to offer services to
 drycleaners considering incorporating new cleaning processes into their businesses.

        Through each DfE partnership project, EPA collaborates with the partners in developing
 incentives for change. These incentive programs are voluntary and industry-run. They are non-regulatory
 and are not implemented nor enforced by EPA. An example of an EPA-sponsored, voluntary incentive
 program is the 33/50 Program. Under this program, industry participants voluntarily determine how to
 reduce emissions of particular toxins by 33 percent within a certain time frame, and  ultimately by 50
 percent by an established deadline. Under the DfE Program, EPA has discussed with the garment care
 industry the development of various incentive programs such as a certification for meeting a standard of
 environmental-friendliness. Perhaps most importantly, however, EPA works with the industry partners to
 identify incentives that may exist in the form of business cost-savings and enhanced customer

        DfE partnership projects involve the development and dissemination of public outreach materials.
 For various business owners and operators who are not trained in the technical subject area, a CTSA
 document may seem technically complex and inaccessible. Therefore, to ensure that the information is
 most useful, the DfE projects typically create a range of related fact sheets, brochures, videos, and case
 studies oriented to the lay person. Further, the Agency attends trade shows, professional conferences, and
 other industry-specific meetings to distribute pertinent materials and discuss pollution prevention
 opportunities within the industry. As appropriate, DfE outreach materials are provided in more than one
 language.  For example, most materials developed for the garment care industry are provided in both
 Korean and  Spanish.

       EPA is committed to the evaluation of each DfE partnership project. The Agency must know
 whether its efforts have provided benefits to the particular industrial sector, and also the degree to which
 those efforts have resulted in the prevention of pollution within that sector.  In order to evaluate success, it
 is necessary to track industry trends and customer awareness and behavior. From both a finance
 standpoint and a pollution prevention standpoint, it is critical that EPA knows whether any new or
 different technology investments, or any other new ways of conducting business, have proven to be
 effective and are acceptable to the particular industry.

       In addition to partnering with a wide range of industrial sectors, the DfE Program has established
partnership projects with various non-industry sectors of our economy. A primary example is the banking
and finance industry. Financial considerations have long-served as barriers to the adoption of pollution
prevention practices. Banks readily finance the purchase of pollution control  equipment that is required

 by a technology-based regulation. In contrast, banks are hesitant to provide financing for pollution
 prevention measures that are not mandated by regulatory agencies (that is, voluntary measures). For this
 reason, EPA has been examining approaches for reducing these barriers. It is important that EPA and the
 DfE Program partners work together to educate the banking community, and prove to banking officials
 that businesses can significantly reduce their overall financial liability, and also increase profitability,
 through adopting production technologies, service technologies, and business operations that prevent
 incurring waste disposal costs, environmental cleanup costs, and employee health and safety problems.
 Banking officials should understand that it is in their own best interest to support businesses mat are
 pursuing pollution prevention opportunities.

        The professional and academic communities also play an important role in DfE partnership
 projects; in the form of both research and education. Regarding research, EPA developed the Green
 Chemistry Program to provide grants for both pure and applied research in the areas of alternative
 synthetic pathways, chemical catalysts, and other chemical considerations. The results of such research--
 when applied—can result in new technologies or industrial process modifications that lessen or eliminate
 the generation of targeted waste and byproduct streams. Creation of the  Green Chemistry Program
 reflects EPA's recognition that the identification of pollution prevention opportunities often requires
 research at the level of the molecule and microorganism. It also reflects  the Agency's understanding that it
 is not always only the chemical used by an industry that causes environmental harm, but also that
 environmental problems often stem from the overall chemical manufacturing process. In this vein, the
 DfE Program is attempting to stimulate exciting, new innovations in pollution prevention and industrial
 ecology. In fact, one such innovation in the garment care industry recently received the Presidential Green
 Chemistry Challenge Award. In all DfE partnership projects, the Agency emphasizes the application of
 sound science to inform industry decisions, to develop new or modified technologies and methods, and to
 make the best use of the nation's tax dollars.

        Another area of DfE-sponsored research is the Department of Defense Green Submarine Project.
 EPA is collaborating with DoD on the Green Submarine project because the results will have very broad
 above-water applications. Products that people need for life in a submarine are identical to products that
 people need for life in their homes and communities. A submarine functions in a manner similar to a city,
 except that waste and byproduct recycling and reuse, and pollution prevention, are imperative. Within the
 enclosed space of a submarine, the use of safer product alternatives such as glues and adhesives is critical.
 EPA and DoD believe that working together it is possible to develop safer products and process systems
 that will, in the future, have applications for civilian life.

        In the area of education, the DfE Program recently created the educational initiative called the
 Partnership for Environmental Technology Education, or PETE. Nationwide, hundreds of community
 colleges in part serve as the vocational training source for much of our industrial workforce. Through
 PETE, DfE is working with community colleges to design pollution prevention curricula. In addition, the
 DfE Program worked with the General Services Administration to encourage the development of "green"
 cleaning products. The Federal government is a large purchaser of commercial products. As a result,
 government's product demands and purchasing patterns can often stimulate changes in within private
 sector markets.

       With regard to professional garment care, EPA has long-standing concerns pertaining to the use
of perchloroethylene, or perc. For this reason, the professional  garment care industry was chosen to be the
first DfE partnership project, termed the Drycleaning Project. For many the initial gathering was at the
landmark roundtable meeting in 1992. The purpose of that meeting was to explore  approaches for

working together in creating pollution prevention opportunities. The goal was to identify clothes cleaning
methods that would result in reduced exposure to perc. EPA did not want to ban the use of perc, rather the
Agency wanted to identify means for reducing the human and environmental exposure resulting from use
of the chemical. In the years since, the partnership has focused on sharing information and on developing
the technical information that has formed the basis of the fabricare CTSA. EPA also has supported the
development of improved perc garment care technologies, as well as entirely new technologies, such as
the computerized and machine-based aqueous process termed "wetcleaning."

       The DfE Drycleaning Project produced many accomplishments of which EPA is very proud.
Drycleaning business owners, garment care experts, environmentalists, labor and community
representatives, and EPA gathered for the first time to speak openly about pollution prevention
opportunities.  The Professional Wetcleaning Partnership was a product of these interactions with the
mutual goal to work for the improvement and promotion of wetcleaning.

       During the Fall of 1996, EPA convened an international conference to discuss progress made in
the Drycleaning Project and future directions. Stakeholders agreed that while changes within the
drycleaning industry were necessary to accomplish pollution prevention goals, they were not sufficient by
themselves to meet longer term objectives.  It was recognized that fibers, textiles, and garment
construction must be compatible with new garment care technologies, and therefore, it was agreed that it
is necessary to address changes throughout the entire industrial chain ending in garment care. This chain
extends from fiber development, to textile development, to garment design and construction, to garment
retailing, and finally to garment care. In other words, in order to achieve a greater level of environmental
protection, it is necessary to address the upstream decisions that affect the ultimate  cleanability of
garments in "cleaner" technologies. Ultimately, for the extended garment care industry to be successful in
attaining pollution prevention goals, garments must be compatible with new garment care technologies.

       These ideas were formalized into an "industrial ecology" approach for garment care, and the DfE
Drycleaning Project evolved over the following year into the current DfE Garment  and Textile Care
Program, or the GTCP.  The expanded GTCP calls for the broadening of the stakeholder base by
including partners who are experts in textile design and manufacture, in garment design and construction,
in retail merchandising, and in any other area that influences the successful care of  a finished garment.
The purpose of this conference is to aid participants in moving beyond the narrow focus of garment care
processes, and to address problems, issues, and ramifications throughout the entire pipeline.

       The mission of the DfE Garment and Textile Care Program is to reinvent the garment and textile
care industry for the 21st Century by: reducing exposure to perc; introducing environmentally-benign
practices throughout the pipeline of commerce; and promoting the design, production, and sale of textiles
and garments that are amenable to environmentally-preferable garment care technologies and practices.
The goal is to create an industry that is more cost effective, more energy efficient, and more
environmentally-friendly, while addressing pollution prevention across all industries within the industrial
pipeline.  Further, it is necessary to address international considerations. A significant portion of the raw
material and product markets for some industry partners is not domestic, but lies overseas. For example,
many garments sold by U.S. retailers are constructed overseas. Also, many textiles used by U.S..garment
manufacturers are produced overseas. EPA is hopeful that its pollution prevention  accomplishments will
increase the domestic market share and that those accomplishments can be exported to other countries, as

        A number of key stakeholders are participating in this conference. The Federal Trade
 Commission, or FTC, will explain their newly proposed garment care labeling rule. Of course, the
 garment care professionals, clothing retailers, and textile and garment designers and manufacturers are
 here as active participants. In addition, consumers, consumer groups, environmental groups, and labor
 organizations have actively collaborated in the earlier stages of the Garment and Textile Care Program,
 and are also represented at this conference. For example, labor unions such as UNITE, environmental
 groups such as Greenpeace, standards organizations such as the American Association of Textile
 Chemists and Colorists, and educational research institutions have all actively participated in the
 Program. In addition to the FTC, other governmental agencies are participating in this conference,
 including: the Occupational Safety and Health Association; the National Institute of Occupational Safety
 and Health; and the Department of Defense.  EPA is delighted to see and welcomes all conference

        In preparation for the conference, four key workgroups were established and met in mid-January
 of 1998. The four workgroups are: Drycleaning; Textiles; Science and Technology; and Outreach and
 Education. The workgroup meetings involved approximately 140 participants from a variety of relevant
 industries, and marked the inception of a dialogue for change within the garment care industry. During
 these meetings, the participants discussed their vision of the future, goals and objectives, and potential
 approaches for accomplishing their goals. EPA encourages you to continue that dialogue during this
 conference. Presentations and discussions will focus on broad program objectives, the evaluation of new
 and emerging technologies, educating industries throughout the garment care chain, and how best to
 engage upstream industries in the ongoing dialogue. It is hoped that this conference will further the
 discussion of change, including the development of meaningful incentives for change.

        The first order of business is to agree on a common goal. Due to the limited time available, it is
 necessary to concentrate on those issues that can be resolved or on which progress can be made.
 Everyone will agree that all of the conference participants' time and resources are limited, and should be
 spent wisely. The intent of the DfE Program  is to generate environmental and human health benefits
 through the hard work of its voluntary partnerships. Keep in mind that all participants are equal
 stakeholders, and should to speak into the process of developing alternative  approaches, and endorsing,
 changing, or rejecting those approaches that are not viable or constructive. It will be necessary for the
 partnership to periodically evaluate their progress and perhaps make mid-course corrections. In addition,
 the Agency invites, and in fact depends on, all partners and conference participants to provide
 constructive feedback on how EPA can be of the most assistance.

       In closing, EPA has high hopes that the discussions and interactions at this conference will
 facilitate raising the pollution prevention goals even higher for the garment and textile care industries.
 Indeed, the focus of all DfE partnership projects is to work with businesses in order to assist them with
the voluntary incorporation of environmentally sound technologies and practices. The DfE GTCP intends
to convene future meetings to  continue the stakeholder dialogue.  These meetings will be scheduled in
conjunction with other industry events, to the  extent possible, in order to ensure the greatest attendance by
the program's partners.  DfE will  continue to look forward to ideas about how the garment care, textile,
garment design and manufacture, and  retailing industries can contribute to a cleaner environment while
operating profitable and competitive businesses.

                  US. EPA
Design for the Environment Program

"Partnerships for a Cleaner Future"

            Mary Ellen Weber, Ph.D.
   Economics, Exposure and Technology Division

                Cindy Stroup
              Program Manager
    EPA DE Garment and Textile Care Program

   Economics, Exposure and Technology Division
      Office of Pollution Prevention and Toxics
       U.S. Environmental Protection Agency
               Washington, DC

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                           Textile Care Industry in Transition

                                      Manfred Wentz,Ph.D.
                  American Association of Textile Chemists and Colorists (AATCC)
                          P.O. Box 12215, Research Park, NC 27709-2215

        Dr. Wentz is an internationally recognized industry  leader who is  active in several
        national and international professional organizations. He chairs the research committee
        RA 43 on drycleaning of the American Association of Textile Chemists and Colorists
        (AATCC) and is a member of the technical committee on drycleaning of the  National
        Fire Protection Association (NFPA). He participates as stakeholder in EPA's Design for
        the Environment  (DfE), Garment and Textile  Care Program  (GTCP). Dr. Wentz is
        currently the President of the International Drycleaners Congress (IDC). He is the USA
        delegate and expert on drycleaning and industrial laundering to the International Standard
        Organization (ISO). He is actively involved in the development of objective test  methods
        for textile care labeling at the national and international level.

        During the last decade, many drycleaners have installed pollution control equipment and
 measures that significantly lower the emission of perchloroethylene (PCE) into the environment. Because
 of the environmental and health concerns about PCE, which is used by about 85% of drycleaners to clean
 clothes today, a substantial number of cleaners are open-minded about more environmentally acceptable

        In my presentation, I will review some of the major developments that brought us here today. I
 will also suggest some actions that we must consider as we embark on implementing changes in the
 textile care industry. Initiatives taken this decade by EPA and the textile care industry will be discussed.
 Proven and emerging textile cleaning technologies will be reviewed. The need for objective performance
 and life cycle assessment for all cleaning technologies will be outlined. Some of my comments on
 alternative technologies will be brief since other speakers will address them in more detail. Finally, I will
 emphasize that the textile care industry must become an integral part of the textile and apparel chain. The
 visuals I used in my talk are attached. They contain additional information which complement this text.


       In the spring of 1992, EPA's Office of Pollution Prevention and Toxics (OPPT) invited experts
 from industry, government, academia, consumer and environmental organizations to Falls Church, VA for
 an international roundtable on pollution prevention and control in the drycleaning industry. Objective and
 subjective information and opinions about drycleaning with PCE were presented and opportunities for
pollution control and prevention measures were discussed. At the same meeting, EPA officials outlined a
new voluntary Program, Design for Environment (DfE), which could be used to address the
 environmental concerns about the drycleaning industry. Shortly thereafter, EPA's DfE drycleaning
program was initiated. It laid the foundation for several meetings of stakeholders from the industry,
environmental groups, academia and government to air their views about the future of the drycleaning

        In September 1996, EPA held the first major conference on drycleaning in Washington, DC. It
 brought together stakeholders and members of the textile, apparel and cleaning industries. The theme of
 the conference was "Apparel Care and the Environment - Alternative Technologies and Labeling." EPA
 and several professional organizations sponsored that event, including the American Apparel
 Manufacturing Association (AAMA), the American Association of Textile Chemists and Colorists
 (AATCC), the American Textile Manufacturing Institute (ATM!) and the American Association for
 Testing and Materials (ASTM). EPA published the proceedings of this conference (EPA74444-R-96-002,
 September 1996). Many conference participants felt that because care labeling laws exist, the introduction
 of alternative textile care methods require close coordination with the apparel and textile industries. This
 was acknowledged by EPA and has resulted in the expansion of the drycleaning program to the Garment
 and Textile and Textile Care Program (GTCP) to include stakeholders from the textile and apparel

        Responding to the renewed focus on drycleaning by Environment Canada and EPA, the
Canadian Fabricare Association (CFA) organized the First North American Environmental Summit in
Hamilton, Ontario in December 1993. It was an open forum on all aspects of textile care. The generic
definition of textile cleaning was discussed and cleaners learned from recognized experts about the status
of alternative cleaning technologies. It was also an opportunity for the EPA stakeholders to interact with
industry leaders from Canada as well as the United States. After a series of open meetings of government
officials and industry leaders, the Canadian industry made the commitment to implement a pollution
control program which would reduce PCE consumption in drycleaning by 65% within a set time.

        The American drycleaning industry organized  the conference "VISION 2000" in Oak Brook, IL
in July 1994. The scope of this national environmental summit was very comprehensive. Speakers from
industry, government, academia and environmental groups shared their views about today's drycleaning
industry. The meeting focused on environmental liability issues, comprehensive pollution prevention
programs for PCE cleaners and pollution prevention options with alternative cleaning technologies.
National and regional trade associations implemented some of the ideas presented at the conference and
developed programs for their members about environmentally friendlier drycleaning practices and
alternative technologies. Trade associations continue to generated objective information for their
members which allows them to make environmentally sound decisions in their plant operations.

       All cleaning processes must clean effectively and maintain or restore the desirable and functional
attributes of textiles. The non-polar and polar properties of the soils and textiles dictate the parameters of
any cleaning process. If professional cleaners have access to non-polar (non-aqueous) as well as polar
(aqueous) cleaning media, they have the tools to satisfy their customer's needs for clean clothes with little
risk of garment damage. The concept of the textile care spectra considers technology options, cleaning
mechanisms, textile property issues, and preferred methods for garments cleaning and the garment
damage potential. More details about these fundamental issues are discussed in the distributed handout
(Reprint from American Drycleaner, November 1996).


        PCE and petroleum have a long history as commercially viable non-aqueous media in the
professional textile cleaning industry. The same holds true for conventional wet cleaning.

        Although PCE cleaners have gotten unparalleled environmental scrutiny for using this solvent,
the record shows that the demand for PCE has been declining by 67 % since 1985. This significant
reduction was accomplished by installing effective pollution prevention measures in drycleaning plants.
Both industry and government agencies can take credit for this accomplishment. The mandatory
NESHAP drycleaning regulations as well as EPA's voluntary DfE program and the commitment of
drycleaners to better plant management were the primary drivers for this positive change.

        Conventional petroleum cleaning is also a well-understood textile cleaning technology. Just like
with PCE, there are concerns about its environmental impact. In addition, the fire hazard associated with
the handling of petroleum solvents is of concern. In fact, the potential fire hazard of petroleum solvents
was the reason for the industry's move away from it to the non-flammable PCE some 30 to 40 years ago.
The emerging new hydrocarbon cleaning technology uses refined solvents and sophisticated control
technologies that virtually eliminate the fire hazard of hydrocarbon solvents. I have summarized the most
important changes in the attached slides, and speakers will give additional information today.

        Drycleaners did a lot of conventional wet cleaning with water and detergents before the evolution
of the charged system in non-polar solvents. The proper use of detergents and water in the non-polar
solvent remove polar, water-soluble soils and stains very effectively and minimize the need for manual
wet cleaning. The new professional wet cleaning technology has been studied extensively with support
from EPA's DfE program. It utilizes controlled and more automated equipment and methods. There will
be a report  given about it, so I need to go no further. I believe that drycleaners have sufficient
information available for informed decision making whether or not to invest in this cleaning technology.

        I see the care labeling laws as the major barrier for advancing wet cleaning. There are efforts
under way to lower these barriers, but these efforts must generate reliable test methods and objective
information for apparel manufacturers. We can not expect their support without assuring them that
professional cleaners using this new process will not damage their products. When a drycleaner wetcleans
a garment which is labeled "Dry Clean Only" he/she may be financially liable if the garment is damaged.

       New cleaning technologies using liquid carbon dioxide or glycol ethers have been investigated
and promised for several years now. I have prepared two handouts that describe the principles of these
two emerging technologies.  Also, we have speakers on the program who will give you progress reports
about these developments. In general, drycleaners are receptive to alternative cleaning technologies, but
they have grown somewhat skeptical of the hype and the lack of credible information about them. I
believe this skepticism can be overcome if or when impartial demonstration projects under commercial
conditions verify the stated claims. There is a definite need for objective cleaning and textile performance
evaluation, practical performance demonstration and realistic cost and benefit data.

       Common sense and experience should guide us to be very careful about embracing any
alternative technology if there are no or few environmental and safety regulations on the books. I

remember the time when PCE was heralded as safe alternative to petroleum solvents, and I remember the
time when there were no regulations about the environmental disposal of PCE. Today's broad concerns
about the environment and the analytical tools available for impact assessment call for responsible
actions. We can expect that the developers of new technologies, EPA, and other regulatory agencies will
work together and generate meaningful, binding recommendations or regulations for professional textile

        The points I made earlier in my discussion about wet cleaning apply here too: we must work with
the .textile and apparel industries and give them the confidence that new professional cleaning
technologies do not damage their products. Otherwise they will not advise their customers to have their
products cleaned professionally.


        today, environmental and resource allocation decision-makers are looking holistically at
products and processes before they decide which product or process to choose or endorse. This approach
is often referred to as industrial ecology. Environmental life cycle assessment of a product or process
from "cradle to grave" may shed new light on the things we intuitively take for granted. For example, it is
easy to believe that cotton is less energy intensive than polyester because cotton is a "natural product" and
polyester is a "synthetic product." Yet, research done after the energy crisis in 1974 demonstrated quite
conclusively that over their respective product life cycles, garments made out of polyester demand less
energy than those made of cotton. The same may hold true for their environmental impact if one considers
that pesticides are used during the growing of cotton.

        As new textile care technologies are developed, we must compare them holistically with  existing
technologies. We must look at product and process parameters. We must collect information on toxicity
and exposure of new solvents, and we must have objective assessments and evaluations of their impact on
people and on the environment. We must go beyond technical and economic decision points and include
political and social  issues in our selection process. Clearly, this approach requires multidisciplinary
expertise far beyond the resources available to the drycleaning industry.  I hope that EPA uses industrial
ecology and life cycle methodology in their assessment of emerging technologies. Drycleaners look to
EPA for answers.

1.     EPA's voluntary Design for the Environment (DfE), Garment and Textile Care Program (GTCP)
      has opened dialogues among its stakeholders and has led to better understanding of each others
      assessment of the drycleaning industry.

2.     The drycleaning industry has implemented pollution control and prevention measurers that have
      significantly reduced its demand for perchloroethylene (PCE).

3.     The concept of textile care spectra provides useful guidelines for the boundary conditions of
      cleaning technologies.

4.    Proven cleaning technologies available to drycleaners today include non-aqueous drycleaning with
      PCE and petroleum (hydrocarbon) solvents and wet cleaning.

5.    Emerging textile care technologies involving liquid carbon dioxide and glycol ethers appear to be
      promising alternatives, but they have not yet been demonstrated as drop-in alternatives for proven

6.    Successful implementation of alternative textile care technologies requires the involvement of the
      textile and apparel chain.

7.    Life cycle assessment and industrial ecology methodology should be used by decision makers to
      compare the viability of proven and emerging textile care technologies.

8.    The drycleaning industry is looking to EPA for objective assessment and approval of proven and
      emerging textile cleaning technologies.


         Dr. Manfred Wentz


          WASHINGTON, DC
        MARCH 31-APRIL 2,1998



Falls Church, VA
May 27-28,1992



 Washington, DC
 September 9-10,1998


                                         INDUSTRY MILESTONE

                                        FIRST NORTH AMERICAN
                                        ENVIRONMENTAL SUMMIT:

                                        "OPEN FORUM ON TEXTILE CARE"

                                        Hamilton, Ontario, Canada
                                        December 3-4, 1993

— Environment Canada
— Environmental community
                                        GENERIC DEFINITION OF

                                        BREAK INTERACTION FORCES
                                        BETWEEN SOIL AND TEXTILE

                                        TRANSPORT SOIL AWAY IN ANY
                                        MEDIUM-LIQUID, GAS, SOLID

                                        CONCENTRATE SOIL FOR PROPER
    FABRICARE (cont.)



                                         INDUSTRY MILESTONE


                                        "THE NATIONAL DRYCLEANING
                                        ENVIRONMENTAL SUMMIT
                                        Oak Brook, IL
                                        July 8-10, 1994



  — Dry cleaners

  - Suppliers

  — Solvent producers
  VISION 2000 AGENDA cont.


   - Regulatory agency
   — Insurance industry
   — Financial industry
   — Real estate industry
   — Environmental community
VISION 2000 AGENDA (cont.)


  — Environmental Response Fund

  - Enhanced pollution control measures for
   perc plants









  Toronto, Canada
  November 19 - 20,1994











 Toronto, Ontario
 February 27-28, 1998



4.5 kT
1.6 kT
2.9 kT


  — Haw to achieve goal

  — Implementation procedures

        Technology Options
Non-Aqueous Cleaning
Aqueous Cleaning


 - Perchloroethylene (Perc)
 — Petroleum Solvents


 - Professional Wet Cleaning




 — New machines are efficient
 — Waste management is available
 — Regulatory frame work exists
 —Associations offer environmental education





 — Retroactive liability
 - Objective assessment remediation technologies
 —Attainable clean-up standards


 — Fire and explosion hazard
 -Airpollution (VOQ

 - Lower explosive limit (LEL)
 - Upper explosive limit (UEL)


 FUEL:  .
 - Solvent vapors are fuel
 — Causes fire when vapor concentration is
  within flammable limits

 — Keep concentration outside ftammabttity

— Oxygen required to support flames
- Normal air contains 21% oxygen

- Keep oxygen below 8%

 —Flame, spark or excessive heat can ignite

 —Avoid open flame and static electricity
 - Use approved electrical wiring

                    NEW EQUIPMENT


                - Vacuum drying
                - Inert nitrogen blanket
                — Controlled air Jlow



                  BARRIERS FOR WET

                QUESTIONS ABOUT "NEW WET
                CLEANING TECHNOLOGY"
                CARE LABELING ISSUES



                  ASSESSMENT NEEDS

                OBJECTIVE CLEANING








                - Chronic
                — Carcinogenic

— Occupational
— Environmental
— Community

    • AIR



                 POLITICAL AND SOCIAL

                • LEGISLATIVE STATUS
                • REGULATORY STATUS
                • LABOR IMPACT
                • COMMUNITY IMPACT
                • GLOBAL IMPACT
              TEXTILE CARE

                OF SMALL BUSINESSES

                OF CHOICE

                MOST DRYCLEANERS ARE

     SUMMARY (cont)



                        Assessing Residential Exposures to Perc

                                      Judith Schreiber, Ph.D.
                               New York State Department of Health

        Judith Schreiber is a senior research scientist in toxicology who has been working for the
        New York State Department of Health for nearly 20 years. She is a recognized expert in
        risk assessment and  risk  management  issues,  especially regarding  exposure  to
        environmental chemicals, transport of chemicals  in humans, and evaluation of the health
        impacts of chemical exposures.
        Every time I go to a new city—and I have been to Washington before, but every time I do go to a
 new city, I usually look in the phone book and try to see how many drycleaners there are in the particular
 city that I am in.  I got here so early today that I didn't have time to actually check into my hotel room, but
 I would guess that there are at least several hundred drycleaners in the Washington area. And I would
 hazard a guess that at least some of those share building space with residents or other businesses, like
 offices or other small commercial entities.

        I mention this because in New York we have done quite a bit of work looking at the impact of
 small neighborhood drycleaners on residential and business neighbors. That is the topic of my talk today.
 We have recognized over the years that we have been doing this work that exposure from drycleaners to
 the neighbors who live and work nearby is quite significant. We believe this is a public health concern
 that needs to be addressed by both the industry and the government.

        Drycleaning has a fairly simple approach. How many of you are actually drycleaners out here, if
 I might ask? Maybe less than half, a quarter or so perhaps? As you know, drycleaning has really evolved
 technologically.  This is, of course, a very simple representation of what cleaning is about, but transfer
 machines going to dry-to-dry machines have improved our ability to control the emissions from
 drycleaning facilities.

        Sometimes however, high tech turns into low tech. As you can see, this piping around the
 drycleaning machine is held together by socks. This is the old sock method.  You may wonder in your
 home washing machine and dryer about those missing socks.  Well, apparently it also happens in
 drycleaning plants because here you have what may be a very sophisticated unit but it is held together by
 socks, which is not very reassuring.

        As was mentioned by other speakers, perc is a toxin and, depending on the amount to which you
 are exposed, can certainly be responsible for health effects. It can cause central nervous system
 intoxication; liver damage; and eye, lung, skin and mucus membrane irritation. There are concerns about
 its cancer potential because of studies in experimental animals and a growing body of evidence in the
 occupational sector indicate that drycleaning workers are at a small but significant increased cancer risk.

        Of course, as we have heard before, perc is widely used in the drycleaning industry. Because of
its volatility, inhalation is by far the major route of exposure both for workers and for residents who live
nearby.  Perc, once it is breathed in, is absorbed into the body via the lungs.  It crosses over to the blood
and once it is in the blood, it circulates through the body and has a particular affinity for fatty tissue. It is
stored in body fat of the person who absorbs it. The reason actually that  I first became interested in this

 question because I was doing a doctoral dissertation looking at breast milk contaminants. We were also
 doing some work in the health department, looking at air levels in apartments near drycleaners and
 finding quite elevated levels. I put two and two together and thought, if there are lactating mothers living
 in these apartments, breathing in elevated levels of perc, what is going on with their breast milk? Would
 we see some contamination in breast milk?

        I did a lot of work looking at mathematical models that predicted the level that would be present
 in milk as a result of the mother's inhalation of concentrations that we had measured in peoples' homes.
 That is how I began thinking about it and looking at it and realizing that it is a public health concern that
 we all should be aware of and try to address.

        PCBs, once they are in your body fat, are very hard to get rid of. Perc, on the other hand, because
 it is volatile, can also be breathed out. You breathe it in and some of it gets absorbed in the blood, but a
 lot of it gets breathed right back out unchanged.

        This is a picture of an infant's bedroom. We first began this interest in looking at drycleaner
 situations back in 1989 in Putnam County, a rural county in Upstate New York. A woman who lived with
 her family in a small apartment above a drycleaner called the county health department and was
 concerned because she was smelling the odor of drycleaning chemicals in her apartment. This was on a
 small main street in Upstate New York, not New York City.  County health department officials, who
 didn't really know how to analyze for that chemical, came to the state health department to ask our
 assistance and together we went in to look at the apartment.

        On the slide you can see a small monitoring device in the corner underneath that teddy bear.
 Basically, we took a 12-hour sample after we had set up the equipment in this child's room, and we found
 in that bedroom levels exceeding the OSHA standard, the OSHA PEL, for this chemical.

        In 1989, in the second floor apartment, we found 197,000 micrograms per cubic meter.  I know a
 lot of you are industry folks and you are more used to parts per million.  Roughly 7,000 micrograms per
 cubic meter is equal to 1 PPM.  That is an extremely high level. As you go across, you can see the  levels
 drop, but they are still quite high even at 5,500.  That is a little less than a part per million. But remember
now, this is in a residential apartment right upstairs from the drycleaning facility.

        The levels had dropped because of a number of things. One, the county health department  closed
 down the facility for a time while they could make repairs in the machinery and try to get the levels
reduced upstairs. Over the course of time, the levels remained elevated and eventually the drycleaner
closed.  Outside the window, on the ledge, you see those levels also are extremely high. So, this was our
wakeup call. We really do consider this a kind of a red flag that happened to us.

        We thought that these numbers are extraordinary. Why should they be so high in an apartment
upstairs from the facility when the facility itself has an OSHA PEL?  If the apartment is exceeding it,
well, what is going on downstairs? It was really quite extraordinary.

        In the general population, we found about 25 micrograms per cubic meter in your house or  mine,
assuming we don't live near a drycleaner. This agrees well with EPA's data.  These levels are found
because we bring in drycleaned clothing or we have certain consumer products that contain perc.
Compare that to the levels that I showed you on that other slide, where we are talking about tens and
hundreds of thousands of micrograms per cubic meter.

       As a result of that finding, we decided to embark on a study. We asked, is this a fluke or is this
something that happens commonly with drycleaners in residential buildings?  We really didn't know. It
turned out that nobody really had looked at this except for some studies that had gone on in Germany. I
think Dr. Kurz and colleagues had done some work at that time.

       So, we looked in Albany, where the state health department is located. We found a hundred
drycleaners total in the tri-cities area, in the capital district.  Only six of those were residential apartments
in the same building as the drycleaners and we looked at each of those six apartments. So, we looked at
the universe of residentially located drycleaners in the Albany area. What we found confirmed our
suspicions about what was going on.  It was unusual. We still haven't found one apartment with as high
levels as that very first one. But look at the levels that we do see.

       We looked at a dry-to-dry machine, but it was in poor operating condition, had bad gaskets, was
run into the ground. The operator was really not conscientious at all and we found levels from 36,000 to
55,000 with a mean of about 45,000.  What is not presented here, but I want to point out, is that we took
two 12-hour samples. We took a 12-hour sample in the apartment during the time when the drycleaner
was operating, 7:00 in the morning until 7:00 at night. Then we took a subsequent air sample, 7:00 at
night until the following morning. If you asked me before we did this, I would have told you that I
expected that the level would go way up in the daytime and way down at night. But it didn't happen.
What we found was the levels were very high during the daytime and they stayed at about 80 percent of
that at night.

       That was a big surprise to our staff when we first did this. We really did not expect that finding,
but we have now confirmed it time and time again in other studies that we have done. These  other
machines in the middle were transfer machines and the last two there were in apartments above
drycleaners that used good, well-run dry-to-dry machines. The numbers range from 100 to 440.  So, there
really was a vast array of differences, depending on the type of machine that was used in the facility.

       This confirmed to us that we did stumble upon a problem of indoor air contamination of a rather
large magnitude as a result of drycleaners.  Drycleaning establishments from a regulatory standpoint, had
been pushed to the side because they were small, mom and pop style operations, using only a hundred or
200 gallons of solvent a year. What we came to realize was that those hundred gallons are lost to the air,
as was alluded to by some other speakers, and that air travels through somebody's apartment on the way
out.  That is the problem.

       I have a lot of respect for drycleaners. I think you are hardworking people. You want to do the
right thing, but you have a tough job and the problem is your neighbor is ten feet away from you. Your
neighbor is ten feet on top of you and ten feet to the side of you and that makes it very difficult.  Even a
conscientious drycleaner with good equipment has a really tough job to try to control those emissions. I
have a lot of empathy for the drycleaners.

       Here, in control apartments, the mean is about 28, which is very similar to what we find
nationwide. This one, I just want to point out, is the first high rise building that we had looked at.  I think
the common wisdom is that perc is denser than air and it will tend to stay low in the facility workplace.
We found time and time again that the air currents, convection currents in a building, quickly overwhelm
the very little density difference between perc and air and, in fact, the perc does travel and migrate
throughout the building.

         On the second floor, where this complaint call first came in, we found 62,000 micrograms per
 cubic meter in the daytime, 48,000 at night. That was very typical of what we find. Then as you go up,
 we took the fourth floor, the seventh floor, and we looked at the 12th floor, the top of the building.  At the
 time we looked at it as an internal control. We did not expect to find anything on the 12th floor, not at all.

         What we found, as you can see, is that the levels on the 12th floor were just about what they were
 on the fourth floor. I have spoken since with some fire department people, who tell me that in smoke with
 fires it also sometimes can skip floors and the pattern of air distribution in a building is really not stacked
 up as you would think. Sometimes you do have a short circuit, so to speak, in the air flow pattern so that
 you can get a buildup in certain areas and not in others.

        But this I put up just to demonstrate that it is not just the second floor apartment.  Ever since then,
 we now realize and we assume that if we find one contaminated apartment in a building, we assume that
 there is the potential for all the apartments in that building to be contaminated.

        This is an interesting piece of information. The toxics reporting in TRI data where the larger
 industries have to report their toxic releases, including perc, nationwide, reported about 16 million pounds
 emitted. Drycleaners don't have to report to the Toxics Release Inventory because they are small source
 generators. We have estimated based on a survey that we did in New York, that the aggregate of all the
 dryclcaners in New York State emits approximately 13 million pounds of perc annually, compared to
 about 16 million pounds reported to TRI nationwide. So, I think that all of these small sources put
 together really represent an awful lot of release of perc in New York State. And I expect there would be
 similar numbers for the other states if such a survey were done.

        Just as a means of comparison, if you had perc in drinking water, 5 micrograms per liter is the
 maximum contaminant level.  A person ingests about 2 liters a day. If you were to drink contaminated
 water at that level, you would be getting about 10 micrograms per day from drinking water.  So, hold that

        If you are living in one of these apartments and the apartment ranges are, let's say, a hundred to
 10,000 (which is probably somewhat conservative), you breathe about 20 cubic meters of air per day. So,
 you are getting from air from 2,000 to 200,000 of micrograms per day. Whereas, you would be only
 getting 10 micrograms per day from  drinking water and your drinking water source would be closed by
 your regulatory agency in your state.

        So, just to put it in comparison, the levels that people are exposed to in these apartments are really
 quite high. There is a misconception that, if you can't smell it,  there is not a problem. There is a number
 of things there. One is that drycleaners and others who are exposed to the high levels can get fatigued.
 Your sense of smell gets fatigued and you no longer recognize the smell whereas your neighbors might.
 People upstairs in your buildings might be able to smell it.

       Another misconception is that perc is denser than air and, therefore, won't escape the facility. We
know that is not true. You have stairwells and elevator shafts.  You have pipe chases. The hot water
pipes that go up through apartment buildings have usually a little doughnut hole of space around the pipe
and that acts as a very effective chimney and pulls the more contaminated air from the drycleaning
facility up through the building. Sealing those pipe chases and  other avenues of dispersal,  therefore, is
very important.

       Yet another myth is that, if it is a problem, it is only in New York City. Again, it is just not so. I
would like places like Chicago and L.A. and Washington and all of the older cities, all of the urban cities
in the country to really take a look at where their drycleaners are. The EPA has done a lot, but it hasn't
looked at that and it is something that we have been proposing now for awhile.  The states really ought to
be getting down to looking at where their drycleaners are located and how they can reduce exposure.

       Just to put this in perspective, you might ask, so why are you picking on us drycleaners anyway?
We are hardworking small business people, which is true. How do they compare to other exposures?
SuperFund often comes up.  These are inactive hazardous waste sites. People are really worried about
them. It has a high profile.

       Well, I will tell you that people living near hazardous waste sites, for perc, at least, are exposed to
much, much less than people living in apartment buildings with operating drycleaners, without a doubt.
In fact, the ATSDR, the health agency that looks at those sites, has  established minimum risk levels for
chronic exposure of 270 micrograms per cubic meter. Nearly every apartment we have measured in
drycleaner buildings exceeds that number. If they were hazardous waste sites, it would be considered an
urgent public health hazard, necessitating immediate action. So, there is a little dichotomy in how we
look at hazardous waste sites and how we look at operating drycleaners, which we permit to operate in
residential areas.

       I know I am running out of time and I am not going to get to my drycleaner study information. I
recommend that you stop by the poster session, take a look at that yellow sheet, and come ask me if you
have any particular questions.  But, basically, we looked at six families living in two buildings in New
York City, where there were operating drycleaners. And we took multiple air measurements in various
rooms. We had the participants  wear carbon absorber badges so we could measure their personal
exposure and we also took blood samples, urine samples, breath samples, exhaled breath, and breast milk
samples from two nursing mothers who were among the study participants.

       We also administered  three vision tests as a way of evaluating neurological impacts on the visual
system. To make a very long involved story very short, we found, as expected, high levels in each of the
apartments—on the second floor, third floor, fourth floor, and sixth floor in these buildings. We found
elevated biomarkers of dose in all of the study participants, including the children we examined, and we
found an effect on vision indicative of neurological impact.

       Now, I would caution that it is a small study.  It is a pilot study. We looked at 19 individuals, a
small number of people.  We hope to receive funding to do a larger study along these lines, a larger
number of people and a wider array of neurological evaluation.  Still, I think the results are important in
that the levels of exposure for  these people were roughly 0.1 to 1 part per million in the apartments.

       If we truly are seeing effects on vision at those levels of exposure, that notches down the degree
to which you need to  be exposed before you see an effect. That is an important finding if it is upheld on a
larger study. So, I think it is something the drycleaning industry should really think about, and along with
thinking about the importance of maintaining your equipment, keeping your solvent containers covered,
doing all those kinds of things that are really important to minimize your own exposure and the exposure
of your neighbors.

       Thank you.

 Abstract for the Society of Toxicology Annual Meeting
 Judith S. Schreiber, Ph.D., presenter
 New York State Department of Health
 2 University Place Room 240
 Albany, New York 12203-3313
 March 3,1998

 If you would like to receive a copy of the report on the study (completion date 4/98) leave
 your business card with Dr. Schreiber or send e-mail note to

 DRY CLEANING FACILITIES.  J Schreiber. New York State Department of Health, Albany
 NY,  KHudnell USEPA, Research Triangle Park NC,  J Parker, USEPA, Washington, D.C.
 Sponsor; L. Kaminsky.

 We conducted a pilot study to assess airborne exposure to tetrachloroethene and biomarkers of
 dose, and to evaluate visual system function in residents living above dry cleaning facilities using
 this solvent. The study population included 19 subjects (6 adult males, 7 adult females, 4 male
 children and 2 female children) who lived in two apartment buildings with operating dry cleaning
 facilities in New York City.  Tetrachloroethene air concentrations were substantially elevated in
 all apartments  above dry cleaners. Nearly all biomarkers of dose (tetrachloroethene in exhaled
 breath, urine, blood (adults only), and breastmilk (when available), and metabolites in urine) also
 were substantially elevated compared to background populations not living near dry cleaning
 facilities. Notably, analysis of some urine samples showed detectable levels of N-acetyl-S-
 (l,2,2-trichlorovinyl)-L-cysteine, a metabolite produced via glutathione conjugation. Metabolites
 produced via this pathway may play a role in the animal carcinogenicity of tetrachloroethene.
 Vision tests were administered to study subjects and to age-and gender-matched controls who did
 not live near dry cleaning facilities. Visual acuity did not differ between groups, but visual
 contrast sensitivity, an indicator of neurological function in the visual system, showed a strong
 significant group difference (F (16,144) = 19.38, p<0.001)). Color discrimination did not show a
 significant group difference, but there was a trend toward poorer color discrimination in the
 exposed subjects.

 (Note: This work was supported by USEPA Cooperative Agreement CR 824400-01 and the
 Strategic Environmental Research & Development Program. This abstract does not necessarily
represent policies of USEPA, SERDP or NYSDOH).

Key words: tetrachloroethene, biomarkers, neurotoxic effects



                        J. Schreiber1. K. Hudnell2, J. Parker3

                 JNew York State Department of Health, Albany, N.Y.
          2USEPA, RTPNC, 3USEPA, Washington, DC, Sponsor:L. Kaminsky
      Elevated perc levels in indoor air in residences above operating dry cleaning facilities
      cause elevated biomarkers of dose and neurological effects.
      We conducted a pilot study to assess airborne exposure to perc and biomarkers of dose in
      breath, blood, urine, and breastmilk, and to evaluate visual system function in residents
      living above dry cleaning facilities in New York City.

•     Elevated perc levels in air were found in all study apartments (n=6).

•     Elevated perc biomarkers of dose were found in all study participants (n=19).

•     N-acetyl-S-(l,2,2-trichlorovinyl)-L-cysteine was found in urine samples of some
      participants.  This metabolite, produced via the glutathione conjugation pathway, may
      play a role in the animal carcinogenicity of perc.

•     Visual acuity did not differ between study group and controls

•     Contrast Sensitivity showed a strong significant group difference (p<0.001)

•     Color discrimination did not show significant group differences, but there was a trend
      toward poorer color discrimination in the study group

                          New York State Department of Health
                               Perc Biomarker Study
                            Preliminary Results, March 1998
Family 1
2nd Floor
Building A
Family 2
2nd Floor
Building A
Family 3
3rd Floor
Building B
Family 4
4th Floor
Building B
Family 5
4th Floor
Building B
Family 6
6th Floor
Building B
Vision Test
Tetrachloroethene Levels
25 - 3,900
65 - 7,250
40 - 3,450
140 - 2,000
30 - 700
4.2 - 6.9
4.3 - 43
2.6 - 6.0
28 - 2,600
3 - 2,000
9.4 - 290
** Visual Constrast Sensitivity
*** Color Discrimination
                                             per liter, Breath = micrograms per cubic meter
4> ** Below the normal range of responses
N = Normal range of responses


CONTRAST = Visual contrast sensitivity measures neurological function in the visual system
      by measuring the ability to see faint wavy lines at certain spatial frequencies. (Vistech
      6001 VCTS; Stereo Optical Co.; Chicago, IL)

COLOR = Color discrimination measures neurological function in the visual system by
      measuring the ability to place 15 color chips in the correct order.  (Lanthohy's
      Desaturated 15 Hue Test according to Farnsworth-Munsell; Luneau Ophthalmology;
      Paris, France)

N = Normal range of responses
  = Below the normal range of responses
mcg/m3 = micrograms per cubic meter

meg/liter = microgams per liter
We gratefully acknowledge the assistance of:

       Dr. Wolfgang Dekant of the University of Wurzberg, Germany, for urinary metabolite

       Dr. Andrew Geller of USEPA for vision assessment.

       Dr. David Ashley of CDC for blood analyses

       Dr. Kenneth Aldous of NYSDOH for air and biomarker analyses.

       Ms. Bettsy Prohonic and Ms. Karyn Langguth of NYSDOH for data analysis and

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                              Standardization and Testing

                                        Norma Keyes
                      American Association of Textile Chemists and Colorists

       Norma Keyes is currently the Director of Fiber Quality Research at Cotton Incorporated.
       She has been an ASTM Member since  1989, serving on  subcommittees for Fabric
       Performance  Specifications,  Yam Test Methods,  Care Labeling, and  Chemical and
       Conditioning Standards.

       My part of the conference today is talking about standardization and test methodology.

       This is a slide that Cindy Stroup used in February at AATCC meetings to give the concept of the
EPA's Design for the Environment. I wanted to show it again to get us focused because part of the
stakeholder part of this initiative really affects the textile industry. I tried to summarize again a little bit
of that concept by listing some of the aspects of the textile industry of which this is a significant part or
significant concern

       Now, we are talking about products for consumers and we are talking about the garment part of
the garments'and textile items. What are consumers concerned about? They are concerned about whether
the color is going to be in it when they wash it. This is specific to home washing or home laundering.
They want to know if the color is going to be in it.  Are the parts going to be the same color?  Is the white
part of it going to be white when I get through washing it? Is the garment going to fit?  Are the seams and
the buttons and the trims going to stay intact when I wash it and clean it?  Does it look and smell clean?

       These are our basic concerns as consumers, not much different from what we expect when we go
to the drycleaning of our textile items. The same things are of concern. Color. Fit. How does it look?
How does it fit? Does it smell clean? Does it look clean?

       But you notice on the bottom of that list, I have added something and that is cost. That is the
other element. It is not seen so much as a big deal when we expect to wash and care for something at
home, but when we take it out to professional garment care people, cost is an issue. We haven't had too
many complaints about drycleaning cost.

       Now, if we move this on to consumers' expectations for new technologies, that list really isn't
going to change at all either. Those same things are going to be of concern. And I left cost on there, too,
because we are still concerned about that aspect down the road, too.

       Now, how does the textile industry translate those concepts into our language? Well, our
language is colorfasmess, change of color, bleeding, staining, dimensional change, appearance. Well,
what do we do with that? What kind of language?  And that transfers into standards and test methodology

       That is how the textile industry deals with this. We do it with the consensus process. We have
interested parties come together and discuss a topic and decide how we are going to test for this property
of change of color or bleeding or staining or whatever it is. The consensus process is very important
because, when a test method gets to the standard stage and gets approval, that is the way we analyze it.

         ASTM's focus is on standards and test methods relates to performance specifications and to basic
  properties, such as tensile properties and tear and those aspects. Also, care labeling and symbols has
  come under the auspices of ASTM.

         In AATCC, our focus is on test methods for the wet processing part of the textile chain.  Now, I
  am going to spend a lot of time on ASTM and AATCC, but I want to mention that the specifications for
  performance related to drycleaning, are based usually on AATCC test methods.

         The AATCC's test methods for garment care relate to home laundering and drycleaning, and we
  have some test methods that predict commercial laundering performance.

         Now, the test methods that are related to drycleaning were developed with perc coming into the
  drycleaning process.  Some of those have dates of 1950s, late 1950s and sixties. So, these standards and
  test methods are a direct result of what was happening to the laundering care product area at that time.
  Some of these are not in widespread use at this  time. Test Method 86 is used. Test Methods 132, the
  colorfastness to drycleaning, and 158 are somewhat used. People may have different perspectives on that
 but it is normal.

         The other aspect of what AATCC does is to help users have evaluation techniques and these are
 called evaluation procedures. These are not only used here in the United States but many of these are also
 used in the international arena.

         So, you can see gray scale for change of color, for staining. There are instrumental assessments
 for change of color and then the nine step chromatic scale.  Now, when perc got to be an ugly word, some
 testing laboratories had to make some decisions on how to deal with perc.  Many times, their facilities
 couldn't handle it or chose not to so sometimes testing laboratories choose to just use local drycleaners for
 some of these evaluations. That is not a standard approach and it is not an official test method, but it is a
 matter of not having to deal with perc in the testing laboratory arena.

        Recognize that there are some other approaches to looking at drycleaning performance. Now,
 many of the ASTM standards are related to performance after drycleaning.  I guess you didn't realize how
 important zippers were in the drycleaning process and that there could be a dramatic effect. There
 happened to be two standards in ASTM related to zipper performance in drycleaning. There are other
 ASTM standards that have references to drycleaning performance.

        Other references to drycleaning and the  textile care chain related to ASTM activity are care
 instructions. Many of these care instructions relate in terminology and the care symbols. We have to
 have a symbol for drycleaning and that is going to come up, I think, later in the conference. Connie is
 going to be talking about care labels and symbols and, you know, we are going to have to have a symbol
 for wetcleaning, whatever wetcleaning is.

       And there is the question. What is wetcleaning? Well, you know, you might be surprised that we
haven't defined wetcleaning yet. We don't know how it is going to fall out.  It may be one or two or three
different things. It may be combinations of processes.

       I hope we define it because it certainly is a concern to the textile industry.  There is a definition
here and you can see a date on that,  1945, by Norbert Berg.  Some of you may know this gentleman. I

don't know him, but he had a definition for wetcleaning in 1945. This was published last month in the
Fabricate Resources Bulletin that is put out by IFI.

       I think that definition really is pretty comprehensive. He went on a little bit and expanded on that
concept, but that definition may cover things. When we get to AATCC and new test method
developments, you had better believe we will be defining "wetcleaning."

       Now, how many emerging technologies are there going to be? Can current test methods be
adapted to predict wetcleaning performance?  We don't know that.  Will new test standards need to be
developed? I would probably say "yes."  It is probably a foregone conclusion that we are going to have to
do some new test methods or are we going to have new equipment in the laboratory to do this. I would
say maybe we can adapt some things.

       When do we need to start working on this for developing test methods? Well, we can't do that
until somebody decides what is going to be out there in the care process. There is the old launderometer,
the tried and true; it has been with us a long time and has been used widely.  There are things coming
along in the home washing area maybe that could help us.

       Front loading technology is coming along with less water usage, less agitation.  Is there
something we can do with home laundering equipment? There is other new equipment that is coming
along to predict shrinkage. Maybe that can be adapted and used.

       But AATCC is prepared to help the textile industry with its garment care processing and where
we are going with that.  We have reactivated the drycleaning committee. It is considering changing its
title and scope and has balloted a new title and scope.

       Here is what the Drycleaning Test Method Committee's scope is currently. It was changed to
Professional Textile Care Test Methods.  That is a big comprehensive title. The scope has been reworded
a little bit to handle this new title and we think AATCC is prepared to deal with the future emerging

       Now, the AATCC is set up to do this. There is a development process for test methods and
standards. Somebody has to say, there is a need for it. It can be an individual. It can be a company.  It
doesn't have to be an AATCC member. It can be an association of drycleaning cooperatives. It could be
anyone who says we think there is a need for this. Present information for it. Once that need is
established, then we decide if it fits under a scope of a committee.  Well, right now garment care is related
to drycleaning and it already has a committee that addresses it.

       Then we go on to some other development stages and it goes through a whole process of studies
and test method development and balloting process. That is how the standardization and test method
process works.  Once it is published, it is official.

       Let me just mention, too, that Manfred Wentz is the chairman of the AATCC Drycleaning
Committee and we will be depending on his leadership. Let me also just briefly mention that in the ISO
arena for textiles that there are several working groups that are associated with drycleaning. In the
Subcommittee for Cleansing, Finishing and Water Resistance there is a Drycleaning Working Group.

        I wanted to show you the spectrum of subcommittees for drycleaning, finishing, washing,
appearance, durability, flame retardant finishes, tumble drying, water resistance, and industrial washing.
In ISO there is also a standardization process in place. These four documents are in the standardization
process in ISO and the USA's position on these has been positive. You can see a time line for that in
1997. Parts 1 and 2 were at draft international standards stage and Part 3 and 4 are coming along in ISO
development Stage 2.

        So, to wrap it up, the AATCC is ready to help the textile industry meet the challenge of the
changing and emerging technologies in garment and textile care.

      The Opportunity for Transitions Planning in the Fabricare Industry

                                        David DeRosa

       David DeRosa has worked for Greenpeace for over 10 years.  He is a toxics campaigner
      . for Greenpeace USA, working on the substitution of chlorinated solvents in drycleaning.

       Hello.  My name is David DeRosa, and I work for the Greenpeace toxics campaign. I'm here to
talk about transition planning—the process of maximizing changes in industrial processes for what we
call stakeholders, such as workers and small business owners, when solving environmental problems. As
our keynote speaker, Ed Barlow, noted this morning, change is inevitable.  This conference is going to
convey a lot of technical information and a lot of elaborate mechanisms for dealing with change, so it's
good to start with the basics: change is coming, it's here, it happens every day. The public deals with
changes in ways the don't even know they're doing. As a provider of a public service, the drycleaning
industry has to be ready for changes, and able to make them as seamlessly as possible.  Satisfying
people's need for convenience is the key, and exposing our customers to toxic chemicals is, on many
levels, a bit inconvenient for many people.  That is what transition planning strives to make possible.
Business books may tell us to "thrive on chaos," but most people would like to know ahead of time which
mechanisms they can depend on when they must change. Just because change happens doesn't mean it
must happen in an uncontrolled fashion. As Mr. Barlow put it, "we must work smarter as well as harder."

       So change should not be feared, but relied upon. Without change, for instance, there would be no
fashion industry because everyone would wear the same clothes for years.  Then where would the
fabricare business be?  But, to set up an extended metaphor, there comes a time when change strikes at
the heart of how you define yourself, when your old clothes (that you know and love) cannot be used any
more. But to get into your new clothes, you must commit to taking the old ones off, which leaves you
vulnerable—even naked—for a little while. Some want to jump into their new clothes; others want to go
gradually, perhaps getting a new shirt on before the old pants come off. Sensible enough. But still others
will want to explain that the old clothes are fine, that there's no reason to waste money on new clothes, or
that if they wait long enough with the ragged clothes on their backs, they'll come back into fashion. This
defensive posture can take many forms; some figure, if I add a new pair of fancy shoes, no one will notice
my old-fashioned clothes. Or by spraying enough cologne, I can cover the smell. These  are rationales
from people afraid to face the truth, get the change over with, and settle in.

       What do you do when the way you make your living becomes undoable? In today's modem
world, this is a prime question faced by people the world over. In an extreme example, people who
weave baskets or make handicrafts all over the third world are finding their job skills no longer needed, as
they can be "better" made by machinery. Closer to home, those who made buggy whips and carriages
found that they went out of work when automobiles wiped out the previous dominant mode of transport.
More recently, workers who make products that should no longer to be made are finding  that their very
good paying jobs in pesticides or plastics factories are being scheduled for phaseout. Many are
represented by unions, which do not exist to put workers out of business. So instead they must find a way
to train their workers for more sustainable and appropriate work.

       Why is there a resistance to transition planning? For some, a denial of the problem; for others, a
doubt that any assistance would be forthcoming, forcing that defensive posture. One thing is sure: those

 who would like to help will only be able for so long. We attempted, through the Professional
 WetCleaners Partnership, to find an amicable solution for an orderly phaseout for one of the most at risk
 groups: co-located cleaners in New York City. Faced with new state regs, potential action on a city level,
 and a lawsuit going through the courts that challenges disproportionate zoning, these are cleaners facing
 huge challenges to their survival. Cleaners may fairly suspect the motives of those who would help them;
 Greenpeace can only say that we would like to be able to point to a transition of this industry as a model
 for how industry can make the changes it needs. Without regulatory requirements,  no one can make the
 industry change; yet change is coming, and the question that most needs asking is how smooth it can be,
 and how much the face of the industry will change. Orderly timetables can most easily be imposed on a
 phaseout; when there is disagreement on what the endpoint is, timing becomes chaotic, and helpful
 mechanisms of funding and training may disappear or go unused.

        Let me ask a question: How far into the future will perc be used?  Let me ask a knowledgeable
 crowd. Raise your hand if you think perc will still be used in the cleaning profession five years from
 now.  OK, how about ten years from now? Fifty years?  One hundred? As you could see, fewer hands
 each round, but some die-hards never took their hands down.  Many people would like to believe that perc
 will be around until their shop closes, or "let the kids deal with it." I'm here to tell you that that attitude
 won't work. Besides what EPA and OSHA and other federal agencies are doing, you should know that
 the UN is negotiating a treaty to phase out sources of long-range pollutants, such as dioxin, which is
 produced in the manufacture and disposal of perc.  So even if you solve all your exposure problems in
 your shop, the actual manufacture of perc, for which most of you are not to blame, may be too dirty to
 continue. Then its gone: So maybe you should drop them before they drop you. It needn't be sudden,
 tomorrow, but you need to plan.

        I have met some cleaners who seem to think that Greenpeace wants to see ever more arcane
 regulations monitoring perc levels down to some vanishing small level, like parts per "zillion" or as low
 as the detecting devices can go. But I think we want the same thing many cleaners want: a cleaning
 method so  clean it doesn't require that kind of regulation. Dr. Wentz said, earlier, that there are many
 different ways you can move toward reducing toxic exposures. That's true.  But even if a whole
 generation of cleaners moves toward fifth generation machines, someone, someday will buy the last perc
 machine, just as someone bought the last buggy whip. Certainly no one would wish to see cleaners
 switch to a care method that ignores what customers need for their garments. Yet cleaners must also not
 trap themselves into denying that other methods can work, and even that to some extent as  fabricare
 changes in this country, clothes will change to reflect that.

        Environmentalist have always joked that we are working to put ourselves out of a job—
 unfortunately, right now there is no shortage of ecological risks, so we're in no danger yet.  Before we
 face joblessness, we are dealing with other industries facing the problem of working themselves out of
 their jobs, like whaling, or  logging. Greenpeace's toxics campaign works on the chemical industry based
 on chlorine, which is used to make perc  It's also used to make many pesticides, many of which are found
 to be dangerous. Production gets  phased out, which means that good-paying jobs disappear.  We are
 working with unions and the chemical industry to adjust that process so it happens in an orderly way.
 This isn't just out of the goodness of our hearts, it would also help us get dangerous products off the
 market faster. We want to  help retrain these people for new productive work, and find the money to do it,
 whether by taxing the products they make or in other ways.

        Drycleaning is different, of course, because it is a service industry, and customers don't care what
you use as long  as it works. As industry leader Bill Seitz has often stated, "Cleaners aren't wedded to

perc."  That's good, but begs the question of how messy the breakup is going to be. We would like to
treat this conference as a turning point. The last couple of years have been an important testing ground:
Phase 1 for wetcleaning. You will be hearing, at this conference, results showing that wetcleaning works.
And we will be hearing from other emerging technologies that could have strong points where
wetcleaning might have weak points. So the proving is over, and the implementing must begin.

        The question is what we as stakeholders can do to make this as easy as possible, while keeping
the industry as prosperous as possible.  We need incentives set up that can "front load" the changes so that
change isn't put off till the last possible minute, and we need to find out what other components, such as
training, or tax breaks, or whatever, need to be in place. Then, when there is confidence in the
alternatives, and an understanding of the feasibility of switching, we can setup a phase out plan so that
everyone has a deadline.

        We all want to see cleaners using clean technology that cannot, even with massive machinery or
operator failure, cause any harm to the environment or human health.  When there  is no alternative to a
dirty technology, it may be considered a necessary evil; when such alternatives do  exist, there must be a
common goal of finding a good way to those new methods.

        I work on the Drycleaning Advisory Committee for the New York State Department of
Environmental Conservation with the trade associations, UNITE, Consumers Union, and other
stakeholders.  It has been really instructive to see how drycleaners get certified, how equipment is
approved, and how regular inspections can serve to give the public confidence in professional cleaning. I
don't know a people more dependent on drycleaning services than New Yorkers, but there is a growing
awareness that there is risk involved. And there are so many hoops to jump through. More expensive
machines to buy, vapor barriers to install—it's what I call an "upgrade treadmill", because every upgrade
costs more, so it's like walking in place up a steep incline. Running to stand still. Forcing an industry to
spend significant amounts of money to come into compliance with current regulations, only to impose
new regulations before that previous compliance machinery has reached the end of its usefulness, is not
good policy. And in the meantime certain towns in New York are not allowing new perc cleaners at all.
So New York is looking into making grant money available for problematic cleaners to get other
equipment, and outreach methods. The time is coming  when people will be looking for clean cleaners,
and they'll know what other quality they want beside price and speed.

        Certain obstacles to change will not go away with new care methods; in particular, retroactive
liability will remain from past contamination even after the process changes. Greenpeace is willing to
explore methods of lessening liability as part of a transition plan, but this must never come at the expense
of needed cleanup. The public would never countenance such a buy-off.  However, there are mechanisms
that might help move existing cleaners to non-polluting methods with a means of capping liability, or
perhaps transferring it to other, more responsible parties.  We do not want to see perc-based liabilities
keep cleaners from switches they would otherwise have made simply because switching makes it look as
though they're guilty. But no such mechanisms can be negotiated until the need for transition is admitted.

       We have talked with industry; trade associations such as IFI and NCA have worked with us in the
PWCP to find mechanisms for change.  We have not always agreed on where the end-points should be, or
how fast change should happen, but we all saw that the  industry is changing and wanted to use that
change to help the industry.  We all have our biases, but must seek to understand each other how each
other benefits from change that works.  Greenpeace has no stake in any cleaning technology; early on we
championed wetcleaning, as it was the only one the fit our criteria for a solution; as others come on the

 market, they too will be studied. Cleaners need help distinguishing among many methods, including all
 types of wet cleaning, other existing solvent technologies, and new emerging technologies that are just
 over the horizon. This is what cleaners look to their trade leaders for: leadership. (They may not look to
 regulators for more regulation, but clear criteria certainly help them decide which alternatives meet their
 needs.) A workable transition plan can start with a certain high-profile group, such as the co-located
 cleaners being studied in New York and elsewhere, but the lessons learned will be applicable to the whole
 country. Even now, various states such as Oregon, Minnesota, and Florida have developed different ways
 to help cleaners prioritize the decisions they need to make. OSHA's pending PEL, further EPA
 regulation, and changes to Superfund will do that even more.

        As part  of the program that led to this conference, EPA is planning to issue a document assessing
 different technologies that will help the trade associations help their members. While not regulatory in
 scope, it will start a dialogue on what transition opportunities exist. It will make it clear to cleaners that
 perc has an effect on their health—in  fact, they're more  affected by it than almost any other sector of
 society, though we are growing our understanding of how it affects customers, and people living upstairs,
 and event hose who live near where perc is made. Of course, among the cleaners, many have known for
 years it was affecting them somehow, but weren't able to admit it to themselves. In a successful business,
 they figure "There are always trade-offs", and besides, they couldn't be sure.  There are plenty of healthy
 cleaners out there, right?  Anecdotal evidence always makes it harder to understand risk. You may be
 healthy, you may not—but it's too late by the time you find out.

        Instead, Greenpeace wants to help cleaners find out how to make this change work for them. The
 same way that you feel most vulnerable when you're changing your clothes, cleaners feel vulnerable
 changing processes.  Any cleaners represented here today are likely to be larger, better capitalized
 shops—the kind that can take weekdays off. Most cleaners, as you all know, are smaller shops, most with
 only one main cleaning machine, usually perc. For them to switch, they need to know that it'll work, that
 they can afford it, that the public will want it, and ideally that garment companies will make clothes into
 the future that respond well to that process. Which is the reason for the industrial ecology approach of
 this EPA program, since it is helpful to the whole process to get the garment and textile companies
 involved if garment care processes are to change. Meanwhile, you bigger shops with more than one
 cleaning machine are the ones that can do the experimenting with carbon dioxide, glycol ethers,
 ultrasonics, and anything else that comes along. The development of all these different alternative
 processes is proof that we may not soon go back to having a major dominant solvent, as perc is now.
 That's fine—if for no other reason than to force the consumer to become more educated about options for
 fabricare they have.

        This conference is by no means the end of this process. The stakeholder process is organizing
workgroups that will extend various key efforts to making any transition work. Greenpeace has always
been a bit dubious of "voluntary compliance" programs, though DfE has gotten some major changes  in
other industries it has worked on. What it hasn't done is show an industry how to get past the expensive
control technologies and find a way out of government scrutiny and into clean processes.  That's where
the workgroups come in. To work, they must find creative ways to communicate that these alternatives
work. That's the good news. When this campaign started five years ago, the only replacements to perc
were other problematic solvents like CFCs and Stoddard solvents. Wetcleaning was being studied as an
adjunct, but there was a lot of sensible doubt as to whether I could replace perc.

       That doubt should be dispelled by now. Shops are doing 100% wetcleaning in this country, and
getting fine results. We do seem to keep getting results from some professional groups  showing that

certain wools and other fabrics kept shrinking. Certainly a danger, but it scares me that the pros can't get
it right. Maybe they're not trying hard enough; when the FCRA allowed a trained professional to work at
their own pace in a side-by-side test last year, difficult garments were wetcleaned fine. But this fact does
show that one of the most important things to be developed is a standardized test method, a first step on
the way to more environmentally sound care labeling, about which we will hear more from the FTC later.

       The main stumbling block to coherent transition planning is forethought.  Other obstacles, such as
training and incentive moneys, can be found if those who might support the planned endpoint know that it
will happen. I've seen, even in the big trade associations, a fear that no money can be available, that no
one wants to help beleaguered small businesses. That thought is a self-fulfilling prophecy. There is an
enormous sympathy for "Morn and Pop" businesses such as drycleaners, one that will last until the public
fears you are poisoning them out of ignorance and defensiveness.  The former can't be helped; the latter is
a crime they won't forgive.

       We know from big cities like New York that people like the convenience of having cleaners in
their buildings.  We also are learning that perc just doesn't belong  in residential buildings, near food
centers, or in otherwise crowded locations. If you honestly think your best option is shopping for
containment pans, floor sealants, filtered ventilation fans, and other very expensive control technology,
well, all we can say is that it's your decision. For now. But if you look closely at inherently safe
technologies like water and CO2, or becoming a drop shop and picking and choosing which methods are
used, you may be being more honest with yourself.

       No one can make the cleaners face their problems. There  is a fine line involved, where public
pressure can help cleaners make such decisions, but too much can push customers away from cleaners,
which does not help them prosper. The more there is a united front from stakeholders on the need for a
transition, the less chance there is to exert too much pressure. We may disagree on certain things—
Greenpeace has its biases, though we don't stand to make money on whichever process comes out on
top—but we can all come together to find a better understanding of what will keep the cleaning industry
viable into the 21st century.  Ken Adamson, a forward-thinking cleaner, has said that the cleaner of the
future will need to know two things: water and something else. This is solutions-oriented honesty.  One
thing I can tell you won't help is a defensive outlook. When you circle the wagons, all you get is circular

                 Industrial Ecology and the Garment Care Industry

                                      Joseph J. Breen, Ph.D.
                                   The Green Chemistry Institute
                                      Rockville, MD 20850
                                       breenj 1

        Dr. Breen currently serves as Executive Director for the Green Chemistry Institute. He is
        retired from the U.S. EPA's Office of Pollution Prevention and Toxics after 23 years of
        Federal service. During his tenure at EPA, he served as chief of the Industrial  Chemistry
        Branch and the Design for the Environment Program.
        The garment care industry faces serious challenges as it leaves the 20th and moves into the 21st
 century. Several significant forces are shaping the future of the business landscape: increasing regulatory
 controls as a result of societal demands for improved environmental performance, market demands for
 increased profitability and productivity, higher customer expectations, and changing employee
 requirements.  How the industry meets these challenges will affect the economic viability of the thirty
 thousand garment care shops across the country.

        To put these challenges into perspective, I would like to discuss with you the systems approach,
 called industrial ecology, that is being considered as a new paradigm for doing business in the future. In
 Figure 1, taken from the President's Council for Sustainable Development (PCSD), we see the PCSD's
 attempt to forecast a 50 year time line as to where society wants to be in the year 2040.  The intent is to
 inform us on how we should be expending our limited and diminishing resources from 1990 to 2040 in
 terms of remediation, monitoring, controls, and avoidance or pollution prevention..

        We see from the Figure, that in the late 1990s, the level of effort we are expanding is
 characterized by no particular set of priorities. Pollution prevention, remediation, control and monitoring
 all seem to be equally important. It is evidence of a chaotic state where we throw our money at whatever
 is the 'crisis of the day, week, or month.  This late 90's performance is contrasted with the plan to have
 most of our efforts in 2040 focused on pollution prevention, with minimal resources committed to
 remediation. I say minimal in that we will always have some expenditures of dealing with the historical
 waste sites and spill that can reasonable be expected to occur in the best of times.

        In the 21st century, the message will be clear, we will want to be expending most of our effort on
 pollution prevention. If we can do it in such a way that we do not bear the cross of liability and
 compliance costs, all the better. What does this mean for the garment care industry? It turns out, as
 illustrated by the cartoon (Figure 2) that the fabricare industry is only a part of a larger interconnecting
 web of activities that make up the overall garment industry. That industry extends from fiber production
 through textile and garment fabrication to the final care by the fabricare professional. As we learn how to
 do business in a more environmentally sound manner and promote cleaner garment care technologies, we
realize we must include them in the process. If they are to provide us with the garments amenable to the
use of more environmentally benign technologies, then we must inform them of what our requirements
are in terms of garment characteristics. We must coordinate our efforts with all  of the industries back up
the production line network.

        The fabricare industry must serve as the central impetus to the technological pull on the providers
 of garment care technology as indicated at the bottom of the cartoon.  Fabricare professionals accomplish
 this by demanding an environmentally benign way of doing business in their shops. You provide the
 market demand on the hardware and chemical distributors, who in turn express your requirements to the
 technology developers and hardware manufacturers. You must also engage the fabricators of the garments
 themselves, expressing your requirement to have garments that are amenable to proper care using
 environmentally benign processes.

        This prompts the garment producer to tug on the fabric manufacturers to construct fabrics to meet
 the new requirements, who in turn pressure the fiber manufacturers to articulate new specifications for
 fibers that will meet not only the usual fabric performance and styling parameters but also the care
 requirements.  To effect such a change would represent a highly successful 'technological pull' on the

        The cartoon also indicates a complementary approach to the technological pull on the system.
 This is illustrated by EPA's companion program, Green Chemistry, that provides the technological push
 to the fiber producers. Chemists develop, at the molecular level, the fibers that are converted into the
 polymers that are converted into the textiles. They are developing ways of learning how we do those
 things in a way that is also environmentally benign, so that you are producing polymers and textiles in a
 more environmentally benign way.

       Earlier today, I picked up on something that the keynote speaker talked about as a systems
 approach, where 1 plus 1 is 3.  In other words, there is a synergistic effect of people rowing together in
 the same direction. We need to understand that garment and textile care is only one part of a complex
 network of business and societal relationships and that technology and practice changes in professional
 cleaning need to be understood in that broader context.

       In fact, here is a graphic depicting the synergistic arithmetic for the garment care case. It is in
 the larger context of how you go from the chemist making the fibers and the polymers, all the way
 through the system of garment manufacturers and the distribution and fabricare system.

       The EPA DfE Program provides information  on product and process design for sustain ability and
 clean production and pollution prevention. We need these technological tools in order to do properly
 compare out options. The goal, from the industrial ecology perspective for the garment and textile care
program, is to understand the complex interplay of the economic forces. In the final analysis, our choices
 of technology must be profitable for them to be economically viable.

       The real challenge in this for all of us is the consumer.  We must aggressively and intelligently
build up consumer demand for environmentally benign processes. If we are to have garments produced
with environmentally benign processes, we will need to use this industrial ecology framework to facilitate
implementation through the stakeholder process EPA has in place. We will need to engage all of the
leaders from the industries beyond the fabricare professional. For the skeptics, may I suggest to you that
some of this is here today. Right now. Let me provide a real-world example.

       This Figure is from the back of the product brochure for the William McDonough Collection. It
is the fabric that is used in upholstery for chairs in the new Ronald Reagan Building in Washington, DC.
This is an interesting story of taking a mixture of safe, pesticide-free plant and animal fibers for the fabric
(ramie and wool) that at the end of its useful life was to be combustible, i.e., would decompose naturally.

 Sixty chemical companies were approached to work on developing the chemical finishes for the fabric -
 all declined. Finally, Ciba - Geigy agreed to work on the project. After considering some 8,000
 chemicals used in the textile industry, they eliminated 7,962 as being problematic. The fabric ended up
 being created using only 38 chemicals. The director of the textile mill reported the amusing anecdote of
 having the regulatory agency finding that the effluent from the mill was as clean as the influent into the
 mill. This is a real-world example of a textile product line being marketed by Design Tex.

        There are other industry leaders of technological change close to the area of fabricare that are
 present here at the workshop. The prestigious R&D 100 Award was won by Global Technologies and
 Hughes Environmental on the one hand, and the prestigious Presidential Green Chemistry Challenge
 Award being won by MiCELL Technologies on the other hand.

        This month's issue of ACS's ChemTech has several relevant articles. One is on impregnating
 porous solids using liquid CC>2. It describes how to get a chemical into the. fiber or into the porous solid.
 This relates to the issue of how to dye textiles with liquid carbon dioxide, without using chlorinated or
 aromatic solvents. This is the same technology proposed by others here in the workshop as a feasible
 technology for fabricare.

        The take home message is that we are not talking about some blue sky, theoretical possibility. It
 is happening real time, here and now. They represent green chemistry and engineering in 1998. The next
 Figure provides the critical building blocks for sustainable corporations in the 21st century that will
 provide the competitive edge in business over the next 25 years.

        The goal is zero waste through: emission and waste reduction; increased material energy and
 water use efficiencies; developing inherently safer products, processes and distribution systems; a
 reduction in the total system impact through design for the environment and life cycle analysis; and
 increased social value per unit of resource invested.  Finally, in order to drive this whole process, it is
 imperative that significant shareholder value is created so that people will invest in these technologies.

        What are the kinds of technology we are talking about? They are listed on the next Figure. They
 are those that are characterized by: high yield; low waste process technology; converting byproducts from
 what was once waste; through reuse and recycle; getting to zero waste; and making the process inherently

        Let us look at some illustrations:

        High Yield - Low Waste: DuPont Spandex fiber. They have improved their process through one-
pass production and they have it now in some facilities where they have reached 99.8 percent.  In one
facility, the waste is so low that they have shut down their treatment plant, and arranged with the publicly-
owned treatment works to accept their waste.

        Byproducts from What was Once Waste: Soil Amenders.  DuPont in one facility generate large
amounts of sulfuric acid.  Now they neutralize the acid to create calcium sulfite pellets. The pellets are
sold to peanut farmers as soil amenders.

        Reuse and recycling: Milk Jugs to Package Envelopes. A portion of the Tyvec polyolethane is
now being recycled back to produce virtually indestructible envelopes. The interesting point here is they
have figured out a way to improve the clean recyclability of polyethylene water and milk jugs and have
now reused 200 million jugs, enough to stretch around the world - twice. It is also an illustration of where



 the recycled product has higher value than the original waste. Such are the kinds of exciting products that
 arise once a group of people with the objective for getting to zero waste are mobilized.

        Getting to 'Zero Waste: Soil substitutes. DuPont at one facility generated a large amounts of iron
 chloride which they landfilled. With their zero waste policy, they found—that instead of landfills - they
 can place the iron chloride in a tank, treat it and then create another product called iron-rich, which is a
 soil substitute.  They now have a revenue stream from what they used to consider a waste and landfilled.
 This illustrates the concept of .atom economy, where every atom that goes into the process comes out as a
 product or a useful byproduct.

        Making it Inherently Safer: ROTIM. In terms of making waste inherently safer, there is ROTIM,
 the recycle or throw it in the mixer way of doing business. This is a process where you throw the
 neoprene monomer and the bag (made of a resin) in which the monomer is packed directly into the mixer.
 This eliminates occupational exposure to the monomer, and there is no packaging waste. Everything gets
 used. And there have been actual examples where the presence  of that small amount of resin has actually
 improved the process and the performance of the product.

        Obviously, I get excited about these developments. This is  green chemistry. There are a lot of
 things going on in this arena, some of them very directly applicable to the fiber, textile and garment care
 industries. EPA, as well as the Office of Industrial Technologies at DOE, are having a workshop in April
 on dense phase fluids, an alternative reaction media where applications to fabricare will be discussed.
 The University of Massachusetts is having a similar workshop in June on polymer R&D in green
 chemistry. We will be discussing how to make polymers for fabrics that will be suitable for green
 garment care.

        Green Chemistry is an international phenomenon. The First International  Workshop on Green
 Chemistry in China will be held in May.  We will be taking both Due and Green Chemistry materials
 there to educate participants on recent research and developments. A similar conference, the Mendeleev
 Chemical Technologies Conference in Russia, where, again, we  will be taking the Due and Green
 Chemistry information to share with them on the garment and textile care process.

        The importance, as Ed Barlow made the point this morning, is that we need to generate
 international markets for these technologies in order for them to  be economically cost competitive. We
 need to  develop international global level systems so that the price of the liquid CO2 technologies or the
 other environmentally benign technologies really becomes cost competitive as we develop the market for

        I hope I have persuaded you that you are participating in something that is both technically and
 economically exciting, and that it is important in terms of the way society does business. I am very
hopeful that the outcome from the breakout sessions during this workshop will be a series of game plans
to move forward in implementing an industrial ecology approach for the garment and textile care
program. If successful, it will serve as a model for other industrial sector projects.

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                             A Cleaner's Vision of the Future

                                           Buster Bell
                                     Bell Laundry and Cleaners

        Walter (Buster) Bell is a seasoned professional in the laundry and drycleaning business.
        He founded his  first  drycleaning business in  1954.   He  is actively  involved with
        environmental certification efforts for perc and petroleum cleaners.
        We are talking about moving into new technologies for the industry but first, we have to reach the
 industry. At this time, we are able to reach possibly one-third of the industry. The associations are not
 able to reach the rest and neither is EPA. To get on with the future, we need a better method of reaching
 this segment of the industry to provide them with the necessary educational materials.  The only way that
 I see that we can reach this segment of the  industry is through meaningful certification programs and the
 actual certification of certain pieces  of equipment, requirements within plants themselves and of the

        The certification should include the participation of both Greenpeace and OSHA. In other words,
 the industry and the regulatory agencies need to mesh. We don't need to be at odds with each other. We
 need to find solutions to get this segment of the industry to the tables. We need certification programs
 that include floor coverings and containment tanks. We need to do away with things like small generator
 classification and transfer equipment. All these things are in the past and we need to move on.

        We need to find a method that is enforceable and manageable.  Part of that process would tie the
 cleaner doing these certifications and certification on equipment, floor coverings, and things of this nature
 to the purchase of solvents. In this manner, we can bring forward new technologies and stop continuous
 contamination now, which is very important to all of us.

        The only way is to tie all this together is through the purchase of solvents. Without this, we are
 not going to reach two-thirds of the cleaners out there to educate them, to teach them what wetcleaning is,
 what carbon dioxide is.

       In South Carolina we passed legislation creating an environmental trust fund for ground water
 contamination.  We put rules in to stop continuous contamination.  But we made one mistake. We should
 have tied it back so that these things  were done by solvent.  Right now, we are going to have to run on an
 amnesty program because 50 percent of the cleaners did not take their certification, did not put
 containment tanks in, or did not even attempt to purchase third party liability insurance.

       The legislation was put there to protect the cleaner. Last week, I had a cleaner call me.  "I am in a
 world of hurt, I am going to lose everything I have.  I can salvage my home if I can sell my business. I
 am not in the fund. Nobody will buy this business from me," he said.

       So, he would have to go back—we  will have to run an amnesty program through the state
 legislation to bring these people in after they finally meet the qualifications.  But if you tie all this back to
his ability to buy his solvent, you will get his attention. You will get him to where he will attend
meetings, he will learn, or else he will decide he doesn't want to be in business.

       We need workable solutions. At this time, this, I think, is one of the most workable solutions we
can up with to reach two-thirds of these cleaners.

                  Introducing Customers to New Cleaning Processes

                                           Ed Boorstein
                                         Prestige Cleaners

         Edward B. Boorstein has been an owner-operator of drycleaning businesses and plants
         since 1951. Over the years he has had as many as 13 locations, but currently all of his
         focus is on Prestige.. .Exceptional Fabricare.

         At your seats you have some examples of some of the educational initiatives my company has
 undertaken to introduce wetcleaning and our particular focus on people who have chemical sensitivities. I
 am going to speak about introducing the public to new professional fabricare processes and I am going to
 ask you to bear with me because I want to read this. I don't think I could speak extemporaneously and get
 all these thoughts to you, so I have organized them.

         One of the most successful, seamless, low tech point of sale campaigns to alter public
 consumption habits is the supermarket checkout question, "paper or plastic?" Notice, that true to the
 tenets of suggestive selling, plastic has the final word, has the best chance of having the most impact.

        I bet that most groceries leave the market in plastic bags. What if every fabricare professional
 offered every customer the at-the-counter choice, "dryclean or wetclean?"  Notice that wetclean is the
 final word. I bet that public understanding of this new process, wetcleaning, would be assured faster than
 you could say drink Coca-Cola. But I believe that this is an unlikely scenario.

        There are inherent risks in pioneering a stance and a myriad of interrelated impediments to a bold
 courting of wetcleaning business, many of which are beyond the ability of the professional cleaner to
 overcome. Wetcleaning is as old as the river and as new as today and now is the only fully realized
 fabricare alternative to petrochemical immersion.

        The acceptance of wetcleaning is limited first by public perception. Mention water and the
 immediate customer response is likely to be, oh, I will wash it at home then. The average cleaner's
 inability to articulate as a professional plays into the public's general apathy about any fabricare process
 until something goes wrong and then the cleaner is assumed by the customer to have damaged or
 destroyed an article through ignorance or negligence.

        Most often, the manufacturer or designer is sacrosanct and the more expensive the article and the
 more expansive the designer's celebrity, the more invaluable the aura. The  fabricare industry lacks the
 economic clout to challenge the operative cliches reinforced by media and standup comics, that the
 cleaner lost my shirt, broke my buttons, ruined my suit and, of course, overcharged, especially women,
resulting in the classic topper of "being taken to the cleaners."

       Rodney Dangerfield said it best. "We don't get no respect." And the proliferation of the one
price discount cleaners and the dominance in urban centers of plant ownership by new immigrants with
limited English communication skills fuel the public impression that cleaning is cookie cutter simple
rather than art and science practice by true professionals.  The fabricare industry seeks respect from
government and finds itself in expensive opposition to local and state initiatives that threaten industry
survival. Most importantly, Federal environmental statutes have caught fabricare businesses in a web

meant for Love Canal level polluters and have saddled drycleaners with an ex post facto law, which many
believe, as I do, should be ruled unconstitutional.

       Perchloroethylene is the solvent used by about 85 percent of America's drycleaners, all of whom
live under a sort of Damocles.  It is paradoxical that this visionary arm of the Environmental Protection
Agency, the Design for the Environment, has enlisted fabricare industry cooperation in seeking
approaches, which could limit the use of petrochemicals, thereby compromising plant owners' lifetime
investments, while EPA's Enforcement Division has the potential to bankrupt almost all of those 85
percent who clean with perc.

       Let's look at the psyche of America's average drycleaner. He feels attacked by his government,
fearful that he may lose both his business and his life savings, concerned that maybe the cancer scare
stories are true. He is unsure of customer loyalty as one-price discounters appear in major neighborhoods.
He has limited space, limited capital, and really doesn't want to add to his notes or risks by embracing
wetcleaning. Despite all the technical assistance his trade association, if he is a member, can provide, he
feels he lacks the  ability to communicate effectively with his customers, many of whom don't respect his
industry or him as an expert in his craft.

       The moms and pops of the nation's fabricare industry are tired, tired from stresses and from
working 12 hour days, six or seven days a week and, even if they are closed on Sundays, coming in to do
book work or machinery maintenance. Despite Money magazine's portrayal years ago of drycleaning
millionaires, most cleaners buy a job and they make no more than a decent living. They have washed
articles, as necessary, as long as they have been in business, but large-scale wetcleaning as an alternative
to their perc machines is going to be a hard sell.                                  .

       The analysis laboratories of the International Fabricare Institute and the Neighborhood Cleaners
Association International have archival histories dating back through at least five decades of apparel and
household articles that did not withstand normally accepted professional care practices.  The advent of the
Federal Trade Commission Care Labeling Rule hasn't stemmed the flow of unserviceable merchandise.
Although manufacturers are required to assure that no harm will come when care label instructions are
followed, the analysis labs year after year report fugitive dyes, dimensional distortions, loss of sizings,
and other disasters, even when care instructions were presumably followed.

       Now, add two new variables: care labels as symbols only, no print instructions—to which,  despite
the potential for confusion, FTC is committed.  The FTC is not ready to develop a separate professional
wetcleaning symbol. So, if the cleaner makes a mistake in judgment, it could be the fabricare
professional who is hung out to dry.

        These perceived impediments are not presented as a rationale  to forget about large-scale
wetcleaning, but they are posited to continue to use aqueous metaphors to offer the cold water of reality.
Water may be the universal solvent but it is not accepted at this time by the fabricare industry as the
universal solution, nor in my opinion should it be.

        Wetcleaning should be viewed as a controllable adjunct  to drycleaning, not a replacement.
Exactly one year  ago, my plant entered the mixed use category and I have a moderate success story to
relate to you. I replaced my 20 year old dry-to-dry perc machine with a petroleum unit using Exxon's
DF2000 fluid and added two computerized wetcleaning machines, a computerized dryer, two
conditioning presses, and a new age wind whip. Fortunately, my cleaning technician is Elaine Harvey,

  former EFI instructor and garment analyst.  And I was counseled by Anne Hargrove, who ran Chicago's
  Greener Cleaner, the hundred percent wetcleaning shop. Our experience has been most favorable.  We
  wetclean about 30 percent of our customers' articles, based upon their requests or our judgment of the
  appropriateness of the water treatment.

         We have not experienced one single damaged piece. I attribute this record to the excellence of
  the technology, Anne's instructions, Elaine's wisdom, and our finishers' hand skills. We announced the
  new technology last April in a mailer to our regular client base and by display information in our call
  office library. We conduct plant tours and advertise in a holistic health magazine.

         Our service approach has been the subject of an article in The Washington Post Home Section. A
  front office mannequin wears a woolen sweater, woolen sport jacket, and pants, all identified with a
  pinned-on sign saying "I was wetcleaned."  Our outdoor signage and all company stationery state, "New
  Cleaning Technologies, Kind to Clothing, Allergies and Ecology."  In an adjacent building we have
  established the Prestige Fabricare Education Center offering instruction to groups and individuals in
  selection and care of apparel and household textiles.  I chose to switch from perc to petroleum partly to
  avoid the stigma with which perc is now associated, but mostly because the lower KB fluid is more
  appropriate as a cleansing agent for the preponderance of delicates we process.

        I have been extremely vigilant to introduce our petroleum cleaning and wetcleaning in positive
 ways and decry the cancer scare tactics used by some weteleaners in promoting their services. Although
 my company is fortunate in having people with fabricare knowledge and developed technical and
 communicative skills, we are nevertheless conservative in offering that new technology called
 wetcleaning. In cases where we recognize high risk processing factors, we  employ a customer agreement
 form and it is no mere disclaimer. We advise our customers to choose wetcleaning if one or more of
 these criteria exists.  I will skip that because it is on the handout if you look at the wetcleaning form there.

        I want to emphasize that the circumstances under which my company offers wetcleaning are far
 from typical. I operate a high end business and have done so for the past 18 years in one of the wealthiest
 counties in America.  My customers are nearly all well-educated, intelligent, and aware. As a senior
 citizen, whose children are grown and  established, I don't face the economic pressures of the average
 fabricare professional. The fabricare industry awaits the proven viability of the newest processes, Rynex
 and liquid carbon dioxide. Until they have been field tested significantly, water remains the new process,
 which needs to be effectively introduced to the public.

        Given all the impediments to which I have referred, I believe that the average drycleaner in
America is not in a position to effectively introduce and market wetcleaning. Although the fabric trade
 associations provide abundant technical assistance to membership through illustrated bulletins, classes,
 and field demonstrations, the associations do not have the public's ear.

        Even a public service media campaign by EPA would disappear without an impact for lack of
context. It is the fashion industry, apparel designers, manufacturers, retailers, the media, and perhaps
most importantly the mediagenic fashion and entertainment and sports superstars, who can show the way.

        A significant portion of stylish  apparel must be truly professionally wetcleanable and are clearly
not home washing candidates. Only the designers can choose the combinations of dyes, weaves,
construction, and trims which will be safe to water process. Only the fashion/entertainment confluence

can offer the excitement which will rivet the public attention vital to a massive effort to redirect public
dressing and fabricare maintenance habits.

     .   EPA's Design for the Environment is wise to have courted the upstream components of the textile
apparel chain to join in a dialogue at this conference. I have a vision that the burden of unfair calamitous
environmental legislation will be lifted and that the truly remarkable successful efforts of the fabricare
industry to clean up its own act will be recognized, that the realities of public education will be faced, that
serviceability and wear and care will be fashion's first concern, and that fabricare will assume a proper
role as a legitimate partner, not an adversary, of the fashion world.

        To the fulfillment of that vision, I propose a "fashion meets fabricare" summit in New York City,
initiated and coordinated by EPA's Design for the Environment to further the stated objective of seeking
an ever cleaner environment.

        Thank you.

  Fabricare  Professionals...Sustaining Life
     First, let's get the terminology right: we
     are not drycleaners. We.'re fabricarists;
  fabricare professionals. Throw in furs and
  leathers, and we go beyond care for fabrics
  and textiles. What's needed is a compre-
  hensive term to encompass all of our refur-
  bishing services.
    For now, I'll settle for fabricarists. We
  sustain and prolong the useful attractive
  life of valued clothing and household arti-
  cles. We provide cleanliness and crispness
  to contemporary humankind's visible
  shells. We make possible the ubiquitous
 garment industry and enhance public
 choice of colorful and warmth-providing
 household goods.
    Fabricarists' services support, for good
 or for ill, the two-worker family which has
 become a vital element of our ever ex-
 panding economy. And despite wash and
 wear and easy care and frumpy Fridays
 and soapless "miracle" home washing
 products, I am convinced that so long as
 we fabricarists provide the level of profes-
 sionalism of which we are capable, we will
 sustain the life of our industry.
   Okay, there is obvious retail room for
 limited-service, low-priced cleaning facili-
 ties, but the industry center, which must
 hold, is characterized by the client-focused
 fabricarist dispensing all the familiar
 virtues of friendliness, courtesy, reliability
 and ethical practices along with technical
 proficiency and the unending devotion to
 quality and service that define the true
 professional in any line of endeavor.
    We fabricarists sustain our lives,  the
 lives of our co-workers, clients, the public
 at large and the ecology of the universe, as
 we seek, find, and develop for usage  the
 safest and most environmentally respectful
 products  and methodologies  possible.
 Sure, our awareness was raised by the
 sometimes "friendly fire" of government
 agencies and issue advocacy groups, but
 our industry has responded, has conceived
 technologies undreamed of a few years ago
 and currently awaits the viability of new
 professional fabricare capabilities that are
 visible now on the horizon.
   Eight years ago  I contributed to the
American Drycleaner a personal memoir
which was printed under my title, "Seek-
ing Serenity at Sixty." Perhaps, oddly, I've
found my "serenity" in continued demand-
ing, hands-on  (and mind-on) absorption in
The former Prestige Cleaners, Silver Spring, now has its own distinctive identity—and earns it.

58                                             AMERICAN DRYCLEANER, JANUARY 1998

my company and my industry. I have been
blessed with reasonably good health, a lov-
ing family and a loyal, caring staff, and I
am sufficiently financially secure to have
invested,  with serenity,  $175,000  in the
one plant I have retained  (in Silver Spring,
Md.) and recently re-named Prestige...
Exceptional Fabricare. Prestige's signage
and all printed matter contain the descrip-
tor: "New Cleaning Technologies, Kind to
Clothing, Allergies and Ecology."
   After 40 years as a perc plant, Prestige,
since March, 1997, is  now exclusively an
Exxon DF-2000 petroleum facility—offer-
ing,  additionally, computer-programmed
wetcleaning as well as our hand washing
and bleaching skills. We built new coun-
ters, carpeted the front half of the store,
removed ancient pitted tile in back, painted
over the resultant uncovered concrete with
shimmering gray deck paint and scrubbed
and painted everything else in the building
that  did not move. Now, I'm  proud to
guide customers on plant tours showing
our "eat off the floor" cleanliness, which I
feel is motivation to maintain this state.
   As I explain the new  technologies and
Ruth and Ed Boorstein find extra serenity
occasionally visiting with their grandchildren
—in this case, Hannah, in California.
their benefits, I have found the revitaliza-
tion of my business exhilarating, and my
enthusiasm, in turn, is  inspirational to my
customers and  my  staff. It was the  right
life move for me to make and our  sales
growth, although not spectacular, is  reas-
suring, as my business has met the new
note payments with ease.
   The "kind to allergies" statement  grew
from drycleaning and wetcleaning service
that I have provided personally to Mrs. H.,
a customer whom I  first met in 1980, after
I bought Parkway Custom Drycleaning, a
high-end petroleum  plant in Chevy Chase,
Md. Parkway is now  owned by my son
Steve (who is doing very well, thank  you).
Mrs. H. is terribly reactive to perfumes and
fragrances, and we developed a whole list
of do's and don'ts to protect her from their
intrusion. Her requirements inspired me,
when Prestige  became a petroleum/wet-
cleaning facility, to use only fragrance-free
detergents and conditioners and to seek to
serve the chemically-sensitive population.
I even  found a fragrance-free liquid  hand
soap that's used by hospitals, and all of our
involved staff scrub their hands in "ER"
fashion before touching articles processed
for the chemically sensitive.
   Our efforts for the allergic have not yet
proven to be a panacea and may never be.
Chemical reactivity is  idiosyncratic.  With
each transaction, I learn more safeguards
to include in our processing protocol.
Almost all of their articles are wetcleaned
and finished  on dedicated specialized
presses, because my chemically-sensitive
clients have informed us that whatever
residual perc, petroleum or perfume odors
remain in press pads  where drycleaned
articles are finished, can precipitate their
allergic responses. The program is not at
this time a "profit  center."  It presents to
me a frustrating but challenging intellectu-
al exercise, an  opportunity to do a social
good, access to practitioners of conven-
tional and alternative health care, a public
                                                  AMERICAN DRYCLEANER, JANUARY 1998

   relations entree, a chance to involve my
   staff in a noble purpose—and, just maybe,
   it will eventually be profitable.
      I write my own  advertisements and
   information pieces, again, for good or ill.
   As a life-long, third generation  fabricare
   professional, I would not knowingly depre-
   cate industry use of perc and have crafted
  my public  statements about our petrole-
  um/wetcleaning capabilities in the most
  focused, positive way  I can.  I  love the
  "hand" that petroleum imparts  and appre-
  ciate its relative safety for delicates.
     Although petroleum is a low toxicity
  solvent,  as  a petro-chemical it remains a
  target of advocacy groups and numerous
  individual "green" people. These  folks do
  seek professional wetcleaners and EPA has
  listed Prestige as such. The designation has
  found its way to the Internet, generating a
  trickle of new customers  which I hope will
  grow to a floodtide.
    So much of contemporary life  seems
  focused on simplifying and standardizing,
  seeking "no brainers." I believe  that life is
 most fully realized in engaging the mind to
 master complexities. As I contemplate  the
 possibility that technological progress rep-
 resented by liquid carbon dioxide cleaning
 could be  the industry's future and render
 my investment obsolete before I make the
 last note payment, it does disturb  my
 serenity.  But I have faith that Prestige's
 professionalism  will sustain its  life and I
 look forward to soldiering on for as many
 more years  of healthy capability as  the
 good Lord gives me.

 Edward B. Boorstein has been an owner-operator of
 drycleaning businesses and plants since 1951, when he
 opened his first business, a drop store, while still in
 college; his first plant opened in  1957. Over the years
 he has had as many as 13 locations, but currently all of
 his focus is on Prestige... Exceptional Fabricare.
   Ed holds a B.S. in marketing and an M.A. in labor
 history/urban studies, both from the University of
 Maryland. In 1956, he also took the three-month
 General Course and Management Course at IFI's pre-
 decessor, the National Institute  of Drycleaning, and
 since then has taken assorted specialized classes.
   He is a Certified Environmental Drycleaner and
 Certified Professional Drycleaner. He has served as
 president of the Metropolitan Drycleaners Association
 and as secretary, treasurer and currently membership
 director of the Mid-Atlantic Cleaners and Launderers
 Association. He has chaired IFI's Quality Assurance
 Peer Group since 1996. He conceived, planned, pro-
 moted and chaired a series of drycleaner-retailer-con-
 sumer seminars through the '80s to help develop com-
 munication, cooperation and understanding among all
 the elements of the "textile chain." In 1988 he wrote
 and helped produce for the Metropolitan Drycleaners
 Association a 10-minute video, "Material Witnesses,"
illustrating the interrelationships among all of those
elements. He may be reached at (301) 588-0333.

For the chemically-sensitive unable to tolerate dry cleaning...
     For the environmentally aiuare searching for "Greener" solutions.
                            A NCUI fllT€RNRTlV€ FflfiRICftR€ TCCHNOLOGV...


An environmentally responsible professional fabricate answer for many of those who are severely reactive to petro-
chemicals, fragrances and perfumes and/or committed to the "greener" way.

Our fragrance-free wetcleaning technology permits us to clean in water without shrinkage up to 70% of clothing and house-
hold articles that are care-labeled "dryclean only". Yes, wools, silks, linens, rayons and cashmeres. Even the most well
designed home washing machine is unlikely to match the capabilities of our computerized wetcleaning equipment.
Micro-processors control water temperatures, cylinder speeds, mechanical action and moisture removal. Special condi-
tioners protect the "hand" or feel of a garment's fabric. Our micro tumbler provides 10 levels of sensor monitored dry-
ing and our Pensioning" presses complete the process by aiding the retention of original dimensions.

We maintain a dedicated "chemically sensitive" area and scrub our hands with a fragrance-free soap in "ER" fashion
before handling articles belonging to our chemically sensitive clients.

For the  remaining 30% of articles which cannot be wetcleaned safely, we offer drycleaningwith a difference; a non-chlori-
nated, fragrance-free, virtually closed circuit, near odorless, uniquely gentle hydrocarbon process; ideal for the most
delicately constructed articles.
        Preslige...€xceptional Fabricate is listed by €Pfl and Greenpeace as an accredited uietcleaner.
                 Hands-on owner-operator since 1964;
                 45 year industry veteran; contributing
                 writer American Drycleaner magazine;
                 Certified Environmental Drycleaner;
                 Certified Professional Drvcleaner
Master Cleaning technician;
35 year industry veteran;
former technical instructor,
textile analyst and lecturer at the
International Fabricare Institute
       Ed Bimrslein
                                                Elaine Harvey
           Should you wish to discuss our methodology, please call €d or €laine at 301 -588-0333.


Please present this coupon with an incoming wetcleaning or
drycleaning order and a $5.00 credit will be applied.
Offer expires May 31,1998
9420 Georgia Avenue, Silver Spring, MD • 20910 • 301-588-0333
• !
.* 1
                PR€STIG€...€tC€PTIONRl  FRBRICRRC
                 New Cleaning Technologies Kind to Clothing, (illergies, & ecology
  9420 Georgia Avenue, Silver Spring, MD 20910   301-588-0333  Fax 301-588-7914

9420 Georgia Avenue,  Silver Spring,  MD 20910   301-588-0333     Fax  301 - 588-79 1
       Kind To Clothing
       Professional Wetcleaning^ is an alternative to the time consuming task of home washing and ironing of articles
       care labeled "washable" and for much clothing care labeled "dryclean only".  Wetcleaning is often a necessity for
       restoring " dryclean only" items with large amounts of water soluble staining, water "rings" or bleachable
       yellowed or dingy areas.

       Even the most well designed home top loader is unlikely to match the capabilities of our new Unimac VF 18 wet-
       cleaning machines. Micro-processors control water temperatures, cylinder speeds, mechanical action and moisture
       removal.  Special conditioners protect the "hand" or feel of a garment's fabric. Our Unimac micro tumbler pro-
       vides 10 levels of sensor monitored drying and our Veil "tensioning" presses complete the process by aidina the
       retention of original dimensions.

       Kind To Allergies*
       For people with petro-chemical sensitivities. Wetcleaning is a viable alternative in maintaining most silks  wools
       rayons, linens and  cottons which are care labeled "dryclean only". All detergents, conditioners and sizings thai
       we use have been customized to our specifications to be fragrance-free. Finished articles should retain no odors or

       Kind To Ecology
      All of our wash products are non-toxic, chlorine and phosphate free and biodegradable.
      Dry cleaning
    ' Kind To Clothing
      Our new Permac K25 cleaning machine uses DF 2000 hydrocarbon fluid, developed for the drycleaning industry
      by the Exxon Corporation. DF 2000 is an extremely mild solvent ideal for safeguarding soft fabrics delicate
      constructions, sensitive dyes and fragile trims such as sequins, beads and pearls. The solvent imparts a soft
      luxurious "hand" or feel to all fabrics.

      The Permac machine is computerized and multi-programmable so that it can be bathtub gentle for fragiles and
      increasingly active as garment durability and state of soiling demand.

      Kind To Allergies*
      DF 2000 fluid is a non-chlorinated, nearly odorless solvent.  All detergents, conditioners and sizings which we use
      have been customized to our specifications to be fragrance-free. Permac's drying sensor assures that cleaned arti-
      cles arc dried thoroughly. No odors or residues should remain.

      Kind To Ecology
      The Permac machine is a combination drycleaning and drying unit; a closed circuit virtually emission free and
      Exxons's DF2000 solvent is so mild chemically that EPA classifies its filter and distillation residues as non-haz-

      *Please understand that we intend to work closely with chemically-sensitive clients to render irritant-free results
     but we cannot and do not guarantee at any time that this goal will be achieved.
          New Cleaning Technologies Kind to Clothing, Allergies, & ecology

9420 Georgia Avenue,  Silver Spring, MD  20910  301-588-0333
                                                                       Fax  301-588-7914
     tifr W  W w W ^^^  ^* WWW ^f  » ~ ~ ^^^r                                 ^k       .^M     M.
  The New  Prestie Fobricore education Center
 Ed Boorstein
 Ruth Boorstein
     i/ * ::
                           Free  Seminars  on  Clothing  Care
              TO:  Prestige Customers, Schools, Church and Synagogue Groups, Clubs, Sororities,
                   Fraternities... and Interested Individuals

              WHAT'S INCLUDED:   Drycleaning plant tour, video on serviceability, explanation and
                                 discussion of new "pictures only" clothing care labels. Question
                                 and Answer segment on any aspect of clothing selection,
                                 professional and home care.

              WHEN:  Daytime sessions for students by appointment,
                      Wednesday evening sessions for adults from 7:00pm to 9:30 pm

              WHERE:   At Prestige—exceptional fabricare
                        9420 Georgia Avenue, Silver Spring, Maryland

              WHO'S TEACHING:  Elaine Harvey, Prestige staff technician and former International Fabricare
                                Institute instructor, textile analyst and national lecturer;
                                Ed and Ruth Boorstein, longtime Prestige owners.
                                Various guest lecturers
              HOW TO SIGN UP:
                                Just fill out the form below, detach it and either leave it
                                with a member of the Prestige staff at the store, or mail it to Prestige at
                                the address above.
              QUESTIONS? Please call Ed Boorstein 301-588-0333
 Elaine Harvey
Group Name   _
Individual Name
                                                     .Contact Person.
                                                     _ Home Phone .
                                                      Work Phone  .
Dale interested in attending: Wednesday,.
                          or Other Choice.
           New Clconing Technologies Kind to Clothing, flllcrgics, & Ccologv

           PR€STIGC...€XC€PTIONDI.  FflBftlCDRC
9420 Georgia Avenue,  Silver Spring,  MD 20910  301-588-0333    Fax 301-58.8-791


       Wetdeaning is a care option we offer
       1. In cases where only water processing will assure optimum spot/stain removal of water soluble
       elements such as heavy soil, large areas of beverage spills or body fluids.

       2. To combat yellowing, greying, dulling or dye transfer.

       3. To those who, because of their environmental concerns, choose to avoid a petro-chemical
      cleaning process.

      4. To those whose chemical sensitivities preclude a petro-chemical care method.

      The term "weteleaning" encompasses all water immersion care methodology from "dipping" in
      cold water, hand washing, bleaching and dye stripping to use of our "new technologies" micro-
      processor programmed wetcleaning washers featuring controlled water temperatures, cylinder
      speeds, mechanical action and moisture removal.

      In wetcleaning we use only biodegradable, fragrance-free detergents, softeners and conditioners
      which contain neither chlorine nor phosphates. We choose, as appropriate, one of four gentle
      drying methods; air, warm air blower, warm air cabinet or micro-processor dryer. After
      wetcleaning and drying, we condition garments on our new "tensioning" steam air finishers to
      relax fibers which may have contracted.

      If an article is care labeled washable, responsible wetcleaning should be virtually risk-free, but
      wetcleaning a drvclean only, piece, contrary to manufacturer instructions, does present concerns
      chief of which are:                                                             '
                        Dimensional change - shrinkage, stretching, distortion
                              Change of "hand" or feel; loss of sizing
               Color change (try to wetclean all parts of a matching outfit at the same time)

      We employ our technologically advanced equipment, fabricare knowledge and hand skills to
      wetclean with maximum safety,  beginning with making sound judgments in determining suitable
      wetcleaning candidates.  We ask that our clients sign below to share the responsibility by
      authorizing the process in full knowledge of the risks involved and agree to hold our company
      "harmless" should change due to the  water process be uncorrectable.
     Customer Signature authorizing water process
                 Chemically sensitive  /	/ yes   /	/no
                 Measuring required   /	/yes    /   /no
         New Cleaning Technologies Kind to Clothing, flllergies, & ecology

                       The 100 Percent Wetcleaning Operation

                                         Debra Davis
                                       Cleaner by Nature

       Deborah Davis is the founder and owner of Cleaner by Nature, a 100 percent wet-
       cleaning operation. Currently, Cleaner By Nature has two stores in Santa Monica and
       West Los Angeles.

       Thank you very much for inviting me to be here today. I must admit that being the only 100
percent wetcleaner on the agenda, I was a little bit concerned about the kind of reception I might get
today.  So, I can put you all at ease right now by saying I am not here to tell you to switch to wetcleaning.
In fact, as a business owner, it is really not in my interest to ask you to switch to wetcleaning. Frankly, I
kind of like having a lock on that market and I am not looking forward to a lot more competition.

       Now, I do have to tell you that I do believe that a switch to alternatives is inevitable and I am here
today not so much as a business person but as a consumer and as a concerned citizen telling you that I am
eager to help other progressive business people who want to switch to these alternatives quicker and
succeed in the future. But the choice really is yours.

       I will tell you briefly about Cleaner By Nature. As mentioned in the introduction, we are a 100
percent wetcleaning facility, but more than that, you need to understand that Cleaner By Nature is a
progressive future-oriented company. We are operating in the future already. We recognized the
convergence of social trends and technological developments and we got involved in these changes ahead
of the curve.

       In our two years of operations, we can now say that wetcleaning is no longer a matter of proving
whether or not it works. Wetcleaning is no longer an emerging alternative, but a proven technology, as
mentioned by one of the speakers this morning.  Furthermore, wetcleaning's success has helped spawn the
rush to market for some of the other alternatives. The genie is out of the bottle. The alternatives are
coming.  The industry is going to change and Cleaner By Nature, I believe, is on the leading edge of that

        I am here today to provide my perspective on how the stakeholders in this  room can make this
change happen more quickly and to the maximum benefit of everybody here. Again, having the unusual
position here of being the only 100 percent facility, I would like to directly address the goals of the
conference and provide you with my perspective on those goals.

        The first goal was to hear about the latest research on new cleaning technologies. Well, there is
no better research laboratory than the real world, right? And I can tell you Cleaner By Nature is two
years old. We are still a small company, but we have grown quickly in that amount of time. We are
processing approximately 6,000 pounds of garments per month.

        We had a profit margin last year that was comparable with industry standards and we just opened
our second store last week in West Los Angeles. So, now we have two agencies and a central plant with
plans to open more. I won't go into that any further. I know that there are others on the program, both
today and tomorrow, who are going to discuss more specifically results from wetcleaning.

          The other goals of the conference are to talk about exchanging ideas and information toward the
  development of long-term plans for incorporation of pollution prevention practices, to engage the textile
  and apparel industry and regulators in dialogue about what can be done to address these emerging
  alternatives, and wetcleaning in specific. To the regulators I say, first of all, recognize that the industry
  has changed. As I said, the genie is out of the bottle.  The change is happening. It is no longer a question
  of if, but when, and how quickly. Why is it changing? First of all, customers are demanding it.

         As we were able to show in our market, and as other wetcleaners are showing in their markets,
  when customers understand the factors involved and that they have an alternative, they want the

         Secondly, entrepreneurs are demanding the alternative. Folks like me and others out there want
  to get involved and push these new technologies.  Landlords are demanding it.  I haven't heard that issue
  raised yet today.

         But, I say to the drycleaners, even I am having difficulty looking for sites. The first thing a lot of
  the landlords and real estate brokers are telling me is we don't rent to drycleaners.  So, that is another push
  factor. And fortunately, the manufacturers are obliging us and  stepping forward and creating these
  technologies to meet the demands of the groups that I have mentioned above.

         So, recognize first of all that this is an industry that really has changed. I shouldn't say is
  changing. It has changed. The change is in process. Get on board now.

        The next thing you can do is facilitate the development and acceptance of these alternatives.
 What you are doing today is a wonderful step in that direction.  I commend the EPA for holding this
 conference today. You could also help to get information out to the public about the industry and about
 the changes happening.

        Furthermore, enforce current regulations on drycleaners and give incentives to help them change
 to these new technologies.  They can add wetcleaning as part of a mixed use  facility and eventually
 switch over entirely.  Use both the carrot and the stick to make this happen.

        Supporting a network of alternative cleaners would also be very useful to us out there. I think we
 have our own set of needs, having a network or a guild or an organization that would help us speak to
 each other, communicate with each other, improve our services, and improve public education would be
 very helpful in helping facilitate this change. Finally, encourage the textile industry toward certain
 beneficial practices.

        The other group we want to address today is the textile and apparel industry and really, Ed did a
 very good job of summing that up, that you are exactly right.  The textile and apparel industry plays a
 very important role in helping the fabricare industry to succeed ultimately.

       Start by making garments that are more friendly to environmentally friendly alternatives.
 Specifically test these garments for compatibility with alternative processes and label them as such. This
has other benefits for you. First and foremost, it is going to increase customer satisfaction of your
product.  You can start marketing your product not only for its beauty and its style, but also for its

       Remember that our speaker this morning spoke about value-added being very important in today's
economy. That is a value added that you can put on your products by saying, not only are they stylish,
but you don't have to pollute the environment by having them cleaned.  It also improves your image and
reputation as a company that is progressive and environmentally friendly.  Finally, the textile and apparel
industry can also be supportive of a network or guild for environmentally friendly cleaners.

       The last two objectives were to review challenges and barriers to certification to gather proposals
for voluntary joint stakeholder-led projects.  Again, I want to stress this notion of a network and I am
willing to step forward today and take the lead in organizing such a network if others will help support

       This network would help provide the education and training that was spoken about by both of the
previous speakers. We do need good education and good training programs as these alternatives emerge
and ongoing training and education as new developments come about.

       We also need to educate the public. A network like this would be useful in distributing good
public information. We need policy support. We need to be  aware of what is going on in policy arenas
and in forums like this and a network would help us get this information out.

       I think that certification also makes a lot of sense. I really believe that in the future it is not going
to be just wetcleaning as an alternative,  but probably a combination of alternatives. That is going to make
the whole industry that much more complicated. I think certification would be a very useful tool for
cleaners  and for the consumers.

        In conclusion, I want to say that Cleaner By Nature recognizes what Ed Barlow said this morning,
that we are not really in the cleaning business. We are in the business of creating and supporting people's
lifestyles, their lifestyle choices.  That is how we see our business. We are already living in the future,
operating in the future and we welcome anyone else out there who wants to join us.

        Thank you very much.

                          A Business Perspective on Wetcleaning

                                           Ken Adamson
                                   Canadian Fabricate Association

         Ken Adamson is currently President and sole shareholder of Langley Parisian Limited
         since 1984.  He has been particularly active in the fields of occupational health and safety
         and environmental issues.
         Thank you very much, Bill.

         I grew up in the drycleaning business and I had the great fortune of being trained by people with
  the level of experience that Bill has. I also grew up in what we call in the industry a mixed plant
  environment.  So, I very much grew up with water and wetcleaning, as well as drycleaning.

         I became involved several years ago on both sides of the border with both EPA and Environment
  Canada m various wetcleaning projects. There were a lot of claims at the time about the feasibility of
  wetcleaning and we were hearing everything from being able to wetclean 100 percent of goods to not
  being able to wetclean anything and clearly neither of those positions was likely true.

         Having grown up in the mixed plant environment, I intuitively thought that a lot of this just
  wasn't a big deal. In that environment there are many factors that determine whether something goes on
  the wet side or dry side and it just isn't the polarized environment that we seem to be encountering.

        So, with that in mind, with the help of Environment Canada and R.R. Street & Company, we
 embarked on a task and experiment of setting up a dedicated wetcleaning plant. By dedicated, I mean that
 only wetcleaning was done on this particular site. We still had access to nonaqueous processing and
 nonaqueous processing should not necessarily be equated with perchloroethylene drycleaning. I think in
 terms of being stuck in paradigms; that is a mistake we often make. Nonetheless, I think as fabricare
 professionals, it is terribly important that we recognize that one of the distinctions that makes us
 professional is that we have access to both aqueous and non-aqueous processes. But we felt for the
 purpose of this experiment, that this particular site had been a drycleaning plant for about 45 years and
 clearly force of habit would enter into things if there was still drycleaning equipment on site.

       The purposes of the study—and we worked very closely with Dr. Manfred Wentz on this study-
 were to define the process parameters for aqueous textile cleaning, to develop guidelines for the process,
 and to demonstrate practical boundaries for the process. We very much focused on having the operator in
 the plant select the proper method, that is, Renee would decide whether something would go aqueous or
 nonaqueous and, most important, we decided very early on—and I do not advocate this in anything other
 than a test sort of situation—we gave Renee the authority that if she felt something labeled "dryclean
 only" was wetcleanable, she had permission to do that and we would accept any liability that might result.

       The test period that we recorded ran from the end of September in 1995 to the end of March in
 1996. There were 12,123 pieces recorded in the test period and we kept track of them by garment and
fiber type. For fiber type, in the case of a blend, it was recorded as the predominant fiber type.  Canada is
a relatively cool climate, cold climate at that time of the year, and the breakdown not remarkable 6 655

wood pieces and you can see how it progresses from that point down. Clearly not a great deal of silk and
linen at that time of year.

       There were just a couple of surprises. For the test period of the wool pieces, we were able to
wetclean 43 percent. There is one qualifier.  This particular site does a lot of work for the local police
department and there are a lot of very tightly woven gabardine wool pants that wetclean very, very well.
We haven't yet encountered any policemen in the Hamilton area running around trying to catch their
breath or looking constricted because their pants are too tight.

       That phenomenon somewhat distorts the wool figure. There are a lot of wool police pants that go
through, but they wetclean very, very successfully. Fifty-seven percent of those pieces were drycleaned.
Generally speaking, cotton will wetclean well and that is demonstrated in the 96 percent.

       I am going to skip rayon for a minute.  The thermoplastics, the synthetics, 80/20.  That is really
no surprise. If you regard 42 pieces of silk and linen as a valid sample, which it really isn't, 21 were
wetcleaned, 21 were drycleaned.  The rayon is a bit of a conundrum. Anybody with a background in
textiles in the room, and I see a number of people that have that background, know that rayon has poor
wet strength; it generally does not perform well in an aqueous environment.

       Renee has had a great deal of success with rayon, however; 67 percent wetclean, 33 percent
dryclean.  I am at somewhat of a loss to explain this from a technical standpoint, other than there is rayon
and there is rayon. There are many different formulations of rayon. We certainly take great care to resize
garments after they have been wetcleaned and we really haven't had any particular problem.

       From an overall perspective for the six-month period, we were able to wetclean 61 percent of the
throughput; 39 percent went off site to be drycleaned. They are only drycleaned off site.  They come
back on to the site for finishing purposes.  We also monitored a three month period from the  1st of
January to the 31st of March in 1996. I reasoned anecdotally—and I tend to do that—that during that
period of time there would be a proliferation of very heavy wool garments and that the feasible
percentage of wetcleaning was going to fall.

        I am not very good, but I am consistent, because I was dead wrong. By this time, Renee was
really getting good at it and she was able to achieve an even higher percentage of wetcleaning. And you
can see what has happened there. The wool numbers have reversed. With the police pants, initially they
were being drycleaned.  Over the fall period, more and more of them were wetcleaned and to this day
they are all being wetcleaned.

        The cotton numbers, again, aren't a surprise.  The rayon numbers are and I am not going to
comment on that. The thermoplastics aren't a surprise and there weren't any silk or linen pieces during
that period of time.

        During the period that we call the endpoint of the cleaning—of the methodology—we were able
to wetclean 75 percent.  We call it the end point because we feel that on this site—and I stress "on this
site"—that is probably the maximum feasible percentage for economical wetcleaning.

        There are three  formulae here that we use. The machine is a Milner. It is a very sophisticated
machine,  an excellent controller. It gives us absolute control over motor RPM, over dwell time, over
temperature parameters. It controls very, very well. We have a programmable American dryer that

  controls by temperature, by time, and by relative humidity, also a very sophisticated machine. It is steam-

         But there is really nothing magic. Anyone that grew up in the laundry business knows that these
  really aren't very exciting formulae, other than we have some dwell time between the reversals in the
  machine and relatively slow RPM.

         I was most interested in my friend, Josef Kurz's numbers this morning in terms of sophisticated
  detergency. We have heard claims about detergents that coat wool fibers to prevent matting and felting.  I
  really don't think there is anything terribly exciting about the chemistry we use.  It is good basic laundry
  wetcleaning chemistry and has worked very, very well for us.

        _ This is a formula for heavier, dirtier garments and really nothing terribly exciting. We have
  extensive cost data on this site going back many years. During the current period, the second line from
  the bottom, we processed 12,123 pieces. In the  prior period, the corresponding period of time the year
  before, sixth month period, we processed 13,439 pieces.  Now, somebody might say the market caught on
  to the fact you were wetcleaning and reacted negatively.  However, Hamilton was a very poor competitive
  environment at that point in time and the governing factor in the reduction in piece count was that we had
  a 50 percent discount competitor open up a couple of blocks away. And for a short period of time, that
  affected the numbers.  You will see in a minute that they have rebounded nicely.

         During the test period, we took all plant processing wages, which exclude counter wages.
 Whether you wetclean or dryclean, you still have to have someone serving the customers. We added a
 plug of $1,350, which accounts for wages in our main facility, where any drycleaning that comes out is
 drycleaned and we arrive at a total processing cost of $13,372 or a wage cost per piece of $1.10.  You can
 see in the prior period, where everything was essentially drycleaned, other than minimal amounts of
 wetcleaning, we had wage costs of $1.07, relatively insignificant differences attributable mainly to the
 drop in piece count, as opposed to any change in process.

        We hypothesized that,  as long as we focus on garments that are wetcleanable and finishable, there
 really is very little difference in finishing costs. Generally, in this site we drew the line at men's tailored
 garments. As soon as we strayed into the realm of men's tailored garments, then costs very much spiked.
 But, again, keep in mind this plant is in a lower middle class area.  The demographics of the area largely
 dictate that we are just not going to get a lot of tailored clothing. There are many, many pieces going
 through this site that perform very, very well in wetcleaning.

        In fact, in this site, the numbers pretty consistently run between 60 and 70 percent. I should also
 emphasize that the threshold level varies drastically for a number of reasons.  We have other sites in the
 city of Hamilton where that number would, in fact, be lower and I think our friend, Mr. Kurz,  this
 morning presented some numbers that in Germany indicate that between 40 and 50 percent seems to be a
 feasible number for wet processing. And I think I would probably concur with that.

        If we monitor utility costs in the current period, or the test period—the boiler was oil-fired—we
 arrive at a cost per piece of 15.07 cents for fuel compared to  12.03 cents in the immediately preceding
year and that is not a surprise. It takes more energy to evaporate a gallon of water than a gallon of
perchloroethylene.  But, again, it is not an earth shattering difference and we recovered a lot of that cost in
the area of electricity because in the prior period,  we were using a fairly old inefficient electric water

heater to do what little wet processing we did. We replaced that with a natural gas unit and—even adding
back the natural gas—we picked up a reasonable amount of the difference.

        I think that demonstrates that you can plan with those numbers and arrive at a reasonably
workable situation. Water consumption was an interesting phenomenon. Water is generally not
recirculated in Canada for two reasons, probably neither of them terribly valid.  There is a lot of water in
Canada, so it is not perceived as a terribly precious commodity. That is unfortunate, but that is the
perception. Secondly, because of the cold climate, water towers can freeze and we tend not to recirculate
water. The drycleaning equipment that was in this plant was second generation. It was quite efficient in
terms of the mileage we were getting but, nonetheless, it was water-cooled.

        One would reason that you would use a lot more water wetcleaning than drycleaning.  But this is
not so, if you happen to be using equipment prior to third generation. That equipment uses a lot of water
for cooling if it is not being recycled.  And as you can see in actual fact, our costs were lower for water in
wetcleaning than in drycleaning.

        Now, I have to stress in presenting these numbers that when we get beyond second generation in
the third, fourth, and fifth generation, those machines make fairly sparing use of water and they would
win hands down in this scenario, but you have to be a little bit careful of making a blanket statement that
wetcleaning uses more water than drycleaning. It certainly wasn't true in this case.

        I think that we can draw several conclusions from the study and I have one overhead slide, after I
go through these conclusions.  Clearly, in my mind, a substantial number of garments that we previously
drycleaned can, in fact, be wetcleaned using either new or really traditional wetcleaning technology. The
one thing I think that newer wetcleaning technology brings to the party compared to traditional
methodologies is process control. Whatever one might say about modem drycleaning, there is a great
deal of process control embodied in the equipment, the solvents, the chemistry.  Traditional wetcleaning
is mired in the 1930s time warp. There is not a lot of work done on it. With newer technologies, we start
to impart some degree of process control and instead of having six sinks and a corresponding number of
people working on wetcleaning, we can start to replace human input with mechanical input and impart
some degree of process control.

        From an overall perspective, however, I think I have to say that a lot of the process control, even
with machine-based wetcleaning, is based in the operator's head as opposed to in the machinery. It is
going to be interesting to see how that develops over the next number of years.

        I think from our  standpoint, in our area and on this site, we certainly still need access to both
aqueous and nonaqueous technologies. That doesn't mean that you have to have them on every site, I
think we proved that. I think we also established that there are a number of factors that determine what a
feasible percentage is.  One that is often ignored—as a matter of fact, I never see anything on it in the
literature—is the phenomenon of lot control. This is a thousand or fewer pieces. This site would process
32 or 33 thousand pieces a year.  So, the weekly piece count is small, well under a thousand.

        Lot control isn't an issue.  If you get up into the two and three thousand piece range, lot control
becomes immensely important. Wetcleaning doesn't deliver pieces down the finishing line consistently in
lots. Some clothing is dried immediately.  Some has to hang for a little while. Some has to hang

        That variability presents a big problem in a high production site, where lot control is an issue. It
 is really not a big issue in a small piece count site. Is wetcleaning the answer to some of our problems?
 No, it is not the answer.  Is it one answer? Yes, very much so.

        Our friend, Dr. Manfred Wentz, this morning, alluded to the textile care spectra. I think as an
 industry we have to stop focusing on whether I should be doing 100 percent or 90 percent or 80 percent or
 75 percent and get back to the basics in terms of focusing on the goods we are working on and basic
 textile parameters. I think we will find that wetcleaning is one of the feasible answers for dealing with
 our problems.

        As a matter of interest, I have some subsequent performance figures for this site. Just to allay any
 fears that there has been a drastic drop in piece count on this site, we can see the numbers of pieces
 processed in the test period, that six month window, is 12,123. That corresponded to 71,889 Canadian
 dollars in sales.

        If we take the two subsequent periods in 1996-1997 and 1997-1998, we can see that the piece
 count is fairly steadily increased along with the dollar sales figures. So, certainly, I think if we look at
 North America as a whole, this may be the longest running wetcleaning site, or it is certainly in the top
 few, and there has been no negative trend there.

       As Buster or Ed said, we have not yet paid a claim on a wetcleaned garment. We tend not to have
 a lot of claims on this site. I think probably in the last three years we paid a half a dozen. They have all
 been on drycleaned items, generally items that were received on a Saturday for sudden service. They go
 off site. They get drycleaned, probably not with a great deal of care and we tend to pay claims.  So, I
 dont think the no claims thing is a commentary on the relative efficacy of wetcleaning versus
 drycleaning. I think it is a commentary on the fact that if you carefully select processes for each piece
 going through the plant and carry them out, you are probably not going to pay a lot of claims and I think
that is the message in the no claims experience.

       I hope I have managed to shed light on our wetcleaning experience and it certainly from my
perspective is going to be very much part of our corporate equation in dealing with some of the challenges
that are now presenting themselves and will present themselves in the next few years.

                               Korean Cleaners' Concerns

                                           Max Oh
                Federation of Korean Drycleaners Association of Greater Washington

       Max Oh has been an advisor for the Federal of Korean Drycleaners Associations for
       many years. He is currently a columnist for the Korean Drycleaners Times, as well as a
       national speaker for the Federation of Korean Drycleaners Associations.
       Good evening, ladies and gentlemen. My name is Max Oh. I want to make a speech only for a
few minutes, I mean less than ten minutes.

       The subject of my presentation is the coach program, which is being conducted by the Korean
Drycleaners Association of Greater Washington. As an activity under the EPA's mantle program, the
objective of the coach program is to educate the Korean businessman about the EPA rules and regulations
so that they totally absorb and implement the drycleaning practices that are environmentally friendly.

       The emphasis is on education rather than administration of government rules and, as such, the
coach program is geared to the cooperation between our association members, mutual support, and self
help.  The Korean Drycleaners Association of Greater Washington conducts two or three technical
seminars each year as a service to its members.  In October 1996, we had a seminar on the environmental
issues where EPA staff was invited to speak.  To everyone's surprise, close to 800 businessmen attended
the seminar. The success of this seminar showed the importance and high interest our members have
regarding environmental issues and gave us the confidence that we are doing the right thing.

       Through several meetings with the EPA officials, we developed a plan to train the directors of the
association as coaches.  Mr. James Kinney of EPA Region 3 served as an instructor to train about 35
directors, who have been made to volunteer and the federal EPA issued a certificate to those of us who
completed the training.  When you have a chance, visit the EPA Web site to find out more about it.

       The coach program works in this way. A certified coach makes a visit to a drycleaning store,
sometimes with advanced notice and sometimes without notice, and inspects the  store using the checklist
of about 87 items, such as store air quality, chemical lists, preventable instruction and measures in place,
and a record in the file.

      . To increase its effectiveness, the coach sometimes invites area businessmen to a mini seminar in
the selected store and has them observe the inspection. When a deficiency or discrepancy is found, the
coach discusses it with the store owner,-suggests ways to make improvements, and gives two weeks time
to correct them. After two weeks, the coach conducts a followup inspection and  EPA issues a certificate
when the store passes the inspection.

       It is a simple program but has many advantages.  First, for the last 18 months, we educated the
coach's to the importance of EPA regulations and helped them adopt environmentally-friendly practices.
Second, it allowed the coaches to pass on what they learned to their fellow businessmen in informal and
open forums.  The goal was not to punish any violation, but to check any discrepancies and to provide a
chance to correct them.  Third, it increased the participation of Korean businessmen in the discussion of
the environmental issues. As you may know, many Koreans, including myself, are not fluent in English

 and this makes them shy away from asking questions or presenting their own concerns forcefully.  But
 with a coach who speaks Korean, they can be as loud as they wish.

        You may'ask what about disadvantages and you are right to raise that question.  As in any
 program, there is room for abuse. A coach may want to use the chance to inspect someone else's store to
 take out his personal grudges or to give personal favors. We thought about that possibility and
 established an environmental committee of nine members in the association.  This committee, of which I
 am the chairman, receives the preliminary results of inspection from the coaches, checks them for
 validity, and serves as a mediator if there is any difference of opinion between the coach and the store

        The committee also schedules meetings to review the overall coach program and to issue periodic
 warnings to not accept even a cup of coffee or a soft drink in order to maintain your integrity as an
 inspector. The effectiveness of the coach program is approved by the EPA at Region 3.  Last year, James
 Kinney carried out his own inspection of the stores randomly selected from the least level store that had
 been the inspected through the coach program.  He reported that 100 percent of these store are in
 excellent shape. Already the coach program is spreading due to its success. Upon request from the EPA
 Region 3, the committee members and I carried out our training program for 12 more drycleaning
 association directors and they were certified as a coach by Dr. Montague on March 15, 1998. They are
 ready to go out and educate their members through informal inspection and training.

       Next time, I am going to spread this program to the Philadelphia area, EPA Region 3.  Dr.
 Montague asked me verbally but not officially.

       Now, I would like to make two recommendations to the EPA.  First, allocate this internal budget
 for the support of the coach program nationwide and for the translation into Korean of EPA rules,
 regulations, best practices, et cetera. Unofficial estimates of Korean businessmen engaged in the
 drycleaning business in America is about 15,000.  Their understanding and compliance with
 environmental requirements would increase greatly if the material were in Korean and the message was
 delivered in Korean through the coach program.

       Second, find a way to provide a low interest loan to the drycleaners. Environmental rules and
regulations change and regulations require the installation of new equipment and  improvement of stores.
Most of the Korean drycleaners are run by mom and pop, who work 60, 70 hours a week to make a living.
They do not have any capital to invest and have very little access to the local banks for the investment
loans.  EPA financial assistance would greatly encourage them to upgrade their facility to the EPA
standard.  I hope EPA finds my recommendations worthwhile.

       Thank you again for the opportunity.

                          The Fabricare Industry and Change

                                       Vic Vandermolen
                                 Canadian Fabricare Association

       Vic Vandermolen has been active  in the association management  field for the past
       25 years.  He became Executive Director of the Ontario Fabricare Association in 1991,
       and is the founding Executive Director of the Canadian Fabricare Association, where he
       continues to serve.
       Good morning, ladies and gentlemen.  Thank you for the opportunity to share with you what has
been happening in the fabricare industry in Canada. To say that we are experiencing change would be to
put it mildly. I hope to share with you this morning some of the things that are happening, some of the
comments about why they are happening, and the role of the Canadian association and some of the
provincial associations in being a proactive part in dealing with the changes and directing those changes
that are affecting the industry.

       Let me say first of all that neither the board of directors nor the reasonable leadership in Canada
has ever had any real aversion to change, never viewed the idea of change with any real horror. The focus
of recognition for change has addressed two specific areas: the need for pollution prevention with
existing technology and the need for development of alternative technologies.  Yes, there remains some
skepticism that even real change will not provide any real benefit to the industry as a whole, but I daresay
that the vast majority of cleaners in Canada look on change as an opportunity for bringing new life to the

       Let me go back just a few years. In December of 1992, the Federal government published the
environmental code of practice for the reduction of solvent emissions from drycleaning facilities.  It is
important to note that the development of the code was at the initiative of the industry because of
industry's recognition of the need for change and to codify that change and its ability to convince
government that this was needed.

       The purpose of the code was to provide guidance to the environmental regulatory agencies and
the  owners of drycleaning facilities regarding the means to reduce chemical emissions from drycleaning
plants. It was because of a shared recognition that a change was needed, both in the way that regulatory
agencies responded to this issue and in the way that cleaners dealt with it, that the code was published. I
say that to further emphasize the fact that the code was developed in a spirit of cooperation and of

       There were 53 people on this task force; eighteen had direct links to the fabricare industry and
allied business interests were  represented. There were also five representatives of the environmental
community and the balance was people involved in both federal and provincial environmental
government agencies.  I point that out because the attitudes that were developed during the work of this
task force were used as guidelines for subsequent issues that have led us to the current situation—that is,
cooperation and consensus building among industry and government and environmental groups when we
deal with issues relative to the fabricare industry.

         When the federal government was running its election platform the first time—they have now
 been in power for some seven years, it promised that it would take a tough stance on issues affecting the
 environment  Very soon after its election, it developed a priority substances list of the chemicals that are
 governed under the Canadian Environmental Protection Act and classified each into either a track one or a
 track two category.

         Track one chemicals were designated and slated for total elimination.  Track two chemicals were
 designated for a cradle-to-grave management policy, and perc was classified as a track two chemical.

         Subsequently, the government established issue tables or discussion groups to deal with each
 track two chemical and proceeded to work toward establishing a set of rules and regulations regarding the
 management of each of those. This included perc, of course. Based again on the spirit of cooperation
 established during the code of practice, government again invited industry representatives to play a key
 role in this process.

         Let me give you a quick overview.  There were 27 members of the actual discussion group; of
 those, 16 were directly related to the fabricare industry, meaning that they were either cleaners or in allied
 trades. Two were members of the environmental community and the balance represented various
 government agencies.

        The issue table  first met in October 1994 and met some six times between then and the time that
 its report was published in February of 1996. I'm not going to give you a whole report. Just let me give
 you a quick overview and executive summary, if you will, of the key recommendations.

        Number one, all first and second generation drycleaning equipment would be eliminated from use
 by regulation by a certain date.  All new perc machines installed after the promulgation of the regulation
 would be required to have a manufacturer's rating of some 1,400 pounds per gallon. The distributors of
 perc would be held responsible for the collection of perc-contaminated waste; that also addressed the
 issue of groundwater contamination and concern that waste be disposed of in a timely fashion to a proper
 and legal depot.

        Just by way of interest, last week I learned that, as a result of an inspection, one commercial
 cleaner was found to have some 60 barrels of hazardous waste stored in his basement. I guess he was
 looking for a volume discount from his waste hauler.

       The fourth point was that a levy would be placed on the sale of every bit of perc sold to the
 drycleaning sector, with the proceeds to be used for a national operator training and certification program,
 a national inspection program, and a compliance monitoring program.

       Then lastly, it was recommended that all cleaners complete a training and certification program in
 the proper handling of perc, equipment operation, and maintenance practices, by a committee to be

       The report and its recommendations received the support of the industry leadership as well as
 government.  I just want to note that the environmental community did not accept and support all of the
 core recommendations, because it favored restriction on the quantity of perc being used, with an eventual
 goal of elimination of perc as a solvent in the industry. That approach was rejected by government for
two reasons. First, it is inconsistent with existing international agreements, including NAFTA. Secondly,

there is confidence within the Canadian government that current technology can reduce perc consumption
effectively within the cleaning industry.

       Since the report was filed, there have been some changes made, all initiated by government,
because of the various government jurisdictions being restricted in what they can do under federal and
provincial mandates. We were made aware of those, and we have been involved in discussions with those
and have agreed as an industry to support the current position being take by the federal government.

       The current status can be summed up as follows: the essence of the report will probably be in
place by September 1 of this year, with full implementation of all recommendations by the spring or early
summer of 1999.  That is the time line that was given to us by government representatives also at the
recent conference in Toronto, hosted by the Canadian Fabricare Association with substantial financial
sponsorship from Environment Canada.

       Just by way of interest, the purpose of that conference was to look at how the industry in Canada
can in a practical manner achieve the goals that were set in the strategic options report on perc that I
referred to earlier.  Let me add that the association Environment Canada previously sponsored a
conference to consider the latest developments in both aqueous and nonaqueous technology. As a result
of that conference, the association has been able to present seminars right across the country, giving
cleaners an opportunity to obtain a better understanding of the need for change and for alternative
technologies and processes. For lack of a better term, this road show, if you will, has also resulted in a
positive interest in creating a number of dedicated wetcleaning sites in various provinces across the

       I referred earlier to a new regulation that we can expect later this year. As I said, because of
provincial and federal jurisdictional mandates, it will deal only with areas that do not impinge in any way
on provincial jurisdictions. So what will it deal with? It looks like it will deal with elimination of all first
and second generation equipment. I anticipate that will be  by the end of 1999, perhaps a bit sooner, but
probably that will be the latest date.  By December 31,1999, it is anticipated that it will be illegal for any
cleaner to operate a cleaning plant using either a first or a second generation machine.

       Perc will be eliminated as a component of any spotting agent. There will be an elimination of any
self service drycleaning machines using perc. We don't have any in use right now, but the government is
anticipating  that might happen, so they are saying right  up front, that will not be allowed.

       All perc will need to be delivered strictly through a closed loop system. The suppliers of perc
will be required to assume responsibility for their waste management and waste collection, either through
their own resources or through contracts with other individuals or other companies. And suppliers will be
required to maintain records concerning perc consumption, the amount and type of waste generated, and
to what legal facility it was disposed.

       The industry leadership has met with government to discuss these issues.  It believes that
implementation of these requirements will indeed create the level playing field that is absolutely
necessary if there is to be good order in the industry, equality of regulation, and implementation of some
minimum standard of competence and knowledge.

       I believe that one of the reasons why the Canadian Fabricare Association has undertaken to work
closely with government and environmental groups is because I believe that CFA recognizes that the

 fabricate industry in North America as a whole is indeed suffering an identity crisis. In some cases it is in
 a state of disarray, confusion, and decline. The association leadership believes that, with a conscious
 effort to proactively obtain results through consensus, those results will reflect an agreement that can in
 fact then be supported by all.

        From my perspective as an association manager, and Sylvia referred to that, as an association
 manager for 25 years, let me be right up front. For those of you who know me, and for those of you who
 don't, let me tell you, I have never been a member of the drycleaning industry. I've never operated a
 plant, don't ask me how to run a spotting board or a cleaning machine; I don't know how.  So I come at it
 from a totally objective standpoint, I hope.

        But from my perspective, a major reason for the woes and the ills of the industry at large today
 has been its resistance to change and its seemingly dogged determination to promote this concept of
 universality. Much of the industry focus today is on the environment, and that is indeed an important part
 of the industry. It is important for us to agree that there is a need to be environmentally responsible in
 whatever process we use, and that we do whatever we can to minimize the potential negative effect of that

        In dealing with those issues, I believe the time has come when we as an industry generally need
 to publicly acknowledge that the concerns about the use  of chemicals in the cleaning industry and their
 impact on the environment, that these are not pronouncements of a bunch of radicals, but that there is a
 need for us as an  industry to address those concerns proactively. We need to act now in the development
 of viable processes that will allow us to continue to effectively reduce the use of chemicals that may have
 a negative impact on the environment in which we all live.

        The major part of the industry discussions today deal with perc. The issue table discussions that I
 referred to earlier dealt with the management of perc.  A great deal of those discussions referred to and
 dealt with the issue of setting goals. The issue table members and the Canadian Fabricare Association
 board of directors discussed the matter of industry goals with government arrived at what is believed to be
 a set of realistic and achievable goals in the reduction of perc consumption in the fabricare industry.

        In 1996, in Canada we used some 4.5 kilotons of perc in the drycleaning industry. The goal is to
 reduce that to 1.6 kiloton by the end of the year 2000.  That is the goal that has been established by both
 government and industry, somewhat of a 60 percent reduction. Now, please understand that what is
 anticipated is that at least half of that goal  will be achieved immediately upon the elimination of first and
 second generation equipment. The balance will be achieved through ongoing education and training.

       All that of course is going to result in a major change in the industry in Canada. For those who
have remained current with technologies and developments, I believe the idea of change is looked upon as
a grand opportunity to restructure their business, to implement new processes and marketing strategies,
and to also improve the impact their business has had on  the communities that they serve. For those who
take the attitude that, I've done it this way for 30 years  and why should I change now, I believe the future
of the industry is going to be bleak indeed, because they will be unable to deal with the new
developments, the new directions and the new regulations that will come into the industry, regardless of
how much we try to resist it.

       In fact, those people would only fit into the third category of people who have to deal with
change. Ed Barlow referred to that yesterday morning. He said we all have to deal with change in our

lives, and there are three categories of people. There are those who make change happen, those who
watch change happen, and those who wonder what happened.  I believe that those who wonder today
what has happened will not be part of the industry tomorrow, because change within our industry is
inevitable, and managing that change in a positive way should be the goal of our industry leadership and
association and members. Determinedly  fighting it, I believe will only result in frustration and chaos.

        This is just a personal opinion. Neither the environmentalists nor government are industry
enemies to be fought by the industry as a  whole, nor is the cleaning industry a target to be shot at by the
environmentalists or the government at every opportunity. I believe it is necessary for each to develop a
recognition that each party has its own set of goals, and to sit down and to reconcile their individual
objectives. I believe that goal is far closer when there is cooperation than when there is dissension and
discord.  That, I believe, from the Canadian perspective is what we have been able to accomplish.

        The fact that industry leadership meets regularly with government, be it at meetings or at
conferences or over lunch or coffee, has allowed each to develop an appreciation for the position of the
other, and has allowed an objective consideration of the issues.

        I sometimes wonder if, because of all the discussion and issues, we haven't lost the ability to be
objective, regardless of what side of the issue we're on. We sometimes seem to have been so ingrained in
our own opinions, that we have lost the ability to listen to someone else. When we start to take the
attitude that universality is our goal, then  we have lost the ability to be objective. When we take the
position that we should be focusing on establishing a universal processor or universal solvent, then we are
no longer objective. I think that is a goal  that is just as achievable as trying to develop a universal
garment that everybody would wear.

        Consider the situation where a cleaner is located in an area where water is in short supply. Is it
then still environmentally sound to promote wetcleaning as the only means to clean domes?  Is it just
possible that sometimes, drycleaning is more responsible environmentally, that sometimes the use of a
solvent-based technology is in fact more environmentally responsible than the use of water?

        I think it is important that we remember that we just can't bury our heads in the sand, nor can we
throw out existing processes and arbitrarily declare them hazardous, because we need to evaluate our
current practices with a very objective mind, based on objective standards.

        Whatever our involvement within the industry, each of us needs to stand back and reconsider our
position and approach it from an objective perspective, looking at all the facts and all the issues. Ladies
and gentlemen, I believe if we do not do that, then the result is meaningless rhetoric.

        Just very briefly, let me tell you what is happening with the province of Ontario with regard to
developments and new regulations. The Canadian Fabricare Association has encouraged each province to
work with its provincial government to establish a set of regulations dealing with education and training.
That is in the process.  The governments of British Columbia, Alberta, Quebec and Ontario have received
those recommendations, and those recommendations are generally consistent in their intent and content.

        Just recently, I met with the Minister of the Environment and had lunch last week, Tuesday, with
his Parliamentary Secretary and assistant. Yesterday, I received a call from the office of the Minister of
Environment stating that they want to have a meeting with us in a couple of weeks, with the specific

 purpose of determining how we can implement the recommendations that have been made by the Ontario
 Association vis-a-vis the fabric registry in that province.

        Let me just tell you very quickly what those recommendations include. First of all, there will be
 created a drycleaners council in the province of Ontario, to which all drycleaners will be required to
 belong.  The council would be governed by a board of directors of nine persons, seven of whom would be
 drycleaners, one a consumer representative, one would be a government representative.

        The council would be held responsible for the setting of competency in all standards for Ontario
 cleaners, and it would work with government in the monitoring of industry members to determine
 compliance with the regulations.  The authority of the board would come from regulations that would be
 passed by government.

        I know that the board of directors of the Ontario Association and the leadership in the Ontario
 industry generally are looking forward to the implementation of those types of goals, because there is in
 fact a specific goal, and a path has been established to achieve those goals.  It is a fact that, unless you
 know where you're going, you never know when you have arrived.

        The important thing is that in the fabric industry in Canada, goals have been set.  They have been
 determined through mutual cooperation and discussion.  They have been accepted as being achievable by
 the parties involved in the process. I believe all of that allows the Canadian association to be very proud
 of the conclusions that have been reached, the goals that have been set, and the ability to point to the
 benefits of an orderly transition.

       In summary, let me suggest to you that what is being created in the Canadian fabricare industry is
 a business environment where number one, there are clear and achievable goals, number two, the rules are
 clearly established, number three, the application of those rules will be consistently applied to the industry
 as a whole, and number four, there is a uniform standard of competence and knowledge required of every
 professional cleaner. All of that allows the creation of a level playing field that is so necessary for the
 positive growth and development of the industry as a whole.

       I believe all of this does much to eliminate the confusion and disagreement, and allows for the
realization of a consistency that helps industry members in the development of their own businesses. I
believe very much that if the Canadian cleaning industry continues to investigate how it can make things
better, and if it continues to  do that in the spirit of cooperation with all interested parties, then we can
indeed look forward to an exciting future. If we ever decide that we are no longer willing to evaluate the
old or to search for the new, then I predict that we will be the instruments of our own demise.

       Thanks very much for your attention.

     Indiana's 5-Star Environmental Recognition Program for Drycleaners

                                         Dave Wintz
                        Indiana Department of Environmental Management

       Dave Wintz is currently an Environmental Manager with the Compliance and Technical
       Assistance Program of the Indiana Department of Environmental Management.  He
       provides confidential compliance assistance on all environmental rules and also manages
       the Indiana 5-Star Environmental Recognition Program for Drycleaners.
       I'm going to talk about Indiana's five-star program. We were the first to develop such a program
in the country. We started in the summer of 1995, working with the Indiana Drycleaning and Laundry
Association (IDLA). It would not be an overstatement to say it wouldn't have happened without strong
IDLA support. I don't think government could have done it alone.  I don't think IDLA. could have done it
alone. But it is truly a partnership, and it has worked to the industry and to the state's advantage in a lot of

       First, let me tell you what the five-star program is not. It is not a certification program. Being
part of the five-star program does not preclude an inspection. It is not an amnesty program.  It does not
reduce your risk of being referred to enforcement from our agency. But it is a recognition program, and
we do say that we recognize the cleaners who are pledging and doing more for the environment. I did
want to make that clear. In the first draft of the report that came out of the January meeting that was held
here, the EPA meeting, it did say it was a certification program, so we need to get that changed.

       A little background on myself.  I work for an office in the Indiana Department of Environmental
Management that provides confidential assistance for small businesses. We are called the Compliance
and Technical Assistance Program, and we do provide confidential assistance.  We are in a separate
building from the inspectors and the enforcement people. I think part of what interested the association
was that we do provide confidential help. I think it was all part of the picture.  No one particular aspect
initiated the process and made it all work, but a lot of pieces came together.

       Obviously, you all know about the drycleaner NESHAP. I would consider the five-star program
and our integrated  education effort as being largely driven by the NESHAP, quite honestly. We're a big
agency, we do pretty well with steel mills and industries that have environmental staffs and that are on a
regular inspection schedule, but how do we deal with small businesses? We weren't particularly adept at
dealing with 450 small businesses throughout the state.

       So we took an integrated education approach, worked with the association, and gave them a grant
to hire a contractor write a simple, easy-to-read manual.  All the drycleaners have that available to them at
a nominal fee - about $25.  The association doesn't make any money on it.  It just covers mailing and
copying costs.

       It is hard to ask cleaners to go above and beyond the rules if you don't tell them what the rules
are. Initially, we developed the manual and concurrently with that developed the criteria for each star in
the program.

         The review committee was also formed at that time.  It is made up of drycleaners, state personnel,
 health department, and solid waste district personnel. That is just to give them a rounded approach. We
 do review each five-star application on its merits. One through four stars is "we trust you," but the fifth
 star is the best of the best, and they need to be reviewed by the committee.

         I'd like at this point to go through the new application. It does become effective in September of
 this year. The program is about two and a half years old, and it is time to raise the bar a bit. I do want to
 point out a couple of things. Why would cleaners want to join the program, number one? Well, you can
 use the program to market your environmental responsibility to your customers.

         In the beginning, the association was a little hesitant for IDEM to publish information and put it
 on the World Wide Web.  I think now, because the relationship has matured,  they are much more open
 to the mailer that we did, the green mailer.  We did a mass mailer to interested parties across the state.

        From the state perspective, we can't endorse a particular cleaner, but we can distribute
 information indicating who we have recognized.  It is a fine line, I agree. However, it is in the statute, so
 we can't do much about that.

        We are transitioning into a new era where the state is going to be doing more pushing of the five-
 star program. In the second to last paragraph, we now visit four and five-star applications. We were
 finding situations where—and there are probably still some—some three- and four-star cleaners shouldn't
 have stars, quite honestly. They have compliance problems. For instance, a five-star applicant did not
 know what the  hazard communication standard even was.  It didn't have a Haz Comm plan. You can't
 even get one star without basic compliance.

        In the new application, we now require that four and five-star applications will receive a visit
 from CTAP, which is usually me.  It is not an inspection; it is still under the guise of CTAP, but it is
 much more comprehensive than an inspection that they would receive from the air program, for instance,
 because the air  program doesn't care about the Haz Comm plan, doesn't care about hazardous wastes,
 other than keeping it in covered containers.

        Therefore, it is more comprehensive.  We look at OSHA, we look at fire marshal requirements,
 and so forth. We're telling them that CTAP looks at more than just environmental issues during our site
 visits. It is a more comprehensive visit. We want to recognize only the best cleaners in Indiana.

       The second page is straightforward, I won't go through that. Name and address, fax number, and
 so forth. One star indicates striving to reduce the use of solvent. It is pretty weak, I know. Respond
 openly and honestly to customers within a reasonable time frame, and then even if they are CESQGs, they
 have to use a hauler. I know most cleaners are doing that anyway, but we just put it in as a baseline

       We are  setting up a tiered approach. You will notice, you go from one to two to three. The two
 stars have to qualify as a one.  This year we are asking them to take hangers and bags, before it was just
bags.  Most cleaners take the hangers back.

       The brochures—in the past we've had these two green and blue brochures.  We are unifying these
two brochures into one, and we're going to call it Garment Care: Where are We and Where are We

Going? That could have been the title of this conference, too. That is going to go into different solvents,
different methodologies, and it is going to be a much more comprehensive brochure.

       Then we are asking the two-star cleaners to do Haz Comm every year, even though the rules
require you to do it only when an employee starts or when you introduce a new chemical into the
workplace. We are asking for a copy of the Haz Comm plan to be submitted to us, and we will probably
include the signature sheet that the employees sign. The purpose of that is to keep people honest, quite
honestly. As I said, we are finding some people who were in the star program and didn't even know what-
Haz Comm was.

       On the three stars, I don't think much has changed regarding the old criteria. We are requiring
now that one person from the organization come to an annual training session that will be provided by
IDEM around the state. Before, we held only one in Indianapolis and it was equally inconvenient for
everybody in the state.  To get from Evansville to Indianapolis requires a three and one half hour drive.  If
you are in one of the comers of the state it would require a long drive, and, as cleaners know, it is hard to
get away from the plant sometimes.

       We also are requiring people to report on drycleaning, wetcleaning, and solvent mileage to
CTAP, and IDEM.  That is really to get an idea of where we  are in the state on solvent mileage.  We don't
yet have good environmental indicators. You do not have to post it in the front of your store as the five-
star cleaners will be required to, but you are required to track it.  As I said, we don't know where people

       We are calling the industry average 300. Is that accurate as far as you're concerned, solvent
mileage, 300?  You have to factor in cleaners who are limping along at 100 or 200.  Most cleaners are
doing four and five and six now, but Elden would disagree, maybe.

       I guess we'll talk about the last page.  On the four-star, the 450 solvent mileage figure was always
in there at the four-star level. We decided not to bump that up, after much discussion with the review
committee. That is a tough one.  Most people are clustered in the three, four and five-star level.

       Quite honestly, one of the big reasons we didn't address that is because so many people are at the
three-star level. We had so many cleaners at the three-star level, and we felt what was holding them back
was that 450 number. Of course, we encourage people to promote themselves and get themselves from
three to four to five, but we felt that because mere were so many people at three stars, we thought we
would go ahead and leave it at 450. We do require them to post the solvent mileage in their stores.

       Do customers really know what solvent mileage is?  Probably not, but that is probably our fault
as much as anybody's. We haven't educated the public on what solvent mileage is and how important it is.
That is the bottom line on the recognition program. We are driving efficient use of drycleaning solvent,
quite honestly.  We want cleaners to get the most they can out of their drycleaning solvent.

       The five-star level has changed quite a bit from the first two years. We are now requiring a five-
star cleaner to be a CED or have other environmental certifications acceptable to us, perhaps like the
NCA-I program. If we had any drycleaners who wanted to become a CHMM, or a certified hazardous
materials manager, that would be fine. That is a very challenging task, much along the lines of—maybe
not as hard as a CPA, but it is very challenging in the environmental field.

        Then we ask them to demonstrate their environmental leadership to the five-star review
 committee. Past examples included converting the vans to run on natural gas, exceptional solvent mileage
 in the 1,200 to 2,000 range per gallon of solvent, elaborate spill containment systems in drycleaning
 rooms, high percentages of wetcleaning.  Those kinds of items are all the justifications that have to be met
 to receive the fifth star.

        A five-star cleaner now also has to get 750 solvent mileage, which isn't particularly aggressive,
 considering the new machines. But we still have to keep it fair enough so that, if you have a third or
 fourth generation machine and you're doing a lot of wetcleaning, you can still achieve that. If you can't
 do the 750 because you have an old machine, or you just can't get your wetcleaning up, but you are
 maybe at 600 or 500—in other words, you're above the 450, but you cannot achieve the 750—we are
 requiring you to mentor five other cleaners.

        This is a new concept this year.  We don't know how many people will take advantage of it. But
 even if we just get one or two to do it, we feel that the state has benefited, because five or ten other
 cleaners are now being helped by a five-star cleaner to achieve high solvent mileage. You never know
 what you're going to find when you go into a plant. Perhaps these five-star cleaners could find some
 disastrous situations that they would be able to help that cleaner through.

        So that is the application. As I said, the newspaper article was something that we do internally
just to get the word out. It has a mailing list now of about 15,000 people across the state. The map was
 something that we do, and we will be taking that to state fairs and related events.

        I do want to talk about a couple of the challenges and the successes. At the risk of sounding
 wishy-washy, I think it has been successful. We have built a relationship with cleaners in Indiana.  As I
 said, a star doesn't get a cleaner out of enforcement, but it does help to have a relationship with Paula
 Smith, who started the  program back in 1995, and with me.

        Sometimes enforcement doesn't get the rule right. I know that would be shocking to everybody in
the room, but actually,  we in some instances are able to intervene on behalf of a cleaner. We can't be an
advocate for the cleaner, but we can sometimes explain the rule.

        That has two effects.  Sometimes we have to remove cleaners from the five-star program because
they aren't in compliance, they were clearly in the wrong, and then sometimes we are able to keep them in
the five-star program and perhaps work it out with enforcement.

       Now, that gets  us in trouble from an internal standpoint, because they  think we are taking sides
with the cleaner. I say I'm not on the cleaners' side, I'm not on the enforcement side; I'm on the side of the
rule and what makes sense. Sometimes we enter into an enforcement action in error.

       Let's discuss the challenges of the program. I see the big challenge of the program as getting
more cleaners involved yet making sure it maintains its level of high quality.

       We conducted a survey recently, and asked how many people were familiar with the five-star
program.  Only about 7 percent said they were familiar with it; 93.1 percent didn't know about it.  So that
is one of the challenges. Then on the same survey,  it said, how likely would it be to drive 10 minutes
further to a five-star cleaner, and about 63 percent were either very likely or somewhat likely to drive
another 10 minutes further to get to a five-star cleaner. So you see the dichotomy.  That is the good news.

This is the bad news: nobody knows about the program, but they do like to see people that are doing
what they can for the environment.

       The other challenge, I would say, is making it tangible to the cleaners to join the program. This is
a five-star cleaner in Indianapolis. He is really using the program in his marketing. He puts hang tags on
his bags, on his garments and shirts. He uses it in his couponing. He is really using the program to set
himself above the market.

       However, he is in Indianapolis, a competitive area. If you are the only game in town, there is not
much incentive to get into the program.

       Those were some of the challenges and some of the issues that we will be working through in
1998 and 1999.

       Thank you very much.

                      Drycleaning Issues Facing the Armed Forces

                                         Joseph J. Nilsen
                                   U.S. Department of Defense

         Joseph Nilsen is a  15-year Federal employee with experience in several pollution
         prevention programs including the Hazmin Program, the Non-Government Standards
         Program, and the Technology Modernization Program.  He currently is serving with the
         Directorate of Clothing & Textiles in the New Technologies Commodity Business Unit
         where his responsibilities include all specialty programs in the directorate.

         Good morning. I hope my speech for you today will be both entertaining and informative. As
 everyone here knows, my name is Joe Nilsen. I'm from the Defense Supply Center, Philadelphia.

        I would like to speak to you today about what we are doing in the military community in regards
 to acquisition reform, changing the way we do business, how we operate, and most notably, our efforts in
 partnering with the Environmental Protection Agency in giving our customers, the military services, the
 war fighters, the Army, Navy, Marine Corps, Air Force and Coast Guard personnel whom we serve as our
 customers, a choice in how they have their garments cared for.

        What is the most visible thing about Washington this time of the year?

        Cherry blossoms. What do cherry blossoms symbolize? Color. What does color mean to the
 military services? The color means a lot to the military services. Those color shades that you see military
 personnel wearing have an identity. They also have performance characteristics.

        In terms of performance, has anyone here heard of reinvention of government? Well, let me tell
 you, it is really happening. I can attest to that.

        See this coat? Prior to acquisition reform, this coat could have been described in a'military
 specification. How many people know that word, MILSPEC, right? I'm here to tell you right now that
 the word MILSPEC in the military community and in the federal community no longer exists. If there is
 anything I can teach you today, it is that military specification is no longer used in the federal vocabulary.

        The words that replace it are "performance specification" and "detail specification." What we are
 seeking to do and what we are doing in the military community, because the train has now left the station,
 is to no longer use MJJLSPECs.  We are using specifications and product descriptions in terms of
 performance. Some of those performance descriptions do have detail. However, the word military
 specification no longer exists.

        I represent the technology modernization program that focuses primarily on the revolutionary
 change in the way we describe what we want to provide for our customers, the military services, in terms
of product descriptions. Because we no longer use MILSPECs, we are now using performance-based
acquisition documents.

        With regard to that concept, we have formed a team that includes the military community, our
customers, the academic organizations that work with us, and the industry.  They meet at our organization

once a year in a main industry subcommittee meeting and also at other times of the year. Right now, the
concept is in the 28 subcommittees that currently exist. The purpose of these meetings are to take these
end items—coats, shirts, hats, whatever it is that we procure for the services that are in clothing and
textiles—and look at the existing document and change the way they are described in terms of
performance. No more detail. We don't have to tell the manufacturers how to make something; they
already know.  We just have to tell them how we want it to perform.

       We do that at our annual conference. Our annual conference is being held this year in
Philadelphia, at the Pennsylvania Convention Center, on June 9, 10, and 11.

       What are we doing in terms of acquisition reform? We are doing a lot.  Federal Standard 191 has
206 test methods. That is a lot of non-government standards;  it is a big program.  We are 95 percent done
converting it to a group of industry associated standards.

       Federal Standard 751, a guidance document used in the manufacture of garments, has been
completed. It is an ASTM type.  We expect to have the final document ready at our June conference.
CF-206, felt document, and Fed Standard 311, leather test methods are all documents that at one  time
were unique military types that are now being converted to industry type documents. We anticipate 305
protected adoption notices that we will be doing in our partnership with industry, and taking these federal
documents and using industry accepted ones.

       Then there is acquisition reform, the way we do business, focusing on what we're doing now in
terms of hazardous minimization. The President signed a series of orders four years ago that enables us in
our acquisition process to remove all hazardous components that we require of manufacturers and use
more environmentally accepted type alternatives. That is basically what we are doing now. We  are doing
that in our military service and test methods, and are going to include them in our solicitations.

       We are replacing some of these documents with what we call a nugget.  Instead of using an
associated component spec, we are converting it to a performance description and allowing the
manufacturer to meet those needs.

       We talk about drycleaning in the military community. Well, basically drycleaning establishments
at military installations are small businesses. They sign agreements with military organizations to come
on board and do business. Members of the military organizations that have uniforms historically are
drycleaned.  Being involved in this program and speaking to representatives of EPA and industry, the
question posed to me was, perhaps there might be an opportunity in the military community to provide
them with information regarding wetcleaning. My response to that is, perhaps.

       We also have to educate the military community about wetcleaning. We have to make them
aware of what wetcleaning is and perhaps how it can perform as an alternative to drycleaning. But in
order for us to do that, we have to prove that it is feasible.

        How are we going to do that? Our plan is simple. We're going to request that our customers in
each military service clean two samples of one type of dress uniform that historically is drycleaned.
We're going to take those five sets  of uniforms and send them to a local drycleaning and wetcleaning
establishment. At that time, one sample garment from each service will be wetcleaned and one will be
drycleaned.  At the completion of the cleaning cycles, we will bring the garments back to the Defense
Supply Center in Philadelphia and  evaluate them on several specific factors, such as colorfastness,

elongation, puckering, and seam strength, using industry-accepted test methods from ASTM and ASTTC.
They have representatives here today, which encloses all partnership with industry in how we are going to
evaluate drycleaning compared to wetcleaning.

        We will give the results to our military customers and, if an agreement is reached, we will then
proceed to educate the military community about wetcleaning and exactly how it can be an alternative to
drycleaning.  Basically our plan is to educate the organizations, whereupon the completion of the tests to
provide the military services with the results of the tests on the garments that they have, and therefore
give our customers the desired choice that they seek as an alternative to drycleaning.

        This concludes my presentation.

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00   00





                      Fabricare Resources for the 21st Century

                                     Sylvia Ewing-Hoover
                              Center for Neighborhood Technology

       Sylvia Ewing Hoover joined the Center for Neighborhood Technology in 1995 to lead the
       outreach and  education  arm of  the  USEPA funded  Alternative Clothes  Cleaning
       Demonstration Project. Ms. Ewing-Hoover is responsible for the dissemination of the
       results  of wet  cleaning  research  conducted over  a  12-month period at  CNT's
       demonstration shop, The Greener Cleaner in Chicago.

       I want to talk a little bit about.CAMP.  It is a public-private venture to answer more questions and
get a better sense of how wetcleaning works in a situation where you have an existing cleaner with long-
time ties to the industry, with a large body of knowledge.

       These charts are part of your handouts.  Let me give you just a sense of some of the information
that they have available. This is a 14-week period. They are using (word lost) machines. For all of us
wetcleaning wonks who keep up with the latest equipment, this is the cheapest equipment that you can get
at mis point that will allow you to move beyond what a commercial washer can do.  They also have one
of Leroy Trevine's Millnors, but it is an older model, I believe. They have the American dryers and are
going to move to Unimac equipment.

       The Rehorst staff had two training sessions with Ann Hargrove.  CNT has worked with them to
try and facilitate finding answers, as well as making Bob's work a little easier. They want to provide
research data and business reports and have received support from the Lake Erie Protection Fund. They
also have found that wetcleaning was a little easier than they had anticipated. They are at a level of
wetcleaning at this point where they haven't yet maxed out.  They are under 30 percent, I believe, so the
equipment that they are using is effective and they are  getting their skill level up. They will be able to
provide us with information on both their water use and what it looks like in a scenario where you have an
existing cleaner who is increasing the amount of wetcleaning that they do.  Therefore, they are decreasing
perc, but haven't yet embraced wetcleaning as 100 percent technology. There are many paths to the top of
the mountain, and people can make their personal business choices about what is good for them, but this
kind of data helps them to understand what the options are..

        Let me  just point out that the production costs associated with wetcleaning have been very
favorable. You can see on,the chart a little bit of that, but I urge you to talk with Mary and get more
details, because it is not fair for me to pontificate about their research.  But I thank her for doing the
research, and I thank Bob Rehorst and his whole crew, because very often the owner will say, I want to
try something new, and the employees are saying, my boss has lost his mind. But we see attitudmal
changes and acceptance as wetcleaning use grows.

        I just want to remind you that those attitude issues—this is what I hope you take away from what
Vic Vandermolen had to say from Canada: attitude issues can mean everything. How we embrace the
future, how we respect our diverse opinions and how we move forward, baggage and all.

        This map gives you a sense of how around the country there are resources that are available. If
you look in the southern region, Carolyn Swasz has got the Blue Ribbon fabricare center, where she is

  prepared to do wetcleaning training, she is working on reinex or glycol ethers, and is a resource. You also
  have the trade associations and their training centers.

          The shaded states—California, Illinois, Wisconsin and Indiana—also have the environmental
  incentive programs, where partnership is encouraged, where pollution prevention methods are agreed
  upon by stakeholders, and where there is a market edge or marketing incentive to say to cleaners, "Do
  this, because it makes good business sense."

          So you can see that there are big gaps in the country in terms of resources, but we are hoping that
  is going to change. For example, the small business development centers of the SBA, which is part of an
  agreement under the auspices of that association, at trade shows around that map, cleaners will have
  access to the latest information on wetcleaning, alternative technologies, resources, and good perc
  housekeeping. As it exists now, perc needs to be handled responsibly as we strive to reduce it. The
  SBDC will help spread the tentacles of information a little further around the country, as will the key
  program that I mentioned earlier.

         We also hope in Illinois to soon have one of the first CO2 machines. A cleaner there is expecting
  to complete negotiations next week to have a machine in his shop in Lansing Cleaners, and we will be
  there to see how that works out. Of course, Illinois is the home base for Ann Hargrove.

         You can't see on this map is how in Canada, there is a growing body of information available to
  cleaners and a growing body of partnerships, as well as in South America. We get requests every day
  from people in Mexico and other Latin American countries who are looking at our model of pollution
 prevention through alternative technology.

         Some of you may know, I have had a dual career working with media, so I would like to talk
 about how attitude and communication and media can affect things. You are allowed to laugh.  What it
 says is that consumer education leaves a lot to be desired.

        This is an illustration of a woman watching her television and the newscaster says, brassieres of
 death, film at  11. It is a little bit of the sensational information that is available that doesn't do anybody
 any good, and doesn't provide solid information that people can make decisions on. While, yes, there is
 sensationalism, we all have to work together to make sure that real information gets out, that real reports
 are respected and read. We need to make sure that cleaners get an opportunity to make their own
 decisions and  come to their own conclusions, and that the things that the various stakeholders do agree
 upon are communicated. As progress is made, that is the best way to go forward while acknowledging
 that some differences exist.

       This sheet that talks about wetcleaning pros and cons is an example of what we hope is solid
 information. Wetcleaning is a technology that is something old and something new. Yes, cleaners have
 always used water, but the new equipment, soaps and knowledge make what you do in water easier and
 the range broader than ever before.

       We  have tried to talk about some of the areas that are problematic that research has pointed out,
 some that are still in development in terms of improvement, and some of that are positive and need to be
 acknowledged. I hope at your own leisure that you take a few minutes to  take a look at this and, as
 always, we welcome your comments, feedback, and never criticism, because I know you don't have
anything critical to say.

       We have a wetcleaning information request form that I want to share with you. It shows the
wealth of information that is already out there, from EPA information to the executive summary of the
UCLA work, a wetcleaning equipment report that tells you all of the soaps, equipment, unbiased options
that are available from a variety of companies. As this industry moves forward and as the stakeholders
move forward, it is important to be aware of diversity and not just talk in a negative way about the
changing face of the industry as Ed Barlow talked about the changing demographics, but embracing it
positively. That is something that we try to do.

       With the help of KYCC, we have our information in Korean. It is exciting to know that it is
saying what you want it to say because, thanks to the help of KYCC, we were able to translate this. We
urge all of you, make your information accessible in different languages. Do that outreach, help bring
everybody to the same level of information, and have equal access to information. We also have the
equipment report I mentioned to you in Spanish as well.

       In conclusion, we have a great opportunity to move forward. We've got the next wave of people
from CAMP and TURI and other organizations, Ann Hargrove and Associates, who are ready to help
make fabricare in the 21st century easier and more successful, so that people can succeed and thrive as we
move into the new century.


Mai—2G-9S  O2:37P
            Wet  Cleaning Resources
            Center for Neighborhood Technology • 2125 W. North Ave. • Chicago. IL 60647
            773/278-4800 ext. 299 • 773/278-3840 fax •^us_manAvet_dn.html
  Ann Hargrove and Associates
  Lyons, IL 60534

    •  The Fundamentals of Wet Cleaning
    •  The Wetcleaner Newsletter
    *  Training and Start-up Consulting
 Occidental College
 1 600 Campus Rd.
 Occidental College
 Los Angeles. CA 9004 1-3314

 •  Pollution Prevention in the Garment Care Industry: Assessing the Viability of Professional Wet Cleaning
   [Report on the Cleaner by Nature wet cleaning demonstration project]
 Korean Youth and Community Center
 680 South Wilton Place
 Los Angeles. CA 90005

   •  Cleaners Assistance Program
      [Wet Cleaning Information and Resources in Korean and English]
Toxics Use Reduction Institute
University of Massachusetts-Lowell
One University Ave
Lowell. MA 01854

   •  Wet Cleaning Training Curriculum
   •  Training for Government Officials

Mar--26-9S O2 : 37P
  . 18554 Haskins Road
  Chagrin Falls, OH 44023

     •   Wet Cleaning Research

  Environmental Protection Agency, Garment and Textile Care Program
  Pollution Prevention Information Clearinghouse
  401 M Street, SW. (7409)
  Washington. DC 20460

     •  Wet Cleaning
        [Listing of Wet Cleaners in the United States and Canada]
     •  Proceedings: Apparel Care and the Environment -Alternative Technologies and Labeling
        [From the September,  1996 Conference]
     •  Resource Guide for Garment and Textile Care Professionals
     •  Web page: http:/A^^

  The following organizations offer wet cleaning classes.
  Please contact them for dates, locations  and fees.

     Blue Wbbon Fabricare Center
     165 County Road 3 5
     Jemison. AL 35085

     Cuyahoga Community College
     FabriCare Technology Center
     2237 St. Clair Avenue
     Cleveland. OH 44114

     International Fabricare Institute
     12251 Tech Road
     Silver Spring. MD 20904

     "Neighborhood Cleaners Association-International
     . 252 W. 29th Street
     New York, NY 10001

Ma>—2S-9S  02:36P
                                                   TABLE 5
                                     AS A % OF TOTAL SALES, 1996 AND 1997
                                       (Source: Reehorst Cleaners Records)


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40.13 avg.
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* ^^^S^^^ff^
39.82 avg.

   1 On 8-30-97, the two Daewoo wet cleaning machines were installed
   : On 9-20-97 three UniMac programmable dryers were installed, two 30 pound and one 50 pound
   n On 10-4-97 Ann Hargrove conducted her first wet cleaning training session
   ' On 10-22-97 Ann Hargrove conducted her second wet cleaning training session
   * On 11-1-97 the CAMP wot cleaning project officially begins
  Results from The CAMP Organochlorine Project
  Presented by research partner CNT
  for EPA Conference

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                                                                                                                S    5

             A Comparative Evaluation of Wetcleaning and Drycleaning

                                       Robert Gottlieb, Ph.D.
                                     Occidental College/UCLA

         Dr. Robert Gottlieb is currently a professor of environmental studies and environmental
         policy at the University of California at Los Angeles. He is the principal investigator and
         co-author of Pollution Prevention in the Garment Care Industry:  Assessing the Viability
         of Professional Wet Cleaning.

         I'm going to spend the bulk of my time talking about a project that we undertook, that took about
 two years, called pollution prevention in the garment care industry. It was a research team involving
 several researchers. Peter Sinsheimer, who was a senior research associate on the project, is here.

         It was an evaluation undertaken by a center called the Pollution Prevention and Education
 Research Center. PPERC as its acronym is known, is a interdisciplinary center. It is a research education
 and outreach center. It is based both at UCLA and Occidental College. It is engaged in a series of
 research projects and it has an affiliated center that does work on sustainability issues. It has staff in
 Sacramento and Washington, DC.

        The key to some of our research projects is that we try and look at opportunities for pollution
 prevention and evaluate the context in which those technologies are being introduced and the real world
 circumstances in which they will be  utilized.

        The wetcleaning project that we undertook in the fall of 1995 had an advisory board that included
 cleaners from the California Cleaners Association and the Korean Cleaners Organization in Los Angeles,
 people from the apparel industry, community groups, government agencies, and environmental
 organizations.  We had collaborators on different parts—components of the research and evaluation, as
 well as the demonstration component of the project.  We were funded primarily through the
 Environmental Technology Initiative of the Office of Research and Development at EPA.

        This project involved an intensive case study of a commercial wetcleaner, a startup cleaner that
 began operations in February of 1996.  It was also a comparative evaluation that looked at wetcleaning
 and drycleaning from a variety of different evaluative methods. We also did the comparison, the
 evaluation in the context of other evaluations that occurred, and integrated the results of our comparison
 with those others that had been already undertaken.

       The research components were based on three fundamental components: performance, finances
 and the environment. It was a real world scientific evaluation, and I want to emphasize that.  It was not a
beta study.  This was a cleaner that began for business, operating in real market terms. It was a viability
assessment looking at the commercial viability of the startup cleaner, and then the comparison in relation
to real world drycleaning cleaner situations. It was also an evaluation that was different from an
exclusive laboratory analysis.

       We had two central research questions. Is cleaner by nature a viable business in relation to the
different components of the assessment? And is professional wetcleaning a viable pollution prevention
alternative to drycleaning  in real terms at this moment in time?

        You heard Deborah Davis yesterday from Cleaner by Nature. This was the startup cleaner. It
 was a private commercial facility, organized as a 100 percent wetcleaner. It had an agency operation, had
 a facility in Los Angeles and a drop store in Santa Monica. The formal evaluation period was from the
 moment the store opened in February 1996 through its first year of operation, although there was
'information gathered and analyzed subsequent to the demonstration period as well.

        What you will notice is, as a startup cleaner, this is in terms of garments cleaned per month; the
 performance and activities at the store increased over time. That has been a trend that has continued in
 the post-demonstration period. In fact, just last week a second agency store was opened as a consequence
 of the increased performance.

        In terms of the performance evaluation, the first component was a profile of the customer
 garments. We also were interested in problem garments.  We did a repeat clean test. We had a wearer
 survey based on wearers who participated in the repeat clean test and the survey of their responses to the
 clothes they were wearing.  We also had two sets of customer satisfaction surveys.

        This was an  integrated evaluation. It is important to note that the different components of the
 evaluation helped create the basis for doing an overall assessment of viability.

        In terms of the profile, Cleaner by Nature functioned as a typical drycleaner in terms of the kinds
 of garments that came into the store and that were cleaned. Sixty-seven percent of those garments were
 dryclean-only garments. That percentage breakdown'broadly corresponds to what you will find in a
 typical small drycleaning operation.

        In terms of problem garments, we found that, as a startup cleaner with the new technology,
 certain trends came into place. The primary one trend was, as the cleaner developed experience in the
 technology, the types of problems defined, for example, as redos or problems associated with claims or
 store credit, decreased over time. There was a slight increase in the number of garments that were
 rejected. That actually paralleled the information about increased experience improving the ability to deal
 with problem garments.  If you see a garment that had a problem that would be rejected by any cleaner
 because of the nature of the problem, that was the decision that was made.

        But the numbers are very small.  We are talking about for example, in terms of claims and store
 credit, a percentage of 4/100ths of a percent. In actual numbers in the post startup period, there were
 three claims out of 29,000 garments.  In terms of the year-long evaluation, there were 14 out of 45,000
 garments with claims and store credit problems.

        Another component of the evaluation was the repeat clean test that involved 40 sets of dryclean
 only garments. The  selection was designed to identify garments that would give potentially the most
 problems for wetcleaning. They were selected in conjunction with members of the drycleaning industry
 who were on our advisory board. There were six wear-ins. We used ACCT criteria, in terms of the
 evaluation.  The California State University lab at Long Beach was used. The test was also triple-blinded
 in terms of the basis  on which the evaluation took place.

        There are substantial details that I urge you to look at in the evaluation,  and the methods are
 described in the appendices. One key area, of course, that is on everybody's mind has been dimensional

         In terms of the repeat clean test component, we found that there was slightly greater shrinkage,
 both lengthwise and widthwise in wetcleaning and a very small amount but slightly greater stretching in
 drycleaning. There was a normal distribution in terms of the dimensional change, although it skewed
 more in the area of shrinkage for wetcleaning and drycleaning.

         In terms of general appearance, a series of different criteria, some of the key categories. With
 regard to the proportion of garments with technical problems, in wetcleaning you have more problems
 that are detected. Again, the number of problems detected are small, but you do have more problems in
 terms of color issues, color migration, consistency, and pressing quality in wetcleaning than in
 drycleaning. You have more problems in stain removal and damage to garments in drycleaning.

        This, as I mentioned earlier, is in the context of wearers who were wearing clothes. They were
 also blinded and didn't know what clothes they were wearing. They wore the identical set of garments. I
 should have mentioned earlier, we had three sets of garments that were identical; one went to the dryclean
 shops, one went to Cleaner by Nature, and one was a control garment.

        After the fifth wearing we did a survey of the volunteers. We found essentially that the results
 showed comparability with the repeat clean test results as well. Wetcleaning was detected in more cases
 in terms of shrinkage problems. In pressing problems, drycleaning had more problems in terms of
 stretching and damage to the garment.
        Customer satisfaction was a key component of the performance evaluation. This is a service
 business, and how customers respond adds significant information in terms of evaluating and assessing
 performance viability. For the Cleaner by Nature survey, it was a block random sample and 180 surveys
 completed, a very high response rate. We used the same survey area, using telephone prefixes as our
 area for developing the response. It was a random sample. We had 100 completed surveys and a parallel
 questionnaire. We had not as high a response rate, but still a significant response rate for the survey.

        The customer satisfaction surveys, were broken down in terms of this cart into two areas. One is
 the positive performance attributes that customers were asked about.  Then a set of negative performance
 attributes were presented. Questions included how the respondent felt about the cleaning of the garment;
 if he or she felt positively sometimes, frequently, or always; and similarly if there were negative problems
 that could be determined by asking how you felt about the cleaning of the garments or issues around
 stretching or shrinkage, sometimes, frequently and always.

       The results show some key variables. For example, in the cleaning of the garment, 96 percent of
 wetcleaning customers felt that frequently or always the garment was cleaned. In drycleaning, the
 response was 79 percent. The major discrepancy area in the positive performance area is in stain
 removal, with 79 percent in wetcleaning and 49 percent in drycleaning.

       On the negative performance attributes, in shrinkage 26 percent felt that there were problem areas
 for wetcleaning; 19 percent thought there were problems for drycleaning. In nine of the 10 areas in terms
 of customer satisfaction, there was either equal or greater satisfaction with wetcleaning and drycleaning.
 Also parenthetically, one should note that there was high satisfaction for both processes, for example, not
 on this chart. To a question, would you recommend your cleaner to a friend, 93 percent in wetcleaning
said they would and 87 percent in drycleaning said they would.

        The second aspect of the evaluation is financial obviously key in determining viability issues.  In
 the case study component we had a startup cost analysis, a profit and loss analysis, and we looked at
 pressing productivity issues. In comparing wetcleaning and drycleaning, we looked at equipment costs in
 terms of the startup costs, equipment costs, and maintenance costs. We did a pressing time comparison
 and we also did an overall cost comparison.

        In terms of the case study, this is an income statement that in effect characterizes the revenues
 and expenses that are occurring at Cleaner by Nature on a quarterly basis.  There are two key things to
 understand about this slide above and beyond the specific issues around the fact that your average pieces
 per day are increasing significantly. This parallels, of course, what is going on your revenue side. So you
 are seeing a change in performance in terms of financial performance, so that by the fourth quarter there
 is a small profit.  That trend actually continues into the post- demonstration period. You not only have
 substantially higher profit margins in the second year; but in the demonstration period your revenues are
 increasing significantly higher than your expenses are over time. You are, in fact, realizing greater
 efficiencies as your number of garments cleaned increases, in terms of the kinds of costs and expenses
 that one would have.

        In terms of the comparative evaluation—equipment costs - the wetcleaning equipment is less
 expensive than the drycleaning equipment. However, if you include pressing equipment—in this case,
 the purchase of special tensioning equipment meant that there were greater costs in that category for
 wetcleaning than drycleaning.

        The total costs are relatively comparable, but slightly  greater for drycleaning. In terms of
 maintenance costs, we found that the costs for drycleaning equipment over time are greater than in

        Pressing is an area similar to dimensional change where lots of questions have been asked in
 relation to wetcleaning. We decided to do an evaluation where we had a series of drycleaners
 participating with Cleaner by Nature.  We literally had the stopwatch and we counted the number of
 garments per minute cleaned.

        There were some difficulties because the basis of that evaluation was the only one available to us,
 because we didn't have the same presser pressing the same garments. As many of the cleaners on our
 board told us, pressing is highly variable. Therefore, the numbers are going to vary depending on
 circumstances and cleaners.

        Environment Canada was able to use the same presser used for the same garment, and we also
 looked at their results.  In both cases you have more time required in wetcleaning than in drycleaning,
 although there are differences if you take into account the difference in the pressers.

        That leads to what we defined as process dependent costs.  In other words, there are costs for both
 wetcleaning and drycleaning that will be the same. They might vary in terms of decisions that are made,
 but they are not dependent on the process. Of course process dependent costs will be identified if there is
 a selection of the different technologies.

        The major cost differential in this area is going to be in terms of the greater costs for wetcleaning.
 These will be in the labor side, particularly in terms of your pressing needs. On the other hand, for
.drycleaning, you have greater costs associated with the area around regulation, liability, and the cost of

 the chemicals that tie into those sets of costs, and those costs are going to vary over time. Broadly
 speaking, we found comparability with tradeoffs in the process dependent cost comparison.

        Now, the third aspect of our study was the environmental assessment, and some issues have been
 raised here that I think come into play in terms of our assessment.  We looked at water, both inputs and
 outputs. We looked at water use and wastewater discharge.  We looked at energy use and at chemical use
 and output issues. We did a basic plant level comparison. We also scaled it to the regional level.

        In terms of the regional scale, the assumption was made that if every drycleaner in the study
 area—the service area of the South Coast air quality management district, or essentially Southern
 California—switched to  100 percent wetcleaning, what would happen?  That was the basis of the regional
 comparison as well.

        In terms of these evaluations we had partners with agencies that do monitoring, or that could
 provide the metering that was necessary to identify very specifically the information that we needed.  So
 we had metering taking place in terms of water and  energy. We also had the drainage pipe for wastewater
 discharges monitored. We were doing the metering, the evaluation through the bureau of sanitation in the
 City of Los Angeles at that point at the drainage pipe.

        In terms of water use, our assumption was, unlike Environment Canada, that the water in the
 drycleaning equipment would be recirculated. So our figures are different from Canada. You do find
 greater use of water in wetcleaning than drycleaning, as would be anticipated. There are uses in
 drycleaning, but there are more substantial uses in wetcleaning.

        When you put that in the context of this regional scale model, the issue came up about what
 would happen in a water-dependent region such as Southern California, where you rely on imported water
 for your water source. Well, we were able to not only quantify what that meant, but we then discussed
 that with regional water planners from the metropolitan water district.

        I was on the board of directors of the metropolitan water district in the 1980s, and we calculated
 that the percentage would be the equivalent of a population increase of 3,000 people, if every drycleaner
 converted to wetcleaning. They felt this was not significant, particularly if you compared it with one
 small production well that is taken out of circulation because of contamination.  That is the more
 significant amount of water lost. So they didn't see water usage as a significant environmental problem
 in the region in terms of a shift to wetcleaning.

        In terms of the wastewater analysis, we found that there were no problem areas in the permitting
 or the standards that had been established for pH, VOD, heavy metals, and so on. This was consistent
with the Chicago study results as well. We were able, as I said, to evaluate it at the drainage pipe.

        In terms of energy use, there is greater use of natural gas in wetcleaning, but because of the
pollution control equipment there is a greater use of electricity in drycleaning. Basically, the two are
broadly comparable. In the regional analysis we also attempted to look at from an AQMD matrix, how
you would translate that information into pollutant levels.

        Stated another way, natural gas is essentially a cleaner technology or cleaner source of energy
than electricity. However, you had greater natural gas use in wetcleaning, so you're talking  about broadly
comparable energy use.

        The big difference as you might expect was in chemical use.  There was no waste sent out from
 the collection on the spotting board and the chemicals used in wetcleaning.  We also evaluated the
 chemical use specifically in terms of their content. In drycleaning, there was a calculation based on
 AQMD in air resource board data. If you did that conversion, you were talking tons per day., for example,
 of a reduction of essentially 4.2 tons per day in terms of PCE emissions and of .4 tons per day in terms of
 hazardous wastes.

        Although we couldn't directly quantify a series of factors, we still looked at them. They play a
 role in terms of thinking about if this technology is viable, if the operation is viable, and about what is
 going to happen in the future. You do have technology changes.  This conference is talking about what
 could happen upstream. You have care labeling issues.

        These factors will influence these changes in terms of technology. There is a whole set of issues
 around marketing that needs to be explored. They will have a significant impact on the future of the
 different processes, as of course regulatory and legislative issues are going to come into play, on both the
 environmental and the financial side. For example, one of those new technologies, the form fitter and
 pants topper, has special tensioning equipment, which changes the dynamic. That was when we were
 able to incorporate into our analysis because we could look at that in relation to the performance

        There is one area in terms of these contributing factors that you could begin to quantify.  We did
 that for this evaluation because, in California, there is no provision right now for state legislation to
 reduce the risk of cleaner liability risks related to perc use. But several states do have laws on the books,
 and some but not all have been supported by drycleaner organizations.

        Wisconsin, for example has a gross receipts tax of 1.8 percent and a five dollar a gallon tax on
 PCE.  Such additional costs in turn need to be incorporated into any evaluation of the financial viability of
 a system.

        Our conclusion,,in terms of the case study, is that Cleaner by Nature is a viable business. It
 cleaned a full range of garments, and it clearly improved performance over time. There was strong
 customer satisfaction and increasing profitability. It has now expanded to a second agency site, and there
 is minimal environmental impact.

        In terms of the comparative analysis, our evaluation identified wetcleaning as a viable pollution
 prevention alternative.  In the performance area, we feel there are challenges that remain in both
 processes. In wetcleaning, there are continuing issues with shrinkage.  Some of these are garment
 manufacturing issues and technology issues that can be addressed; some are performance with experience.

       Drycleaning, as has been pointed out in studies and discussions in the trades, has problems
 around stain removal and garment damage. But they are probably comparable in terms of the evaluation
 that we provided.

       Looking at financial issues, there are tradeoffs in wetcleaning and drycleaning. I think you want
to think about the overall context and perspective. In wetcleaning, you do have higher labor costs, and
you do have higher detergent costs. In drycleaning, you have higher equipment costs and higher
regulatory costs. As I said, that is also a changing dynamic in terms of the contributing factors.

        On the environmental side, wetcleaning is more viable. The environmental impacts are minimal
 on the wetcleaning side.  They are significantly greater in drycleaning, and can be measured specifically
 in terms of the chemical use issues.

        Where do we go from here? We completed phase one of our research. We feel there are
 significant issues of research, policy, and industry development that need to be addressed.

        In terms of policy, in the rulemaking processes at both the state and federal levels, how do you
 assess and evaluate where you put a wetcleaning technology in the rulemaking framework. In a broad
 statement, wetcleaning can be considered best available control technology.

        There are technical and financial issues. Every cleaner, wet or dry, obviously is interested in
 making opportunities available, particularly where it has decided to incorporate a wetcleaning system or
 switch to wetcleaning.

        There are structural issues. Care labeling is going to be discussed tomorrow.  We had on our
 advisory board garment manufacturers and retailers. We have begun a process of working with them to
 deal very specifically with issues that can be addressed on the future of this process.

        There clearly needs to be wetcleaning facilitation.  There needs to be quality control, as in any
 kind of service industry.  That is an issue that needs to be developed and expanded. There needs to be a
 specific home for wetcleaners where they can not only share information, but also develop the kinds of
 tools, whether it is performance tools or the marketing tools and the financial tools that are going to
 facilitate the development of this industry.

        Part of our effort was also a demonstration project.  In California we had intense interest by
cleaners in a tour that the Korean Youth Community Center organized. We had about 30 Korean cleaners
that came to the site. The dialogue with cleaners and others who are interested in wetcleaning has to occur
and has to really be expanded in a number of different venues.

        Just one final thought. Pollution prevention, I think, can best be characterized as solutions  that
create opportunities for an industry.  For cleaners, the presence of a viable pollution prevention alternative
opens doors.  It establishes, I think, a basis not just for survival, but for growth and sustainability, and in
fact, I would argue, for peace of mind.

      Taking an Industrial Ecology Approach to Garment and Textile Care

                                    Braden R. Allenby, Ph.D.
                         Vice President for Environment, Health and Safety

        Brad Allenby is currently Vice  President for the Environment, Health and Safety for
        AT&T.  He has authored a number of articles and book chapters on industrial ecology
        and Design for Environment; writes a column for the Journal of Industrial Ecology; is
        co-editor of The Greening of Industrial Ecosystems, published by the National Academy
        Press in 1994; and is co-author of several engineering textbooks, including Industrial
        Ecology,  published  by Prentice-Hall in  January of 1995, Design for  Environment
        published by Prentice-Hall in 1996, Industrial Ecology and the Automobile,  published by
        Prentice-Hall in 1997, and Industrial Ecology: Policy Framework and Implementation, to
        be published by Prentice-Hall in 1998. The views expressed in these comments are the
        author's and not necessarily those of AT&T.
        The purpose of my remarks today is not to try to talk about drycleaning and fabrics. Rather, I'm
going to try to establish a little bit of a context so that you can see how the very tumultuous kinds of
things that are going on in your industry in fact are mirrored in a lot of other industries, and the
implications are just as serious in those industries as they are in yours.

        There are two important principles that go a long way toward establishing this context. The first
is that what we are talking about is not really environment. What we are really talking about is
technology. That is important because, as long as people think they are working with environment, they
have a tendency to slip into the old compliance or remediation mind set. Such a mindset treats
environment as overhead, for both the firm and society. But if the changes caused by environmental
issues are occurring in your base technologies, then you are dealing with strategic technology issues that
are critical to your business, not just environment.

        The second related point is that environment is in fact moving from overhead—overhead is
putting it over in a corner and letting somebody else take care of it, which is the way most companies still
treat it—to strategic for the firm and for society as a whole. Part of that process is that environment no
longer dominates the decision-making process.  That is a difficult transition for people who work with the
environment, and it is a difficult transition for the ordinary business person who has to think about
environment in ways that she or he never had to before.                             ,

        So what does all this mean?  Well, let me go through a little bit of it. I will offer some scenarios
in doing so, not because they necessarily are what will happen, but because scenarios can help you think
about what might happen and how you would adjust to them if they did happen.

        Let me begin by discussing some of the requirements of the Blue Angel ecolabel in Germany,
which is now in place for personal computers.  The first requirement, that personal computers be designed
so they are modular and can be upgraded by the user, is a profound challenge to a design team.
Functionality in a personal computer is very protean; it can reside in a lot of different places in the
software-hardware system.  So as soon as you tell me I've got to go to modular design, you're telling me
I've got to begin freezing that functionality in different places in the computer. You're also telling me that

 the interfaces between those modules have got to be robust enough so that the technology can be
 upgraded in unpredictable ways throughout that computer, and I can still maintain a working system.
 Moreover, this is a volunteer standard, so you're telling me that I've got to do all that and still compete
 with manufacturers that don't bother to do any of it.

        The result is a very profound design challenge. It has significant market implications as well. In
 this case, about two weeks after these ecolabel standards were put into place, NCR and a couple of other
 companies met the standards and, based on meeting the standards, were awarded a large contract from the
 government of Denmark which piggybacked their procurement policies on the ecolabel standards. The
 strategic and marketing implications of the Blue Angel are apparent.

        The point of this example is not computer design, but to illustrate the gap between environment
 as strategic, and the way we usually think about it.  This is not the kind of challenge that you solve by
 working with a scrubber or by putting more water treatment plants in.  This is profoundly strategic for
 anybody that manufactures computers and intends to compete in the global market.  That is the difference.
 This is what environment is today.

        I'll take another example. Let's take one that is near and dear to my heart, a central server. A
 central server is basically a computer with a whole lot of memory that you can put in the network as
 information and entertainment are increasingly digital, pretty  soon, you're putting all kinds of songs,
 films, performances, and even art on the central server with new broadband technology, you'll be able to
 access it in real time.  In fact, next year there are going to be cars on the road that are fully equipped with
 Windows 98.  (You think you've got problems with cellular phones wait until you're rolling down the
 highway in a PC.)

        What this means is that you potentially can achieve discontinuous environmental improvements
 in the data storage industry. Why?  Because you dematerialize the CD and the tape industry. You no
 longer have to go out and buy a CD with one song that you like from Madonna and 15 that you don't.
 You just pull off what you want from the Internet in real time.

        So by substituting electrons for pressed plastic, you can achieve significant environmental
 benefits. However, think about the other implications of doing this.  A whole sector of small business just
 got knocked for a loop. What happens to the people who owned video rental or music stores, or people
 who make and manufacture CDs? Where is that distribution chain? What about the shops that are now

       The downsides of any technological evolution - for that is what it is - become clear in the
 example. We shouldn't think that this kind of technological change is going to be easy or painless. In
 fact, it is liable to be very, very painful for some people. One of the reasons that you want to study these
kinds of scenarios as a private company is to try to understand where you are liable to get blindsided.
You also want to study this as a society so that you can prevent or mitigate some of the pain that
technological evolution is going to cause.

       Another interesting scenario illustrates another basic trend in our economy which has the
potential for significant environmental efficiencies. Consider a very interesting shift in the auto industry.
Companies such as PPG used to basically manufacture stuff, in this case, paint.  And the more paint they
shipped out the door, the more they got paid. So in fact, their  incentive was probably to get people like
GM and Ford to use as much paint as possible, right?

        But then both the automobile manufacturers and the paint producers decided to try a new business
model which offered both parties better value: rather than sell paint, the paint manufacturers would
contract to provide a service, painted "bodies in white," or care chassis.

        As a result a sector that was previously offering a product, paint, is now offering a service, car
painting, and getting paid on that basis. The process is being expanded, because it has been very
successful. The savings to the car manufacturers have been substantial and the savings to the people that
provide the service have been substantial.

        Now, what are the implications?  First, if you thought your business was making paint and
shoving it out the door, guess what? You just lost a critical customer, because these service contracts are
locking in supplier relationships.

        More subtly, it used to be that my business plan was to make as much paint as possible. My
business plan now has shifted fundamentally to trying to understand how I can paint cars with minimal
liability, minimal exposure, minimal waste costs, and as little paint as possible. I am now a service
company, and the people I hire are very different than the  people I hired when all I did was manufacturer
paint. One lesson of this experience has been, in fact, that service firms require different skill mixes than
manufacturing firms.

        It is at least possible to develop a framework that can be used to think about some  of these issues
(Figure 1). The vision is sustainable development, but it remains a vision because it cannot yet be

        There are at least three separate paths of evolution that have to occur as we begin to really work
into these issues. The first is ethical and theological.  For  example, if you look at the climate change
negotiations in Kyoto and why they were so rocky, it was  not because of the science and technology; it
was because the institutions to make Kyoto work do not exist. It was an institutional problem, not a
science and technology problem.

        Industrial ecology is the field that tries to study  these very difficult and complex multidisciplinary
issues, which essentially amount to the impact of human economic activity on the environment.  It may be
thought of as "the science of sustainability."

        Assume that we provide companies and individuals can be convinced to do the right thing
environmentally.  The industrial ecology infrastructure  then is the answer to the question:  What do we
need to provide as a society so that they can do so?

        At the most operational level, you have implementation at the firm level through things like
Design for the Environment.  Here, a whole set of tools  relying on practices such  as Design for the
Environmental (DfE) and life cycle assessment are being created.  It is not overhead, it is not compliance,
it is not remediation. You are dealing again with a strategic dimension of technology driven by
environmental constraints, not by remediation and compliance.

        I would like to close with a scenario for drycleaning that integrates some  of the things that I have
talked about (Figure 2). Remember some of the themes: the importance of technology and the shift
between simply offering a product and offering a service.

         One dynamic that is apparent in the figure is that the distances between different pieces of the
 supply chain collapse. Taking our previous example, PPG and Ford are now heavily dependent on each
 other. That linkage becomes very strong; for PPG and for Ford it is a win-win. For the people who get
 cut out of that, it is a significant loss. So you see, offering a service within which the product is
 embedded is beginning to replace just passing on materials.

         Turning now to dry cleaning, and the major environmental issue associated with existing
 technology, emissions of perchloroethylene.  First consider technology options: You can do things such
 as better housekeeping and emission controls, working within your existing infrastructure.  There are also
 some service options for reducing emissions. The most obvious is offering a pressing service without
 requiring cleaning. In many cases, people are happy with that. So there are things that can happen with
 only minor changes in the existing system.

        But now jump one up. Go to a future environment where you are looking at alternative cleaning
 technologies. Suddenly, the issues begin to get broader. The advantage of doing end-of-pipe stuff is that
 the impacts are pretty minimal if you make a mistake. You just put on a little bigger scrubber than you
 need or something like that. But once you begin changing process technologies, you have upped the ante
 considerably, because a process technology will be locked in for a relatively long period of time.  So if
 you choose the wrong options, the economic and environmental costs are far greater.

        This also begins to lock you in to a larger network economically. It is hard to begin looking at
 alternatives without also looking at the fact that you as a dry cleaner become more dependent on different
 parts of the supply chain to make the changes. You are, after all, dependent upon the firms  that make the
 cleaning machines, so they become part of the system.

        What happens? You may begin to form complex cleaning and garment management paths. That
 is to say, when somebody comes in, you take the garment and push it into the process that works best for
 that particular garment, given those particular circumstances, the equipment that you've got, the
 equipment that is available, and the kinds of products and materials that are available to use in that

       Finally, let's jump much further out, and look at what might happen with really fundamental
 technological evaluation.  As most of you know, you can grow cotton now that has already got polyester
 in the fiber as it comes off the field. It is only a couple of percent, but the possibility of wash and wear
 right off the boll cannot be ignored.

       Think about somebody downstream perhaps, some large garment manufacturer that makes blue
jeans, that suddenly says to itself, if people are going to start liking things that don't need to  go through
 complex cleaning processes, I can begin to design my fabrics and my clothes differently. What happens?
 Drycleaning is getting awfully close to the Blockbuster scenario, to getting blindsided by technology that
 is coming out of a part of industry that you weren't paying attention to.

       So what happens? First, remember that this is only a scenario, there are a lot of things like
 cultural inertia which in practice make many such technology shifts problematic. A lot of people like
wearing clothes that need to be drycleaned. They are used to them; they are comfortable with them; there
is a pattern of habit that will tend to persist. It may take some time before any of this really happens, if it
ever does.

        If it should occur, everyone in the clothing industry will see a shift in the network of
relationships. You're talking about going all the way back perhaps even to the people that grow the
cotton.  Or perhaps you even go back to companies like Monsanto, that now decides, in addition to
making cotton that works with Roundup, they are going to start putting polyester in the boll.

        Obviously, there are enormous problems as soon as you get into these issues.  For example, how
does an industry characterized by very small operations deal with some of the other pieces of the supply
chain that are so far away and have interests that are very different from the interests of the drycleaners?
These are not easy questions to resolve.

        Finally, you've got the possibility that you evolve a new kind of service. A lot of people,
particularly in urban areas, are going to like using a service that manages their garments, whether it is
drycleaning them, just washing them, or perhaps even mending and maintaining them. The reason is
affluence combined with diminished free time. Do they want to spend their one free day working on
clothes? No. You begin to see the possibility that there are service options that can pick up and integrate
some of these offerings, present a new and integrated service to the public that in fact, creates more
demand rather than less.

        Figure 2 suggests some possibilities, but they are only illustrative at this point. The main value,
as with any scenario, is beginning the creative planning process. How would you restructure your
offering to cement your relationship with the end customer and make your service important to them by
locking them in? What might work? Why might it not work? What is it that you really do? Do you
need to  form new alliances or business relationships to make it work?

        In the end, this is the value of the application of industrial ecology principles to the drycleaning
industry: not just to resolve an immediate environmental issue, but to suggest new market structures
where not just the customer, but every element of the supply chain enjoys enhanced value - in other
words to build a better future.




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    Setting Up a National Distribution System for a New Cleaning Technology

                                     Jack Belluscio, President
                                       Global Technologies

         Jack Belluscio is President of Global Technologies, LLC, since 1994.

         Thank you.  Global Technologies was created to address many of the issues that we just heard
 from the executive from AT&T. When brought into an industry, technology cannot just be converted
 haphazardly without considering the implications of its impact on the industry, on how we present the
 new technology to government officials, how we present it to the marketplace. We also have to consider
 what its ultimate cost is, not only to the end user, in this case the small to medium sized businesses, but
 also to the consumer, and how we might be able to use technology to revitalize an industry.

        What I was asked to discuss today was not the technology that we are commercializing called
 Dry Wash, but our process of how we look at commercializing this technology. I thought it would be nice
 just to share some of the ways in which we look at technology. Our role is specific to defense technology
 conversion and transfer.

        In this case, my company is marketing the DryWash cleaning process and we are targeting the
 mom and pop operations. Our company wants to make sure that when we say that we have no hazardous
 chemicals, less energy consumption and better cleaning, that we are addressing the needs of at least 70
 percent of the marketplace.  We have to make sure that we can not only sustain the needs of the industry
 today, but hopefully look towards some growth for the industry's future.

        We have a very specific process. This particular technology came out of the aerospace industry.
 It normally takes 15 years to have an aerospace technology come out of the laboratory and into a usable
 form. We have come up with methods of how to commercialize technology in a five-year period with
 five very specific steps.

        This is our commercialization time line.  This particular technology came out of what was
 originally called The Hughes Aircraft Company.  It has since been purchased by Raytheon Systems.
 Before it gets to product, a technology goes through its own life cycle.  At Hughes Aircraft, it had
 investment and competencies far beyond or far different than anything that our own industry could pull
 off, so it has a very large investment in technology from the beginning. As time goes on, the technology
 provider reduces its investment.

       At the same time, it is a company like mine that encourages manufacturers of that industry to join
 the team and see how to share the technology and how to start their investment moving towards a final
product, so that we have a smooth transition between technology and end product.

       In the commercialization business, we call this the valley of death. This is where most
technologies fail, because the laboratory is developing something wonderful for an application, but the
marketplace is not ready to accept it. This happens either because of lack of investment or lack of vision
or because the competitive forces within that industry seem to be too  great for one company to take on.
So collectively, we understand this and say to ourselves, we have a good technology and we want to move
it to the marketplace We say, what are we looking to do?

       The life cycle of the technology is risky. Most people know somebody who is an early adaptor or
an innovator.  If we bring technology such as the Dry Wash to the market too soon, and we are only
looking towards the early adapters here who are the top 10 percent of the industry, chances are good that
the technology will fail. If the technology doesn't fail, then the industry will be hurt because 90 percent of
the marketplace can't afford it, or doesn't know how to use it because it is too complicated.

       This is why we go through this process of assuring that when we release the DryWash
technology, it will address at least 70 percent of the marketplace. We must look at the needs of the entire

       There are approximately 150,000 drycleaning plants around the world. Each one of them is
cleaning clothes, each one of them is using solvent, and each one of them has machinery. If we come up
with a technology without this total industry approach to ecology, then we have failed in our mission. We
must look at a whole product model when we are commercializing this technology.

       We have to look at the installation and the logistics. We have to make sure distribution is in
place, because the sales and service is what makes it affordable for the technology. We have to make sure
that we have system integration. The machine that we and our manufacturers produce must fit in the
same location as the old machine. It must have a chance to improve the business.

       When we understand the different models that we are considering for our technology we come up
with five specific steps that take a total of five years.  But the technology must consider the industrial
ecology point of view. It must consider the entire concept of what the industry is trying to do, and how it
could help the business grow. The technology must be widespread, and it must be a better performer.
And ultimately at the end of the day, we have to be able to make money with the technology.  It has to
have some economic benefit. It has to go beyond being environmentally sound. There are far too many
consumer studies that say people love to be environmentally friendly, but they may not be willing to pay
more for it. As my company moves forward, working with 14 manufacturers and  sharing technology, we
always have to keep that in mind.

       Step one was to create a technology  for market needs.  This was our first year. It was  1994, when
you may have heard of the DryWash process coming to the New Orleans convention in '95. In '94 we
created a technology group.  On one side, we had Los Alamos National Laboratories with the support of
the government agencies, such as EPA and the Department of Energy, helping to validate the core
technology, which you know as DryWash today.

       On the other side was Raytheon Environmental Systems which was developing the technology.
Between Los Alamos validating the concepts and Raytheon's scientific team developing the process, we
were able to come up with a usable technology that we were able to demonstrate for worldwide services.
Throughout this process, we had to maintain that easy-to-use concept. More importantly, the technology
should not change the way we are doing business. We should not be saying we are going to pull out our
old machine, or tie into some satellite store, or add a truck on the road that may be polluting more, or
looking at another way of doing the business.

         We have a good industry structure today, and it is our job at Global Tech to make sure that the
  technology uses that industry structure. That structure allows the industry to accept the technology and
  helps us to keep that mind set that we are looking at it from an industrial point of view.

         In year two, we introduced the technology in June of '95 at New Orleans. It was a laboratory
  bench model. That was the first time we allowed the marketplace to talk to end users, distributors, and
  manufacturers.  We told the industry that there was another team on the case that was bringing technology
  out of the aerospace industry.

         In year three, we needed to demonstrate the commercial use.  In 1996, we were looking at
  improving the performance of the carbon dioxide technology. We wanted to demonstrate that there was
 no hazardous waste in the process and that we had a way to expand the business for the future.

         Last year was our fourth year. This is where we had our commercial teams sharing the DryWash
 process. There was a demonstration in Las Vegas in 1997.  Over 3,000 people came into our booths to
 meet the manufacturers of the process and to watch demonstrations.

         This is a very unique situation. We have major manufacturers sharing a portfolio of core
 technologies so that they can work on the industrial ecology concept.  At the same time they work on
 applying the technology to the demands of the industry, which is unusual. For most technologies, the
 industry has to change to meets its requirements, which  is something that we heard from our last speaker.
 But we have to look at it as a better performing solution, or it is not going to fly.  Our customers, our
 industry participants, know that they need to pay the bills and make money; it has to be more than just
 environmentally sound.

        We are now in our fifth year. You will start to see DryWash units popping up. There are eight
 locations right now around the world that are using it in  a test mode. They are not only perfecting the
 machinery, but the DryWash fluid and the chemical additives. Chemical companies offer a full line of
 chemical additives that are hazardous waste-free and that are not dangerous to workers. Manufacturers
 such as Electrolux, Raytheon Commercial Laundry, and Comico are all working on their designs.  They
 are all working on how to meet the current needs of today's machinery.

        Caled Chemical, Sales Star, and a few other chemical companies that asked not to be mentioned
 today, are all helping my organization work together in sharing this one core technology.  Together, we
 work on the trade relations and the government issues.

        One of the things that we don't want to see happen with this technology is what took place in the
 German marketplace. In one year, they had over 8,000 drycleaning locations and then the next year they
 had around 4,000. I know we have a speaker from Germany, and perhaps we could ask him why.
 However, the one thing we don't want is to lose half our industry because somebody thinks that there is a
 solution here in technology, and that we need to shake the tree or something.  We need to keep our
businesses active. We have to look for other applications and other ways to expand the business.

       It is important that whatever technology comes out, whether it is  the one that Global Tech or
another is presenting, it has to be low cost. Again, it cannot change the way we do business today. It
can't have any environmental problems and we have to have a chance to improve.

        Speaking of improvement, these are some of the early results of the DryWash chemistry that is
coming out. Here is a grape juice stain. We have the actual swatches we can pass around. This is a grape
juice stain that was cleaned with liquid CO2 using the DryWash process.  It worked a little bit on the
stain. But the moment we added the DryWash fluid, the detergent package, we were able to remove the
grape juice stain almost completely on wool and on polyesters.

        Why are we doing this? Because when a new technology comes into our marketplace, we have to
find a way to do business better. We have to have the chance to say, "How can we be more profitable?"
Our goal with the DryWash system is to eliminate pre-spotting, so that we don't have the labor step there.

        The nice part about using carbon dioxide is that it works in a cool environment, as you will leam
from the technology council. We clean clothes at 58 degrees Fahrenheit,  so you are not setting the stains.
The DryWash package along with its additives has a better chance to work.

        There is a very good possibility that today we are looking at how to solve the problem with perc
and tomorrow we can be looking at how to clean clothes in water. This is a laundry standard. This is the
target that we are looking at.  How we could help bring additional business back into the marketplace.

        A lot of people are saying, we heard that you were out here, and we want to have results on where
you are, where you stand.  You have 14 companies sharing technology. Currently, we have machines
located in: Los Angeles, Minnesota, Wisconsin, Milan, Italy, Sweden, and China. These are locations
where manufacturers are developing their equipment. They are preparing to release it, and are working
with their local distribution channels.

        When we do  come to market, we will have both a wide span of knowledge base on the process,
and an understanding of the cost structure involved. Then can they provide the services that we promised,
while not changing the industry?  I can't emphasize that enough. When we commercialize a technology,
it must address a minimum 70 percent of the industry. When we support a technology in this room or as
part of this industry, we have to make sure that it is going to expand the business and assist the neighbor
across the street, as well.

        Whether you are a competitor in a drycleaning environment, whether you are right across the
street from each other, you need friendly competition. You need to create an environment for providing
services to the consumer.  We have to think together about how to use technology to improve our

        We set up a five-year plan for developing a distribution system for a technology that came out of
the aerospace industry—somewhere completely outside the drycleaning industry—and-we brought it this
quickly into the industry.  Now you will start to see local drycleaners having these DryWash machines,
and you will be able to see them for yourselves. I think that to do this in  five years is pretty astounding.

        I just want to personally think Mary Ellen Weber of the Design for the Environment, 'it has
turned out to be a good project from the beginning. Many people are hesitant about talking to
government officials. However, the leadership that DFE has provided us in giving us an opportunity to
 discuss new technologies and problems has been very special for me.

         So thank you very much for your attention. I truly appreciate your time.

          Results of Pilot Study Comparing New Technology Performance

                                        Perry Grady, Ph.D.
                         College of Textiles, North Carolina State University

         Dr. Perry Grady has taught and conducted extensive research in textiles in instrument and
         control  system  design  and  development,  energy  utilization  and  conservation,
         electrotechnology applications, fiber production and properties, and garment and textile
         care. He is co-editor of the books Microprocessors and Minicomputers in the Textile
         Industry and Automation in The Textile Industry: From Fibers to Apparel.

         Well, you see you are going to hear from three professors, and you know that professors only
 speak in terms of 50-minute blocks, so this will be an hour and 50-minute speech, I guess. But hopefully
 we'll make it a lot quicker and a lot shorter than that. I think the reason they left me out of the program is,
 they probably discovered that I hadn't done anything. The two guys who are going to talk to you most
 have actually been more intimately involved with the research.

        This is a joint project between the North Carolina State University College of Textiles and Texas
 Women's University, the Department  of Fashion and Textiles.  I would also like to recognize that this
 work was supported by EPA, the Office of Research and Development,  and the project coordinator for
 that is Mr. Chuck Darvin, who is seated over here. He  has graciously agreed to answer any nasty
 questions we get.

        Our main purpose in this project is to generate  some comparative data on the cleaning ability of
 various technologies mat you have heard a lot about. You will see some very specific data on different
 stains, different fibers, and different technologies. These are truly preliminary results that have not really
 been reviewed thoroughly yet. Therefore, we are not planning to give them out as  a handout, because we
 won't set input from in these results until later.

        The primary purpose of the project was to develop methods to compare different technologies and
 also work on developing new technologies such as ultrasound cleaning and CO2 cleaning.

        We are still in the process of developing protocols both for swatches and for garments, and
therefore we are looking for input.  We also have a poster session in the Arlington Room, and we would
be happy to have you come by and look at even more results than you will see in the paper coming up.

        Dr. Michael Overcash is also going to be involved in this presentation and has done a life cycle
analysis, and he has a poster session as well. I'm sure he would like to talk to you if you're interested in
life cycle analysis.

       We are also doing physical tests that will not be covered here; we will be covering just cleaning
tests, and those are being analyzed and will be presented later in the final report.  I also want to recognize
Mr. Bob McCall, who actually put this presentation together. He was going to be a big part of the
presentation rather than the three of us, but Bob had surgery yesterday to remove his gall bladder, so he
was unable to attend today. But he did do a lot of work on this, and I do want to recognize it.

       With that, I'll turn it over to Charles who will start the presentations on the results.

   Results of Pilot Study Comparing New Technology Performance (continued)

                                      Charles L. Riggs, Ph.D.
                                    Texas Woman's University

         Dr. Charles Riggs is a tenured professor and Coordinator of the Texas Research Center
         for Laundry  and Drycleaning and the  Textile Testing Center at Texas  Women's
         University, Department of Fashion and Textiles.  He is a member of the American
         Association of Textile Chemists and Colorists, American Chemical  Society, American
         Oil Chemists Society, and the International Textile and Apparel Association.

         Thank you. It is a real pleasure to be here. One of the things that Manfred did not say in the
 introduction is that I have been involved in the textile cleaning industry for some 24 years. During that
 time, my emphasis has always been quality, that is, the quality of the service. I think it is something that
 hopefully is not being overlooked, but little is being said about it.

         By quality, I am dealing with the question of whether the garment comes back much like it was
 when the customer bought it new. Now, that includes, is it clean?  Is it damaged? Has it shrunk? Is it
 finished properly?  All of these elements need to be evaluated as we look at the performance of these

         Now, we are going to concentrate primarily on the cleaning aspects. I think you are going to see
 some results that indicate that performance depends a lot on how you do the individual process, whether it
 be drycleaning, wetcleaning, or whatever system. There are variables within those processes that can give
 you a tremendous range of results.

        When we start to clean garments, we invariably are looking at a compromise. Two of the inputs
 that go into the process are a chemical input and a mechanical input, usually through the agitation or
 rotation  in the cylinder.  Invariably if we start looking at more and more sensitive garments, we tend to
 reduce the mechanical input and if we don't make up for the loss of mechanical input with chemical input,
 we end up not getting things clean.

        My point is that we should not compromise getting things clean. I don't think that is exclusive of
 our environmental concerns.  What I have found throughout the years in working with laundries in the
 drycleaning industry is that the management factors that you have to employ to get good quality tend to
 give you good environmental results.  Because you have to manage  each detail of the process, the
 equipment also has to work properly, and you have to manage all the inputs and outputs.

       In terms of the overlap of quality and environment, I'd like to borrow a quote from John Michener
 and summarize it. John was at the September '96 conference and has been involved in the industry for
 many, many years. John talked about his recollection of the 1970s of how we began to be concerned for
 environmental topics such as phosphates in detergents.  Once the phosphates were taken out it became
 somewhat more difficult to clean things in laundering.

       Shortly thereafter, we had an energy crisis, and we were encouraged to wash in cooler water
temperatures, and it became more and more difficult to do the chemical process of removing soils.

       Now we are talking about other technologies, and we need to keep this in mind in terms of
cleaning abilities.  John's comment was that to him, his environment began at his underwear.  Then the
cleaning aspects of his environment went from his underwear outward.  So I don't think we are
necessarily excluding one for the other, and I encourage us to keep this in mind.

       In terms of the technologies evaluated, we took on the task of looking at production scale
machines. These are not laboratory studies so we evaluated production scale machines that were
currently available to the cleaning industry. The technology involves perchloroethylene and it is well
defined.  I'm going to come back to the definition of perchloroethylene technology again, because as we
move forward with any of these industries' technologies, we must first define what we mean by that
technology if we are to use the technology properly. That definition then is backed up by a test method,
and then  garment producers have a test to apply to determine what care label is appropriate.

       At the present time, there is a definition for drycleaning, which in my mind could use some
refinement.  Hopefully, with input from the FTC, we will see some refinement as well as some new

       For example, the definition for the  solvent process specifies up to 75 percent relative humidity
and moisture content. But yet, we see terms that say low moisture and general cycle that aren't defined.

       We also put hydrocarbon solvent cleaning into our system. We opted to use the new generation
synthetic hydrocarbons, in part because the composition is more precisely known and more reproducible
results arise  from that kind of a system.

       We also looked at machine wetcleaning, which at this point is not a defined term. I think some of
the deviation we see in results from different demonstration projects comes from the fact that we have not
defined what we meant by wetcleaning.

       Ken Adamson is the only one that showed details of the process. He showed processes ranging
from a machine turning at five RPMs, a very gentle cycle, to one turning at 28 RPMs, a much more
aggressive process. How you do the test determines how much damage or how well this process cleans.

       For this test, we used the machine operating guidelines that are being proposed by the Europeans
in their round-robin testing of wetcleaning  machines and wetcleaning systems.  It is the definition that we
will propose to the AATCC as a definition for what wetcleaning consists of. In the protocol we are
following, we will set forward and encourage them to adopt a certain standard.  The standard would tell a
manufacturer if they could wetclean something  using this process based on a wetcleaning label or if it
needed to have one of the other labels attached.

        In looking at the evaluation, we used the IWS wool  test fabric. This is a fabric that is commonly
used in Europe. It is actually part of a test  for compliance of home machines for home use in Europe, but
it is also a reasonable fabric to look at in terms of potential for damage in these technologies. The fabric
will shrink if it is not handled properly.

        We also looked at  the standard testing device used widely in the cleaning industry. The device
was produced by IFI, which includes some water soluble and some soils required to be removed by
mechanical  action. We also looked at some standard soil materials from WFK in Europe. We actually

  tended to drift towards the WFK material as our preferred one.  It is a composite of 16 different soils, that
  is, 16 different combinations of soil and fabric.

         Here is a slide which summarizes the shrinkage data for one cycle and eight cycle cleaning,
  wetcleaning, hydrocarbon cleaning, and perc cleaning. Not too surprising, we see more shrinkage with
  wet cleaning because of the nature of the wool fiber on exposure to moisture.

         Looking at the soil removal, we see the soil properties depend on what kind of soil we have.  The
  dye stain on the IFI soil test swatch is a water soluble dye. It comes out very nicely in wetcleaning. How
  well it does in solvents depends primarily upon the detergent additive.

         In this particular case, the detergent that we used with the perc turned out not to be a very good
  one. In fact, with the other detergents, we would see the perc and hydrocarbon results look more similar.
  But it depends very much upon what detergent system you use.

         The WFK fabrics consisted of combinations of polyester with pigment and sigma soil. Sigma soil
  is a simulation of colored soil, and the pigment is something that requires some mechanical action to
  remove. The slide shows silk fabric with same soil; wool with an olive oil; and wool with a pigment and
  sigma soil stains.

         This particular choice of fabrics probably did not give wetcleaning a fair shake, because these
 fabrics primarily have soils that are more suitable to a non-polar solvent such as perc or hydrocarbon.
 Indeed, the results are much as you would expect, which means if we were trying to wetclean these soils
 in these fabrics, to do it successfully we need a better detergent system than the one that was used.

        There are 16 soils.  I won't read the list, but let me just point out that what we have with these 16
 is a very good combination of soils that are removed by polar materials and non-polar materials, that is,
 solvents versus water. So this seemed to be a good selection of soils and fabrics that would give all the
 technologies a relatively fair shake in the evaluation.

        Here are the results. I call  this slide the skyline of New York City. The peaks and valleys depend
 very much upon which soil and which cleaning system.  You can see the cleaning systems as we go
 across the far chart and the one in the front is perchloroethylene with a detergent.  Then we have three
 wetcleaning systems with three different detergents and three hydrocarbon systems with three different

        Now, I won't show you every single set.  You can see those in the next room in the poster session,
 but let me look at a couple at random. This is a sigma soil.  This is a soil that is a non-polar soil. It is best
 suited to solvent systems and we see that wetcleaning does not do as well as the others.

       However, we are now looking at a soil that is more suitable to a water based system.  Indeed, the
 wetcleaning process does better than the soap color systems with blood, milk and ink on cotton.

       Now, how do you address this in practice?  If you are using this kind of a cleaning system where
you are trying to remove a polar soil with non-polar solvents, you have to add moisture and detergent to
the system. On the previous slide we had a water based soil that did very, very well after wetcleaning.

       In this slide, we have the reverse, a non-polar soil that is best removed by solvent. In this
process, the wetcleaning system again would need some kind of an additive to better address the removal
of the soils, or more mechanical action.  However, if you increase the mechanical action, you also
increase the potential for fabric damage. So at what point can you still clean and not damage the fabrics?

       In the poster session, you will see additional data, additional results, and a view of actual cleaned
samples. Our future plans would call for us to continue with the fabric damage aspects of this research.
Other cleaning technologies would hopefully include a carbon dioxide system, (if we can convince them
to put the machines in the plant), and a system using the glycol ethers that are primarily promoted by

       The poster session will look at the various cleaning processes and the dimensional performance of
actual garments. Concerning the bottom line, I advise you, the cleaner, to match the cleaning system with
the soil and the fabric.  Based on the data we are seeing, there is not a single universal system that works
for everything. The best solution is something like what Ed Boorstein is doing.  He takes in the garments
and has technologies both wet based and solvent based. He then uses his personnel's knowledge to select
the right system for the right soil and the right fabric.

       The additional data is presented by Gary Mock on an emerging technology.

   Results of Pilot Study Comparing New Technology Performance (continued)

                                         Gary Mock, Ph.D.
                          North Carolina State University, College of Textiles

         Gary Mock is a professor at North Carolina State University in the Department of Textile
         Engineering, Chemistry  and Science. He has held many professional positions  in the
         textile  industry,  including Development Engineer and Quality Control Manager at
         Milliken & Company.

         Thank you, Charles.  I see that I have already used up all the time available to us, thanks to a
  tardy start.

         For several years, we at NC State have been a team looking at alternative technologies and the
  possibility of using ultrasound as a means of improving dye penetration; or of improving dye washoff
  after dyeing to get rid of unfixed dyes. Results were very promising and showed that we could lower the
  temperature or shorten the time that was needed for these operations. We also used less chemicals, in
  particular salt as an additive for dyeing.

         When EPA decided to examine alternative cleaning systems, we proposed a series of studies to assess
 the replacement of oxygenated solvents with perchloroethylene, and to use ultrasound to provide the
 thermomechanical energy needed to help loosen soil.

        I'd like to talk to you about the three methods studied. We took a look at tumble drying, using
  100 percent perchloroethylene as a standard. This was done several years ago, where we used a'
 launderpmeter as the sample test method in the laboratory.  We then proposed using ultrasound as the
 alternative to that, where we would use 100 percent solvent, and we would either put it in
 perchloroethylene or several of the oxygenated solvents that I will mention shortly.

        What we looked at was ultrasound wetcleaning, where we would use about  six percent solvent
 instead of 100 percent solvent. The solvents that we chose to use were n-methylproladone or NMP,
 propylene glycol tertiary butylether, or PTB, and PNB, or propylene glycol n-butyl ether. These were
 selected after going through an extensive screening to look at a number of potential  solvents that would fit
 a number of factors that we wanted to look at such as flash point and so on.

       The one that we finally decided on was water, solvent and detergent. The solvents used were the
 ones mat I just mentioned:  NMP, PTB and PNB.

       The fabrics that we chose were chosen from local stores where we could go  in and purchase
 samples of wool, silk, rayon and  acrylic typically used by a typical home craftsman.  We did this just to
 see what was available on the market. This was before we got into standard samples that were available
 from standard sources.

       The soils that we chose initially were ones that we thought would be particularly difficult to
remove. So we decided we would use motor oil, that would typically get on peoples' clothing if they were
changing oil in their car. We thought about ballpoint ink and finally settled on using a stamp pad of ink.

We also used lipstick as another type of soil that could somehow make its way onto clothing. I don't
know how that happens, but it does happen.

       Some of the results that we show are looking at a gray scale, an AATCC gray scale, were five is a
perfect result.  Results show that not surprisingly, engine oil is very well removed by perchloroethylene.  If we
looked at ultrasound added cleaning, we see various results. All technologies remove lipstick quite well.

       Incidentally, the temperature that we used here was about 50 degrees C, corresponding to about
120 degrees Fahrenheit.

       Looking at silk fabric, again we see that engine oil can be removed by a number of different
processes.  However, none of the processes remove ink very well and lipstick is removed better with a
wetcleaning than with a perchloroethylene  cleaning.

       Rayon fabric, is cleaned with different results with the different technologies. I think this backs
up what Charles said. You have to know what kind of soils you have, what kind of fabrics you have, and
choose the optimum one. You almost need an expert system and experience is an excellent guide to
choose what you want.

        Lastly, the slides show acrylic fabric, with these results. You can see all these results detailed in
our poster session.

        One  other thing that we thought we needed to ask was, "what happens to the fabric after we have
cleaned it?"  It is not sufficient just to clean something if you have thoroughly destroyed the system.  At
our College of Textiles, we happen to have access to a Kawabata surface roughness evaluation system
that literally was developed using a mechanical fingering system that moves across the surface of the
fabric to determine the relative roughness of the fabrics.

        Here we see a series of results that we can look at: how perchloroethylene works with the various
samples. We have a grouping across the bottom, ultrasound for 18 minutes, then ultrasound for 30 minutes. We
have groupings of the three oxygenated solvents, but we couldn't get into the Power Point presentation.

        The  conclusions from all of this work, which is very, very condensed, is that we feel that
ultrasound aqueous based cleaning has a very good potential for removing hydrophobic soils that are
normally removed only by drycleaning.  The cleaning times were also significantly shorter using
ultrasound.                                                                     .

        What we haven't talked about, but was another part of the study, was that no shrinkage was seen
 for wool samples or silk. Based on these results, it seems ultrasound is a really good technology to

       What we want to work on in the future is to continue to look at ultrasonic cleaning, and how it
works with standard soils, and aqueous solutions. We will also perform some additional testing on some
new equipment that we have acquired from a company that makes a near-field processor, Advanced
Sonics of Connecticut. We would like then to move on to testing how ultrasound can clean small

       Thank you very much.

                            Textile Care with Glycol Ethers

                                    Stephen P. Bates, Ph.D.
                                     Rynex Holdings, Ltd.
       Dr. Stephen P. Bates is currently an assistant professor of environmental technology at
       New York Institute of Technology.  He is a certified professional chemist, professional
       environmental  auditor, certified  environmental  trainer,  and registered  hazardous
       substance professional and certified environmental inspector.

       Thank you, Manfred. It is a pleasure" to be here. Good afternoon. I'd like to thank you for
inviting me to the EPA Design for the Environment conference.  I am pleased to be here on behalf of
Rynex, which is a breakthrough product in scientific technology.

       Rynex is participating in the U.S. EPA Design for the Environment Garment and Textile Care
Program, because we are excited about this product, and because we believe that this program is vitally
important for our industry. Rynex also believes that we really do need sound unbiased science, and that it
is critical in the decision making.

       As an environmental chemist, I'm concerned about our future. My background is really involved
in testing and looking for toxic and hazardous materials. After getting involved in this program, we really
had to look to see where we were going with this.  We didn't want to start working with materials that
were going to end up biting us in the back later on.                                        .

       As we approach the next millennium, we are reminded of our past problems in this industry and
the promise for the future. We owe it to our children to bring forward new technologies that are
environmentally friendly and will minimize the impact on our environment. The drycleaning industry is
going through a tough time, and trying to make decisions on alternative technologies today is very

       My goal today is to present to you Rynex, an alternative technology.  One thing I want to point
out, Rynex is a clean, modern, organic chemistry.  It is designed specifically for the drycleaners. This
program arose in response to finding alternative technologies using conventional drycleaning equipment.
We didn't want to have to re-invent the wheel.  After all, there is so much equipment out there already.
We needed to make sure that we look to protect our atmosphere, our biosphere, and the environment in

        The Rynex product is designed to bring less stress and more cleaning into fabrics.  This is a
unique technology.  The United States Patent and Trademark Office has accepted our patent claims, and
as we speak, our patent attorneys are working on worldwide patent claims.

        Some of the benefits and features of this product are that we have 30 to 50 percent greater solvent
efficiency than perc. We are actually getting garments cleaned better than perc. Our whites are whiter,
the garments don't turn gray, there are less chemical byproducts, we are earth friendly, human friendly

   and atmosphere friendly. Another great point that we need to make, is that we have enhanced optical
   brightness in the garments.

          The chemistry here is important, too. Rynex is an oxygenated solvent. It is a P series glycol
   ether.  Presently this is a proprietary formula, primarily because we are going through patent claim issues
   and we have to make sure that the intellectual property is protected.

         But one thing that is important to note is that we have the ability to carry water along with our
  solvent system. The molecules are able to form an azeotropic mixture.

         The other important thing to note is that this is really more than just a solvent. We have a
  surfactant that we are working with here. The molecules that we are working with have both polar and
  non-polar sides to them, where they become hydrophobic and hydrophilic, so it does act as a surfactant.
  This enables extraordinary cleaning properties.

         When we are looking at trying to come up with alternative technologies, we really have to look at
  a large number of properties in solvent systems in order to come up with the various drycleaning
  requirements. As you can possibly imagine, there are many items that have to be dealt with.

         Rynex is able to clean so well by the nature of our formulation.  We have both the sufficient
  solvency to break down solvent soluble fatty acids, and the ability to carry sufficient moisture and water
  to break down the water soluble stains. The beauty of this  process is that we can take care of both
  problems simultaneously.

         Another requirement that we have is that the solvent must be removable from the garments at
 relatively low temperatures. You can't overheat these garments, or else you will end up with shrinkage
 and all kinds of other problems that could occur from overheating.

         Another requirement is that the material has to be filterable, so you can remove some of these
 soluble and non-soluble materials. And you have to be able to distill it and refilter it or recycle it.  We
 need to be able to recycle these materials.  It is very important that we  get to get the most usage out of
 whatever resource we're going to use in this process. The more we can reuse the same resource over and
 over again, the better off we are.

        Another drycleaning requirement is that you've got to assume that the fabric that you're cleaning
 is going to be there when you're finished. A lot of problems arose when we tried different solvents in the
 past, and one of the jokes was that we clean a jacket and people would say, "I hear you're having
 problems with acetates, and we would say no, we're not having problems with acetates; we just can't find
 them when we're finished."

        So we have learned from our mistakes.  There are plenty of problems, trying to find the right
 formulation, and certainly we have to deal with buttons and sequins and dyes, and trying to figure out the
 best alternatives and to balance all of these things. It is quite a task.

       Another procedure we have to  deal with is separating the solvent system from the water. We
 carry water, but we don't want to carry excess water. We have to be able to reject water.  In that regard
we're very good, because we can get a clear demarcation between the Rynex solvent and excess water.
As you all know, excess water causes shrinkage, so we have to be very  careful.

       Some people ask, "Why do you use an azeotropic solvent?" And what is an azeotropic solvent?
Well, this isn't new technology.  We have been using azeotropic solvents for a very long time. But what
we have here truly is a major breakthrough with the azeotropic solvent system, because our solvent acts as
a surfactant. This combined with the water helps to remove and suspend the soils in the solution.  We can
then take the soils out and reject them, and there is no repositioning of the soils into the textiles. This is
very important.

       Another important attribute of working with water and a propylene glycol ether system is that it
has the ability to act like a single substance.  This occurs because the water combines through various
molecular forces, that is, hydrogen bonding,  and different dipole induced effects, where the water actually
attracts to the molecule and stays with it, in such a way that we can deal with the water soluble side of the
problem as well as the oil and fatty acid side of the problem. This  allows us to avoid any soil
redepositioning. We can reject water and take only what we need. We have a low level admissibility,
meaning that we can take in a certain amount of water and then reject whatever excess water is there.

       There have been a lot of questions about safety regarding glycol ethers, and not all glycol ethers
are created equally.  There are good glycol ethers and there are bad glycol ethers. Rynex is a good glycol
ether because it is a propylene based glycol ethers. There have been numerous studies done including
laboratory animal studies conducted by Arco Chemical, who is the supplier of the material. These studies
have concluded that propylene based glycol ethers don't produce the same types of toxicological effects
that are associated with the ethylene based glycol ethers, such as the neurological system issues, as well
as the developmental toxicity problems.

       We have to look at the environmental sides of it as well. The propylene glycol ethers are
environmentally friendly compounds, and they are inherently biodegradable.

       Performance criteria is another very important issue when we are looking at drycleaning.  In our
testing and pilot testing, we found that we were 100 percent effective  at cleaning 99 percent of the
garments, and that we are removing the water soluble  stains and the oil soluble stains.  Rynex is also very
good with removing  animal protein, and it doesn't shrink wool.

       The one area of problems that we are seeing—which seems to be prevalent throughout the
industry—is dealing with acetates and poorly bonded dyes. We are working hard to try to solve those

       Another issue is economics. There is no sense in developing  a system that no  one can afford.
One of our goals is to try to use conventional technologies by just  having a replacement solvent system.

        When you look at the entire big picture, Rynex is cost effective to use because we are getting
much greater solvent mileage and we're not producing hazardous wastes. There is far  less chemistry
required for the cleaning process, unless spotting agents are being  used.

        Our cycle times are overall approximately equal to perc on closed circuit dry to dry machines.
We continue to do research in this regard. Rynex has our own applications laboratory, where we have
drycleaning machines, and we are constantly testing different things.  We are also working quite closely

 with Arco Chemical in tweaking the formula.  We are looking at removing certain isomers and other
 similar procedures.

        I am also pleased to announce that our relationship with TNO Netherlands has resulted in the
 installation of a machine there.  TNO Netherlands is an independent research laboratory supported by
 major research laboratories and manufacturers, and they have been able to secure one million dollars in
 funding to thoroughly test this product. They will be performing 60 different tests on Rynex, and we are
 very excited about that working relationship.

        In summary, we are very proud that this is a scientific breakthrough in cleaning technology, and
 that we are an environmentally friendly solvent specifically dedicated for the drycleaning industry.

       I'd like to thank you for taking the time to listen, and also to offer people who are working in the
drycleaning industry a drycleaner information packet which I could mail to anyone. We have a poster
session outside, and some forms where you could ask for additional information. If you would be so kind
as to leave a card or whatever, please do so or stop me and talk. I'd love to talk to you and tell you all
about Rynex.

       Thank you very much.

Rynex Corporation
          U.S: EPA Design for foe Janironntent
          Garment and Textile Care Program
                   Stephen P. Bates. Ph.D.
         Rynex - A Scientific Breakthrough in Cleaning
          Technology using Earth Friendly Chemistry
                                                        I Overview
                                                         • Rynex is clean modem organic chemistry
                                                          designed specifically for the drycleaners.
                                                          the environment the atmosphere and the
                                                         • Rynex is designed to bring less stress and
                                                          more cleaning into fabrics.
                                                         • USPTO has accepted patent claims.
                                                         • Unique formulation (P- Series Glycol ether)
         Features & Benefits
         • 30 to 50 % greater solvent efficiency man
           Perc (1250 Ibs. /gal. vs. 850 Ibs./ gal )
         • Better cleaning than Perc (whites are
         • Garments don't turn gray.
         • Less chemical by-products.
         • Earth friendly, human friendly, atmosphere
                                                        Rynex is a proprietary
                                                        formulation using a
                                                        Propylene glycol ether.
                                                        We are able to cany
                                                        some water molecules
                                                        through hydrogen
                                                        bonding and other
                                                        molecular attractive
                                                        forces futtiuiig an
                                                        azeotropic mixture.
•p~- npj. /sw.-    Th6 b**e molecule
-'X''--^"'-    is not only a solvent
^-^       but a surfactant as
     O      wdl. One end of the
            molecule is
            hydraphilic and the
            other is lipophilic.
    ^CHOH  This enables
    /       extraordinary
         Dry Cleaning Requirements
' A drycleaning solvent requires the
  following characteristics:
• Sufficient solvency to break down solvent
  soluble fatty acids.
• The ability to carry sufficient moisture
  /water to break down water soluble stains.
                                                        Dry Cleaning Requirements
                                                                    The solvent must be removable from the
                                                                    garments at relatively low temperatures
                                                                    during the drying process.
                                                                    Filterable to remove non-soluble paniculate
                                                                    Be able to be distilled to remove soil, fatty
                                                                    acids, dyes and any additives and reclaim as
                                                                    a pure solvent.

Rynex Corporation
        | Dry Cleaning Requirements
         •  Must not cause any damage to die broad
           spectrum of natural and man made fibers or
           the accessories (buttons, sequins, dyes etc.)
           used in modem garments.
           The solvent must be able to separate from
           excess/free water.
           The solvent must remain stable in the
           presence of other chemicals and after
           repeated distillations.	
   Why Use an Azeotropic Solvent?
    The Rynex solvent is an azeotropic mixture
    of water and a propylene glycol ether.
    This safe solvent system has the advantage
    of behaving like a single substance.
    A mixture of chemicals is azeotropic if the
    vapor composition is identical to that of the
    liquid phase.
    The drycleaning process requires water to
        Why Use an Azeotropic Solvent?
          Soil suspension capabilities to reduce
          A solvent for textile cleaning must be able
          to carry water but reject excess water.
          Rynex has a low level of irascibility and
          free water is easily separated out.
          Excess free water may cause shrinkage.
  • P-Series Glycol ethers are inherently safe.
  • Based on laboratory animal studies,
   propylene glycol ethers do not cause the
   type of toxicological effects that are
   associated with exposure to ethylene glycol
         Propylene glycol ethers are environmentally
         Studies indicate that the material is
         inherently biodegradable in 35 days.
\Performance Criteria
 • 100% effective cleaning on 99% of the
 • Removes water soluble stains.
 • Removes solvent soluble stains.(i.e. oils and
   fatty acids.)
 • Removes animal protein stains.
 • No shrinkage of wool.
 • Poorly bonded dyes may bleed.

Rynex Corporation
          Cost effective to use.
          30 to 50% greater solvent mileage.
          Far less chemistry' required for the cleaning
          Less spotting agents being used.
        Research & Development
          Rynex Research Laboratory
          ARCO Research Laboratory
          TNO Netherlands Independent Research
          Laboratory supported by other major
          laboratories and manufactures.
                                    ! Machine Cycle Times
                                       Overall cycle time approximately equal to
                                       Perc on closed cvcle to drv to drv machines.

                                CC>2 Process Testing Results

                                     Craig M.V. Taylor, Ph.D.
                                  Los Alamos National Laboratory
         I'm Craig Taylor from Los Alamos National Laboratory. I'm in the chemical sciences and
 technology division.  The technology that we have been working with was an R&D 100 award winner.

         This next slide here gives you an idea of the different areas that we work in as far as supercritical
 fluids and dense based fluids. We work all the way from supercritical CO2, which goes into fabric
 synthesis, dye impregnation, et cetera, all the way over to the supercritical water. Supercritical CO2 tends
 to make things and supercritical water tends to destroy them, so we work the gamut there.

         LANL's role in this project was originally with LANL and Hughes Environmental Systems, who
 has now become Creda, which was partially funded by DOE and EPA to develop this alternative solvent.

        Liquid CO2 is based on a weapons technology that was essentially made so that you could clean
 parts and not leave any residue on the parts. Zero residue technology was the idea behind all of this. It
 moved into nuclear laundry, because there you have a lot of problem with any solvent, including water
 and the discharge.

        This is just a quick slide to show you some attributes of CO2. It starts out as a gas, then it is
 liquefied under pressure. Once in liquid form, CO2 has these great properties—non-carcinogenic,
 non-mutagenic, non-toxic, non-flammable, non-ozone depleting, and it is basically non- everything, very
 good for the environment.

        CO2 naturally occurs. There is a carbon cycle at work in the world which is very efficient at
 removing it then from nature. I think a lot of people have been putting this up, but just to give you an
 idea, this slide shows the solvent properties of CO2 versus perc, petroleum and water.  The ones in black
 are the ones we're going to stress and point out.

        The first black item is density. The density of CO2 is adjustable all over the board, but in the
 liquid region it generally tends to be between 0.6 and .9. Density is important because the solvent
 property of any given solvent varies as a function of its density.

        Surface tension is a measure basically of how well a material can wet a surface. If the surface
 tension is high, i.e., water, then it requires the use of surfactants in order to allow and enhance the waters'
 ability to wet the surface and cause effective cleaning.  The supercritical, or liquid, carbon dioxide in this
 case, you can see, has a very low surface tension, supercritical having a zero surface tension. This means
that it is very good at wetting material so that it can clean it.

        Then last, but not least, is the viscosity. The viscosity for the liquid is veiy, very low. This
factors in when you're looking at power requirements to pump it, and also for how it is going to affect
clothes when you use mechanical agitation.

       The main goal of the entire technology is to get a product that cannot only be recommended, but
whose use is beneficial.

       What we entered into was a system where we were using perchloroethylene as a baseline, much
like everybody else that you have seen today. We were going to compare our technology to the
perchloroethylene, which is the industry standard right now.

       The first item we looked at is the operating parameters. Liquid CO2 operates at 700 to 750 psi, 54
to 58 degrees Fahrenheit. It uses a hydrodynamic agitation, which means that it is actually the liquid that
is moving, not the drum. We tried to keep down the number of moving parts so that we don't have to
worry about having seals fail under pressure and affecting the lifetime of the machine.

       The solvent was liquid CO2.  It says plus additives, but what I am going to go through today, just
to keep everyone on an even keel, is just straight CO2 numbers. So everything I go through today,
remember, is just straight CO2. There are no additives used, because as we all know, there are at least
three different companies that have been presenting today that have different additive packages and
different machines. So we're just dealing with CO2 with this kind of an agitation system.

       This is a list of the textiles that were evaluated. Trims were also evaluated, as well as leather, furs,
buttons, zippers, decorations, et cetera.

       I just want to show you this slide real quick to give you an idea of how this works. Remember,
we're at 700 to 750 psi. You can see that means that essentially we are operating at lower pressures than
the soda fountains in the drugstores.  That is an important thing to remember, that we are in a range that
people are very used to handling, and it is also very important to note that we are in a range that actually
is about where the liquid CO2 gets delivered.

       Here is an evaluation category that compares CO2 performance to perchloroethylene. These
studies are done in a very similar fashion to Dr. Riggs'  studies. We have actually collaborated with.him
on many of these.  IFI supplied most of the materials that we were actually testing. Most of the materials
we first tested were swatches. We found that because of the mechanical agitation that is necessary to
cause effective cleaning, you needed to take the swatch and actually pin it on to the inside of a garment.
This gives you enough length in the garment to go ahead and cause the stretching and compression, which
causes the dirt to separate from the garment.

       Again, you can see that in all cases and for all of these swatches, the cleaning was essentially
equivalent or better than perchloroethylene.

       I've got to tell you  a story before I put this next slide up. When I was growing up, my mother
drove a school bus. She got home before everybody else did. She got home one night and our dog,
which was a boxer at the time, was sitting there just proud and happy, and had a dead rabbit in its mouth.
Well, our neighbors raised prize floppy-eared rabbits, so she had been told a lot of times that if this dog
came over and killed one of the rabbits she was going to be in real trouble.

       After finding the dead rabbit she panicked. She took the rabbit and she ran into the house and she
got it in the shower and shampooed it, cleaned all the dirt off, and she got a hair drier and dried it, and it
looked just right.  She snuck over into the neighbor's yard and she put it into the cage, and she tiptoed
back, and she raked leaves for a little while.

         The lady came home and she went back out the cages and she heard this blood-curdling scream.
 She ran over there to find out what was happening, and the lady told her, "Oh my God, it's Fluffy.  He
 died and I buried him three days ago, and now he's back."

         The reason I told this story is because when I put this slide up, I want to say that things aren't
 always as they seem. This shows a comparison of soluble soil removal for the IFI cleaning with soap and
 water, CO2, perchloroethylene with additives and in perchloroethylene without any additives.

         Remember that CO2 has no additives in this example. The CO2 did outperform the
 perchloroethylene with additives. However, the perchloroethylene without additives went negative. This
 is because we are actually using the gray scale testing and what happened was that perchloroethylene
 without additives was actually redepositing on the surface.

        This next slide shows the shrinkage after liquid CO2 exposures.  We did these tests at zero percent
 humidity, 70 percent humidity and 100 percent humidity. You can see the list of materials that we did the
 tests on.  You can  see that CO2 didn't perform very well on dye acetates in almost all cases. However,
 only for the zero percent humidity case are we actually outside the industry standard, which is around two
 percent, usually.

        This slide  is a very interesting thing because it isn't exactly what it appears. The  dye acetate also
 causes a problem in the perchloroethylene, though, and therefore they are actually fairly comparable. But
 performance wise, this is  where there is a problem for just straight CO2.

        This  slide  shows the average percent weight change for all fabrics. Again, zero to 100 percent
 humidity. You can see that immediately after exposure, and then two to four days, and after ten
 exposures, that there is a weight difference. This difference is in percent, and in most cases we don't have
 very much trouble. However, you do see as you begin to build up pressure and humidity, a problem
 which people have mentioned before, which is a formation of the carbonic acid. This can be taken care of
 very easily using a buffer in the surfactants that are actually used.

        These are the advantages of the CO2. Number one, I think we have shown that it  cleans well.
 There is no heat setting of stains. This is basically because the temperature never gets above 56 degrees
 Fahrenheit, so it is  relatively cool all the time.

        Also, CO2  cleans everything and is safe to use on most dyes.  The reason we say  most dyes is
 that we haven't tested all dyes.  However, I can tell you that at the temperatures and pressures at which we
 are running, thus far we have not found any dyes that cause any problems.

       Another benefit of CO2 is that there is no residual solvent in the waste.  This is true if you are
running plain CO2. However, it can change when everyone starts examining what kind of surfactants they
are going to add to  the CO2. That is, if you add surfactants, the CO2 is going to go away very easily, but
you're going to be left with the surfactant and the dirt that you have to dispose of.

       There is no health problem with CO2. A lot of people have asked questions about what happens
if this thing goes off and fills the room full of carbon dioxide.  There are a couple of things to remember.
One, if you have a dramatic release of carbon dioxide, it is going to turn into dry ice and bleed off

gradually.  You're not going to fill a room with carbon dioxide unless you have an insidious release, i.e., a
leak, and that is fairly easy to handle. Most of these machines will have to have some sort of detector
sitting next to them to determine the CO2 levels.

        There are also no hazardous waste costs and no environmental problems associated with CO2.

        Basically what I'm going to do here with the last couple of slides is just give you an idea of how
the machine works. It basically uses jets that are introduced tangentially into the cylinder itself. This
causes the fluid itself to move, pick up the clothes, and move the clothes around. Some of these jets move
in one direction and some move in another so that you can switch direction and get the agitation motion
that you need.

        This slide shows a blocked diagram of the process. As you can see, this process does not have
any kind of separator. What you have is a storage vessel. It has an offline still which will repurify the
CO2. It goes through pumps and a series of filters, and then back into your vessel.

        Basically, this is a very simple system. It has been kept that way for a reason. Also, the drying
does go on within the same vessel, meaning that when you take these garments out, they are already dry,
they are a little bit cool, and they aren't very wrinkled. It is a very  high performance machine.

        The cycle time for the process is usually about half. It is usually about 20 to 25 minutes for the
entire cycle and again, it is coming out dry at the end of that cycle.

        This is the conclusion of the talk.  I think that most of the data that I have presented is available in
the handout that everybody should have. Anything that is not there that you would require, I welcome
you to contact me and get copies of the slides, or you can also get onto our website, which is

       Thank you very much.

               >  .  ^ 1997 R&'Q.tQOMjOfnJEcitty,
                                 -9 •'•• « fc !*. .* :«..
                                                       *-»• *-**•<**   .        ;* i " ,
  PI//S dry-cleaning
'.!;   timeijy50%
s  s »     :  «'•»"• ,4, - i •
-;  Deduces energy
         ,     •.•  _
         labor costs

 1997 R&D 100 Joint Entry
 Los Alamos National Laboratory,
 Global Technologies, LLC, and
 Hughes Environmental Systems, Inc.
The red food stain shown in the background photograph might send
anyone scurrying to a dry cleaner. But rather than cleaning this
polyester swatch in perchloroethylene (perc), the hazardous solvent
that dry cleaners typically use, we have removed the stain with
dense-phase carbon dioxide (CO,). The stain is greatly reduced
partway through the cleaning simulation (left inset) and is
completely gone by the end (right inset). Our DryWash™ process,
which agitates and cleans garments with high-speed jets of liquid
CO2, offers an effective, environmentally friendly alternative to perc.

                                   Los Alamos
                                   NATIONAL LABORATORY

          Executive Summary
 DryWash™ is a fast, nontoxic dry-cleaning process based on liquid
 carbon dioxide (CO2) that is applied through high-speed fluid jets.
 Liquid CO2 is an odorless, nonflammable, nonhazardous solvent
 that effectively removes oils, sweat, and dirt from a wide variety
 of fabrics. Both efficient and environmentally friendly, DryWash
 is the needed replacement for the hazardous dry-cleaning methods
 currently used.
DryWash cleans most linens, throw rugs, and everyday or fine
garments—even furs, leathers, suedes, and items with sequins.
It can be used worldwide by retail dry cleaners, hotels, military
installations, corporate facilities, nursing homes, and hospitals.
Future applications include dishwashing and decontaminating
machined parts. Eventually, small-scale versions of DryWash
may be used in homes for cleaning laundry and dishes.
  Uses a nonflammable, nontoxic, inexhaustible solvent.
• Does not deplete the ozone or pollute the ground water.
  Helps the dry-cleaning industry comply with federal and state
  environmental regulations because the process minimizes
  hazardous wastes and emissions.
• Cleans in half the time required for conventional dry-cleaning
  Reduces dry-cleaning costs by lowering energy consumption,
  run times, and labor costs.
  Reduces soil redeposition on fabrics, or graying, leaving laundered
  garments bright and clean.
I997R&D 100 Joint Entry
Page I

1997 R&D 100 Award
Joint Entry Form

/. Submitting organization
               City, State, ZIP
 Los Alamos National Laboratory
 Mail Stop E537
 Los Alamos, NM 87545
 Craig M.V. Taylor
 (505) 665-3545
                               AFFIRMATION: I affirm that all information submitted as a part of,
                               or supplemental to, this entry is a fair and accurate representation of
                               this product.
2. Joint submitter(s)

               City, State, ZIP


               City, State, ZIP
Hughes Environmental Systems, Inc.
Box 902, Building E4
Mail Stop P103
ElSegundo,CA 90245
Sidney C. Chao

Global Technologies, LLC
222 North Sepulveda Boulevard
Suite 2200
ElSegundo, CA 90245
Jack R. Belluscio
3. Product name
1997 R&D 100 Joint Entry
Page 2

 4. Brief product description
 DryWash is an efficient, nontoxic dry-cleaning process that uses
 liquid carbon dioxide (CO2) as the cleaning solvent. The DryWash
 machine consists of a stationary cleaning vessel, CO, storage and
 distillation tanks, and a recirculation loop. Inside the cleaning vessel,
 high-speed jets of liquid CO2 soak and agitate the garments.
                                DryWash is a Trademark of Hughes Aircraft Company.
 5. Eligibility: When was this
 product first marketed or
 available for order?
                        Month   July
                          Year   1996
 6. Principal developer
                        Name   Craig M.V. Taylor
                      Position   Technical Staff Member
                  Organization   Los Alamos National Laboratory
                        Phone   (505) 665-3545
                          Fax   (505)667-6561
7. Product price
 Begin Proprietary Information
                                $60,000-$80,000 per 10,000-pound machine with a capacity of
                                22 pounds (assuming one garment per pound).
                                 End Proprietary Information
8A, Do you hold any patents on
this product?

Hughes Aircraft Company holds the following patents:
"Cleaning by Cavitation in Liquefied Gas," US Patent
No. 5,316,591, May 31, 1994
"Low Cost Equipment for Cleaning Using Liquefiable Gases,"
US Patent No. 5,339,844, August 23, 1994
"Method Using Megasonic Energy in Liquefied Gases," US Patent
No. 5,456,759, October 10, 1995
"Dry Cleaning of Garments Using Liquid Carbon Dioxide under
Agitation as Cleaning Medium," US Patent No. 5,467,492,
November 1995
7997 R&D 100 Joint Entni
Page 3

8B. Do you have any patents
8C. Do others hold patents on
this product or a similar
product line?
9. Primary function
    The dry-cleaning industry is seeking a replacement for
perchloroethylene (perc), the toxic organic solvent currently used
by 90% of all dry cleaners. Our Dry Wash process, which cleans
with liquid CO,, offers the most effective yet environmentally
friendly alternative that has been developed (see "Carbon Dioxide
as an Environmentally Conscious Drycleaning Solvent" in the
Appendix). Carbon dioxide, either in its liquid or its supercritical
state, has been used in the past to clean a variety of electronic,
mechanical, and optical equipment, but Dry Wash is the first process
that uses CO2 as a cleaning solvent for fabrics. The Dry Wash process
can be used for most fabrics that dry cleaners commonly encounter
and can also safely clean furs, leather, sequins, and other sensitive
items (see "Fabric Compatibility and Cleaning Effectiveness of
Drycleaning with Carbon Dioxide" in the Appendix).
    In the DryWash system, liquid CO2 at 54°F-58°F and
700 pounds per square inch is pumped from a storage tank into the
cleaning vessel, and a recirculating loop through a  lint trap and filter
train is established. During the cleaning cycle, the CO, must remove
three types of soil: soil soluble in CO2, soil soluble in water, and soil
insoluble in both CO2  and water (pigment soil).
   The CO2-soluble soils, including many common organic stains
such as body oils, dissolve in the nonpolar, liquid CO2 and are
carried from the cleaning vessel. The water-soluble soils, such as
salts, are usually removed by agitation but may require pretreatment
with a detergent that helps the soils dissolve in CO2. Pigment soils
are the most difficult type of soil to remove. They are chemically
bound to garments through surface tension, electrostatic forces, and
Van der Waals forces,  or they are mechanically trapped between
two adjacent fibers of the fabric. Removing them involves two steps:
(1) breaking the chemical bonds and dislodging the trapped panicles
and (2) removing the pigment-loaded CO2 from the cleaning vessel.
   The design of the cleaning vessel makes DryWash particularly
effective at removing pigment soils. The garments are held in a
perforated basket inside a stationary cleaning ve'ssel (see diagram).
To get mechanical action equivalent to that of the rotating basket
7997 R&D 100 Joint Entrv
Page 4

                                   Begin Proprietary Information
              Perforated basket and
              jet configuration: side view
                             Perforated basket and
                             jet configuration: end view
                                  End Proprietary Information
                                  in conventional dry-cleaning equipment, DryWash uses a process
                                  called hydrodynamic agitation, in which nozzles located on the inside
                                  periphery of the basket spray high-speed jets of liquid CO2 onto the
                                  garments. The jets soak the garments in CO2 and create a vortex that
                                  causes the clothes to spin around inside the basket. As the outermost
                                  garments pass through the fluid jets, they momentarily accelerate and
                                  stretch slightly; once they have moved away from the jets, they relax
                                  and return to their original size. This stretch-relax cycle effectively
                                  dislodges particles. The layer of peripheral fluid immediately carries
                                  the dislodged particles out through the drain without penetrating the
                                  bulk of the load. This process minimizes the amount of soil that is
                                  redeposited on other garments (see "DryWash™: A Revolutionary
                                  Garment Dry-Cleaning Technology with Liquid Carbon Dioxide"
                                  in the Appendix).
                                     At the end of the cleaning cycle, the liquid CO, drains from the
                                 cleaning vessel to the storage tanks, which are connected to a still
                                 equipped with a heater. As the CO2 is converted to a gas in the still,
                                 the dirt carried from the garments collects at the bottom of the still;
                                 this dirt is the only waste generated in the DryWash process. The
                                 clean, gasified CO2 is then recondensed into the storage tank for use
                                 in the next cycle. More than 90% of the CO2 is recovered in each
                                 cycle. Because CO2 has a low surface tension and evaporates rapidly,
                                 only a short, "cold" (54°F-58°F) drying cycle is necessary. As a result,
                                 the entire cleaning process takes 18-25 minutes, approximately half
                                 the time of conventional dry-cleaning processes.
                                     The short video accompanying this entry, which includes portions
                                 of a CNN segment aired October 27, 1996, provides an overview of
                                 our DryWash process. A photograph of the Drywash machine, a letter
                                 of endorsement from the EPA, and articles explaining Drywash's
                                 effectiveness and environmental benefits are included in the Appendix
1997 RAD 100 Joint Entry

10A. List of competitors
   Many companies worldwide use the following dry-cleaning
solvents and associated equipment:
1.  Perchloroethylene (perc)—a chlorinated organic solvent that is
   currently used by more than 90% of cleaners in the US.
2.  Petroleum—known as Stoddard solvent, it contains a range of
   light hydrocarbons. It was once the primary solvent in the dry-
   cleaning industry, but less than 10% of dry cleaners now use it.
3.  Water—used as a primary solvent by less than 1 % of US dry
   cleaners. Wet cleaning technologies that use specialized
   detergents are currently being developed.
7997 R&D 100 Joint Entry
Page 6




er) Comments






In dry-to-dry units, washing and drying occur in the same vessel.
This design eliminates the transfer step in which solvent can escape
into the atmosphere. Fluid jets and rotating baskets both agitate the
load of laundry, but fluid jets remove pigment soil more effectively.
eX -O

S *» .£

s, s

"9 eo
2 .S
5 s

Dry-to-dry unit,
rotating basket


•o u <«
• O. ei
S f 
Q IE c

g_ e
Values are from tests on "dirty" fabric samples obtained from the
International Fabric Institute. When no detergent was used with
perc, fabric samples appeared dirtier than when they started out
(indicated by negative values). Most of the available detergents
are insoluble in CO, and cannot be used with DryWash.




2 g*
« 5 o\
U CO „ O
3:8 at

4) -
3 s
•i il

These times include sorting, washing, and drying. DryWash
requires a much shorter drying step than the other technologies.


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Shrinkage is generally less than 1% for CO2, perc, and petroleum
but well above 1% for water. On average, CO, shrinks fabrics the
least. In dye bleeding, dyes from one area of a garment bleed
into other areas of the same garment; in graying, excess dyes from
one garment are redeposited on other garments. Petroleum-based
cleaning requires the hottest drying temperature and therefore
tends to set in stains permanently.


ob aj ^
.£ -o 2

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-° "° 2 —
"o •- 3 o
-£> ~o -= 'E
f u a. ui


U. (/-
- .i
IOC. Improvements on
competitive technologies
    The improvements of our Dry Wash system over competing
technologies fall into three categories: (1) health, safety, and
environmental benefits, (2) performance benefits, and (3) financial
benefits. Petroleum-, perc-, and water-based technologies are all
deficient in at least one of these categories; Dry Wash is the only
dry-cleaning process that meets or exceeds expectations in all
three categories.
    Health, safety, and environmental benefits. Liquid CO, is a
readily available solvent that produces no hazardous wastes or
emissions, will not deplete the ozone, and is nonflammable and
odor-free. Because the CO2 is under high pressure, a minimal risk of
rupture exists, but Dry Wash uses CO2 at pressures no higher than
those in soda fountains at restaurants. Both petroleum and perc pose
far more serious health and safety hazards. Petroleum is  a highly
flammable solvent that easily explodes; perc is a hazardous toxic
substance that may cause cancer (see "A Cleaner Bill of Health" in
the Appendix). Many local, state, and federal ordinances prohibit
or limit the use of petroleum, stringently restrict perc emissions,
and force dry cleaners to dispose of used perc solvent and perc-
contaminated filters as hazardous wastes. Water,  touted as an
environmentally friendly solvent, has its own set of shortcomings.
In many parts of the world, water is a scarce resource, but cleaners
do not distill and recycle water used in dry cleaning. Depending on
the chemicals that have been added in the  cleaning process, the
wastewater may be considered a hazardous waste.
   Performance benefits. The Dry Wash  system not only uses a
more environmentally friendly solvent than competing technologies,
but the system also performs better. When we tested the cleaning
performance of CO2, perc, and water on "dirty" fabric samples
(containing ground-in soils, including CO2-soluble, water-soluble,
and pigment soils), we found that CO2 removed more dirt than perc
did. Furthermore, we are currently developing  new detergents that
should considerably increase DryWash's ability to remove dirt.
Although we also cleaned the fabric samples in soap and water, these
results are inaccurate for wet cleaning, which uses specialized
chemicals rather than standard soaps. (See "Fabric  Compatibility and
Cleaning Effectiveness of Drycleaning with Carbon Dioxide" in the
Appendix for test results.)
   Of all the dry-cleaning technologies, Dry Wash  is the most
effective at removing pigment (insoluble)  soil. Its high-speed fluid
jets greatly reduce pigment-soil redeposition (graying) because the
CO2 carrying dislodged soil does not penetrate the bulk of the load
and because the high-speed flow of the solvent quickly removes the
1997 R&D 100 Joint Entry-
Page 8

11 A. Principal applications
                                  displaced soil. In the other technologies, which rely on rotating
                                  baskets to agitate the garments, dislodged particles become
                                  sandwiched between the layers of the load and are easily

                                     The Dry Wash system offers several other performance benefits.
                                  In water-, perc-, and petroleum-based methods, the heated drying
                                  cycles (at about  140°F) often set in stains and wrinkle or shrink
                                  garments, which then require significant amounts of finishing labor.
                                  In the DryWash  process, however, liquid  CO2 is simply converted to
                                  a gas and evaporated from the garments at about 54°F-58°F. The
                                  lower temperatures set in fewer stains and wrinkles and, as a result,
                                  reduce the amount of finishing labor necessary. These temperatures
                                  also make DryWash faster and  more  energy-efficient than the
                                  competing methods. In addition, liquid CO2 will not cause the fading
                                  and dye transfer in colored garments that water, perc, and petroleum
                                  can cause. Because liquid CO2  is a more gentle solvent than perc,
                                  CO2 can clean "problem" materials such as leathers and furs as well
                                  as accessories such as sequins without damaging them.
                                    Financial benefits. DryWash is also cost-effective. At $0.50 per
                                 pound, CO2 is a cheaper  solvent than either perc ($5-$7 per pound)
                                 or petroleum. In  addition, DryWash minimizes the costs of
                                 environmental compliance, such as costs of hazardous waste
                                 disposal and new emissions-control equipment. Cleaners  using perc
                                 must pay l%-3% of gross receipts for hazardous waste disposal. In
                                 some states, they must also pay solvent taxes of $1-$12 per gallon of
                                 perc purchased and annual fees of $100-52250 for clean-up of perc -
                                 contaminated sites. Initial investment for the DryWash equipment is
                                 approximately equal to that for the current fifth-generation perc
                                 systems, but the DryWash equipment is less expensive to  operate.
                                 Because the process (including  the drying cycle) operates at low
                                 temperatures,  it does not  wrinkle garments or set in stains.
                                 Therefore, DryWash also dramatically reduces the need for costly
                                 finishing labor and nearly eliminates liability costs associated  with
                                 damaged garments.
                                    The DryWash process can be used to clean almost all types of
                                 fabric encountered in the dry-cleaning industry, including those that
                                 cannot be cleaned by current perc technology, such as leathers, furs,
                                 suedes, and sequined garments. Seven machinery manufacturers and
                                 five chemical companies will be licensed to produce equipment and
                                 supplies for the DryWash process.
7997R&D 100 Joint Entrv
Page 9

11B. Other applications
11C. Future applications
12. Summary
                                     Currently, DryWash is used for cleaning textiles, such as
                                 garments, linens, and throw rugs. This application affects billions of
                                 people worldwide who rely on retail dry cleaners or industrial
                                 laundries at hotels, military installations, hospitals, nursing homes,
                                 and corporate facilities.
   Our DryWash system and fluid jets could be used in other
applications, including the following:
• Dishwashing: minor modifications to the cleaning vessel, such as
  adding dish racks, would allow restaurants and other food services
  to use DryWash.
• Cleaning in the home:  scaling down the size of DryWash,
  decreasing its cost, and expanding the delivery network for carbon
  dioxide could allow households to use small DryWash systems for
  laundry or dishwashing in the home.
• Degreasing and decontaminating machined parts: after modifying
  the fluid jets to deliver supercritical carbon  dioxide, we expect
  DryWash to be more effective than current supercritical cleaning
  devices at removing grease and grinding particulates (such as
  cerium oxide and diamond dust).

   From industrial laundries that service hotels, military
installations, and hospitals to retail dry cleaners that cater to the
public, the garment-cleaning industry affects billions of people and
generates nearly $20 billion in worldwide revenue each year. The
global demand for dry cleaning  is increasing as garments become
more specialized, economic development continues, and consumers
find themselves with less time to clean their own clothes.
Unfortunately, dry cleaning has  its costs, not just to our pocketbooks
and to the fabric in our clothes or linens, but also to our health and
our environment.
   Currently, most of the health and environmental  risks in the
dry-cleaning industry are caused by the cleaning solvent perc.
A suspected carcinogen with a strong odor, perc is hazardous to
workers who handle it directly, to consumers who breathe the
residual solvent on their freshly cleaned garments, and to apartment
residents who inhale the fumes that escape from perc-based
equipment in dry-cleaning establishments beneath their apartments.
Although perc's emissions are regulated under revisions to the Clean
Air Act and under various state regulations, in October 1995 the
Consumers Union reported that even the most modern perc
equipment does not necessarily  prevent perc levels from exceeding
7997 R&D 100 Joint Entry
Page 10

                                   safe limits (see the summary from "Upstairs, Downstairs" in the
                                   Appendix). Nationally and internationally, the costs of
                                   environmental compliance for perc have skyrocketed to the point
                                   that many cleaners literally cannot afford to operate.

                                      Because of the hazards and costs associated with perc, it seems
                                   inevitable that perc will gradually be phased out, provided that an
                                   adequate replacement exists. Dry cleaners desperately need a
                                   replacement solvent that cleans effectively but that is
                                   environmentally friendly and cheap. Petroleum is not a contender-
                                   it has already been phased out because of its fire hazard. Water is not
                                   a viable alternative either because it damages many types  of fabrics
                                   and/or requires excessive amounts of finishing labor. Currently, the
                                   only alternative that fits all the characteristics is our liquid-CO,
                                   DryWash system.                        ,                  '

                                      Dry Wash poses very few health, safety, or environmental
                                   hazards. Not only does it effectively clean a wider variety  of clothes
                                   and remove pigment soil better than any other dry-cleaning solvent,
                                   but DryWash is also faster and less expensive. Carbon dioxide is a
                                   virtually inexhaustible resource that is readily available from
                                  refineries, calcine furnaces, and breweries; and because other
                                  industries use CO2 (to carbonate soda,  for example), a distribution
                                  network for it already exists. Introducing CO2 into the dry-cleaning
                                  industry will benefit cleaners and society as a whole through lower
                                  costs, better service, and improved environmental conditions.
                                  The same benefits will extend to future DryWash applications in
                                  cleaning home laundry, washing dishes, and cleaning industrially
                                  machined parts.

                                     Because of its tremendous worldwide benefits, DryWash was
                                  recognized in the 1996 "Best of What's New," Popular Science's list
                                  of the year's 100 greatest achievements in science and technology.
                                  Popular Science readers, who could vote on-line for their favorite
                                  technologies from the list, also honored DryWash with the  Readers'
                                  Choice Award.
1997 R&D 100 Joint Entry
Page 11

Organization Data
13. Chief executive officer
                                              City, State, ZIP
                              Dr. Siegfried S. Hecker
                              Los Alamos National Laboratory
                              Mail Stop A100
                              Los Alamos, NM 87545
                              (505) 667-2997
14. Contact person to handle all
arrangements on exhibits,
banquet, and publicity
               City, State, ZIP
Melissa Miller
R&D 100 Coordinator
Los Alamos National Laboratory
Mail Stop C331
Los Alamos, NM 87545
(505) 665-5377
(505) 667-0603
15. To whom should reader
inquiries about your product be
               City, State, ZIP
Craig M.V. Taylor
Technical Staff Member
Los Alamos National Laboratory
Mail Stop E537
Los Alamos, NM 87545
(505) 665-3545
                                                        Fax   (505)667-6561
 1997 R&D 100 Joint Entry-
Page 12

  List of Co-developers
  Figure 1. Photograph of Dry Wash machine
  Endorsement letter from the EPA

  "Carbon Dioxide as an Environmentally Conscious Drycleaning
      Solvent," a Los Alamos National Laboratory document
      presented at the Aerospace Hazardous Materials Management
      Meeting in San Diego, California, July 1996
  "Fabric Compatibility  and Cleaning Effectiveness of Drycleaning
      with Carbon Dioxide," a Los Alamos National Laboratory

  "DryWash™: A Revolutionary Garment Dry-Cleaning Technology
      with Liquid Carbon Dioxide," a Hughes Environmental
      Systems, Inc., document (reprinted with approval from Hughes
      Environmental Systems, Inc.)

 Summary from "Upstairs, Downstairs: Perchloroethylene in the Air
      above New York City Dry Cleaners," a Consumers Union
      special report from October 1995
 "A Cleaner Bill of Health" from the May 1996 issue of
     Environmental Health Perspectives
 Profiles of Global and Hughes
 Los Alamos Profile
                                Eight copies of a 4-minute video tape accompany this entry.
1997 R&D 100 Joint Entrv
Page 13

List of Co-developers
                        Name  W. Dale Spall
                      Position  Senior Researcher
                  Organization  Isotag, LLC, Isotag Research
                        Phone  (505) 662-6933
                          Fax  (505) 662-9033
W. Dale Spall was the former principal investigator of the Dry Wash
project at LANL.

Figure 1. The alpha prototype of Dry wash, .first unveiled in March 1996 in Milan, Italy.

                               WASHINGTON, D.C. 20460
Dr. Craig Taylor
Los Alamos National Laboratory
Bikini Atoll Road
TA35/125/01U mail Stop E537
Los Alamos, NM 87545
      OFFICE OF, •
Dear Dr. Taylor:

As you are well aware, the U.S. Environmental Protection Agency has been extremely interested
in the area of investigating new alternative solvents which will be safer to human health and the
environment. One of the projects that we have been pursuing for several years under the Design
for the Environment/Green Chemistry Program is the area of dry cleaning.  Because of the
environmental concerns that have been raised with regard to certain dry cleaning technologies,
EPA has been trying identify ways that the risks from these technologies could be reduced or
mitigated. It is exactly for these reasons that we at the EPA find the research and development of
the DryWash process to be so exciting.

The DryWash system using liquid carbon dioxide as the solvent for dry cleaning not only
addresses the problems associated with hazardous solvents but it does so in an innovative and
revolutionary way. What truly amazes me as a scientist is the time frame wherein this process was
developed. To conduct such remarkable basic research and development and bring it to the
implementation and commercialization stages in such a short period is an exceptional

The impacts of this new DryWash technology will hopefully be felt not only in the United States
but internationally as well. I view this approach to be a quantum leap forward in protecting
human health and the environment from the risks from hazardous solvents and EPA is pleased to
be associated with this endeavor.
                                                      Paul T. Anastas, Ph.D.
                                                      Chief, Industrial Chemistry Branch
                                                      Office of Pollution Prevention
                                                      And Toxics
            R«cycl«d/R*cyclabte • Primed with Vegetable Oil Based Inks on 100% Recycled Paper («0% Postconsumer)

                      CARBON DIOXIDE AS AN
                      DRYCLEANING SOLVENT
                               W. Dale Spall
                       Los Alamos National Laboratory

Carbon dioxide (CO2) offers an environmentally sound replacement solvent to the
currently used drycleaning solvent, perchloroethylene (PERC). In addition to the health
and safety benefits of a CO2 based cleaning system, large savings in solvent costs
provide an incentive for conversion to the new system. Lower operating costs for the
new technology provide further incentive. Projected energy savings for the current year
are 2.18x1012 BTU if this technology were to be fully accepted by the industry.

                                W. Dale Spall
                        Los Alamos National Laboratory
The technique of drycleaning has been practiced in the United States for more than 150
/ears, and has seen many changes during that time. In essence, drycleaning is a
nonaqueous'method for removal of soils from fabrics, especially from garments not
compatible with water washing due to shrinkage, or dye incompatibility. The term has
become synonymous with the cleaning of suits and fine clothing, specifically for spot
and oily residue  removal. Spot removal per se is really a separate part of the
drycleaning process and constitutes hand application of selected solvents to affect the
removal of the spot before the actual drycleaning process but since this has  traditionally
been done at the time of the drycleaning, the two are inexorably intertwined. Institution
of a different solvent system would not alter the spot removal portion of the cleaning

Initially, drycleaning used spirits of turpentine for the removal of oils and greases, but
the unpleasant odor left on the garments forced research into other cleaning media.
One of the main solvent systems developed during the 1920's was petroleum based
Stoddard solvent. Stoddard solvent is still used in about 10% of all commercial
drycleaning units today. In the late 1920's, chlorinated hydrocarbons were being
developed and used in the drycleaning units of that time. In the 1930's,
perchloroethylene (PERC), another chlorinated hydrocarbon with good drycleaning
solvent properties, became available. Due to its gentleness with fabrics and  dyes, this
solvent now dominates the US drycleaning market, with an annual usage of more than
200 million pounds.

There are currently 30,000-40,000 PERC drycleaning units in the US. This figure does
not include systems using Stoddard solvent (10%) or other solvent systems  (1%).
These drycleaning machines are for the most part small machines used in small to
medium sized businesses. The average new unit costs $50,000, and is called a dry-to-
dry unit, in which the clothing is placed into the unit dry, the cleaning operation carried
out, and the garments removed in the dry state, ready for return to the customer. This
type of unit is dictated by the emission regulations for PERC, both from an
 environmental perspective as well as a worker health and safety standpoint. The PERC
 loss from these units has decreased over the years since 1930 so that current PERC
 losses are about 0.5 to 1% of the  200 gallons used per cycle. Since one 55  gallon drum
 of PERC  can wash about 30,000 - 40,000 pounds of clothes, the amount of PERC used

  The drycleanmg industry will require time and research to find a suitable replacement
  for PERC. to retool the industry for the manufacture of new equipment, and to place the
  new equipment in the field. In the meantime, costs for the solvent PERC are rising from
  a current cost of $5.00 per pound to an estimated $7.00 per pound by the end of the
  year. In order to maintain this industry and the jobs it represents, new technologies for
  drycleaning must be found. Increasing environmental controls resulting in increased
  capital outlays and increased operational costs resulting from rising PERC costs will
  cause consumers to purchase less garments requiring drycleaning, and the drycleaning
  industry will fade. This could ultimately mean the loss of up to 200,000 direct jobs, and
 as many as 1,200,000 total jobs from the decline of the industry.

 One promising solvent technology which  can serve as a replacement for PERC is
 .:arbon dioxide. Carbon dioxide (CO2) is derived from two sources, either as a by
 product of air distillation or from ground wells rich in the gas. CO2 is environmentally
 benign; it is a non-toxic, non-flammable gas at ordinary conditions. When compressed
 to either its liquid or supercritical state, it becomes a excellent solvent for many of the
 types of compounds which are currently removed by PERC from garments, indicating
 that it would be a good solvent for use as a PERC replacement. The primary
 disadvantage of CO2 as a solvent is that elevated pressures are required for its use,
 which could cause the equipment costs to be higher than those associated with PERC
 operations. Prudent engineering should be able to keep the price equal to the current
 PERC machine costs, and since the recovery of the solvent is an inherent portion of the
 equipment, any price differences in  initial  cost will be more than compensated for by the
 lower solvent cost and usage anticipated with CO2. Current PERC units have been
 modified to minimize fugitive emissions of the PERC. CO2 units are inherently closed
 systems due to the pressure requirements, so that solvent loss control is built into the
 units. High solvent recovery, low operating costs and performance equivalence to
 PERC machines are the hallmark of CO2 equipment under design.

 The economics of CO2 use are appealing. CO2 costs about $0.05 per pound, and can
 be readily separated from the soils found in dry cleaning. Residual CO2 on garments
 constitute a harmless release. Initial studies indicate that little CO2 is retained by the
 garment, further limiting the already low solvent losses and fugitive emissions.
Assuming the cost of the PERC to be $5.00 per pound, and CO2 cost to be $0.05 per
 pound, a factor of 100 in solvent costs would be recognized each year. This amounts to
approximately 900 million dollars solvent cost savings to the industry yearly. If the
energy saved per pound of PERC is assumed to be equal to the energy of formation of
the compound, this corresponds to 4.17x1011 BTU per year energy saved at current
solvent usage.

We believe it possible to produce a drycleaning machine which uses CO2 as the solvent
for the same cost as current dry-to-dry PERC units, about $50,000, making the
purchase of a CO2 unit equal in initial capital costs to that required for a PERC
machine. The average PERC use per unit  is 5.000 pounds, at a cost of $25,000 per unit



         S.B.Williams, K.E. LaintzV W.D. Spall*,  L Bustos, and C. Taylor

                Chemical Science and Technology Division, CST-12
                         Los Alamos National Laboratory
                         Los Alamos, New Mexico 87545


Liquid carbon dioxide (LCO2) offers an environmentally sound replacement to the widely
used drycleaning solvent,  perchloroethylene  (PERC).  In addition to the health and
safety benefits of a C02 based cleaning  system, savings in solvent and operating costs
provide an incentive for conversion to  the new system.   Experimental  studies were
conducted using  C02 in both small scale and pilot scale test systems in order to address
fabric compatibility with this  alternative cleaning method. Results from these tests show
that fabric shrinkage using  CO2 is controlled  to the same level as current drycleaning
methods. Additional tests evaluating  the cleaning performance of liquid CO2 drycleaning
were performed.   These results show the prototype liquid C02 cleaning system to  be
better than PERC at insoluble soils removal, and  worse than PERC at inorganic salt


 Eight fabrics representing  a complete range  of commonly encountered  drycleaned
 fabrics were used in the test series: cotton twill, acetate satin,  linen suiting, dacron
 polyester, dacron cotton, polyester cotton, rayon, silk crepe de chine, and wool flannel.


 All test fabric exposures were performed using a 260D  syringe  pump fitted with a
 cylinder water jacket and controlled with a series D pump controller.  SFE/SFC certified
 grade C02 containing a diptube and a 1500 psi  helium headspace was delivered via the
 pump to a 200 ml modified  commercial filter housing cell containing the fabric samples.
 This exposure  or  extraction cell was  submerged  in  a thermoregulated  constant
 temperature bath. Water was circulated to the 260D syringe pump's water jacket at the
 same temperature setting as the constant  temperature bath in order to insure liquid C02
 delivery.   The  CO2  exposure system allowed for  static, no flow,  and/or  dynamic,
 continuous flow operation to be carried out  by  opening and closing the inlet and outlet
 valves.  The exit gas was vented through  a 1/4 inch stainless  steel tubing pressure
 restrictor at the end of the exposure.

 Los Alamos National Laboratory Report Number LA-UR-96-822
 'Current address: Isotag, L.L.C.. Isotag Research, 1285 Trinity Dr., Suite B,
 Los Alamos, NM 87544

  Drycleaning Experiments

  Sets of two open mesh bags containing duplicate sets of the eight fabric samples for
  each experimental set were processed by two drycleaners.  Each facility processed one
  bag using a standard 30-minute wash cycle with "clean" or fresh PERC with no additives
  and the second bag with "dirty" or used, end-of^cycle PERC with additives the second
  cycle  assumed to be more  representative of a  standard drycleaning wash' cycle   The
  fabric samples in each of the bags were then analyzed accordingly.

  Soil Removal Studies

  Fabric performance testing standards, "virgin" (containing no soil) and "dirty" (containing
 a specific amount of ground-in soil), were obtained from the International Fabric Institute
 The monochrome luminance values, the amounts of light reflected, were determined with
 the Optimas system.   Soil removed directly correlates  to  a higher amount of light
 reflected and therefore a higher value. Values were obtained for the "virgin" and "dirty"
 standards  by measuring four different areas -of  each fabric standard three times  The
 value for the standards was set to 100 or 100% for "virgin" and 0 or 0% for "dirty".

 Nine fabric samples were processed as follows:  CO2 was the solvent in six runs- PERC
 the solvent in two runs; and soap and water in one run. Mesh bags containing duplicate
 "virgin" and "dirty" fabric standards were processed at two drycleaners   Pre- and post-
 exposure measurements were obtained in three different areas on each of the fabrics for
 determination of soil removal.

 Salt Removal Studies

 Prior to conducting the salt removal  experiments, fabric samples were first  washed in a
 3:1  isopropyl alcohol/H2O solution to remove potential interfering inorganic species
 After drying in a class-100 paniculate hood,  the washed fabrics were then spiked with
 NaCI at two contamination  levels,  100 ng/g and  500 ng/g of fabric   Four sets of
 duplicate fabric samples spiked with the two concentrations  of NaCI were processed
 Two sets each of the same samples were processed by drycleaners using  fresh PERC
 on one and dirty PERC on the other.  After the cleaning had been completed the fabric
 samples were soaked overnight in  5 ml of (Dl) water.   The concentration of NaCI
 remaining on the fabric samples after cleaning was then back-calculated based on the Dl
wash concentration.

The primary goal of these experiments was to determine the feasibility of LC02 as a
replacement solvent for  PERC in the existing drycleaning  industry.   Reports from
attempts to use supercritical C02 as a drycleaning solvent replacement in Europe and
pilot studies done in our laboratories indicated that although supercritical CO2 was an
excellent solvent for removal of body oils from fabric, the relative high pressures and
temperatures involved required controlled pressure let-down to avoid fiber damage. This
difficulty  leads to  long processing times,  which is generally  unacceptable to the

bulk substrate.  Both the degassing of CO2 and the polymer fractionation could change
the hand of the synthetic fabrics as well as contribute to shrinkage.  From a natural fibers
standpoint, LCO2 will likely extract some of the natural oils and resins that they contain.
While this phenomenon could potentially change the hand of the fabric, it is unlikely to
cause significant shrinkage.  For these reasons, weight change was selected to test the
compatibility of various fabrics in LC02.

The eight fabric test materials were placed in a small 200 ml vessel and exposed to
LCCb for 10, 20, and 40 minutes at potential cleaning conditions along the CO2 boiling
line (Figure 1).  Initial weight measurements were made immediately following, at 24
hours,  and at 48 hours after exposure.. The data  was averaged for all fabric samples
and is  summarized in Table 1. As seen  in Table 1, exposure to LCO2 at 0% relative
humidity resulted in a weight gain in most of  the  fabrics which was attributed to  CO2
absorption.  Conversely,  the fabrics conditioned at 70 and 100% RH had from 1-5%
weight losses immediately after exposure  to LCO2. Since a majority of this weight loss
can be attributed to the loss of water from the fabrics, weight measurements were taken
4  days after exposure to ensure complete degassing and to re-establish  equilibrium
moisture content within the fabric. However, in the extreme cases of weight loss( more
than 3% of original weights) compounds were extracted from the fabric which resulted in
shrinkage. For example, at 0 and 70% RH  diacetate had approximately a 3% average
weight  loss.   Since it is believed  that  C02  was extracting lower molecular weight
oligomer fractions from diacetate, this weight loss was accompanied by significant
shrinkage, which will be discussed later. As a solvent, G02 is  much more efficient as an
extractant when it is modified with a polar cosolvent such as water.  For this reason.
higher weight loss and corresponding shrinkage  were  expected to occur with higher
water concentrations. This was indeed observed as presented in Table 1, especially at
100% RH. It was found that wool had a significant  weight loss at 100% RH. The extract
from a wool sample that had been exposed to LC02 at 1000 psi and 25 °C was collected
to determine what was contributing to this loss in weight. The extract was analyzed by
gas chromatography using a mass selective detector and found to contain lanolin-like

Several conclusions are obvious from the data summarized in Table 1.  The  dominant
factor  in weight loss due to LCO2 exposure is  relative humidity.  The more water in the
system, the greater the overall weight loss. This  is believed  to be primarily due to the
solvent action of the water modified LC02 extracting  compounds out of the fabric matrix
as well as removal of water from the polymer. The  fabrics that were conditioned at 100%
 RH prior to LCO2 exposure had an overall weight  loss of -2.8%.   In contrast, those
fabrics conditioned at 70% RH  had an  overall weight loss  of only -0.6%, and those
 conditioned at 0% RH posted an overall weight gain of  +0.9%.  While  pressure  is
 certainly  expected to effect the solvent strength of LC02  and thus  weight  loss, it
 appeared to be a factor only at 100% RH.  In this case the fabrics exposed at 700 psi
 and 10 °C, (LCO2 density of 0.86 g/rnl) had an average weight loss of -3.2% while those
 exposed  at 1000 psi and 25 °C, an LC02 density of 0.74 g/ml, had an average weight
 loss of -2.3%.  At high  humidity, the higher  the  density, the greater the weight loss.
 Again, this is due to the solvent power of LCO2. where in general, the greater the density,
 the greater the solvent strength.  Finally, exposure time was not a significant factor as far
 as overall weight loss was concerned.

 Soil Removal

 In addition  to fabric  compatibility studies,  general  cleaning comparisons were also
 conducted.  One measure of cleaning  performance commonly used to  measure the
 quality of the cleaning method is the removal of rug soil from fabric. Commercial rug soil
 standards are commonly used to rate the performance of different cleaning processes
 The standards consist of 4"x6" pieces of cotton fabric that have been impregnated with
 rug soil, labeled as "dirty", and attached to a conventional garment.  The rug soil  is
 industrial vacuum dust which is ground into the fabric using a ball mill. The removal of
 this soil by the cleaning process is a general gauge of the agitation  present within the
 cleaning vessel as well as a measure of the soil suspension ability of the cleaning fluid
 There is also  a baseline clean fabric performance testing standard that contains no
 ground in  rug soil,  and  this standard is labeled as "virgin".   Hughes Environmental
 Systems, Inc. processed dirty fabric performance standards using the prototype LC02
 drycleaning machine with vigorous agitation.  The  cleaned samples were then compared
 with dirty fabric performance standards that had been run at local  drycleaners using
 PERC both with and without detergent additives.  Finally, for comparative purposes  a
 dirty fabric standard was also cleaned using conventional soap and  water laundering
 These cleaned fabrics were then compared to the  initial virgin and dirty samples  to
 assess overall soil removal efficiencies. These results are summarized in Table 3.

 From the data presented in Table 3, it can be seen that standard soap and water
 provides the best result for the removal of ground-in soil.  This is expected since the
 detergent functions as  a flocculant to disperse and suspend paniculate soil   In fact this
 is one reason why detergents are added to PERC to enhance the overall drycleaning
 process. PERC with detergent additives was far superior to PERC without additives in
 removing the rug soil from the  test standards.  Moreover, the test standards that were
 run in PERC without additives actually came out with more dirt  on them than when they
 were initially placed into the drycleaning vessel or wheel.  This can be explained as a
 redeposition  of soil.   This makes the sample appear  "dirtier  than  it was  prior to
 treatment.  High redeposition is usually a sign of  inadequate flow, washer  overload or
 improper filtration (process maintenance deficiencies).  While the "charged" PERC  or
 PERC with  detergent  additives, performed adequately,  LCO2 proved superior  usinq
 appropriate agitation.

 Salt Removal

 In order to gauge the effectiveness of the different cleaning methods at removing water-
 soluble soils, the removal of salt was investigated.  The primary  soil of  this type found in
 garments would be sweat, and  for this reason, the removal of sodium  chloride (NaCI)
was tested.  Water-soluble soil  removal is one of  the reasons detergents are currently
 added to PERC in conventional drycleaning. The  detergent helps to solubilize water in
the PERC, and this  water is what  actual dissolves this type  of  soil in the cleaning
process.  For comparative purposes,  PERC with  and without detergent additives was
investigated.  It is common  knowledge that LC02 by itself is ineffective at solubilizing
water-soluble materials such as salt.  It has been shown that using supercritical CO2 with
a high flow rate is much more effective  than with a low flow rate in a cleaning process for
the removal  of  low  solubility contaminants.   In addition,  unrelated  studies in our

known that PERC does an excellent job at removing oil and grease type organic based
stains.  It is also known from our previous work that LCO2 .is an excellent solvent for
these same residues, especially body oils.  For these reasons, the removal of organic
based soils from the test  fabrics  was  not studied.  Drycleaning with PERC is  not
particularly effective in removing inorganic or food based stains.  Previous work has also
shown the  relative  ineffectiveness of LC02 at removing the  same  types  of  soils.
Currently, such stains are pretreated using various spotting methods prior to drycleaning
in PERC.  It is assumed that the same pretreatment would also be used when cleaning
with LC02 for the removal of the same types of soils. While spotting applications have
yet to be  tested,  commonly used  spotting solutions were  sprayed onto fabric test
samples.  These samples were then run  in the prototype machine. It  was found that all
of the spotting solutions tested were compatible with LC02 cleaning in that they were all
removed from the fabric test samples.

During  the course  of the  investigation, several  "problem"  fabrics were  tested  to
determine the effects of the LC02 and PERC cleaning on the fabrics.  Leather and fur
goods present a special problem for drycleaning, due in part to the incompatibility of the
fabric with the solvents. The leather and fur fabrics tested for compatibility with the LCO2
process showed no loss of hand and complete removal of body oil soils.  These tests
were not extensive and should be considered with care.

The compatibility of notions on the various fabrics is a concern to drycleaners, so a brief
study of the effects of the LCO2 process  on buttons,  sequins, metallic thread and fabric,
zippers, and closures was done.  In general, there were no adverse effects  observed for
any of the materials tested. Normal buttons show no effects whatsoever, with no weight
loss even after repeated exposures. Sequins, metallized fabric and thread,  zippers, and
closures reacted similarly.  Repeated  exposures of metallized fabric caused  some
delamination in  one case and no  effects in any of the  other cases.  Sealed metallic
buttons having an internal air space tended to deform due to the pressure of the LCO2
operating conditions.

 Liquid CO2 is certainly not a drop-in replacement for PERC drycleaning; however, it is
 known that liquid CO2 is an effective solvent for the removal of common types of organic
 soils.  From this standpoint, LCO2 can potentially replace PERC as an environmentally
 friendly drycleaning solvent.  Experimental studies have shown that LC02 processing
 had no deleterious effect on test fabrics.  In general, LC02 processing results indicate
 that pressure/density has no significant effect on shrinkage or weight loss.   However,
 higher  humidity or water content results in  greater shrinkage and weight loss,  with
 shrinkage being greater with longer exposure times. Nevertheless, shrinkage from LCO2
 processing and cleaning was within acceptable standards, and LCO2 cleaning had much
 better soil removal performance than standard PERC drycleaning. Work is underway to
 evaluate  full scale prototype cleaning units, and the data from these ongoing studies
 should present a clear determination of the capabilities of drycleaning with LCO2.

Table 1. Average percent weight change for all fabrics.
700 psi

800 psi

900 psi

1 000 psi


Immediately After
CO2 Exposure
+ 2.58
+ 4.19
After 2-4 Days
After 10 CO2 Exposures
+ 1.13
+ 0.27
+ 1.05
+ 0.54
+ 1.40
Average weight error is ± 0.34%
•Post equilibration time was 2 days for samples run at 0% RH and 4 days for samples run at 70 and 1000/
Table 2. Average percent shrinkage for LCO2 exposure.
0% Humidity
+0.56 %
70% Humidity
-0.82 %
100% Humidity
-0.52 %
Table 3.  Comparison of average soil removal efficiency.
Cleaning Method
PERC with additives
PERC without additives
Soap and water laundry
Percent Soil Removal
57.99 ± 3.2
35.51 ± 12.7
-31.41 ±12.3
80.67 ± 6.7
Table 4. Comparison of average NaCI removal efficiencies

100 ug spike removal
500 ug spike removal

100 ug spike removal
500 ug spike removal
high rate of mixing standard rate of mixinq
14.9 ug (14.9 %)
5.8 ug (1.2%)
13.3 ug (13.3 %)
8.0 uq (1 .6 %)
"Dirty" "Clean"
46.4 ng (46.4 %)
1 22.8 ug (24.6%)
60. 9 uq (12.2%)

                       WITH LIQUID CARBON DIOXIDE

                                 Dr. Sid Chao
                                 Mariana Purer
                                Carl Townsend
                    Hughes Environmental Systems Inc. (HESI)
In its dense phase,  both supercritical and  liquid, carbon dioxide has good, organic-
solvent-like  properties. In its  supercritical state, it has been  extensively used for
extractions, by the food and pharmaceutical industries. More recently, the use of liquid
carbon dioxide has  been  expanded to general  and precision  cleaning  of various
substrates, as a substitute for hazardous, polluting, or ozone-depleting compounds.

DryWash™  is a patented  carbon dioxide garment dry-cleaning technology, that uses
liquid  carbon  dioxide  (LCO2>  jets  as a means of  providing  the  mechanical  action
necessary for soil removal.

This article briefly addresses the LCO2 jet agitation  garment cleaning principles, the
general performance of the DryWash™ process, substrate compatibility and the main
features of a typical LCO2 dry-cleaning machine that embodies the DryWash™ process.
This document shall not be published or copied in whole or in part except with written permission of Hughes
                             Environmental Systems Inc.
        Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

 All solvents used in the current, conventional dry-cleaning process present health, safety and
 environmental problems. Perchloroethylene (perc) is a suspected carcinogen, and the petroleum
 based solvents are flammable and smog producing.  Containment, disposal and emission control
 costs are forever increasing equipment and operational costs. For these reasons, the industry is
 continuously searching for an acceptable, "green" alternative solvent  and technology that can
 resolve these issues in a cost competitive manner.

 Carbon dioxide is an unlimited natural resource, an atmospheric component, at a 0.035% level by
 volume.  It is non-toxic, non-flammable, non-smog producing, and non-ozone depleting. In its
 dense phase, both supercritical and liquid, it has good, hydrocarbon-like solvating properties  (is a
 good solvent for fats and oils) that are well known  and documented in the literature.  Its low
 surface tension also gives it good wetting properties, thus natural detergency. It can be liquefied at
 relatively low pressures and the saturation pressure at room-like temperatures of 10-15°C is below
 800 psi.

 Because of its  desirable physical and chemical properties, liquid carbon  dioxide is a  good
 candidate for use as a replacement solvent for garment dry-cleaning. Its properties in liquid state
 are compared to those of the conventional dry-cleaning fluids in Table  1 below:

                                          Table 1.
1,1, l.trichloroethane
Petroleum (C12)
Liquid CO2
(Dynes /cm)
(gin /cm3)
0.84 -0.9
(K.B. value)
0.88 (20°C)
1.2 (20°C)
1.35 (25°C)
2.86 (20°C)
0.082 (12°C)
* Calculated solubility parameters that incorporate both "chemical state" (polar-nonpolar, hydrogen bonding) and
"physical state" (pressure and temperature) considerations, have indicated that liquid carbon dioxide (at or around
1000 psi and 77°F) is most like trichloroethane. Experimental data indicates more petroleum-like solvent power.

Our objective was to develop DryWash™, an alternate dry-cleaning process,  based on Hughes-
specific carbon dioxide technology, and do so at a competitive price.

The approach has been to:
       a) set a target price range for the equipment that was to house the process;
       b) identify the main cost drivers in a high pressure cleaning machine, and;
Tills document shall not be published or copied in whole or in part except with written permission of Hughes
                                 Environmental Systems" Inc.
         Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

       c) set developmental limits on these cost drivers, such that the pre-set equipment target
       price range can be met.

The most obvious cost driver in a pressure system is the pressure itself: the higher the pressure, the
higher the cost of every system component that has to contain it, and the higher the operational
(energy) and maintenance costs. For this reason, the developmental pressure limit was preset at
1000 psi, where the goal was the lowest working pressure under this value. This automatically
placed the process development in the liquid state of the carbon dioxide.
Although the public at large is more familiar with the use of the supercritical phase, given that it
has. .extensive applicability in the food and drug industries, the higher pressure of the supercritical
phase comes at a premium that the dry-cleaning industry cannot afford. In addition to this, liquid
carbon dioxide is a better solvent: to achieve equivalent solvency in the supercritical state as in the
liquid state, pressures of 2-3000 psi are required. Also, the pressure/temperature dependent solvent
selectivity of the supercritical carbon dioxide, though it is a valued  property in food and/or drug
extractions, does not present an advantage in garment dry-cleaning.

The second  cost  driver in  a pressure  system is the mechanical action.  Agitation  by the
conventional  mechanical means of a rotating basket, either through a break-through shaft or
magna driver, is expensive, due to the cost of the drive itself, seal maintenance (for break through
shafts), and the required large chamber diameters. For this reason, the developmental limit  was set
for an agitation method without mechanically moving parts. High velocity fluid jets were selected
as a means for mechanical action.

The process additives were identified as the third cost driver: the target was a process augmented
by pre-spotters only. This objective was initially set based  on  the higher water solvency of the
liquid carbon dioxide, and prior to any testing.


By simple definition, a cleaning process means soil removal, without  substrate damage. In garment
dry-cleaning three distinct types of soil are present: solvent soluble, water soluble and insoluble, or
pigment soil. The mechanism of solvent soluble soil removal is one of simple dissolution, while
the mechanism  of removing  water  soluble  soils  is one of  secondary  solubilization,  or co-
solubilization. This article addresses mainly the pigment soil removal mechanism, as it represents
the novel aspect of the LCOa-DryWash™ garment dry-cleaning technology.

The two steps of pigment soil removal in garment cleaning are the actual removal of the pigment
off the garment and into the solvent,  and, the transport of the pigment loaded solvent out of the
cleaning drum, to prevent graying, or, redeposition.

Pigment soils are bound to garments  by two distinct types of mechanisms. The first mechanism
consists of surface tension, electrostatic forcess and Van der Waals forces. The second binding
mechanism is when the particles are trapped between two adjacent  fibers. Pigment soil removal
can take place only when the forces acting on the pigment particle exceed the binding  forcess
between the particle and the garment.

This document shall not be published or copied in whole or in part except with written permission of  Hughes
                                 Environmental Systems Inc.
         Copyright © 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

 In fluid jet cleaning, power for the process originates in a pump and is transferred to the particle as
Pump— »
pressure AP
velocity v
 The garments are submerged in the LCO2 within an enclosed cylindrical perforated basket (inside
 the cleaning drum, or pressure vessel). The load is then set into motion and agitated by high
 velocity fluid jets. The jets are discharged through the nozzles of manifolds set in an appropriate
 configuration, within the perforated basket as shown in Figure 1. (Note: this figure represents the
 unoptimized chamber configuration  of the  developmental  prototype  and is used  only  for

 The cleaning zone is near the jet source, on the outermost periphery of the rotating load.  The
 garments within the load are entrained by the high velocity fluid jets through a Venturi effect As
 they enter the high velocity jet cleaning zone, they experience a momentary acceleration. At a
 constant flow F, this acceleration is dependent on the pressure drop AP across the jet nozzles. As a
 result  of this acceleration,  the garments experience a stretch. As the  garments exit the jet, or
 cleaning zone, they relax and snap back to size. This stretch-relax cycle repeats itself throughout
 the entire cleaning step and effects the pigment soil removal/expulsion.
Perforated basket and jet configuration: side view
Because the cleaning zone (as described above) is on the outermost periphery of the rotating load,
the dislodged pigment is carried out of the perforated drum by the peripheral fluid layer of the
vortex / spiral (set up by the jets), and out of the vessel itself, through the exit port. It does not
penetrate the bulk of the load.
This document shall not be published or copied in whole or in part except with written permission of Hughes
                                  Environmental Systems Inc.
         Copyright® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

The pigment soil concentration within the wheel at any one time is relatively low, since the load is
cleaned outer-layer-by-outer-layer, the garments being entrained sequentially by the fluid jets. As
such, the graying factor is inherently lower than in the conventional process. The graying factor is
further lowered, since the flow demand is inherently higher in the fluid jet cleaning process (per
equivalent load). The number of solvent exchanges per unit time is higher, and thus the soil
residence time and redeposition, lower.

To summarize, in fluid jet cleaning, where the cleaning fluid has a low viscosity, higher levels of
cleanliness can be obtained since smaller ("graying") particles can be removed off the surface, and
less redeposition will be noted, since  the colloidal particles will have  a shorter residence time in
the wheel (higher pump capacity), and  overall particulate soil concentration within the wheel is
always low (peripheral cleaning zones).


Comparative surface reflectance  results of pigment soil standards validate the  pigment soil
removal  concept described above. As  the differential pressure of the jets  rises, soil removal
improves: smaller,  and  more firmly embedded  panicles  are  removed.  Thus, the higher  the
reflectance of the resulting surface.

A comparative quantification of the  jet cleaning mechanical action and the conventional drum
mechanical action was performed by the Los Alamos National Laboratory,  using International
Fabricare Institute (IFI) rug soil standards. The reflectance values of  jet cleaned standards were
compared against the reflectance of the standards that were processed in "common" cleaning loads
by commercial dry-cleaning establishments, using charged (soap and water) perc. A standard that
was cleaned  by hand scrubbing with soap and water was also included in this evaluation.  To
increase resolution, the reflectometer was calibrated so that the "virgin"  standard would read 100%
reflectance, while the reflectance of the initial, soiled IFI, was set at 0%. The quantitative results
are illustrated by the bar chart in Figure 2.
                           Comparison of Soil Removal Capabilities
                          IFI Clean
           ' Result is due to redeposition ol soil
                                    Soap &
Perc (No
                                        Cleaning Method
                          Fig. 2. Pigment soil removal comparison

This document shall not be published or copied in whole or in part except with written permission of Hughes
                                  Environmental Systems Inc.
         Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

 Overall process performance,  was also evaluated in a  more  controlled fashion against  the
 performance of the commercial perc cleaning process, both charged and uncharged. The results
 correlate closely with  those obtained by independent equipment manufacturers, using industry
 accepted standards.

 Cleaning performance categories investigated were as follows:

 • oily soil removal
 • "collar dirt"
 • paniculate soil removal
 • dye transfer
 • stain removal
 • whitening / redeposition
 • water soluble soil removal
 • cycle time.
 Within the process parameters (pressure and temperature)  selected, the liquid carbon dioxide jet
 cleaning process performance compared to the perc cleaning process as follows:

                                         Table 2.
           Water soluble soil3
1 Indicates a "better-than" condition compared to an uncharged perc system, and equivalency when
compared to a charged perc system
2 In this case the equivalency indicated that stain removal without prespotting was equally poor for
the LCO2, and perc (charged, or uncharged)
This document shall not be published or copied in whole or in part except with written permission of Hughes
                                 Environmental Systems Inc.
         Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

3 The water soluble soil removal capability of the LCO2 was equivalent to that of the uncharged
perc, and lower than that of a charged perc system.

The results as illustrated above, indicate not only a practical equivalency, but also a "better than"-
potential, compared to the  conventional process  performance, when incorporating additives or


Liquid carbon dioxide is a non-polar dry-cleaning solvent, that primarily removes non-polar soils
such as oil and grease. Since water soluble, or hydrophilic soils are polar or ionic  in nature, they
have a low solubility in liquid carbon dioxide (and other conventional dry-cleaning solvents).

It is obvious that in order to efficiently remove common polar or ionic soils such as salt (from
perspiration) and glucose (from beverages), LCO2 compatible additives have to be introduced into
the system, or  pre-spotters used. They will either  directly facilitate the co-solution of the above
named soils into the liquid carbon dioxide system, or, increase the moisture transport ability of the
liquid carbon  dioxide. The solvated water, in its  turn, can  than  dissolve  the  hydrophilic soils,
through a secondary solubilization mechanism, as documented in conventional dry-cleaning.
This document shall not be published or copied in whole or in part except with written permission of Hughes
                                 Environmental Systems Inc.
         Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.


 Common fabrics

 A number of common fabrics, both natural (cotton, silk, wool, linen) and synthetic (polyester,
 poly/cotton, rayon, diacetate) were repeatedly exposed to the process. Dimensional changes noted
 were within the same range as those produced by the conventional process. The shrinkage of the
 diacetate was above that of the conventional process.  The evaluation was performed by the Los
 Alamos National Laboratory, and a report will be issued. Actual garments,  both simple and of
 complex construction (i.e. jackets, with linings, shoulder pads...)  were also processed repeatedly,
 without noticeable degradation or dimensional change.

 Also, vividly colored garments were co-processed with "lights" without noticeable color loss or

 Leathers and furs

 A number of vividly colored leather (finished one side,  split the other), and fur samples were
 submitted to the jet agitated liquid carbon dioxide cleaning process and than compared against
 unprocessed standards, for visual damage and  color  difference verification. No color  change,
 stiffening, brittleness, or general hand-and-feel change was noted on any of the samples.

 Actual leather garments were not processed due to the small chamber dimension. We expect this
 type of garment processing to be problem free, although loading ratios will likely be reduced due
 to their natural bulkiness.

 Leather work (machinist) gloves were also successfully cleaned.

 Buttons and decorations

 A large number of various common and decorative buttons (metallic, natural:  shell and bone, and
 synthetic) were attached to fabric and were co-processed  in a 0.4 (Ib/gal) loading ratio load  to
 simulate the maximum expected agitation in a cleaning load. The buttons were subjected to eight
 agitation cycles, 15 minutes each. No visual damage was noted on any of the buttons. Please note
 that none of the buttons had  sealed cavities. We expect that any decorative buttons  with sealed
 cavities would have to be removed off the garments prior to processing, to avoid being crushed by
 the pressure.

 Metalized sequins also appear undamaged.

There is occasional weakening of the elastic  inserts, not  unlike that noticed  in dry-cleaning
processing with conventional cleaning fluids.
This document shall not be published or copied in whole or in part except with written permission of Hughes
                                 Environmental Systems Inc.
        Copyright ® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.


 A typical DryWash™ cleaning cycle is is 18-24 minutes long and is comprized of a number of
 steps:  fill, jet-agitation, drain,  and vapor-recovery/decompfession. A machine that houses this
 process has to accomodate these steps in the most cost efficient manner from the point of view of
 capital (machine) and operational (energy, labor, maintenance, solvent, cycle time) costs.

 An exemple process and instrumentation drawing incorporating the full technology is illustrated in
 Figure 3. Some notable aspects of this drawing include the reversible agitation, top side drain
 circulation, and the vapor recovery /load  warming strategies, all designed to reduce energy
 consumption and cycle time.
        Vapor Recovery
                                RRer Train
                     Fig. 3
                      DryWash™ Dry-cleaning machine
All test results and  economic analysis  suggest that the DryWash™-liquid carbon  dioxide jet
cleaning process is not only a viable alternative for garment dry-cleaning, but it has the "better,
faster and cheaper" potential, compared to the conventional process,  through further equipment
optimization, scale up, and chemistry (soap) development

1. Perry & Chilton, (Eds) Chemical Engineer's Handbook McGraw-Hill, 1973
2. Musselman,  et  al.  "Shear  Stress  Cleaning  for  Surface  Departiculation",  Journal  of
Environmental Sciences, Jan 1987
3. Brandreth, D.A. and Johnson, R.E., "Removal of Particulates for Optical Lenses", the Optical
Index's Journal of Ophthalmic  Dispensing, Jan 1979
4. William H. Smith, Manfred Wentz, and Albert R. Martin," Comparison of Soil-Deposition and
Redeposition Tests in Evaluating Drycleaning Detergents" National Institute of Drycleaning.
This document shall not be published or copied in whole or in part except with written permission of Hughes
                                 Environmental Systems Inc.
        Copyright® 1996, Hughes Aircraft Company. An unpublished work. All rights reserved.

   Upstairs, Downstairs: Perchloroethylene in the Air above New York City Dry Cleaners
                Consumers Union Special Report, October 1995
      Tests conducted by the New York  State  Health  Department
 in 1991 demonstrated that the  air  in  apartments  located  above
 dry cleaners is polluted with  perchloroethylene  ("perc,"  for
 short), the primary solvent used in dry cleaning.  NYSOOH has
 called this "a high risk environmental health problem."   The
 state has also established 100 micrograms of perc  per cubic
 meter of air (100 jig/m3)  as  a guideline for maximum safe long-
 term public exposure to this pollutant.

      In the NYSDOH study, the highest perc  levels  were found
 in apartments above dry cleaners that had old-fashioned dry-
 cleaning equipment; apartments above cleaners with more modern
 "dry-to-dry" equipment had lower,  although  still rather high,
 perc levels.  In 1994,  New York State concluded a  negotiated-
 rulemaking process which produced a proposal to require all
 dry cleaners located in residential buildings to use modern
 unvented,  dry-to-dry machines.  The proposal has not yet been
 implemented by the Pataki administration.

      Our study examined whether the use of modern dry-cleaning
 equipment would produce acceptably low perc levels in the air
 of residences located above  the cleaners.   We selected 12 dry
 cleaners with modern,  dry-to-dry machines,  located in New York
 City apartment buildings,  and tested the air in 29 apartments
 in those buildings for perc.   We sampled for 24-hour periods,
 on four different days, in each apartment.

      We found that modern equipment does not prevent serious
 perc pollution of apartments  above  dry cleaners.   Twenty-four
 of the  29  apartments had average perc levels above 100 /tg/m3/
 the state  health guideline;  eight  apartments had average perc
 levels  above 1,000 ftg/m3.  The highest average perc level  in
 an individual apartment was  25,086  /tg/m3.  Exposure to perc at
 the levels we found in  many  apartments we tested poses a clear
 danger  to  the health of the  apartments'  residents.

      Although perc pollution  from dry cleaners in residential
 buildings  has been recognized  as a  significant public-health
 problem for several years, to  date  local, state and Federal
 governments have failed to solve the  problem.   These  findings
 suggest  that the approach currently being pursued by  New York
 State,  requiring all dry cleaners to  install more modern dry-
 cleaning equipment,  will  improve the  situation above  cleaners
with  older equipment, but will  not  guarantee acceptably  low
perc  levels in  apartments' air.  We recommend that  the New
York  City  building code be amended  to  prohibit dry  cleaners
from  operating  in  residential buildings.  We also recommend
that  people who live in apartments  upstairs  from  a  dry cleaner
get their  air tested for perc.

Volume 104, Numbers, May W6 •  Environmental Health Perspectives

A Cleaner Bill of Health

Liquid carbon dioxide (CO2) is getting serious consideration as the dry cleaning fluid of the future. With
encouragement from the EPA's Design for the Environment program, liquid CO2 could replace
perchloroethylene—known as "perc"~today's dry-cleaning solvent of choice. Perc, a chlorinated hydrocarbon,
has been linked to cancer and other health problems.

Based on animal studies and other data, the International Agency for Research on Cancer (IARC) calls perc a
probable human carcinogen. The EPA puts the solvent in the possible-to-probable category of carcinogens.

James Huff, a toxicologist with the NIEHS, says perc-cleaned clothes pose virtually no cancer risk to the
wearers; the amount of perc on such clothing is probably negligible. The NIEHS has reported, however, that
rats exposed to perc vapors have an increased incidence of leukemia and kidney tumors, and mice similarly
exposed have increased numbers of liver tumors: Moreover, Huff says, epidemiological studies have linked
perc-contaminated drinking water to increases in leukemia in an exposed population cohort and to increased
urinary, bladder, and esophageal cancers in perc-exposed dry-cleaning workers. Other perc-related cancers
include cervical cancer and non-Hodgkin's lymphoma. Because of these data, Huff believes occupational
exposures to perc do present a hazard.

Robin Hill, a risk manager at Health Canada, says, that Canadian health authorities disagree with IARC, and
don't think the evidence is strong enough to label perc a human carcinogen. Even so, cutting back on perc
seems to be a widely accepted goal, even in Canada. The Ontario government has already proposed reducing
workplace exposure from 50 parts per million (ppm) during an 8-hour workday to 10 ppm.

While current regulations of the Occupational Safety and Health Admini-stration (OSHA) limit worker
exposure to 100 ppm, the agency is examining evidence to see if the standard should be changed. "There is a
long-standing relationship between the agency [OSHA],  the dry-cleaning industry, and public interest groups
aimed at reducing exposure," says Joseph Cotruvo, who oversees chemical screening and risk assessment at
the EPA's Office of Pollution Prevention and Toxics.

The U.S. dry-cleaning industry, which employs more than 250,000 people, has taken steps to cut back on
perc usage. "Perchloroethylene use in  1988 was approximately 250 million pounds in the U.S.; in 1994 it was
150 million pounds," says Mary Scalco, director of government relations for the International Fabricare
Institute (IFI), the dry-cleaning trade association. She says improved technology is the primary reason for the
decrease. And attempts to develop alternate methods in dry-cleaning are being explored with the support of
several agencies, including the EPA, and industry.

Liquid  CO2

One technology being investigated uses liquid carbon dioxide (CO2) as a dry-cleaning solvent. Hughes
Environmental Systems of El Segundo, California, has developed a prototype dry-cleaning machine and
process called DryWash. The system, which uses liquid CO2, was exhibited in Milan at an international
dry-cleaning exposition in March. While  the EPA's Design for the Environment program hasnot funded
research on liquid CO2, it has held conferences and encouraged the exchange of information about its

Sid Chao, president of Hughes Environmental Systems, says liquid CO2 doesn't have the environmental and
health drawbacks of perc. OSHA limits exposure of CO2 to 5,000 ppm for an 8-hour day.

 tests indicate that it is better than the perc process."

 Besides performance, other questions remain about how a liquid CO2-based system would fit into the
 operations of the approximately 30,000 dry-cleaning establishments in the United States.

 Cost is one crucial concern for dry-cleaners. "Commercial dry-cleaning is not a high-profit business, and many
 dry-cleaners are barely able to stay in business," states a 1995 EPA profile of the trade. Acording to the EPA
 report, the cost to start up a dry cleaning business in 1993 was $113,000.

 Scalco says that she's seen no information on the cost of liquid CO2 machines from Hughes, but "for liquid
 CO2 [to be a viable option] you have to have equipment that's affordable. That's probably the biggest thing
 right now."

 "Can we provide a system where the unit costs per pound for producing a clean garment are comparable [with
 existing technology]?" wonders Wentz. He notes that liquid CO2 may have some economic factors in its favor.
 The shorter cleaning cycle means more garments can be cleaned in less time. Furthermore, labor costs for
 finishing or pressing the garments may be reduced, since the garments are cleaned at lower temperatures,
 which  reduces wrinkling. Such factors will help determine if the liquid CO2 process will fit within the present
 dry-cleaning infrastructure, says Wentz.

 If the Dry Wash machines prove too costly for individual "morn and pop"  dry-cleaners (which make up most of
 the dry-cleaning operations in the United States, according to the EPA), the machines may find homes in
 central facilities, with customers dropping their clothes off at storefronts or so-called "dry stores" to be taken to
 the central facilities for cleaning. This is already a trend in dry-cleaning, says Scalco. But this system may
 negate some of liquid CO2's potential environmental advantage by causing increased fuel consumption and
 pollution from transporting the clothes, Wentz cautions. A life-cycle study of factors such as these would have
 to be done to assess the advantage of liquid CO2 from an environmental perspective.


Wet-cleaning is another method being examined to replace perc. Highly touted by the environmental  activist
group Greenpeace, this European-developed method uses water and specially designed soaps instead of
solvents to clean clothes.

The machines that do the cleaning are sophisticated washers and dryers in which humidity, agitation, and heat
are computer controlled. "By controlling all those factors in  a better way,  it's possible to clean clothes with
water that used to be dry-cleaned," says Jack Weinberg, a campaigner against toxic chemicals for Greenpeace.

Wet-cleaning, or wet wash as it is sometimes known, is used in Germany and Austria and has also been tried
on a demonstration basis in the United States and Canada.

With funding from the EPA, Greenpeace, and the Center for Neighborhood Technology (CNT) in Chicago
have been examining how well wet-cleaning cleans clothes in a study with the Greener Cleaner, a private
dry-cleaning business that has been operating since May 1995. The study  is part of an agreement between
Greenpeace, the CNT, and the IFI to assess perc alternatives.

Jo Patton,  CNT project director for the wet-cleaning demonstration, says the wet-cleaner has successfully
cleaned virtually all garments brought to it,  rejecting only about one-tenth  of a percent because tests at the store
showed that dyes would run. She says wet-cleaning has been able to clean clothing made of wool, silk, rayon,
cotton, and blends of fabrics. Weinberg claims that even leather can be wet-cleaned satisfactorily.

In Canada, a wet-cleaning demonstration project begun in 1994 and funded in part by the government reported
that 30-80% of garments currently dry-cleaned can be satisfactorily wet-cleaned, a figure far greater than the
3-15% of clothes (excluding shirts) now cleaned in water at  dry-cleaners.  A report on the project, which
involved six cleaning facilities, concluded, however, that wet-cleaning "does not appear to  be a complete

                         Global Technologies, LLC

Global Technologies, LLC, is a technology management company created to
commercialize technologies such as Dry Wash™ coming out of the aerospace industry.
We are jointly owned by Itochu Aviation, part of global trading company Itochu Corp.,
and Anscott Chemical Industries, services laundry, drycleaning, and garment industry.
               Hughes Environmental Systems, Inc. (HESI)

Hughes Environmental Systems, Inc. (HESI), was incorporated in 1989 as a wholly
owned subsidiary of Hughes Aircraft Company.  HESI has two missions:

1.  To provide Environmental, Health, & Safety Services to Hughes Electronic.
2.  To commercialize appropriate Hughes technologies in order to realize dual use of
   technologies that began with military applications.

HESFs strategy to fulfill the second, key, mission is to identify a market need, match the
need to an appropriate Hughes-owned technology, and then follow a rigorous due
diligence process of evaluation, partner selection, and technology validation. HESI
concurrently develops that technology for the market application while forming alliances
(partnerships, licensing agreements, etc.) with companies who are experienced in
productizing, marketing, and distribution in the targeted industry.

HESI team members have had success with a number of ventures including DryWash™,
CO2 textile cleaning; SuperScrub™ precision cleaning; and HF1189™ solder flux.


  Los Alamos Profile
                                  Los Alamos National Laboratory is
                                  one of the largest multidisciplinary,
                                  multiprogram laboratories in the world.
                              Situated on more than 43 square miles in
                              northern New Mexico, the Laboratory has
                              6700 regular full-time employees and an
                              approximate FY97 budget of $1 billion.
                              We are operated  by the University of California
                              for the Department of Energy and are one
                              of the Department's nine multiprogram
                              national laboratories.
                              Over our 50-year history, our primary mission
                              has been to apply science and technology to
                              problems of national security. Well before the
                              end of the Cold War, however, this mission
                              was expanded to include addressing energy,
                              economic competitiveness, and other national
                              problems. In support of this broad mission,
                              we conduct basic and applied research in
                              hundreds of areas ranging from advanced
                              manufacturing techniques to human genome
                              studies, from alternative energy sources to
                              new polymers. Four key areas of expertise and
                              resources are expanded upon below. A vital
                             facet to all our work is R&D collaboration with
                              private industry.
                              Chemistry and Materials Science. In a far-
                              reaching materials science and technology
                              program, we conduct research in metallurgy
                             and ceramics, high-temperature superconduc-
                             tivity, materials chemistry, and condensed-
                              matter physics. We have contributed to the
                             development of advanced high-strength alloys
                             and composite materials and to advances in
                             manufacturing processes like high-energy
                             welding and near-net shape fabrication
                             techniques. Our special strengths are the
                             availability of multidisciplinary research teams
                             and the accessibility of integrated capabilities
                             for the design, prototyping, analysis, and
                             testing of new materials.
                                                                         Advanced Computing and Modeling.
                                                                         Los Alamos has always been on the frontier
                                                                         of computational science and has driven
                                                                         developments in the computer industry.
                                                                         We have one of the world's most advanced
                                                                         computer networks, with the combined
                                                                         computing  power of about 75 CRAY-1
                                                                         machines. To complement this computing
                                                                         muscle, we have a multidisciplinary staff
                                                                         skilled in developing and applying complex,
                                                                         versatile algorithms to real-world problems.
                                                                         The upshot is an ability to model and simulate
                                                                         a wide range of processes important
                                                                         to industry.
                                                                         Biotechnology. Our mission is to address bio-
                                                                         logical problems at the molecular, cellular, and
                                                                         whole-organism levels. We have pioneered in
                                                                         such areas as developing flow cytometry and
                                                                         applying accelerator-related technology to
                                                                         improve biomedical techniques,  instruments,
                                                                         and models. We have programs  under way to
                                                                         understand how radiation and chemicals affect I
                                                                         human health and to study the structure and
                                                                         dynamics of biological macromolecules. The
                                                                         Laboratory is also one of three Department of
                                                                         Energy Centers for Human Genome Studies.
                                                                         Environmental R&O. We have a  broad
                                                                         environmental R&D effort that encompasses
                                                                         site characterization and remediation, waste
                                                                         minimization, and environmentally conscious
                                                                         manufacturing. We  have developed advanced
                                                                         lasers to detect and track air pollutants,
                                                                         computer codes to forecast the direction and
                                                                         speed of pollutant transport, technologies to
                                                                         isolate and extract metals and other toxic
                                                                         materials from waste streams, environ-
                                                                         mentally benign industrial solvents, and
                                                                         manufacturing techniques that incorporate
                                                                         environmental safeguards from design
                                                                        through product lifetime.
Los Alamos
                             A US DEPARTMENT OF ENERGY LABORATORY
                             January 1997 • Los Alamos National Laboratory, an affirmative action/equal opportunity employer,
NATIONAL  LABORATORY   is operated by the University of California for the US Department of Energy under contract W-7405-ENG-36.

                        Surfactant Research for CO2 Processes

                                      Jim McClain, Ph.D.
                                     MiCELL Technologies

       Dr. Jim McClain is one of the co-founders  of MICELL ™ Technologies, Inc.  He
       currently serves as the Director of Research, Development, and Engineering where he is
       responsible for technical leadership and overall coordination of the development of active
       chemistry,  formulations, process research and development, system  engineering, and
       mechanical build-up and engineering.

       Thanks. I appreciate the opportunity to talk in front of this audience and also the fortitude of this
audience to still be here at this point in the day.

       I'm going to take a pretty big change in the slant of my presentation. I'll cover all of the benefits
of CO2 and CO2 based technology, CO2 as a replacement for drycleaning as well as other solvents and
water based technologies. I believe in those items, and I wholly support all the advantages and everything
that Craig and all the other speakers on the CO2 field have gone over.

       What I will do that is different is to try to get into how can we make detergents for carbon
dioxide. I have been involved in the study of CO2, and specifically the design and characterizationpf
surfactants for CO2, for about the last five years. My work started out with Joe DeSimone at UNC, where
my work culminated at about the same time as the green chemistry award; that is probably a coincidence.
Then I moved on to MiCELL, where I have been trying to take these surfactant developments and turn
them into a commercial reality.

       The key to operating and designing a surfactant for CO2 is not so much in finding something that
dissolves or finding something that forms a micelle. The key is integrating it into a cleaning process so it
can get the job done, so it can provide clothes that are clean and in a state ready for finishing. It should be
in a state acceptable to both the professional drycleaner and the customer.

       I don't profess to be a drycleaner, but I have had the opportunity to work with and get advice from
a lot of the best professionals in this field. The first time I ever met Manfred Wentz, he told me, "just
because you've got something that dissolves or just because you've got a micelle, doesn't mean you have a
good cleaning system. What you have really got to do to develop a good cleaning system is, you have to
get dirt off a substrate. Nobody really cares how you do it or how pretty your chemistry is, or how
beautiful your machine is.  You have to get an unfavorable soil into the fluid and the fluid taken away."

       In CO2, that means it either has to dissolve in the fluid, be removed by agitation and taken out of
the system, or carried into the fluid by some kind of surfactant, detergent, soap, micelle.

       This slide shows a schematic of a basic CO2 cleaning process. This has been touched on in some
of the other talks today. The surfactant can pull the dirt up off the substrate and into the solution  in the
micelles. The fact that the core region in 'these micelles is water is one of the most important parameters
for good drycleaning.  I have been tutored and have tried to listen time and time again, to the fact that
moisture is the key to getting effective detergency. A large part of a tremendous body of research has

  been trying to get free water micro-emulsions or emulsions into a CO2 environment to effect removal of
  polar stains.

         We have hit upon the physical properties of CO2 and what makes it different. What I want to
  touch on just for a second is how these properties influence the design of surfactants for CO2.

         Carbon dioxide is a very gentle solvent in the liquid state. There have been studies that prove its
  excellent effect on the garments, its effects on fibers, finishes and what have you. However, it is a very
  good solvent for drycleaning. It is a very challenging solvent to try to build soap for, because it has a
  tremendously low viscosity and an extremely low dielectric constant. The dielectric constant is the
  parameter that we like to use as opposed to a KB value or a solubility parameter. We are down here in
  the region that is really analogous to fluorinated solvents with its ability to stabilize a polar system, and
  petroleum and perc are better in that order.

         What this means is that CO2 can only dissolve a  select few materials in the readily available
  liquid state, around ambient or slightly sub-ambient conditions.  This is essentially high vapor pressure
  fluids. Basically anything that you could pour into  a glass, except water, dissolves in CO2 fairly readily.

         Soon hydrocarbon monomers, were explained in talks by Joe DeSimone, where we worked very
 hard on polymerization processes. Then as far as high molecular weight materials that can provide you
 building blocks for a surfactant, we are limited to the lowest surface energy materials available. They are
 the siloxane polymers and the amorphous fluorinated materials.

         In this slide, insoluble in CO2 is summarized best by the first line. It is very hard to get plastics,
 heavy oils, heavy greases to dissolve in CO2 when you get into higher loadings of grease, and heavy
 stains, and the things that we care about in drycleaning. They are very hard to get to dissolve, because
 they are highly polar substances; water being the key that has a very low solubility in CO2, and almost all
 of their polymeric building blocks.

        What we are able to do is take advantage of the solubility of polymers in carbon dioxide and
 classify them two different ways. We have a CO2 philic classification, and a CO2 phobic classification.

        Under CO2 philic, we can divide the world into traditional hydrophilic materials, these are water
 loving materials that have the potential to dissolve or be swollen by water, as well as oil  soluble materials,
 like polystyrene or poly methylmethacrolate, your traditional plastics. This is one of the things that
 makes us able to clean textile fibers in CO2, because these materials are not significantly swollen or
 dissolved by carbon dioxide. But it also means that  we have a field of surfactant design that includes both
 oil based materials and water based materials to get  the most effective detergent action in carbon dioxide.

       What we wanted to build are surfactants based on a combination of a CO2 phile and a CO2 phobe.
 A lot of this technology and terminology has been published in the literature. But through design of this
 structure of a CO2 loving and a CO2 hating material  which are logically designed for a CO2 system, we
 can build detergents that are active in carbon dioxide. Then, we can build processes around these
 detergents that put them to work to actually get the job of drycleaning done.

       The picture of the kind of surfactant and detergent we are trying to build is best done in the balls
and swiggles methodology that we have seen a few times. But, in traditional water systems, you build a
micelle.  You do this every time you do the dishes or you wash your clothes in water or you wash your

hands in the restroom. You build a micelle to cany the oils and greases into the water phase. The oils
and greases don't want to be in the water phase; they need to be carried there by a specific amphophilic
molecule. The molecule is able to pull an oil phase into the center of its domain and act on soils not
otherwise soluble in the continuous phase.

        The exact same idea drives the design of surfactants for CO2, except that we have to get very
creative. Here you see these PFOA and PEO. PFAO stands for a fluorinated acrylate material. It is one
of the amorphous fluoropolymer chemicals that is soluble in CO2 that we can use to design the corona of
a micellar structure to drive and pull water into carbon dioxide.

        The next task is how to make this water core act as a detergent.  It is one goal to be able to build a
micelle, it is another goal to be able to make it work. The best example published of making micelles go
to work is a paper that came out in Nature in 1997 that was a massively collaborative effort with the
University of California, University of North Carolina, Oak Ridge National Labs and others.

        Essentially, we made a surfactant out of one molecule. We made what is called a dendromer. It
is a CO2 based surfactant, and it proved the concept that we could take a CO2 philic exterior and a CO2
phobic hydrophilic interior and make it act on a water phase. The colored pictures on the right of this
slide show that as we go from A to D, this is a CO2 phase sitting on top of a  water phase. In the
beginning, we have dye dissolved in the water.  Toward the end, you can see that the dye has been pulled
out of the water phase and trapped into the CO2.

        We made a micelle, and then we made it go to work. We made it pull this material out of the
water and into itself. That is a great start, but we need to make these things act on a surface. That has
been a lot of the work that has gone on at MiCELL.

        The next part of the structure that can be developed is the design and application of surfactants.
We took this to a slightly higher level, in that we actually measured them. We built a surfactant micelle
in CO2, and measured its characteristics with neutron scattering. With this information we can start to
build micelles; we can start to put them together, we can start to take them apart. We can start to do
things that take care of one of the problems that Craig brought up. When you add a surfactant to a
system, you are essentially adding to your dirt in a traditional system.

        What you can do in a CO2 based system, through proper tailoring of a surfactant, is to cause it to
open up and release its dirt. This is under development still in academic labs with Professor di Simone.
However, it is a concept that has the ability to change the pressure of CO2, the ability to change its
solubility characteristics, and we can open up this window. This feels like science fiction.  You make
your soap go over here, go to work, you bring it over here and you drop your dirt and you send it back. It
will never be 100 percent.  It will never function just like that, but it is something that is possible  in CO2
that is next to impossible in any other kind of fluid.

        I want to shift gears for one or two minutes here and bring up another topic that we hit on.
Having soaps that work is the first step, integrating  them into a process that cleans clothes is the second
step.  With the MiCARE process that Brad Lienhart alluded to and described a bit earlier today, we follow
a similar drive towards simplicity. Ours is a rotating basket design.  We can get into the details and
differences between Dry Wash and MiCARE for the rest of the year.

         Essentially, we integrate our detergents into the system in such a way that they act on the clothes
  and can be removed and separated from the contaminants. It is essentially a traditional system, except
  that now, the fluid used instead of perc and detergent is CO2 and detergent. We have designed the
  systems to work in almost exactly the same manner. I've been tutored by drycleaners like Williams
  Cleaners and Buster Bell, and I ask drycleaners a lot of questions. I want to find out what we can do to
  make the transition of operation to a new system as painless as possible. We want to know how best to
  change from a very common solvent such as a liquid solvent such as petroleum or a chlorinated material
  to something that is really unique, a densified version of the same gas we are all exhaling into this room.
  We want to keep the system as close to optimum as possible.

         We have tested the compatibility of the CO2 and the CO2 with our additives. I could make a very
  long story out of the short answer, that it works fine, much like the additives in a typical perc or
  petroleum machine. However, it is not so much a problem with the additives, it is a problem with what
  you do with them. If you go home and dump a half gallon of water into this system, you're going to
  damage acetate and you're going to shrink some woolens, but under normal operation and normal kinds of
  controls, it will work just like another soap and solvent system.

         We have looked into—with the assistance of some friends in the College of Textiles at NC
 State—the comparability with real small sampling of dyed fabrics with much the same result and the
 same story. We haven't and we won't look at every dye in the world, but all the dyes that we were able to
 come up with showed very little change before and after exposure to our chemistry.

        We have also embarked on a study of buttons and  finishes and other related issues. These are on
 display fairly regularly, as well as on our website; you can get more information on the computability
 with everything that we have looked at.

        The same cleaning challenges hold true with leather and suede.  We have embarked on the ability
 to both treat, clean and fix up leather and suede.

        I'll leave this presentation on something positive. That is, if we can get a detergent additive into
 CO2, get it to pick up water, and act like a detergent additive and like a detergent solvent system that we
 are all used to with perc and petroleum, then we can make these things clean exceptionally well.

        This is an old slide where we were comparing CO2 with perc performance from a local
 drycleaner. I have no intention of showing people that clean with perc how well they do or don't do. I
 will rather focus on our cleaning performance versus the untreated stain. We are able to remove the broad
 gamut of stains without pretreating, and using a room temperature process.  We give our system a chance
 to do its best on a stain or on the fabric,  and then if necessary, there is the option for post treatment
 without any heat setting.

        There is a lot of this performance data across the range of stains. This slide shows blueberry
juice, and there is a spaghetti sauce version on different fabrics. The addition of water gives you an acidic
 system that acts to our benefit in removing stains.  The production of isolated domains of water of a
 typical micro emulsion surfactant in a solvent system allows a very high performance level of cleaning in
 a traditional manner.

       I thank you for your attention.

             Changing the Care Labeling Rule to Fit Changing Times

                                        Connie Vecellio
                                   Federal Trade Commission

       Connie Vecellio is currently an attorney in the Division of Enforcement of the Bureau of
       Consumer Protection at the Federal Trade Commission, where she has served since 1977.
       For the last several years her responsibilities have included enforcing the Commission's
       Care Labeling Rule, which requires care labels on textile wearing apparel.

       I am happy to be here today to speak at this very forward-looking conference, and I am very
happy to speak to you on this particular day because something happened yesterday that I can tell you

       The Federal Trade Commission voted to issue a notice of proposed rulemaking to make some
changes in the Care Labeling Rule that we talked about in the January workshops and previously in the
conference in September 1996, sponsored by EPA. The notice has not been published in the Federal
Register yet.  It is hot off the press, as Mary Ellen said. You have copies of it at your desks. You are all
getting advance notice of this.

       My remarks today are strictly my own opinions and don't necessarily represent the opinions of the
five commissioners. That is another reason the notice is so valuable. Because it does represent the
opinions of the five commissioners. They all voted for it and they are  voting to move forward with the

       So, today, I am  first going to discuss with you the proposed changes in the Rule.  Secondly, I
want to discuss a proposal that I have for gathering more data about problem garments, garments that are
damaged when dry cleaned. Based on what I have heard here the last two days, I believe that a large
database of problem garments would be a great help to the goals that we are trying to achieve and the
goals that were brought up in the January workshops.  But, first, I want to talk to you about the largely
EPA-inspired changes in the Care Labeling Rule and I am going to move  over here and start using my

       In 1994, as part of its ongoing review of all its Rules, the Commission published a notice asking
about the usefulness of the Care Labeling Rule. The general response was that it is very useful and it is
one of our most popular Rules.  But that 1994 notice did note that EPA had designated perchloroethylene,
or perc, as a hazardous air pollutant under Section 112 of the Clean Air Act and that EPA had been
working with the drycleaning industry to reduce exposure to perc.  That led to proposed revisions in the
Rule, which the Commission published in November 1995.

       The revision of most interest to everybody here today, I think, was a proposal that the Rule be
changed to allow for labeling for professional wet cleaning. Secondly, though, and also relevant to the
goals of reducing exposure to perc, is the proposal to change the Rule to require that any garment that
could be laundered at home be labeled for laundering at home.

         The Rule currently requires a washing instruction or a drycleaning instruction, but does not
  require both. Some garments labeled "dryclean" could be washed at home, but the consumer can't be
  certain that is true. The Commission asked for comment on both of these issues.

         When I talked in 1996 at the EPA conference, I spoke about professional wet cleaning and the
  fact that we would need a definition of professional wet cleaning before we could allow garments to be
  labeled for professional wet cleaning. I want to remind you that the Rule defines "drycleaning" very
  specifically - that is, as a commercial process by which soil is removed from products or specimens in a
  machine which uses any common organic solvent—for example, petroleum, perchloroethylene or
  fluorocarbon.  The process  may also include adding moisture to the solvent up to 75 degrees relative
  humidity, hot tumble drying up to 160 degrees Fahrenheit, and restoration by steam press or steam air
  finishing. (Now, some of you are going to be noting, by the way, that we are probably going to have to
  change that definition to delete fluorocarbon. We may also need to add some of the new solvents, like
  liquid carbon dioxide and Rynex, but that is in the future.)

         The purpose of the definition is to ensure that when a label says a garment can be drycleaned, the
  garment is able to withstand a clearly-defined process without damage. Because the process is defined,
  the manufacturer who labels a garment and the cleaner who cleans it are talking about the same process.
 A manufacturer who wishes to label a garment "dryclean" can subject sample garments to the defined
 process, and, if they survive the process without damage, the manufacturer will have a reasonable basis
 for labeling them "dryclean." The Rule also provides that the manufacturer must put a warning on the
 label if any part of the process must be modified, in order for the garment to be drycleaned without
 damage. For example, if the garment would be damaged by hot tumble drying at 160 degrees Fahrenheit
 but can withstand the drycleaning process with low heat, the garment can be labeled "dryclean, low heat."

        In order to include professional wet cleaning in the Rule we need a standardized definition for
 professional wet cleaning similar to what we have for drycleaning so that manufacturers will  know
 precisely what is meant by "professional wet cleaning" and will be able to determine if their garments can
 withstand that process without damage. The Rule requires that manufacturers have a "reasonable basis"
 for the care instruction they place on their garments.  If there is a standardized definition of professionally
 wet cleaning, a manufacturer could subject sample garments to that process, and, if they survive without
 damage, the manufacturer would have a reasonable basis for labeling them for professional wet cleaning.

        We also need a standardized definition so that garments that cannot withstand the process as
 defined but could withstand the process with certain modifications can be labeled for professional wet
 cleaning. That is, such garments could be labeled for professional wet cleaning with appropriate
 warnings about specifically how the professional wet cleaning process should be modified so that those
 garments can be professionally wet cleaned without damage.

        Let me show you the definition for professional wet cleaning contained in our notice of proposed

        Professional wet cleaning means a system of cleaning by means of equipment consisting of a
computer-controlled washer and dryer, wet cleaning software, and biodegradable chemicals specifically
formulated to safely wet clean wool, silk, rayon, and other natural and man-made fibers. The  washer uses
a frequency-controlled motor, which allows the computer to control precisely the degree of mechanical
action imposed on the garments by the wet cleaning process. The computer also controls time, fluid
levels, temperatures, extraction, chemical injection, drum rotation, and extraction parameters.  The dryer

incorporates a residual moisture (or humidity) control to prevent overdrying of delicate garments. The
wet cleaning chemicals are formulated from constituent chemicals on the EPA's public inventory of
approved .chemicals pursuant to the Toxic Substances Control Act.

       Now, please feel free to attack this definition and improve it. We just wanted to get the ball
rolling. We proposed defining it as a system of cleaning by means of specific equipment, as you can see.
And with the use of chemicals on EPA's public inventory of approved chemicals.

       Now, back to the requirement that a manufacturer have a "reasonable basis" for its care
instructions. A reasonable basis under the Rule may be tests showing that the garment can be cleaned as
directed on the label. It may be technical literature indicating that the garment can be cleaned as directed.
It may be past experience or industry expertise. But, of course, in the case of professional wet cleaning,
past experience is almost non-existent, so testing becomes more important. But there are currently no
standardized tests for professional wet cleaning. So what can a manufacturer do, given the definition that
we proposed here, to have a reasonable basis for a label that recommends professional wet cleaning? He
or she can have sample garments cleaned in equipment similar to that defined in the Rule. And if they
survive, that can constitute a reasonable basis for the label.

        If instead we have a very general definition of professional wet cleaning of the kind that has been
proposed - for example, "clean in water" - what could the garment manufacturer do to have a reasonable
basis for labeling  garments for professional wet cleaning? Let's say a manufacturer has made a wool suit
that would survive professional wet cleaning in the type of equipment we have described with no damage,
and he wants to label it for professional wet cleaning. But if professional wet cleaning simply means
"clean in water,"  he would have to have a reasonable basis for saying it could be cleaned in water by any
available method, including simply washing it in a home washing machine.  And most wool suits would
not survive washing in a home washing machine.  Therefore, under that definition, the suit could not be
labeled "professionally wet clean." If the goal is to allow garments that cannot be currently be labeled
for home washing - either by hand or by machine - to be labeled for cleaning in water, we need a precise
definition of the process by which those garments can be cleaned. And we need that precise definition for
two reasons. First, to make clear that the garments cannot be washed in a home washer or hand washed at
home. Second, we have to define the process clearly to make sure  that the manufacturer who labels the
garment for wet cleaning and the person who cleans the garment are talking about the same thing when
they say "professionally wet clean."

        Now, back to the new Commission notice of proposed rulemaking.  It proposes a very specific
definition for professional wet cleaning, and it says that if a "professionally wet clean" instruction is
included, it must state at least one type of equipment that can be used, unless all types of equipment can
be used. Again, I really encourage you to comment on these issues. We are just trying to get the ball
rolling. This may not be what is needed, but I want to stimulate some comment and ideas on that.

        The notice also proposes that, if a care label recommends professional wet cleaning, the fiber type
must be included on that care label. We proposed this because a number of comments we already
received indicate that fiber type is particularly important in professional wet cleaning, and currently fiber
type can be on a separate label that can be cut off. Thus, the proposed Rule requires that the permanent
care label have the fiber content if professional wet cleaning is recommended.

         You should also notice that while the proposed Rule allows professional wet cleaning to be
  recommended on the care label, it requires that another type of cleaning must also be recommended,
  either washing or drycleaning. Now, the reason for that is the limited availability of professional wet
  cleaning to consumers.  From the evidence we had on the record from the last round of comments, it
  appeared that there were large areas of the country in which there were no professional wet cleaners so
  that consumers in those areas would not really have that option.  But this notice seeks comment again
  with regard to how many wet cleaners there are and where they are. I certainly encourage you to give us
  that information.  If the number is growing by leaps and bounds and the option is available widely around
  the country, the requirement could probably be removed.

         Now I'd like to take just a few minutes to discuss a proposal that I have for gathering more data
  about garments that are damaged when cleaned. The goal is to establish a large database on the safety
  and effectiveness of the various cleaning methods for various types of textiles and garments, both new
  and old cleaning techniques. Thus far, there is only one such computerized database available and it is
 maintained by the International Fabricare Institute,  IFI.  They have been computerizing a portion of their
 data for more than ten years. It is an expensive process, and they don't computerize all the garments they

         But they have also always asserted that their data is just the tip of the iceberg, that is, of the total
 number of garments that are damaged in cleaning. So, what we are trying to do is get a view of more of
 the iceberg. Then that data would help manufacturers to label and to make a more rational decision about
 what care instructions to put on their garments. It could also help cleaners to become aware of what types
 of garments are particularly prone to certain problems. The data might also identify  problem cleaners and
 problem garments, and trade associations might use that data to identify cleaners  who may need or want
 more training.

        Let me just quickly talk about this plan for getting more data because I do hope we can talk about
 that later in our breakout workgroups.  One idea is to create a method for an electronic filing of
 complaints; and the FTC might be able to create an electronic form. A paper form could also be used but
 would probably take more time to process.

        Another issue involves where the should data be sent. Should the FTC be the only recipient?
 Should it be sent to a third party, such as the American Apparel Manufacturers Association, which could
 sort it and forward it to the manufacturers involved,  or should it be sent to a third  party for analysis, such
 as a university professor and/or students? There are advantages and disadvantages for each possible
 recipient. The FTC would use the data to investigate and bring cases, where appropriate. We could
 share it with EPA.  We could provide it to the experts, who are currently evaluating the effectiveness of
 cleaning methods.

       The American Apparel Manufacturers Association  (AAMA) could evaluate the data in terms of
the combinations of trim, fabric, et cetera, which have been damaged and pass that information along to
its members. The firms who have a high number of complaints  could use it to take corrective action.

       Now, another idea for getting more data is to help DPI, the Neighborhood Cleaners Association,
and also state associations. These entities may separately be gathering data and may be willing to
computerize all their data. We have the same issues  about where that gathered information should go and
the pros and cons of sending it to the various sources.

       A third possible source of data is the Better Business Bureaus, which get many
complaints—disputes between drycleaners and their customers. We could work with them to computerize
that data and add that to our source.

       Finally, we could help small claims courts, which also get a lot of these disputes, computerize
their data and we could add that to our source.

       I will stop there and we can, hopefully, discuss this further in the breakout sessions.

   Proposed  Rules
                                         Federal Register

                                         Vol. 63, No. 89

                                         Friday, May 8,  1998
  This section of the FEDERAL REGISTER
  contains notices to the public of the proposed
  Issuance of rules and regulations. The
  purpose of these notices is to give interested
  persons an opportunity to participate in the
  rule making prior to the adoption of the final

  16 CFR Part 423

  Trade Regulation Rule on Care
  Labeling of Textile Wearing Apparel
  and Certain Piece Goods

  AGENCY: Federal Trade Commission.
  ACTION: Notice of proposed rulemaking.

  SUMMARY: The Federal Trade
  Commission (the "Commission") is
  commencing a rulemaking to amend its
  Trade Regulation Rule on Care Labeling
  of Textile Wearing Apparel and Certain
  Piece Goods, 16 CFR Part 423 ("the Care
  Labeling Rule" or "the Rule"). The
  Commission proposes amending the
  Rule: (1) To require that an item that can
  be cleaned by home washing be labeled
  with instructions for home washing; (2)
  to allow that a garment that can be
  professionally wet cleaned be labeled
  with instructions for professional wet
  cleaning; (3) to clarify what can
 constitute a reasonable basis for care
 instructions; and (4) to change the
 definitions of cold, warm, and hot water
 in the Rule. The Commission is
 commencing this rulemaking because of
 the comments filed in response to its
 Advanced Notice of Proposed
 Rulemaking ("ANPR"), and other
 information discussed in this notice.
 The Commission invites interested
 parties to submit written data, views.
 and arguments. This notice includes a
 description of the procedures to be
 followed, an invitation to submit
 written comments, a list of questions
 and issues upon which the Commission
 particularly desires comments, and a
 description of a workshop conference
 that will be held to discuss the issues.
 The  Commission will announce the
 time and place of the public workshop
 after the close of the comment period.
 Any persons wishing to participate in
 the public workshop must file a
 comment in response to this notice and
 must indicate therein their interest in
 participating. The comments will be
available on the public record and on
the Commission's web site on the
   Internet ( so that
   interested parties can review them.
   After the conclusion of the workshop,
   the record will remain open for 30 days
   for additional or rebuttal comments. If
   necessary, the Commission will also
   hold hearings with cross-examination
:  and rebuttal submissions, as specified in
   Section 18(c) of the Federal Trade
   Commission Act, 15 U.S.C. 57a(c).
   Interested parties who wish to request
   such hearings should file a comment in
   response to this notice and indicate
   therein why they believe such hearings
  are necessary and how they would
  participate in such hearings.
  DATES: Written comments must be
•  submitted on or before July 27,1998.
  ADDRESSES: Written comments should
  be identified as "16 CFR Part 423—Care
  Labeling Rule—Comment," and sent to
  Secretary, Federal Trade Commission,
  Sixth and Pennsylvania Ave., N.W.,
  Washington B.C. 20580. To facilitate
  prompt and efficient review and
  dissemination of the comments to the
  public, all written comments should
  also be submitted, if possible, in
  electronic form, on either a 5V4 or a 3%
  inch computer disk, with a label on the
  disk stating the name of the commenter
  and the name and version of the word
  processing program used to create the
  document. Programs based on DOS are
  preferred. In order for files from' other
  operating systems to be accepted, they
  should be submitted in ASCII text
  Constance M. Vecellio or James Mills,
 Attorneys, Federal Trade Commission,
 Division of Enforcement, Bureau of
 Consumer Protection, Sixth St. and
 Pennsylvania Ave., N.W., S-4302,
 Washington, D.C. 20580, (202) 326-2966
 or (202) 326-3035.
 Part A—Introduction

   This notice is being published
 pursuant to Section 18 of the Federal
 Trade  Commission ("FTC") Act, 15
 U.S.C. 57a et seq., the provisions of Part
 1, Subpart B of the Commission's Rules
 of Practice, 16 CFR 1.7, and 5 U.S.C. 551
 et seq. This authority permits the
 Commission to promulgate, modify, and
 repeal trade regulation rules that define
 with specificity acts or practices that are
 unfair  or deceptive in or affecting
 commerce within the meaning of
  Section 5(a)(l) of the FTC Act, 15 U.S.C.
    The Care Labeling Rule was
  promulgated by the Commission on
  December 16, 1971, 36 FR 23883 (1971).
  In 1983, the Commission amended the
  Rule to clarify its requirements by
  identifying in greater detail the washing
  or dry cleaning information to be
  included on care labels. 48 FR 22733
  (1983). The Care Labeling Rule, as
  amended, requires manufacturers and
  importers of textile wearing apparel and
  certain piece goods to attach care labels
  to these items stating "what regular care
  is needed for the ordinary use of the
  product." (16 CFR 423.6(a) and (b)). The
  Rule also requires that the manufacturer
  or importer possess, prior to sale, a
  reasonable basis for the care
  instructions. (16 CFR 423.6(c)).
   As part of its continuing review of its
  trade regulation rules to determine their
  current effectiveness and impact, the
  Commission published a Federal
  Register notice ("FRN") on June 15,
  1994, 59 FR 30733. This FRN sought
  comment on the costs and benefits of
  the Rule, and related questions such as
  what changes in the Rule would
  increase the benefits of the Rule to
  purchasers and how those changes
 would affect the costs the Rule imposes
 on firms subject to its requirements. The
 comments in response to the 1994 FRN
 generally expressed continuing support
 for the Rule, stating that correct care
 instructions benefit consumers by
 extending the useful life of the garment,
 by helping the consumer maximize the
 appearance of the garment, and/or by
 allowing the consumer to take the ease
 and cost of care into consideration when
 making a purchase.
  Based on this review, the Commission
 determined to retain the Rule, but to
 seek additional comment on possible
 amendments to the Rule. The
 Commission published an ANPR on
 December 28, 1995, 60 FR 67102, which
 elicited 64 comments on the several
 possible amendments of the Rule
 described^herein.1 Based on the
  1 The comments were from: 41 consumers; one
consumer group; four academics; one clothing
retailer; one textile manufacturers association; one
apparel manufacturers association; one professional
cleaner; one professional cleaners association; one
wet cleaning equipment manufacturer; two
manufacturers of cleaning products; one cleaning
products manufacturers association; one
environmental protection group; one non-profit

                     Federal Register/Vol.  63, No. 89/Friday, May 8, 1998/Proposed Rules
comments and the evidence discussed
herein, the Commission proposes to
amend the Rule in the following ways.

Part B—Analysis of Proposed
1. Labeling for Home washing

a. Background and Discussion of
  The 1994 FRN noted that the
Environmental Protection Agency
("EPA") had heen working with the dry
cleaning industry to reduce the  public's
exposure to perchloroethylene ("PCE"
or "perc"), the most common dry
cleaning solvent,2 and asked whether
the Rule poses an impediment to this
goal. The Rule currently requires either
a washing instruction or a dry cleaning
instruction; it does not require both.
Thus, garments that can legally be
labeled with a "dry clean" instruction
alone also may in some cases be
washable, a fact not ascertainable from
such an instruction. The 1994 FRN
asked about the extent of care labeling
that fails to indicate both washing and
dry cleaning instructions. Finally, the
1994 FRN asked whether the use of dry
cleaning  solvents would be lessened,
and whether consumers and cleaners
could make more informed choices as to
cleaning  method, if the Rule were
amended to require both washing and
dry cleaning instructions for garments
cleanable by both methods. 59 FR
   In the 1995 ANPR, the Commission
analyzed the comments submitted in
response to the 1994 FRN and proposed
amending the Rule to ensure that
consumers are provided with
information that would allow them the
choice of washing garments when
possible. The Commission concluded
that lack of such information can result
 in substantial injury to consumers in the
 form of unnecessary expense and/or the
 inability to use what they regard as a
 more environmentally friendly method
 of care. 60 FR 67104-05.
  The ANPR asked for comment on an
amendment of the Rule to require a
home washing instruction for all
covered products for which home
washing is appropriate; providing dry
cleaning instructions for such washable
items would be optional. Manufacturers
marketing items with a "Dry Clean"
instruction alone would be required to
substantiate both that the items could be
safely dry cleaned and that home
washing would be inappropriate for
them (as the Rule currently requires
them to do when providing a "Dry
Clean Only" instruction). This proposal
would not result in the additional
substantiation testing (and increased
PCE use) that the comments suggested a
"dual disclosure" requirement could
necessitate, because a dry cleaning
instruction would be optional, as would
the necessary substantiation to support
it Id. at 67105. That is, manufacturers
labeling their goods for home washing
(and possessing the appropriate
substantiation for that instruction)
would not have to also provide a dry
clean instruction or have substantiation
that dry cleaning would harm the
   Fifty-three comments addressed
whether the Commission should require
a home washing instruction for items
that could be safely washed at home,
and only  three of those opposed the
   Eighteen commenters, including
individual consumers, academics, and
an appliance manufacturers' trade
association, contended that many
manufacturers currently label items that
can be both washed and dry cleaned
with a "dry clean" or "dry  clean only"
instruction."4 Many commenters
stressed that knowing that garments can
be washed at home would save them (or
consumers in general) garment care
dollars.5 Two consumers stated that
 clearinghouse for information on emissions control;
 one home appliance manufacturers trade
 association; one manufacturer of home appliances;
 one home applicance repairman; one international
 association for textile care labeling; one federal
 agency; and the Economic Union of European
 Countries. The comments are on the public record
 and are available for public inspection in
 accordance with the Freedom of Information Act, 5
 U.S.C. 552, and the Commission's Rules of Practice.
 16 CFR 4.11, at the Public Reference Room, Room
 130, Federal Trade Commission, 6th and
 Pennsylvania Avenue, Washington, D.C The
 comments are referred to in this Notice of Proposed
 Riilemaking ("NPR") by their name and the number
 assigned to each submitted comment.
   z Congress designated PCE as a hazardous air
 pollutant in Section 112 of the Clean Air Act; many
 state legislatures have followed suit under state air
 toxics regulations.
washing garments that are labeled "dry
clean" or "dry dean only" but that
appear washable (such as 100% cotton)
is risky because, if the garment is
ruined, the manufacturer will not stand
behind it.6 AHAM, a trade association
for appliance manufacturers, noted that:
the cost for testing a garment fabric sample
for proper care instructions is just a fraction
of the consumer expense experienced by
many thousands of individuals incurring
ongoing dry cleaning expenses for a garment
that could be washed at home.7
  Many commenters also noted that
consumers beh'eve there are
environmental benefits from home
washing rather than dry cleaning
washable items.8 Consumers Union
stated, "If only one method must appear
on the label, it has to be the least
expensive and the least hazardous to the
consumer and the environment."9
   Three commenters recommended that
both washing and dry cleaning
instructions be included if both are
appropriate.10 Two comments
specifically opposed this type of "dual
labeling," however, because.of the
increased levels of dry cleaning
substantiation tests that would follow.11
   Two commenters (one of which is an
association for apparel manufacturers)
argued that manufacturers (having made
the items) are best qualified to make the
decision as to how garments can best be
cleaned and urged the Commission to
leave apparel manufacturers the
   » Aqua Clean Systems, Inc. ("Aqua Clean") (34)
 pp. 8-9; Center for Emissions Control ("CEC") (44)
 pp. 5-6: American Apparel Manufacturers
 Association ("AAMA") (57) p.2.

   « Henry Gluckstem, Esq. (16) pp. 1-2; Bette Jo
 Dedic, University of Kentucky College of
 Agriculture Extension Service ("Univ. of KY") (20)
 p. l; Vera Rines (28) p. 1; Thelma Carpenter (30)
 p. 1; Katherine King (32) p. 1: Ida Carpenter (33)
 p. 1; Margie Helton (38) pp. 1-2; Jewell Brabson
 (40) p. 1; Susan DuBois (42) p. 1; UCLA Pollution
 Prevention Education and Research Center ("UCLA
 PPERC") (45) p. 3; Aileen Mills (47) p. 1;
 Association of Home Appliance Manufacturers
 ("AHAM") (51) p. 2.; Helen DuBois (52) p. 1; M.
 Adkins (54) p. 1; Teresa Mills (58) p. 1; Sarah
 O'Neal (59) p. 1: Frances McCarter (61) p.  1; Gladys
 Bebber (62) p. 1. But see Aqua Clean (34) p. 8: "As
 a general observation, garments which can be home
 laundered or drycleaned are usually labeled with
 both care instructions."
   s Univ. of KY (20) p. 1: Vera Rines (28) p. 1:
 Thelma Carpenter (30) p. 1; Katherine King (32) p.
 1; Ida Carpenter (33) p. 1; Carolyn Powers (35) p.
 1; Spencer and Diana Hart (36) p. 1: Margie Helton
 (38) pp. 1-2; Jewell Brabson (40) p. 1; Susan DuBois
 (42) p. 1; Aileen Mills (47) p. 1; Joyce Rash (48) p.
 1; S.K. Taylor (49) p. 1; Helen DuBois (52) p. 1; M.
 Adkins (54) p. 1; Teresa Mills (58) p. 1; Sarah
 O'Neal (59) p. 1: Frances McCarter (61) p. 1: Gladys
 Bebber (62) p. 1.
  « Dana Dodson (4) p. 1; Margaret Petty (37) p. 1.

  'AHAM (51) p. 2.
  "Linda Smith. Tenn. State Univ. Cooperative
 Extension Program (3) p. 1; John & Elizabeth Gray
 (15) p. 1: Univ. of KY (20) p. 2; Vera Rines (28) p.
 1; Thelma Carpenter (30) p. 1; Katherine King (32)
 p. 1: Ida Carpenter (33) p. 1: Margie Helton (38) pp.
 1-2; Jewell Brabson (40) p. 1: Susan DuBois (42) p.
 1; Consumers Union (46) p. 2; Aileen Mills (47) p.
 1; S.K. Taylor (49j-p. 1; Helen DuBois (52) p. 1; M.
 Adkins (54) p. 1; Teresa Mills (58) p. 1; Sarah
 O'Neal (59) p. 1: Frances McCarter (61) p. 1; Gladys
 Bebber (62) p. 1.
  o Consumers Union (46) p. 2.
  "International Fabricare Institute ("IFr') (56) p.
 2; Ginetex (the International Association for Textile
 Care Labeling) (63) p. 4; European Union (64) p. 3.
  "Univ. of KY (20) p. 2; Consumers Union (46)
 p. 2. See also the discussion of "dual disclosures"
  The Commission has learned from several
 commenters, primarily manufacturers, that
 requiring both washing and dry clean labels (a
 "dual disclosure" amendment) would require a dry
 cleaning instruction on virtually all washable items.
 According to these commenters, this would
 necessitate additional testing expenses for
 manufacturers and a resulting increase in PCE use,
 to the detriment of human health and the
 environment. (60 FR 67105', n. 30)^

                        Federal Register/Vol. 63, No. 89/Friday. May a. 1998 /Proposed  Rules
                                           were used and whether they will
                                           survive washing.
                                            Accordingly, the Commission
    eMJf***™""1™"™"'' ••••"•"••••Q ^^J "J*^"' •• ' f\t
    stated that there did not appear to be
    many instances of washable items being
    labeled "dry clean." "

    b. Proposed Amendments and Reasons

     Based on the comments, the
   Commission has reason to believe that
   "dry clean" labels on home-washable
   items ara prevalent and that consumers
   have a preference for being told when
   items that they are purchasing can be
   safely washed at home. Moreover, the
   information about washability may be
   important to consumers for economic or
   environmental reasons, or both. Some
   consumers wish to avoid the use of PCE
   and clean in water when possible
   because they believe it is better for the
flexibility to decide which care
instructions to use.12 A third commenter
in opposition to the proposal, a non-        "^^v»uxugxy, LUC v>uuuiiu>:>iun
profit clearinghouse for information on    proposes amending the Rule to require
emission control in chlorinated solvent    a home washing instruction for
applications, including dry cleaning,      garments for which home washing is
,»efnrl thnt t>t«re rliH nnt onnoa. *„ i«,      appropriate. This amendment would
                                       permit optional dry cleaning
                                       instructions for such washable items,
                                       provided dry cleaning would be an
                                       appropriate alternative cleaning
                                       method. The amendment would,
                                       however; require that manufacturers
                                       selling items with a "dry clean"
                                       instruction alone be able to substantiate
                                       both that the items could be safely dry
                                       cleaned and that home washing would
                                      be inappropriate for them.18
                                        As notea in the comments, the
                                      proposed amendment would enable
                                      consumers to make a more informed
                                      purchasing choice and provide them
                                      with the option of saving money by
                                      washing at home instead of incurring
                                      the higher expenses of dry cleaning. In
                                      addition, consumers who are concerned
                                      about reducing the use of PCE will have
                                      information about the "washability" of
                                      all apparel items they are considering
                                       The Commission agrees, as it did in
                                      the ANPR, with the commenters
                                      (primarily manufacturers) that
                                     cautioned against a "dual labeling"
                                     instruction requiring both home
                                     washing and dry cleaning instructions if
                                     both methods are appropriate. Such an
                                     instruction would result in some
                                     manufacturers of traditionally washable
                                     products performing dry cleaning tests
                                     to substantiate that dry cleaning was an
                                     appropriate care method, which would
                                     be contrary to EPA's goal of reducing
                                     the use of dry cleaning solvents.
                                     Moreover, the comments do not indicate
                                     a consumer preference  for such dual
                                     labeling. The Commission has no reason
                                     to believe at this time that it is either
                                     unfair or deceptive for a manufacturer
                                     or importer to fail to reveal that a
                                     garment labeled for washing can also be
                                     dry cleaned, and to require such dual
                                     labeling might raise costs without
                                    providing any real benefit to consumers.
                                      The proposed amendments would
                                   permit a home washing instruction only
                                   for those covered products for which
                                   home washing—and traditional home
                                   finishing processes such as ironing—
                                   would be an appropriate method of care.
                                   Many commenters cautioned that, for
                        aspect of the
  Rule is an impediment to EPA's goal of
  reducing the use of dry cleaning
    When a garment that can be washed
  •t home is labeled "dry clean," many
  consumers may be misled into believing
  that the garment cannot be washed at
  home, and they may incur the
  unnecessary expense of dry cleaning the
  garment and/or potential damage to the
  environment that they wish to avoid."
  Moreover, it can be extremely difficult
  for consumers to obtain the information
  about washability of an item for
  themselves. Although fiber content can
  be a guide to washability, other
  factors—such as the type of dye or
  finish used—can also determine
  washability, and consumers have no
  way of learning what dyes and finishes
   "Aqua dean (34) pp. 8-9; AAMA (57) p. 2.
 noting that "There an some garments with 'dry
 dun only' labtli that can be washed at bom*
 * *  '
 can lead to damage.
   "EPA's commant (73) to the 1994 FRN stated, at
 P. 1, that tie Rulo should bo parked to require
 manufacturers to state whether a garment "can be
 clianad by solvant-besed methods, water-based
 methods, or both. We believe this change is
 necessary to advance the use of water-baaed
 clwming technology." EPA's comment to the 1995
 FRN reftrrad to the 1994 comment, and stressed the
 need for recognition in the Rule of professional wet
 cleaning. EPA (17) p. i.
  "A Perdue University survey found that 89.3%
 of the 962 respondents indicated that they would
 not wash a garment labeled "dry clean." Staff
Report to the Federal Trade Commission and
Proposed Revised Trade Regulation Rule (IB CFR
Part «3) (May 1978). p. 141. Other surveys showed
similar results. Id. at 142-143.
                                     "The Rule currently requires this level of
                                   substantiation for a "dry cloan only" instruction.
                                   Under the proposed amendment, any garment for
                                   which home washing is not recommended and dry
                                   cleaning is recommended, would have to be labeled
                                   "dry clean only." In other words, a "dry clean"
                                   Instruction by itself would no longer be
    some items that could be washed in
    water, there would be many additional
    finishing steps required for the garment
    that the average consumer could not
    perform at home. In the case of some
    garments, such as suits made from wool
    or silk (fibers that generally can be
    safely washed in water), post-home
    washing finishing processes like
    steampressing and pleat and crease
    setting are necessary for proper
    refurbishing. These processes are
   beyond the capabilities of most
   consumers and the equipment available
   to them.17 Under the proposed
   amendments, a home washing
   instruction would not be appropriate or
   required for an item that could be safely

   cleaning agents but could not be
   finished properly at home by the
   average consumer. Moreover, the
   Commission recognizes that
   manufacturers, have experience with the
   consumers who buy their garments, and
   the Commission would expect to defer
   to manufacturers' decisions in the case
   of garments that would be difficult to
  refurbish for some but not all

  2. The "Professionally Wet Clean"

  a. Background and Discussion of
    The ANPR asked whether the Rule
  should he amended to recognize the
  new technology referred to as
  "professional wet cleaning" by
  requiring a professional wet cleaning
  instruction for products that cannot be
  washed at home but could be cleaned by
  means of this new technology.19
  (Professional wet cleaning uses
  computer-controlled washers and dryers
  to achieve precise control of mechanical
  action, fluid levels, temperatures, and
 other important factors.) The ANPR
 asked for information on the cost of wet
 cleaning, the availability of wet cleaning
 facilities, whether the process currently
 could serve as a practical alternative to
 dry cleaning, and whether fiber

   "See Aqua Clean (34) pp. 8-9.
   '•In addition, manufacturers that -wished to stress
 that a particular garment could be refurbished at
 home but might be difficult for some consumers to
 refurbish adequately at home could add a phrase
 such as 'Tor best results, dry clean."
  "In the narrative discussing this issue in the
 ANPR, the Commission sought information on the
 feasibility of a "professionally wet clean"
-———™»^ MB « £*ftMiAQ«oAwuaiiy w0i ClBou
instruction on "all covered products bearing a dry
cleaning instruction." 60 FR 67105. In the Request
for Comments Section of the Notice, however, the
Commission limited the applicability of the
question to "a garment that cannot be home
laundered but can be dry cleaned." 60 FR 67107.
Most of the commenters responded in the latter

Federal Register/Vol. 63, No. 89/Friday, May 8. 1998 /Proposed Rules
identification should be on a permanent
label. 60 FR 67105, 67107.
  Twenty-nine commenters addressed
the "professionally wet clean"
instruction.40 Only four opposed the
proposal to amend the Rule to require
a "professionally wet clean" instruction
for wet cleanable garments that cannot
be washed at home. The Soap and
Detergent Association and Procter &
Gamble contended that the term
"professionally wet clean" maybe
confused with a home washing
instruction by consumers.21 The Center
for Emissions Control contended that
wet cleaning is a new technology that is
neither well understood nor widely
available, and that a required wet
cleaning instruction now would
therefore be unreasonable and
counterproductive.22 SDA, P&G, and
CEC all recommended requiring some
version of a "professionally clean"
instruction that would encompass both
dry cleaning and professionally wet
cleaning.23 CEC also suggested that
eventually the Rule could provide for a
"professionally wet clean" instruction
that would be permitted, but not
required, when the manufacturer
thought professional wet cleaning
would be appropriate.24 AAMA opposed
any provision in the Rule for
professional wet cleaning on the ground
that it is too new and that there are too
few cleaners who can provide the
   (1) Defining Professional Wet
Cleaning.2* Six organizations provided
  zojoyce McCarter (14) p.l; John & Elizabeth Gray
 (15) p.l; Henry Gluckstern, Esq. (16) pp.1.3; EPA
 (17) p.l: Linda Arant (18) p.l: Vera Rines (28) p.l:
 Thelma Carpenter (30) p.l: Ida Carpenter (33) p.l;
 Aqua Clean (34) pp. 6-7; Margie Helton (38) p.l;
 Jewell Brabson (40) p.l; American Textile
 Manufacturers Institute ("ATMI") (41) p.3; Susan
 DuBois (42) p.l; The Soap and Detergent
 Association ("SDA'T (43) pp.1; 3: CEC (44) pp.l-
 2,5: UCLA PPERC (45) pp.2-3: Consumers Union
 (46) pp.1-2; Center for Neighborhood Technology
 (••COT") (55) pp.2.4; IFI (56) p.2.; AAMA (57) p.2;
 Teresa Mills (58) p.l; Sarah O'Neal (59) p.l; P&G
 (60) pp.2; 4; Frances McCarter (61) p.l: Gladys
 Bebber (62) p.l; Ginetex (63) p.3.
  *» SDA (43 pp.1,3; Procter & Gamble ("P&G") (60)
  »CEC (44) p.5.
  » SDA (43) pp.1.3; CEC (44) pp.1-1.5; P&G (60)
  "AAMA (57) p.2.
  "The ANPR noted that EPA had published a
 summary of an alternative cleaning process referred
 to as "Multiprocess Wet Cleaning." 60 FR 67103
 Pec. 28,1995). According to several commenters,
 "multiprocess wet cleaning" is a cleaning process
 that involves knowledgeable individuals hand-
 cleaning individual garments, often employing a
 "spot cleaning" technique rather than full
 immersion, and using water, heat, steam and
 natural soaps instead of perchloroethylene or
 petroleum solvents. Aqua Clean (34) pp.1-2, noting
 that "Professional wet cleaning has already
 supplanted multiprocess wet cleaning. Indeed.
                    information describing the wet cleaning
                    process.27 They defined "machine wet
                    cleaning" or "professional wet
                    cleaning" as an automatic, water-based
                    cleaning process that relies on the use
                    Of sophisticated, computer-controlled
                    washers and dryers in which the
                    washing and drying cycles, including
                    heat, moisture, and agitation, can be
                    precisely controlled according teethe
                    requirements of the various fiber, fabric,
                    and garment types.28
                      Three organizations provided
                    information about the equipment used
                    in professional we.t cleaning.29 UCLA
                    PPERC and GMT said that five
                    companies provide the equipment
                    systems necessary for professional wet
                    cleaning.30 Aqua Clean provided a
                    detailed description of the equipment
                    needed to provide professional wet
                    cleaning services:                 . .
                    All professional wet cleaning systems consist
                    of a computer-controlled washer and dryer,
                    wet cleaning software, and biodegradable
                    chemicals specifically formulated to safely
                    wet clean wool, silk, rayon, and other natural
                    and man-made fibers.. The washer always
                    uses a frequency-controlled motor, which
                    allows the computer to precisely control the
                    degree of mechanical action imposed on the
                    garments by the wet cleaning process. The
                    computer also controls time, fluid levels,
                    temperatures, extraction, chemical injection,
                    drum rotation and extraction parameters, etc.
                    The dryer always incorporates a residual
                    moisture (or humidity) control to prevent
                    overdrying of delicate garments. The wet
                    cleaning chemicals are formulated from
                    constituent chemicals which are on the
                    EPA's public inventory of approved
                    chemicals pursuant to the Toxic Substances
                    Control Act (TSCA).31
                       (2) As an Alternative to Dry Cleaning.
                    The ANPR asked two related questions
                    about the feasibility of wet cleaning as
                    a practical alternative to dry cleaning,
                    and the extent to which items that have
                    historically been dry cleaned could
                    successfully be professionally wet
                    cleaned. Five commenters responded
                    directly to the first  question. ATMI and
                    AAMA pointed out that, while the fibers
                    and dyes now in use will stand up to
                    the chemical solvents used in the dry
                    cleaning process, the textile industry
                    does not know if they will stand up to

                    those cleaners (Ecofranchising, NY: Cleaner Image,
                    CT) which initially used multiprocess wet cleaning
                    have converted to professional wet cleaning
                    because of the economic advantages." See also CEC
                     (44) p.4. Consequently, Multiprocess Wet Cleaning
                     is not addressed in the remainder of this Notice.
                       "Aqua Clean (34) pp.1-2; CEC (44) p.4; UCLA
                     PPERC (45) p.3; CNT (55) p.2; IFI (56) p.2; Ginetex
                     (63) p.3.
                       "AquaClean (34) pp.1-2; UCLA PPERC (45) p.3.
                       »Aqua Clean (34) pp.2-3: UCLA PPERC (45) p.3;
                     CNT (55) p.2.
                       3° UCLA PPERC (45) p.3; CNT (55) p.2.
                       31 Aqua Clean (34) pp.2-3.
professional wet cleaning.32 ATMI
predicted that:
If consumers just assume that they can use
the new cleaning method on their existing
wardrobe and current clothing purchases, we
would expect to see an increase in apparel
damage claims. This is because the fabrics
used in these clothing items have finishes
and formulations designed for dry cleaning.
We told EPA that the industry would need
a long phase-in time (2—3 years) to adjust
our dyes and finishes to work compatibly
with "wet clean" processes.33
  Ginetex, which is responsible for the
care labeling system used in European
countries, indicated its interest in the
wet cleaning technique, but said it is
waiting for a standardized test method
so manufacturers can test garments to
determine whether wet cleaning would
be a safe care method.34 IFI cautioned
that wet cleaning technology is new and
stated its determination to undertake
research into the process:
The use of machine wet cleaning is still in
the investigative or infant stage. The
technology originated in Europe and the most
extensive analysis of these systems has been
completed by two European research
groups—Hohenstein and FCRA. The
conclusion of these studies is that machine
wet cleaning is an adjunct to dry cleaning,
not a complete replacement The
Environmental Protection Agency, as a result
of its evaluation of wet cleaning under its
Design for the Environment Program,
concludes that machine wet cleaning is not
a complete replacement for drycleaning.
There is still much investigative work to be
done in this area. To that end, IFI has formed
a partnership with Greenpeace, other
industry groups, and other environmental
and labor groups to explore the possibilities
of wet cleaning—The Professional Wet
Cleaning Partnership.35
  Aqua Clean estimated that 90% of
garments can be safely and satisfactorily
cleaned by professional wet cleaning.
Aqua Clean stated that it has found no
significant wetcleanability versus
drycleanability differences applicable to
wool, silk, rayon, acetate, linen, etc.
with the exception of heavier wool
suits, which are made with  linings and
shoulder pads that dry at a rate different
from the wool, and thus require extra
time.36 CEC stated that estimates of the
percentage of garments labeled "dry
clean only" that can be successfully wet
  « ATMI (41) p.3; AAMA (57) p.2.

  "ATMI (41) p.3.

  « Ginetex (63) p.3.
  "IFI (56) p.2.
  38 Aqua Clean (34) p.4. Aqua Clean said that it has
corresponded with the International Wool
Secretariat (IWS), the research and marketing arm
of the wool industry, and anticipates cooperating
with the IWS's announced intention to develop
wool processing technologies at the mill level that
will make wool garments better suited to
professional wet cleaning, so they can be dried
faster at higher temperatures. Id. at 5.

                       Federal Register/Vol. 63, No. 89/Friday. May 8, 1998/Proposed Rules
   cleaned vary from 30% to 70%, with
   industry experts narrowing that spread
   to 30% to 50%.37 EFT contended that it
   js too early to estimate the percentage
   with any certainty, but stated that early
   indications are that the percentage of
   "dry clean" labeled garments that could
   be effectively machine wet cleaned
   could be anywhere from 25% to 75%.38
   CNT estimated, based on its own
   research and research conducted by
   Environment Canada, that from 30% to
   70% "of clothes generally cleaned in PCE
   could be safely cleaned using standard
   commercial or domestic laundering
    (3J Businesses that Provide Wet
   Cleaning. When it filed its comment in
  early 1996, Aqua Clean estimated that,
  by the end of 1996, approximately 350
  businesses would have-professional wet
  cleaning systems.40 Three other
  commenters estimated that professional
  wet cleaning is currently being offered
  by 100 businesses.'*1 CEC also estimated
  that it will be several years, even at best,
  before a substantial number of the
  nation's 30,000 cleaners have purchased
  professional wet cleaning technology.42
    (4) Costs to Consumers. ATMI said
  that the additional costs incurred by
  textile and apparel manufacturers to
  substantiate a wet cleaning instruction
  would be passed on to consumers.43
  Both UCLA PPERC and CNT stated that
  the costs to consumers for wet cleaning
  services are comparable to the costs of
  dry cleaning.44 CNT estimated that the
  range for wet cleaning a two-piece wool
  suit was from $4.50 to $9.00, and added
  that interviews with cleaners indicated
  that those who provided both types of
  cleaning were  providing them for
 approximately the same cost, and that in
 no case were charges for wet cleaning
 higher than for dry cleaning.4*
   Aqua Clean said that it was not aware
 of any cleaner  charging more for wet
 cleaning services than for dry cleaning
 services, and that in some cases the cost
 of wet cleaning is less, because many
 dry cleaners impose a surcharge
 (typically 50 cents) to cover the rising
 cost of disposing of hazardous dry
 cleaning waste.46
  "CEC (44) p.4.
  <> UCLA PPERC («) p.3; CNT (55) p.3; AAMA
(57) p.2.
  "ATM! (41) p.3.
  «•> UCLA PPERC (45) p.4; CNT (55) p.4.
  "CNT (55) p.4.
  •••Aqua Clean (34) p.5. Aqua Clean also raised an
IMUO that was nqt addressed in the ANPR—
consumer access to cleaning services:
  Many devilopers and owners of strip centers and
shopping centers, which is where most consumers
     (5) The Environmental Impact of the
   Process. Aqua Clean and CNT stated
   that none of the substances used in the
   process are prohibited by EPA; further,
   Aqua Clean said that the only materials
   released into the environment in
   connection with the process are
   chemicals that appear on EPA's public
   inventory of approved chemicals under
   the Toxic Substances Control Act.47 CEC
   suggested, however, that the primary
   environmental issue associated with the
   wet cleaning process is water
   consumption, because the process uses
   2.5 gallons of water to clean a pound of
   clothes. CEC pointed out that,  although
   this compares favorably to the 6 gallons
  per pound used by home clothes
  washers, the wet cleaning process uses
  more water than the dry cleaning
  process, which uses water primarily for
  cooling purposes, and typically recycles
  it-w UCLA PPERC stated that research
  suggests that wet cleaning is a safe
  alternative to dry cleaning.49
    The Commission notes that it has not
  made an independent assessment of the
  environmental desirability of'the
  various methods of cleaning textile
  wearing apparel. Rather, it has  noted
  EPA's goal of reducing the use of dry
  cleaning solvents and the preference of
  numerous consumers for information
  about whether garments can be cleaned
  in water. The Commission has-prepared
  a proposed Environmental Assessment
  in which it analyzed whether the
  amendments to the Rule were required
 to be accompanied by an Environmental
 Impact Statement. Because the main
 effect of the proposed amendments is to
 provide consumers with additional
 information rather than directly to affect
 the environment, the Commission
 concluded in the proposed
 Environmental Assessment that an
 Environmental Impact Statement is not
 necessary. The Commission requests
 comment on this issue. The
 Environmental Assessment is on the
 access cleaning services, are refusing to rent space
 to or renew leases for drycleaners. These landlords
 simply do not want to bear the legal exposure or
 insurance expense associated with drycleaning
 machines and their toxic waste stream. Aqua Clean
 Systems is currently negotiating with a major
 national shopping center owner to become their
 exclusive tenant for 100% pare-free cleaning
 facilities. At present, they refuse to allow a
 drycleaner in any of their 1.800 shopping centers.
 Similar discussions are taking place with a major
 chain in the Southeast. This trend will continue. If
 the Rule is not amended to accommodate
 professional wet cleaning, access to cleaning
 services will decline as regulatory and landlord
pressures cause a decline in the number of
drycleaners, which will eventually reduce
competition* and cause an increase in consumer
prices. Id., pp. 9-10.
  •"Aqua Clean (34) p.3: CNT (55) p.3.
  «CEC (44) p.3.
  "UCLA PPERC (45) p.4.
   public record and is available for public
   inspection at the Public Reference
   Room, Room 130, Federal Trade
   Commission, 6th and Pennsylvania
   Avenue, Washington, D.C. It can also be
   obtained at the FTC's web site at http:/
   / on the Internet.
     (6) The Requirement for Fiber
   Identification on a Permanent Label.
   Eight comments addressed the
   desirability of a requirement for fiber
   identification on a permanent label, and
   all favored the idea.50 Five
   recommended that the fiber
   identification be on the same label as
   the care instructions.51 Several
   commenters said that fiber information
   need'not necessarily be on the care label
  but should be on a permanent label.52
  Most of the commenters said that
  cleaners need fiber identification
  information in order to provide the best
  cleaning services for their customers.
  Aqua Clean explained as follows:
  [Fjabric identification [should] be on a
  permanent label because it is essential
  information for all cleaners regardless of the
  technology employed; requiring this by
  regulation will merely codify a nearly
  uniform practice at no measurable cost to
  manufacturers. A secondary consideration is
  that individuals with allergies to certain
  fibers (e.g., wool) should be provided with
  this information. It is clear that requiring
  fiber identification on a permanent label
  should be acceptable to manufacturers and
  consumers because it has already become an
  accepted part of business at all-levels of
  manufacture, distribution, sales, and garment
   b. Proposed Amendment and Reasons
 Therefor. The comments show that
 professional wet cleaning is a process
 that is of interest to consumers;
 especially those who believe it has the
 potential for less negative impact on the
 environment than dry cleaning. Thus,
 the Commission is proposing
 amendments that will incorporate
 professional wet cleaning into the Rule's
 system of instructions for care.
   Nevertheless, professional wet
 cleaning is a very new technology, and
 it does, not appear to be widely
 available. Moreover, there is not a
 standardized test by which
 manufacturers can establish a
 reasonable basis for a professional wet

  "Univ. of KY (20) p. 1; Aqua Clean (34) p. 7;
 ATMI (41) p. 4; CEC (44) p. 2; UCLA PPERC (45)
 p. 3; Consumers Union (46) p. 2; AHAM (51) p. 2;
 P&G (60) p. 4.
  "CEC (44) p. 2; UCLA PPERC 945) p. 3;
Consumers Union (46) p. 2; AHAM (51) p. 2: P4G
(60) p. 4.
 "Univ. of KY (20) p. 1; Aqua Clean (34) p. 7.
 53 Aqua Clean (34) p. 7.

Federal Register/Vol. 63, No. 89/Friday,  May 8, 1998/Proposed Rules
cleaning instruction.54 For these
reasons, the Commission is not at this
time proposing an amendment to the
Rule that would require a wet cleaning
instruction. Instead, the Commission is
proposing amendments that would add
a definition to the Rule for "professional
wet cleaning" and would permit
manufacturers to include a
"professionally wet clean" instruction
on labels for those items for which they
have a reasonable basis for a
professional wet cleaning instruction.
The proposed amendments do not
require manufacturers who label items
with a "dry clean only" instruction to
be able to substantiate that professional
wet cleaning would be an inappropriate
method of care.
  The Commission also concludes that
fiber identification on a permanent label
is important to professional wet
cleaners.?5 The record contains
numerous references to the need for
precise fiber content information due to
the complexity of the computer-
controlled equipment used in the wet
cleaning process. Therefore, the
proposed amendment requires that, if a
care instruction recommends
professional wet cleaning, the fiber
content must be provided on the
permanent care label  along with the care
instructions. The Commission seeks
comment as to whether any
accompanying change should be made
to the Textile Rules.56
  Finally, it should be noted that at this
time, the Commission proposes
allowing a "professional wet clean"
instruction along with a conventional
care instruction because many
consumers do not currently have access
to professional wet cleaners.
Nevertheless, because professional wet
cleaning appears to be growing rapidly,
the Commission seeks comment on this
                   3. The Reasonable Basis Requirement of
                   a. Background and Discussion of
                      The Rule requires that manufacturers
                   and importers of textile wearing apparel
                   possess, prior to sale, a reasonable basis
                   for the care instructions they provide.
                   Under the Rule, a reasonable basis must
                   consist of reliable evidence supporting
                   the instructions on the label. 16 CFR
                   423.6(c). Specifically, a reasonable basis
                   can consist of (1) reliable evidence that
                   the product was not harmed when
                   cleaned reasonably often according to
                   the instructions; (2) reliable evidence
                   that the product or a fair sample of the  .
                   product was harmed when cleaned by
                   methods warned against on the label; (3)
                   reliable evidence, like that described in
                   (1) or (2), for each component part; (4)
                   reliable.evidence that die product or a
                   fair sample of the product  was
                   successfully tested; (5) reliable evidence
                   of current technical literature, past
                   experience, or the industry expertise
                   supporting the care •information on the
                   label; or (6) other reliable evidence. Id.
                      The 1994 FRN solicited  comment on.
                   whether the Commission should amend
                   the Rule to conform with the
                   interpretation of "reasonable basis"
                   described in the FTC Policy Statement
  54 Testing is one of several types of evidence that
 can serve as a reasonable basis for a care
  55 The Textile Fiber Products Identification Act
 ("Textile Act"). 15 U.S.C. 70 etseq., requires
 marketers of covered textile products to mark each
 product with the generic names and percentages by
 weight of the constituent fibers present in the
 product. The Commission has issued Rules and
 Regulations under the Textile Act ("Textile Rules").
 Rule 15 of the Textile Rules, 15 CFR 303.15, allows
 any type of label to be used as long as the label is
 securely affixed and durable enough to remain
 attached to the product until the consumer receives
 it; Rule 15 does not require a permanent label.
  '•Rule 16 of the Textile Rules, 16 CFR 303.16.
 requires, with some exceptions, that all information
 required by the Textile Act shall be set out on one
 label, and on the same side of the label. The
 Commission recently sought comment on
 modifications of the Textile Rules. 61 FR 5344 (Feb.
                    F.T.C. 839 (1984), or to change the
                    definition of "reasonable basis" in some
                    other manner. The comments in
                    response to the 1994 FRN suggested that
                    a significant number of care labels lack
                    a reasonable basis. Based on these
                    comments, the ANPR proposed
                    amending the reasonable basis
                    requirement to reduce the incidence of
                    inaccurate and incomplete labels. The
                    ANPR sought comment on that
                    incidence, the extent to which it might
                    be reduced by clarifying the reasonable
                    basis standard, and the costs and
                    benefits of such a clarification.
                      The Commission further solicited
                    comment on whether to amend the Rule
                    to clarify that the reasonable basis
                    requirement applies to a garment in its
                    entirety rather than to each of its
                    individual components. In addition, the
                    Commission asked for comment on
                    whether the Rule should specify
                    standards for determining acceptable
                    and unacceptable changes in garments
                    following cleaning as directed, and
                    whether the Rule should identify
                    properties, such as colorfastness and
                    dimensional  stability, to which such
                    standards would apply.
                      The ANPR sought comment on  the
                    option of indicating in the Rule that
                    whether one  or more of the types  of
evidence described in Section 423.6(c)
constitutes a reasonable basis for care
labeling instructions depends on the
factors set forth in the Advertising
Policy Statement and whether the Rule
should be amended to make testing of
garments'the only evidence that could
serve as a reasonable basis under certain
circumstances. Finally, the ANPR
sought comment on whether the Rule
should specify particular testing
methodologies to be used. Ten •
commenters responding to the ANPR
discussed the reasonable basis
provision.57 Seven supported the
modification of the Rule, arguing that
the provision should be clarified and
strengthened to reduce mislabeling.58
Two maintained that the reasonable
basis provision should not be amended,
because the proposed changes would
likely increase the cost to consumers
and apparel firms without materially
increasing the benefits to consumers.59
  Only two commenters provided data
on the incidence of mislabeling. Both
concluded that there is a high'incidence
of inaccurate and/or incomplete
labeling. IFI cited statistics from its
Garment Analysis database (which, in
1995, consisted of 25,160 damaged
garments) indicating that inaccurate
care labels were responsible for 40% of
the damaged garments. *° Clorox
concluded from its own study that 70%
of all home washing instructions
provide inaccurate bleach
  ATMI, however, stated that most
home washing labels are accurate, and
that the vast majority of dry clean
instruction labels are accurate, despite
limited problems associated with care
instructions for special items such as
beaded apparel, sequins, and leather
appliques.6? ATMI and AAMA both
  " Univ. of KY (20) p.2; Clorox (31) pp. 4-5; ATMI
(41) pp. 5—7: SDA (43) pp. 1.3; Consumers Union
(46) pp. 2-3; AHAM (51) p.2; IFI (56) p. 3; AAMA
(57) p. 2; P&G (60) p. 5: Ginetex (63) p.4.
  " Univ. of KY (20) p. 2: Clorox (31) pp. 4-5; SDA
(43) pp. 1.3; Consumers Union (46) pp. 2—3; AHAM
(51) p. 2; IFI (56) p. 3; P&G (60) p. 5.
  " AAMA (57) p. 2; ATMI (41) pp. 5-7. Ginetex,
the European care labeling organization, stated that
it gives technical advice "to give indications how
to test in the case of uncertainty to choose the
correct care label." Ginetex (63) p. 4.
  "in (56) p.3.
  •» Clorox (31) p.2.
  •2 ATMI (41) p.5. See also AA\iA (57) p.3 ("There
are a few problems with leather patches and some
other materials attached to garments.") The
Commission has litigated one case involving
inaccurate care instructions that resulted in damage
to garments. FTC v. Bonnie &• Company Fashions.
Inc. and Bonnie Boerer. Civ. Action No. 90-4454)
(D.N.J.). In addition, since that litigation, the
Commission has obtained five settlements that
alleged violation of the Rule due to inaccurate care
instructions; in three of those five settlements, the
Commission alleged that the trim on the garments
was damaged when cleaned.

                       Federal Register/Vol.  63.  No. 89/Friday. May 8, 1998/Proposed Rules
   stated that the costs to consumers of
   complaining to manufacturers or
   retailers about garments damaged in
   cleaning is minimal, usually consisting
   of returning that item to the store, a
   telephone call, or postage for mailing a
   letter.03 Moreover, according to both
   commenters, garment or piece goods
   manufacturers generally offer refunds
   for products damaged in cleaning
   despite adherence to care label
   directions if numerous consumers
   complain about an item.84
    Several commenters specifically
   addressed whether the Rule should
   require testing as a reasonable basis in
   certain situations. Two commenters
  argued that testing should be the only
  permissible reasonable basis.03 Clorox
  stated that tests performed on a
  representative sample of each garment
  are "the most reliable evidence of care
  instruction accuracy," and that
  textbooks and manuals should not be
  allowed as evidence of a reasonable
  basis,68 Clorox maintained that such a
  requirement would place little
  additional expense on manufacturers
  because "published tests on specific •
  fabric and dye combinations are already
  shared among the trade."07
   Two commenters, ATM! and AAMA,
  however, opposed such an amendment
  to the Rule.68 ATMI expressed its
  concern that a testing requirement
  would substantially increase the prices
  for apparel and home furnishing
  items.00 AAMA noted that its members
  already test new styles and fabrics for
 use in garments; thus, it is unaware of
 any garments which "would  need a
 legal requirement to be tested."70
   A number of commenters discussed
 whether the rule should specify testing
 methodologies to be used. Consumers
 Union asserted that the Rule should
 specify test methods that relate to
 consumer expectations, assessing
 "product performance after repeated
 cleaning, shrinkage, colorfastness,
 appearance retention, and at least one
 fabric strength test."71 In contrast,
 AAMA contended that requiring
  •» ATMI (41) p.7; AAMA (57) pA. But see Univ.
of KY (20) p.2 (consumers may not complain to
(tons bocausa they are intimidated or do not thin
their problem* will be resolved).
  "ATMI (41) p.7 (noting that if only one
couumar complains about an item "of which
thousand! vote produced. It is likely that the
damage was caused by a commercial cleaner or by
tbt consumer"); AAMA (57) p.4.
  «IF1 (56) p. 3: Clorox (31) pp. 4-5.
  "Clorox (31) p. 4.
  ««ATMt (41) p. 5: AAMA. (57) p. 3.
  ••ATM! (41) p. 7.
  "AAMA (57) p. 3.
  " Consumers Union (46) p. 2.
   specific test methods may impede the
   introduction of new fibers and fabrics.72
     Several commenters responded to the
   Commission's questions relating to
   whether the Rule should require a
   reasonable basis for a whole garment
   versus each component. Three
   commenters maintained that the Rule
   should require a reasonable basis for a
   garment in its entirety.73 IFI noted that
   its database shows that "a large portion
   of the garments damaged are the result
   of the trim or component part of the •
   garment failing in a specified care
   procedure."7* Consumers Union also
   argued that "to state an instruction that
   excludes its applicability to garment
   trim is not often practical as some trim
   are hard to remove and reposition after
    Two commenters stated that the Rule
  should not require testing on a complete
  garment70 AAMA asserted that many
  garments are made of just one major
  fabric. Accordingly, there may not be a
  need to test an entire garment, as
  opposed to the materials used, if the
  other materials used in the garment are
  of the same fiber and basic
  construction.77 Moreover, AAMA
  argued that it is sufficient for
  manufacturers to specify in care
  instructions that a specific trim is
  excluded, because consumers are
  thereby warned that care must be taken
  when refurbishing the garment.78 ATM!
  stated that testing of completed
  garments would significantly raise the
  cost of manufacturing apparel, but noted
  that trim should be covered by the Rule,
  and that manufacturers should be
  responsible for selecting and combining
  component materials that can be
  refurbished together.78
   Many commenters responded to the
 Commission's request for comments on
 whether the Rule should refer to
 performance standards, concluding that
 it may not be feasible for the Rule to do
 so. Consumers Union, for example,
 noted that because fabrics and apparel
 items are continually offered and
 discontinued, it may not be possible for
 the Commission to set performance
 standards in a timely fashion to cover
 all properties and types of garments.8°
   AAMA asserted that although there is
   "reason to look at minimum
   performance standards, including
   colorfastness, abrasion resistance, etc.,"
   the Commission should not modify the
   reasonable basis requirement until the
   United States, Mexico and Canada have
   harmonized their labeling standards.81
     Finally, two commenters stated that
   the Commission would improve the
   effectiveness of the Rule by
   incorporating the criteria from the
   Advertising Policy Statement.82

   b. Proposed Amendments and Reasons
    Section 423.6(c)(3) of the Rule
  currently states that a manufacturer or
  importer establishes a reasonable basis
  for care information by "possessing
  prior to sale: [r]eliable evidence *  » *
  for each component part of the
  product" Based on its review of the
  comments, the Commission proposes to
  amend the reasonable basis standard to
  make dear that the reasonable basis
  requirement applies to the garment in
  its entirety rather than to each of its
  individual components. The
  Commission believes that the record
  establishes that in some cases care
  instructions may not be accurate for the
  entire, garment A garment component
  that may be cleaned satisfactorily by
  itself might, for example, bleed onto the
  body of a garment of which it is a part
  Thus, in the proposed Rule, Section
  423.6(c)(3) has been amended to clarify
  that a manufacturer must possess a
  reasonable basis for the garment as a
  whole, including any trim.83 Proposed
  Section 423.6(c)(3) provides that
  "Reliable evidence * *  * for each
  component part of the product, in
  conjunction with reliable evidence for
 the garment as a whole" can constitute
 a reasonable basis for care instructions.
 The proposed Rule does not require
 testing of the entire garment if there is
 an adequate reasonable basis for the
 garment as a whole without such
 testing; the proposed change would
 clarify, however, that testing of separate
 components is not necessarily sufficient
 if problems are likely to occur when the
 components are combined.84
  »AAMA (57) p. 3.
  "Univ. of KY (20) p. 2rConsumers Union (16)
  "IFI (56) p. 3.
  "Consumers Union (46) p. 3.
  "AAMA (57) p. 4; ATMI (41) pp. 5-«.
  "AAMA (57) p. 4.
  "ATMI (41) p. 6.
  ""Consumers Union (46) p. 2 (suggesting that the
FTC implement • rule that requires manufacturers,
retailers, and importers to issue refunds for
products damaged in cleaning despite adherence to
the label).
  "AAMA (57) p. 2.
  « SDA (43) p. 3; P&G (60) p. 5 (also suggesting
that the Commission consider methods of
certification and other tools such as U.S. Customs
requirements to reduce the number of mislabeled
imported goods, especially those labeled "Dry
Clean Only.")                      *
  "The Commission notes that an instruction to
clean "exclusive of trim" is only a valid care
instruction if the trim can be easily removed and
easily reattached.
  "For example, red trim that is to be placed on
white fabric should be evaluated to determine if it

Federal Register/VoL  63, No. 89/Friday, May 8,  1998/Proposed Rules
  The Commission, however, believes
that the comments do not provide
sufficient reason to propose modifying
other aspects of the reasonable basis
provision at this time. As noted by the
AAMA, the United States, Mexico, and
Canada are in the process of
harmonizing their labeling
requirements. Until this harmonization
is complete, the Commission believes
that further modification of the
reasonable basis provision may be
4. Definitions of Water Temperatures

a. Background and Discussion of
  The Rule currently requires that a care
label that recommends washing must
also state a water .temperature that may
be used unless "the regular use of hot
water will not harm the product." 16
CFR 423.6{b)(l)(i). The Rule also
provides that if the term "machine
wash" is used with no temperature
indication, "hot water up to 150 degrees
F (66  degrees C) can regularly be used."
16 CFR 423.1(d). This definition is
repeated in Appendix l.a. "Warm" is
defined in Appendix l.b. as ranging
from 90 to 110 degrees F (32 to 43
degrees C), and "cold," in Appendix
I.e., as cold tap water up to 85 degrees
F (29  degrees C).
  Some comments to the 1994 FRN
recommended that the Commission
revise the definition of cold water.
Commenters noted that tap water
temperatures vary across the United
States, and that such differences can
cause problems because, in the winter
in colder parts of the country, detergents
may not fully activate during a cold
wash cycle. Other comments suggested
that the Rule's definition of hot water
should be changed. The American
Association of Textile Chemists and
Colorists ("AATCC") commented that
the temperatures stated in the Appendix
should be changed to match the AATCC
definitions, which the AATCC believes
"more accurately reflect current
washing machine settings and consumer
practice." ** The AATCC defines "hot"
as 120 degrees F phis or minus 5
degrees (49 degrees C plus or minus 3
  The ANFR sought comment on
whether the Commission should amend
the Rule to change the definitions of
"warm" and "hot" water, or to include
                   a new term such as "cool" or
                   "lukewarm" in the Appendix. The
                   Commission further sought comment on
                   whether the Rule should be amended to
                   state that care labels recommending
                   "cold" wash must define the highest
                   acceptable temperature for "cold" on
                   the label, and on the benefits and costs
                   to consumers and manufacturers of such
                   an amendment.
                    All eleven comments received hi
                   response to the ANPR that discussed the
                   definitions of cold, warm, and hot water
                   favored some change.86 ATM! stated
                   that it is very important that the Rule's
                   water temperature definitions be
                   consistent with those used in standard
                   test methods developed by AATCC
                   because those test methods are used by
                   the textile and apparel industries.87 Six
                   of the commenters also supported the
                   idea of including a numerical
                   temperature on the care label.88
                   Consumers Union, for example, stated
                   that consumers need to know the actual
                   range of water temperature in which
                   they can safely wash their .clothes.
                    Words such as lukewarm, cold, warm or
                   hot serve their purposes only if the
                   consumers are aware of safe water
                   temperature ranges. Testing laboratories have
                   assigned temperature ranges onto each of
                   these words. They use these "safe
                   temperature ranges" to test products for
                   durability to repeated cleaning. Consumers
                   should know what these safe water
                   temperature ranges are.19
                    (1) Definition of cold water. As noted,
                   six commenters favored the inclusion of
                   a numerical temperature on the care
                   label. Two others favored a numerical
                   temperature when the label
                   recommends a "cold" wash. SDA noted
                   that hi northern locations in winter,
                   cold water washes can be as cold as 40
                   degrees F and that "the performance of
                   all laundry products is seriously
                   diminished if they are used in water
                   temperatures below 60 degrees F."90
                   SDA suggested the following care
                   instruction, in lieu of "cold":
                    Wash in the warmest available water, not
                   to exceed (approximate temperature) degrees
is likely to bleed onto the surrounding fabric. A
company may possess reliable evidence—for
example, past experience with particular dyes and
fabrics—that a particular red trim does not bleed
onto surrounding fabric. In such a case testing of
the entire garment might not be necessary.
  "Comment 34 to 1994 FRN. p. 1.
                    "Bruce Fifield (22); ATMI (41); SDA (43);
                   Consumers Union (46); AHAM (51); Maytag
                   Appliances ("Maytag") (S3); IFI (56); AAMA (57);
                   P&G (60); Ginetex (63); European Commission (64).
                    •'ATM! (41) p.l.
                    •»Fifield (22) p.l; Consumers Union (46) p.l.;
                   AHAM (51) p.l; AAMA (57) p.l: European
                   Commission (64) p.2; Ginetex (63) p.2. In a meeting
                   with staff on August 7.1996, AHAM indicated that
                   it no longer favors this.

                    "Consumers Union (46) p.l.

                    *>SDA (43) p.2. P&G (60) stated, at p.3. that "all
                   detergency and cleaning performance decreases
                   substantially in cold water below 70 degrees F."
  Maytag suggested that a range of 65 to
80 degrees F should be stated on the
care label because
consumers are not aware that water can be
too cold to activate detergents, thus they
experience poor cleaning and other laundry
problems. By incorporating a temperature
range consumers would know exactly what
temperatures will provide good results."
  P&G said that a national consumer
study it had conducted showed that
78% of "cold" loads washed in January
and February were in temperatures
below 65 degrees F (with some as low
as 34 degrees F), and that, year round,
50% of "cold" loads were washed hi
temperatures below 65 degrees F.92
  ATMI suggested that "cold" be
defined consistently with the definition
specified in AATCC test methods [27
degrees C plus or minus 3 degrees, or 82
degrees F plus or minus 5 degrees] and
with standards developed by the
American Society for Testing and
Materials ("ASTM") [30 degrees C, or 86
degrees FJ.«
  (2) Definition of warm water. Section
l.b of the Appendix to the Rule defines
warm water as 90 to 110 degrees F (32
to 42 degrees C). Several commenters
recommended maintaining this
definition, but adding the term
"lukewarm," defined as 70 to 89 F (21
to 31 C).94 Other commenters opposed
"lukewarm," stating that it would be
confusing to consumers because
washing machine dials only offer the
choices of cold, warm, and hot.95 ATMI
suggested a definition of 40 degrees C
plus or minus 5 degrees (104 degrees F
plus or minus 9 degrees), which it
described as consistent with the
definition established by AATCC for use
in garment testing [41 degrees C plus or
minus 3 degrees, or 106 degrees F plus
or minus 5 degrees] and by ASTM in its
standards [40 degrees C or 104 F].
  (3) Definition of hot water.
  Maytag stated that "the current
definition of&ot water as up to 150
degrees is unrealistic due to scald laws
in some states" and because new water
heaters are preset at 120 degrees F.96
P&G also noted that hot water heaters
are now usually preset at 120 F, "much
less than the 140 degrees F of older
models."97 SDA estimated that "20% of
today's homes have hot water heaters
set at 120-125 F." w Maytag favored
  "Maytag(53) p.2.
  "P&G (60) p.3.
  "ATMI (41) p.2.
                      Federal Register/Vol. 63, No. 89/Friday,  May 8, 1998/Proposed Rules
   defining hot as 120 to 140 degrees F,
   ?nd SDA and P&G favored defining hot
   as ill to 140 F. ATMI recommended 50
   degrees C plus or minus 5 degrees C,
   which it described as consistent with
   'definitions used by AATCC [49 degrees
   C plus or minus 3 degrees C, or 120 F
   «lus or minus 5 degrees FJ and ASTM
     Several commenters argued for the
   addition of "very hot" »°o P&G noted
   that some American consumers will be
   able to achieve the higher temperatures
   "as new washing machines from Europe
  with onboard heaters enter the U.S."101
  JFI noted that professional laundries can
  achieve the higher temperatures, and
  that the higher temperatures are
  necessary to clean certain types of
  clothes, such as men's dress shirts.102

  b. Proposed Amendments and Reasons
   The Commission believes that the
  definition of cold, warm, and hot water
  should be changed because of changes
  in settings on hot water heaters and in
  consumer washing practices in the years
  since the definitions were established.
  The AATCC has changed its definitions,
  which are used in textile testing, to take
  account of these factors, and AATCC
  test methods are used by much of the
  apparel industry. Consequently, the
  Commission believes that the
  definitions in the Rule should be
 changed to be consistent with the
 definitions used by AATCC The
 Commission proposes changing the
 upper range of temperature definitions
 in the Rule to the upper range of what
 is allowed in tests published by AATCC.
 Thus, the upper range for "cold" would
 be 30 degrees C (86 degrees F); for
 "warm," 44 degrees C {111 degrees F);
 and for hot, 52 degrees C (125 degrees
   Finally, the Commission proposes
 adding the term "very hot" to the rule,
 defined consistently with the AATCC
 definition,* i.e., with an upper range of
 63 degrees C (145 degrees F). The
 comments indicate that some garments
 do need to be cleaned at temperatures
 higher than 125 degrees F, and that
 some consumers have access to water
 hotter than 125 degrees F, either at
 home or through laundering by
 professional cleaners. The addition of
 the term "very hot," together with
 appropriate consumer education, should
give notice to those consumers whose
hottest water is 120 degrees F that they
may have to have garments that should
  be cleaned in very hot water
  professionally laundered. The
  Commission is aware, however, that the
  term "very hot" may be confusing to
  some consumers because most washing
  machine dials only offer the choices of
  "cold," "warm," and "hot." The
  Commission requests comment on this
  issue, and, in particular, on suggestions
  for methods of consumer education to
  alleviate this problem.
    In addition, some comments indicate
  that consumers need more precise
  information in order to select the
  appropriate temperature setting on their
  washing machines. Consumers may be
  using water that is too cold to activate
  detergents. Similarly, the  addition of a
  precise temperature (52 degrees C, 125
  degrees F) after the word "hot" on the
  care label of a garment might give those
  consumers some notice that their hot
  water may be too hot for that garment.I03
  An upper range for "warm" might also
  be helpful to consumers because, on
  many machines the dial setting for
  warm simply produces a mixture of hot
  and cold, and if the incoming tap water
  is very cold, the water in the machine
  may be too cold to produce optimal
  cleaning of the clothes being washed.
    The Commission does not believe,
  however, that the solution to these
  problems at this time is to require
  numerical temperatures on care labels.
  Such additional information may not be
  cost-effective because most American
  consumers do not know the temperature
 of the tap water entering their homes or
 the cold or warm water in their washing
 machines. Indeed, some may also lack
 precise information about the
 temperature of the hot water heated by
 their water heaters, and, even those who
 know the upper limit of their hot water
 may not know the temperature of the
 hot water that enters their washing
 machines given the heat loss that occurs
 as water is piped to washing machines.
  Therefore, at this time the
 Commission is not proposing to modify
 the Rule to require that precise
 temperatures be listed on care labels.
 The Commission is interested, however,
 in non-regulatory solutions to this
 problem. Accordingly, this notice asks
 questions about the possibility of a
 consumer education campaign on these
 issues. The Commission solicits
 comment on the feasibility of such a
 consumer education campaign, the form
   it should take, and industry members
   and consumer groups that would be
   interested in participating. Moreover,
   should the comments provide
   additional information about how
   numerical temperatures on care labels
   could be of use to American consumers,
   the Commission is willing to reconsider
   that issue.
    The following changes are proposed
   in the definitions Section of the Rule
   and in the Appendix to the Rule.
    Section 6.(b)(l)(I) of the Rule would
  be modified to read as follows:
    The label must state whether the product
  should be washed by hand or machine. The
  label must also state a water temperature—
  in terms such as cold, warm, hot, or very .
  hot—that may be used. However, if the
  regular use of very hot water will not harm
  the product, the label need not mention any
  water temperature. [For example, "Machine
  wash" means very hot, hot, warm or cold
  water can be used.]

    The last sentence of Section l(d) of
  the Rule would be modified to read as
   When no temperature is given, e.g.,
  "warm" or "cold," very hot water up to 145
  degrees F (63 C) can be regularly used.
   "Hot" water would be defined in
  Appendix l.a as ranging from  112 to 125
  degrees F [45 to 52 degrees C], "warm"
  water would be defined in Appendix 1.6
  as ranging from 87 to 111 degrees F [31
  to 44 degrees C], and "cold" water
  would be defined in Appendix l.c as
 ranging up to 86 degrees F [30 degrees
 C]. In addition, "very hot" water would
 be defined in Appendix l.a as ranging
 from 126 to 145 degrees F [53 to 63
 degrees CJ.
   The Commission seeks comment on
 these proposed changes, their
 importance to consumers, the necessity
 for a  consumer education campaign to
 help  consumers understand and use
 information about water temperature,
 and the form such a campaign might

 Part C—Rulemaking Procedures
   The Commission has determined,
 pursuant to 16 CFR 1.20, to follow die
 procedures set forth in this notice for
 this proceeding. The Commission has
  103 Although new water heaters are being set at
lower temperatures, the comments indicate that
many homes still have older heaters that produce
water at 140 degrees F or even hotter. A garment
that has been tested in water heated to 125 degrees
F may withstand washing in that temperature
without damage but nevertheless be damaged by
water at 140 degrees F.
  104 Some companies have already begun to
educate consumers about these issues. A consumer
chart prepared by Maytag, with numerical
definitions for hot, warm, and cold water, states,
"The clothes washer will not ensure these
temperatures because the actual water temperatures
entering the washer are dependent on water heater
settings and regional water supply temperatures.
For example, cold water entering the home In the
northern states during winter may be 40 degrees E
which is too cold for effective cleaning. The water
temperature in this situation will need to be • "
adjusted by selecting a warm setting or adding some
hot water to the fill."

Federal Register /Vol. 63, No. 89/Friday, May 8, 1998/Proposed Rules
decided to employ a modified version of
the rulemaking procedures specified in
Section 1.13 of the Commission's Rules
of Practice. The proceeding will have a
single Notice of Proposed Rulemaking,
and disputed issues will not be
  The Commission will hold a public
workshop conference to discuss the
issues raised by this NPR. Moreover, if
comments in response to this NPR
request hearings with cross-examination
and rebuttal submissions, as specified in
Section 18(c) of the Federal Trade
Commission Act, 15 U.S.C. 57a(c), the
Commission will also hold such
hearings. After the public workshop, the
Commission will publish a notice in the
Federal Register stating whether
hearings will be held in this matter, and,
if so, the time and place of hearings and
instructions  for those desiring to present
testimony or engage in cross-
examination of witnesses.
Part D—Section-By-Section Description
of Proposed  Amendments
2. Amendments Relating to Required or
Permissible Care Instructions
  The Commission proposes to amend
section 423.1, "Definitions" to include
the following definition:
  (h) Professional wet cleaning means a
system of cleaning by means of
equipment consisting of a computer-
controlled washer and dryer, wet
cleaning software, and biodegradable
chemicals specifically formulated to
safely wet clean wool, silk, rayon, and
other natural and man-made fibers. The
washer uses  a frequency-controlled
motor, which allows the computer to
control precisely the degree of
mechanical action imposed on the
garments by  the wet cleaning process.
The computer also controls time, fluid
levels, temperatures, extraction,
chemical injection, drum rotation, and
extraction parameters. The dryer
incorporates a residual moisture (or
humidity) control to prevent overdrying
of delicate garments. The wet cleaning
chemicals are formulated from
constituent chemicals on the EPA's
public inventory of approved chemicals
pursuant to the Toxic Substances
Control Act.
  The Commission proposes to amend
section 423.6(b) of the Rule to read as
  (b) Care labels must state what regular
care is needed for the ordinary use of
the product. In general, labels for textile
wearing apparel must have either a
washing instruction or a dry cleaning
instruction. If an item of textile wearing
apparel can be successfully washed and
finished by a consumer at home, the
                   label must provide an instruction for
                   washing. If a washing instruction is not
                   included, or if washing is warned
                   against, the manufacturer or importer
                   must establish a reasonable basis for
                   warning that the item cannot be washed
                   and adequately finished at home, by
                   possessing, prior to sale, evidence of the
                   type described in paragraph (c) of this
                   section. If a washing instruction is
                   included, it must comply with the
                   requirements set forth hi paragraph
                   (b)(l) of this section. If a dry cleaning
                   instruction is included, it must comply
                   with the requirements set forth in
                   paragraph (b)(2) of this section. An
                   instruction for professional wet cleaning
                   may also be given. If an instruction for
                   professional wet cleaning is given, it
                   must comply with the requirements set
                   forth in paragraph (b}(3) of this section.
                   If the product cannot be cleaned by any
                   available cleaning method without
                   being harmed, the label must so state.
                   [For example, if a product would be
                   harmed both by washing and by dry
                   cleaning, the label might say, "Do not
                   wash—do not dry clean," or "Cannot be
                   successfully cleaned."] The instructions
                   for washing, dry cleaning, and
                   professional wet cleaning are as follows:
                    It should be noted that, in addition to
                   the additions to section (b) noted in
                   bold, the following sentence has been
                   deleted: "If either washing or dry
                   cleaning can be used on the product, the
                   label need have only one of these
                    The Commission also proposes to add
                   the following subsection to section (b).
                    (3) Professional wet cleaning.
                    If a professional wet cleaning
                   instruction is included on the label, it
                   must state at least one type of
                   professional wet cleaning equipment
                   that may be used to clean the garment.
                   However, if the product can be
                   successfully cleaned by'all
                   commercially available types of
                   professional wet cleaning equipment,
                   the label need not mention any type of
                   wet cleaning equipment. A care label
                   that recommends professional wet
                   cleaning must list the fiber content of
                   the garment and must recommend one
                   other method of cleaning, such as
                   washing or drycleaning, or must warn
                   that the garment cannot be washed or
                   drycleaned if such is the case.
                   2. Amendment of Reasonable Basis
                    The Commission proposes to amend
                   § 423.6(c)(3) as follows:
                    (c) A manufacturer or importer must
                   establish a reasonable basis for care
                   information by possessing prior to sale:
                    (3) Reliable evidence, like that
                   described in paragraph (c)(l) or (2) of
this section, for each component part of
the product in conjunction with reliable
evidence for the garment as a whole;

3. Amendment of Definitions of Water
  The Commission proposes to amend
the last sentence of § 423.1(d) of the
Rule to read as follows:
  When no temperature is given, e.g.,
"warm" or "cold," very hot water up to
145 degrees F (63 C) can be regularly
  The Commission proposes to amend
section 423.6(b)(l)(I) of the Rule to read
as follows:
  The label must state whether the
product should be washed by hand or
machine. The label must also state a
water temperature—in terms such as
cold, warm, hot, or very hot—that may
be used. However, if the regular use of
very hot water will not harm the
product, the label need not mention any
water temperature. [For example,
"Machine wash" means very hot, hot,
warm or cold water can be used.]
  The Commission proposes that
Appendix A.l.a-l.c be modified to read
as follows:
  1. Washing. Machine Methods:
  a. Machine wash—a process by which
soil may be removed from products or
specimens through the use of water,
detergent, or soap, agitation, and a
machine designed for this purpose.
When no temperature is given, e.g.,
"warm" or "cold," very hot water up to
145 degrees F (63 degrees C) can be
regularly used.
  b. Hot—initial water temperature
ranging from 112 to 125 degrees F [45
to 52 degrees C].
  c. Warm—initial water temperature
ranging from 87 to 111 degrees F [31 to
44 degrees C].
  d. Cold—initial water temperature up
to 86 degrees F [30 degrees C].
Part E—Regulatory Analysis and
Regulatory Flexibility Act
  Under section 22 of the FTC Act, 15
U.S.C. 57b, the Commission must issue
a preliminary regulatory analysis for a
proceeding to amend a rule only when
it (1) estimates that the amendment will
have an annual effect on the national
economy of $100,000,000 or more; (2)
estimates that the amendment will
cause a substantial change in the cost or
price of certain categories of goods or
services; or (3] otherwise determines
that the amendment will have a
significant effect upon covered entities
or upon consumers. The Commission
has preliminarily determined that the
proposed amendments to the Rule will
not have such effects on the national

                      Federal Register/VoL 63, No.  89/Friday, May 8, 1998/Proposed Rules
      n0iny, on the cost of textile wearing
    ooarel or piece goods, or on covered
   ffiejnesses or consumers. The
   rojnmission, however, requests
   ^roent on these effects.
    The Regulatory Flexibility Act
   p'RFA"). 5 U.S.C. 601-12, requires that
   {he agency conduct an analysis of the
   anticipated economic impact of the
   proposed amendments on small
   businesses.105 The purpose of a
  regulatory flexibility analysis is to
  ensure that the agency considers impact
  on small entities and examines
  regulatory alternatives that could
  achieve the regulatory purpose while
  minimizing burdens on small entities.
  Section 605 of the RFA, 5 U.S.C. 605,
  provides that such an analysis is not
  required if the agency head certifies that
  the regulatory action will not have a
  significant economic impact on a
  substantial number of small entities.
    Because the Care Labeling Rule covers
  manufacturers and importers of textile
  wearing apparel and certain piece
  goods, the Commission believes that any
  amendments to the Rule may affect a
  substantial number of small businesses.
  For example, unpublished data
  prepared by the U.S. Census Bureau
  under contract to the Small Business
  Administration ("SBA") show there are
  some 288 manufacturers of men's and
  boys" suits and coats (SIC Code 2311),
  more than 75% of which qualify as
  small businesses under applicable SBA
  size standards*106 There are more than
  1,000 establishments manufacturing
 women's and misses' suits, skirts, and
 coats (SIC Code 2337), most of which
 are small businesses. Other small
 businesses are likely covered by the
   Nevertheless, the proposed
 amendments would not appear to have
 a significant economic impact upon
 such entities. The amendment to allow
 for labeling for professional wet
 cleaning simply provides an option that
 can be taken advantage of by businesses
 if they wish. The amendment to require
 that garments that can be safely washed
 at home be labeled for home washing
 will also not add significantly to the
 cost of compliance for most businesses
 because businesses will still only be
 required to provide instructions for one
 method of cleaning. It is true that those
 businesses that currently label garments
 for dry cleaning without investigating
  »« The RFA addresses the Impact of rules on
"small entities," defined as "small businesses."
"small businesses." "small governmental entities."
and "small [not-for-profit] organizations." 5 U.S.C
601. The Rula does not apply to the latter two types.
of entities.
  1MSBA's revised small business size standards
arc published at 61 FR 3280 (Jan. 31.1996).
  whether they can be washed at home
  would have to make that determination.
  Most businesses, however, obtain
  information about the washability of the
  components of their garments from the
  sources of those components, and in
  many cases this simple inquiry will
  provide a reasonable basis for either a
  dry clean instruction or a home washing
  instruction. Although some businesses
  may have to engage in additional efforts,
  such as testing, to make this
  determination, it does not seem likely
  that this will be the case for most
  businesses. The Rule specifies that a
  reasonable basis can consist of various
  types of reliable evidence other than
  testing, and most businesses do not
  routinely test each garment style  they
  manufacture or import. Nevertheless,
  the Commission specifically seeks
  comment regarding these amendments'
  potential impact on small businesses.
   In addition, the Commission is
  proposing to amend one category of the
  types of evidence that can constitute a
  reasonable basis, i.e., evidence of testing
  of components of the garment, to  clarify
  that the manufacturer or importer must
  also have reliable evidence that the
  garment as a whole can be cleaned as
  directed without damage. The
  Commission specifically has indicated
 that testing of the garment as a whole is
 not required in all instances, however;
 what is required is an evaluation of
 whether the garment as a whole can be
 successfully cleaned without damage in
 the manner recommended on the  care
 label. The Commission views the
 amendment of this section of the Rule
 as simply a clarification of the fact that
 the manufacturer or importer must have
 a reasonable basis for the garment as a
 whole, not simply for the separate
  Based on available information, the
 Commission certifies that amending the
 Care Labeling Rule as proposed wiU not
 have a significant economic impact on
 a substantial number of small
 businesses. To ensure that no significant
 economic impact is being overlooked,
 however, the Commission requests
 comments on this issue. The
 Commission also seeks comments  on
 possible alternatives to the proposed
 amendments to accomplish the stated
 objectives. After reviewing any
 comments received, the Commission
 will  determine whether a final
 regulatory flexibility analysis is

 Part F—Paperwork Reduction Act
  The Rule contain various information
 collection requirements for which the
Commission has obtained clearance
under the Paperwork Reduction Act, 44
  U.S.C. 3501 et seq., Office of
  Management and Budget Control
  Number 3084-0103. As noted above, the
  Rule requires manufacturers and
  importers of textile wearing apparel to
  attach a permanent care label to all
  covered items and requires
  manufacturers and importers of piece
  goods used to make textile clothing to
  provide the same care information on
  the end of each bolt or roll of fabric.
  These requirements relate to the
  accurate disclosure of care instructions
  for textile wearing apparel. Although
  the Rule also requires manufacturers
  and importers to base their care
  instructions on reliable evidence, it does
  not contain any explicit recordkeeping
   The Rule also provides a procedure
  whereby a member of the industry may
  petition the Commission for an
  exemption for products that are claimed
  to be harmed in appearance by the
  requirement for a permanent label, but
  only one petition, subsequently
  withdrawn, has been filed in recent
  years. A Notice soliciting public
  comment on extending the clearance for
  the Rule through  December 31,1999,
  was published in the Federal Register
  on August 26,1996, 61 FR 43764. OMB
 has extended the  clearance until
 December 31,1999.
   The proposed amendments would not
 increase the paperwork burden
 associated with these paperwork
 requirements. The Commission's
 proposed amendment regarding
 professional wet cleaning does not
 increase the paperwork burden because
 it is optional. Businesses that do not
 believe'it is beneficial to label for
 professional wet cleaning are not
 required to do so.  The proposed
 amendment of the Rule to require that
 any garment or fabric that can be
 washed at home be so labeled will not
 increase the burden for businesses
 because they will  still need to label for
 only one method of cleaning.
  The proposed amendment to change
 the numerical definition of the words
 "hot," warm," or "cold," when they
 appear on care labels, and to add the
 term "very hot," will not add to the
 burden for businesses because they are
 already required to indicate the
 temperature in words and to have a
 reasonable basis for whatever water
 temperature they recommend.
 Moreover, businesses are not burdened
 with determining what temperature
 should accompany the words "very
 hot," "hot," "warm," or "cold"; the
 proposed amendment would provide
the numerical temperature that should
accompany each term. OMB regulations
provide, at 5 CFR 1320.3(c)(2), that "the

Federal Register/VoL  63, No. 89/Friday, May 8, 1998/Proposed Rules
 public disclosure of information
 originally supplied by the Federal
 government to the recipient for the
 purpose of disclosure to the public is
 not included within (the definition of
 collection of information.]"
  Thus, the Commission concludes that
 the proposed amendments would not
 increase the paperwork burden
 associated with compliance with the
 Rule. To ensure that no significant
 paperwork burden is being overlooked,
 however, the Commission requests
 comments on this issue.
 Part G—Request for Comments

  Members of the public are invited to
 comment on any issues or concerns they
 believe are relevant or appropriate to the
 Commission's consideration of
 proposed amendments to the Care
 Labeling Rule. The Commission
 requests that factual data upon which
 the comments are based be submitted
 with the comments. In addition to the
 issues raised above, the Commission
 solicits public comment on the costs
 and benefits to industry members and
 consumers of each of the proposals as
 well as the specific questions identified
 below. These questions are designed to
 assist the public and should not be
 construed as a limitation on the issues
 on which public comment may be
 A. Requiring Instructions for Cleaning in
  (1) Is there empirical evidence
 regarding whether consumers interpret a
 "dry clean" instruction to mean that a
 garment cannot be washed?
  (2) How many domestic businesses
 provide professional wet cleaning, as
 denned iri Part D.I. above, to the public
 on a regular basis?
  (3) Should the Rule provide that, if an
 instruction for professional wet cleaning
 is provided, no other instruction need
 be given, or should a professional wet
 cleaning instruction only be allowed
 along with another cleaning instruction?
 B. The Reasonable Basis Requirement of
 the Rule
  (4) Would the amendment of Section '
 423.6(c)(3) of the Rule, which provides
 that a reasonable basis can consist of
 reliable evidence that each component
 of the garment can be cleaned according
 to the care instructions, to state,
 additionally, that a manufacturer or
 importer must possess a reasonable
basis for the garment as a whole, clarify
the reasonable basis requirements? Is
any additional clarification needed?
                  C. Definitions of Water Temperatures
                    (5) How can consumers best be made
                  aware of the approximate water
                  temperatures in which they can safely
                  and effectively wash their clothing?
                  How can consumers best be made aware
                  of how these temperatures correlate to
                  the descriptors "hot," "warm," and
                  "cold"? Do consumers need to
                  determine the actual or approximate
                  water temperature in their washing
                  machines when they select "hotv"
                  "warm," and "cold" on their washing
                  machine dials, and, if so, how could
                  they easily and practically do this?
                  Could consumers use this information
                  to select the optimal temperature offered
                  by their washing machines for clothes
                  labeled for "hot." "warm," or "cold"
                    (6) -Would consumers understand an
                  instruction to use "very hot" water?
                  Could consumers  use this information
                  either to select the optimal temperature
                  offered by their washing machines for
                  clothes labeled for "very hot" washing
                  or to determine that such clothes should
                  be washed by a professional cleaner?
                    Authority: Section 18(d)(2)(B) of the
                  Federal Trade Commission Act, 15 U.S.C.

                  List of Subjects in 16 CFR Part 423
                    Care labeling of textile wearing
                  apparel and certain piece goods; Trade
                    By direction of the Commission,
                  Commissioner Azcuenaga not participating.
                  Donald S. Clark,
                  IFR Doc. 98-12233 Filed 5-7-98; 8:45 ami
                  BILLING CODE 6750-01-P

                  Office of Surface Mining Reclamation
                  and Enforcement

                  30 CFR Part 934
                  [SPATS No. ND-037-FOR, Amendment No.

                  North Dakota Regulatory Program

                  AGENCY: Office of Surface Mining
                  Reclamation and Enforcement, Interior.
                  ACTION: Proposed rule; public comment
                  period'and opportunity for public
                  hearing on proposed amendment.

                  SUMMARY: The Office of Surface Mining
                  Reclamation and Enforcement (OSM) is
                  announcing receipt of a proposed
                  amendment to the North Dakota
                  regulatory program (hereinafter, the
                  "North Dakota program") under the
                  Surface Mining Control and
 Reclamation Act of 1977 (SMCRA). The
 proposed amendment consists of
 proposed changes to North Dakota's
 revegetation policy document,
 "Standards for Evaluation of
 Revegetation Success and
 Recommended Procedures for Pre- and
 Postmining Vegetation Assessments."
   The changes pertain to (1) prime
 farmland woodland productivity
 standards, (2) woodland cover
 standards, (3) wetland standards, (4)
 woodland and shelterfaelt standards for
 recreational lands, and (5) methods for
 sampling woodland cover. The
 amendment is intended to revise the
 North Dakota program to be consistent
 with SMCRA and the Federal
 regulations, and to improve operational
 DATES: Written comments must be
 received by 4:00 pan., m.d.L, June 8,
 1998. If requested, a public hearing on
 the proposed amendment will be held
 on June 2,1998. Requests to present oral
 testimony at the hearing must be
 received by 4:00 pan., m.d.t. on May 26,
 ADDRESSES: Written comments should
 be mailed or hand delivered to Guy
 Padgett at the address listed below.
   Copies of the North Dakota program,
 the proposed amendment, and all
 written comments received in response
 to this document will be available for
 public review at the addresses listed
 below during normal business hours,
 Monday through Friday, excluding
 holidays. Each requester may receive
 one free copy of the proposed
 amendment by contacting OSM's Casper
 Field Office.
 Guy Padgett, Director, Casper Field
   Office, Office of Surface Mining
   Reclamation and Enforcement, 100
   East "B" Street, Federal Building,
   Room 2128, Casper, Wyoming  82601-
   1918, Telephone: 307/261-6550
 James R Deutsch, Director, Reclamation
   Division, Public Service Commission,
   State Capitol—600 E. Boulevard,
   Bismarck, North Dakota 58505-0480,
   Telephone: 701/328-2400.
 Guy Padgett, Telephone: 307/261-6550;
 Internet: GPadgettOSMRE.GOV
 I. Background on the North Dakota
   On December 15,1980, the Secretary
 of the Interior conditionally approved
 the North Dakota program. General
 background information on the North
 Dakota program, including the
 Secretary's findings, the disposition of
'comments, and conditions of approval
 of the North Dakota program can  be



       Tip of the iceberg: At the workshops in January,  1998 sponsored by EPA's Design
 for the Environrnent/Garment and Textile Care Program,  there was much discussion of the
 need for a good database of the safety and effectiveness of various cleaning methods on
 various types of textiles and garments. The staff of the Federal Trade Commission (FTC),
 which is responsible for enforcing and updating the Care Labeling Rule, also believes the
 compilation of a large database about the effects of various cleaning methods -- new and
 old -- is very important. Our primary goal is to see that care labels provide correct
 information about methods by which a garment can be safely cleaned.  The International
 Fabricare Institute (IFI) has been computerizing data about garments that were damaged in
 cleaning for more than ten years, and IFI has shared this data with FTC staff,  which has
 used this data to locate targets for investigation. In appropriate instances, the Commission
 has brought actions for civil penalties against garment manufacturers and importers for
 violating the Care Labeling Rule.  IFI has always asserted, however, that the data it provides
 is only the "tip of the iceberg."
       More of the iceberg: If more of the iceberg could be revealed,  several thing could
 happen.  If the data is sent to  FTC, staff could  bring more cases against garment
 manufacturers and importers who attach incorrect care labels to their garments, causing
 problems for consumers and cleaners alike. If the data is sent to AAMA, garments
 manufacturers and importers could benefit by using it, along with  other information, when
 deciding what care instructions to recommend.  Data about "problem garments" would
 include data about both new and old cleaning techniques, and would help manufacturers
 and importers make a rational decision about what care instructions to recommend.
       A plan for gathering data and taking action:  This goal of gathering more data
 about "problem" garments overlaps with the goals expressed at the January workshops by
 cleaners and manufacturers alike.  Part I below quotes from relevant parts of the Working
 Drafts from the work groups.  In Part II below, we suggest several  ways  of collecting a large
 database  of information about garments that were damaged when  cleaned.  We also suggest
various uses that can be made  of this database.  We hope this will  help stimulate ideas at
this conference.



GOAL 1:  Develop standardized methods and objective criteria for the side-by-side
evaluation of new cleaning technologies, identifying and listing the limitations of each in a
matrix or database listing performance for cleaning systems and fabrics, (p.5)
 1. Issue 5: Need for Database of Problem Garments
       •      Cleaners need a way to "look up" whether or not a particular garment can be
             cleaned using a particular cleaning method, (p.5)

       •     Develop a cleaning method performance matrix	The reason for this is to see
             where solvents are performing well and where they are performing poorly	For
             a given process, problems should be highlighted,  (p.6)

GOAL 7: Persuade the garment industry to adopt more accurate care labels, (p. 14)
Issue 1: Damaged garments are a liability for dry cleaners.
       •     A more comprehensive knowledge base for garment care needs to be accessible,
             so that when testing on garments is performed, there is more solid ground for
             assessing the cleanability of the garment, (p. 15)

             these goals  are consistent with the needs of FTC staff for
       more data in order to assure the accuracy of care labels by bringing
       suit, where appropriate, for civil penalties for violation of the Care
       Labeling Rule, and for helping  garment manufacturers and importers
       devise correct care labels.  Indeed, this Workgroup noted the
       following barrier to change, which could be reduced by the
       increased enforcement additional data would allow.

Barriers for Change:
       •     The garment industry's goal is to sell their garments, not to provide care for them.
             There is no real incentive in place,  (p. 15)


GOAL #1: Test each alterative technology "system" using standardized testing protocols
and produce a "matrix" which compares the technologies by standardized measures in
order to provide guidance to dry cleaners and further scientific understanding, (p.4)
       •      Conduct both controlled laboratory testing (for uniformity of results) and on-site
              testing (for "real world" practicality). Some participants thought that on-site
              testing should be conducted by dry cleaners, others by independent researchers.

GOAL #3:  Change care labels to recognize alternative cleaning technologies, (p.8)
       •      Make the matrix (see goal #1) available to apparel manufacturers as input into
              care label development process,  (p.8)

       These goals are also consistent with the goals of FTC staff.  If a
       large database of  "problem garments" is compiled and shared with

       garment manufacturers and importers, they will be able to use that
       "real world" information to recommend safe care procedures.

 C. THE TEXTILE WORKGROUP: January 14,1998

 GOAL #4: Identify fibers and fabrics that cause cleaning problems with ACP [Alternative
 Cleaning Processes] technologies and communicate that information to the textile industry.
       •     Collect and formally document problem fiber/fabric information vis-a-vis
             application of new ACPs (strive to collect as much information as possible).
             A database should be developed.
       •     Information on problems for dry cleaners associated with specific fibers,
             fabrics, and apparel is available from sources such as the local small claims
             courts, the Better Business Bureau, the International Fabricare Institute
             (IFI), and the Neighborhood Cleaners Association International (NCAI).

 GOAL #5: Create and implement a method of ongoing communication between the textile
 industry and the fabricare industry,  (p. 14)
       Key Issues:
       •     Close communication between the textile, apparel, sundries, and fabricare
             industries is necessary in order to facilitate the
             development/commercialization/refinement of new ACPs.  Also this
             communication link should provide information on problem fibers and
             fabrics. This information will help textile and apparel manufacturers to
             produce products that can be readily cleaned with the new ACP technologies.
      Goal 1  lists many of the sources of data which we suggest using in
      Part II  below.  All of these sources receive complaints about
      damaged garments, but some of them do not currently report it, as
      is discussed below.  Goal 5 is relevant because the database that is
      gathered can be shared with the textile industry.

      1. Create an electronic form that can be filled in on-line and that is compatible with
an existing data-base software package. [FTC may be able do this.]  A paper form could
also be used, but would probably be more costly to collect and evaluate data from paper.

      2.  Create a mailbox for filing the electronic form. [FTC could do this, if that is
most efficient and desirable to all the parties.  Or the data could be sent directly to the
source(s) described in point 4. below.]

      3.  Publicize existence of form and mailbox to cleaners [via existing cleaner chat
rooms, via trade associations, etc.]

      4.  Automatically forward the data to an appropriate party for analysis, [e.g., a
university textile professor and/or students  -  grant might be necessary.]

      5.  Party that evaluates the data could forward it to FTC.  FTC could use it to
investigate and bring some cases [in the most egregious cases], but could also share the
data with EPA, which could provide it to experts who are evaluating the effectiveness of
various cleaning methods.

      6.  EPA and FTC could share data with AAMA.

      7.  AAMA evaluates data in terms  of combinations of trim, fabric,  etc., which have
been damaged when cleaned and passes this info along to its members in general form.

      8.  Either FTC or AAMA notifies specific firms that have a high number of
complaints (but not so high that they have been sued) of the existence of the complaints.


       1.  Provide personnel to help IFI computerize all relevant data.  [Grant would be

      2.  Provide personnel to help NCA begin computerizing data. [Grant would be

      3.  Provide help to state associations that are not part of IFI or NCA (e.g., Calif.,
Dakota). Some such associations may already be collecting data, and others may not.
[Grant might be nee.]

      4.  Send all such data to  FTC (as IFI is currently doing).  FTC could share such data
with all the above-listed sources  (i.e., textile professor/students who are analyzing data,


       1.  If data is not already computerized in a useful form, provide personnel to help
computerize all  relevant data. [Grant might be necessary.]

       2. Send all such data to FTC (as IFI is currently doing). FTC could share such data
with all the above-listed sources (i.e., textile professor/students who are analyzing data,


       1. Ask courts if they have a large number of claims involving cleaners. [Use
Internet list serve.]

       2. For courts that do have a large number of such claims, ask if they would be
interested in sharing their data (and probably in collecting some data they do not currently

       3. Send ail such data to FTC (as IFI is currently doing). FTC could share such data
with all the above-listed sources (i.e., textile professor/students who are analyzing data,

                             Fabricare Industry Perspective
                                        Jackie Stephens
                                 International Fabricare Institute
        Good morning.
        One of the major concerns of the fabricate industry continues to be proper care labeling.  The care
label on a garment implies that the garment can be cleaned and refurbished by the care process that is
listed. When a garment is accepted at the counter, the drycleaner and the drycleaner's customer have a
certain level of expectation regarding the serviceability of that garment to that care process. Frequently,
however, the drycleaner experiences significant shade changes, color loss, staining from dye migration,
loss of designs, and loss of trim in the cleaning process.

        Many of these garments are submitted to ZFI's Garment Analysis Laboratory for a fair assessment
of the damage and to determine who is responsible for the damage that is caused in the cleaning process.
The IFI database, as Connie mentioned, has been in use since 1988. We have compiled information from
garments received for testing through the analysis laboratory. The garments are categorized in terms of
responsibility for the type of damage that we see in the laboratory as determined by the IFI analyst. The
main categories include manufacturer causes, consumer responsibility, responsibility caused by the dry
cleaner, and the unknown category representing garments with no obvious damage.

        In 1997, we analyzed over 20,000 garments in the Garment Analysis Laboratory. The problems
that were attributed to manufacturer responsibility represent around 39 percent of the total problems
submitted to the laboratory; consumer-caused damage represented 35 percent of the problems. The
cleaner caused around  12 percent of the problems and again we have  "unknown", or no obvious damage
to the garments, which was 4 percent. Garments submitted for restoration only represented 9 percent of
the problems.

        Problems from color loss represent 45 percent of that total number. One of the most common
problems being color loss in drycleaning, solvent soluble dye, or loss of print in drycleaning. In the
category of the manufacturer-caused damage, the 39 percent category, the most common problems that
we  see are from color loss.

        Garment defects  and garment construction problems represent about  16 percent of that total and
problems with trim are around 5 percent. This can be caused by a loss of trim, beads melting, loss of
sequins, et cetera.  That is around 5 percent of that total manufacturing problem.

        An analysis of the trends since 1989 shows that the manufacturing problems have been
consistently in the 35 to 40 percent range for that 10 year period. Actually, from 1989 to year to date
1988, they have been in the 35 to 40 percent category.

       The majority of the problems that we see in the laboratory are overwhelmingly in women's wear.
Women's wear represents 70 to 75 percent of the total problems that we see in the manufacturing
category. Men's wear falls between 17 and 23 percent. Problems with unisex and children's garments
average around 5 to 8 percent.

       An analysis of the data for the last 3 years shows that U.S.-made goods have consistently
contributed to 25 to 36 percent of the problems that we see in the laboratory.  Seven to 10 percent have
originated in Hong Kong and 6 to 9 percent in Korea. Other countries pose around 3 to 4 percent of the
problem that we see in the laboratory.

       Acetate and acetate blend fibers have contributed to  13 to 19 percent of the problems since 1995;
cotton and cotton blend fibers, 13 to 20 percent of the problems; polyester, 10 to 12 percent; and silk and
silk blend fabrics, 11 to 13. The "other" category represents  fibers with less than 8 percent of the

       We realize that this database is limited to the problems that are submitted to the Garment
Analysis Laboratory and does not represent the magnitude of problems that many drycleaners, retailers,
and consumers face daily. However, we feel that it has been a very useful resource in developing
educational and training materials for our industry, working with fiber and apparel manufacturers, and
testing and performance criteria for fabrics and garments, as well as contributing to the type of dialogue
that we should experience today.

       The Association of Professional Drycleaners and Launderers

                     DRYCLEANING WORKGROUP

                     Co-chairs: Bill Fisher, IFI & Bill Seitz, NCA-I

                             Monday, January 12, 1998

As we begin the Drycleaning Workgroup discussions, the following three points may help give  a
jumping-off point to begin discussions on long-term strategic goals within the context of the Design
for the Environment Program and our industry's continuing environmental responsibility.

The suggestions given here are not intended to be either exclusive or limiting on the discussions of
the Drycleaning Workgroup, but will hopefully provide a framework and focused areas to help start
our discussions.

                                                   Bill Fisher
  A.   How Should New Technologies and Alternative Processes be Evaluated?

       The mosfcritical issue facing the perchloroethylene drycleaning industry in trying to evaluate
       a new technology can be summarized in a very basic question:  "Will this process readily,
       easily, and satisfactorily handle the garments I currently receive for drycleaning?"

       A simple question—but one that has highly complex answers.  No single process or cleaning
       medium is "perfect," in the sense that no single process can readily and satisfactorily handle
       all types of garments and household items (including both textile and non-textile items).

       In any discussion of other processes, the first factor that must be recognized is that there are
       trade-offs in performance characteristics between each process.  The key to assessing the
       adequacy of a process—as a result—becomes not how good it is, but whether there are one
       (or several) critical performance areas where the process is effectively ruled out as a substitute
       or replacement for perchloroethylene systems.
       12251 Tech Road SUver Spring, Maryland 20904 ~  (301) 622-1900 [~  FAX (301) 236-9320

      Compounding this problem, the decision as to whether there are characteristics which make
      a. process unacceptable is a highly subjective one—and one for which there will be, at times,
      widely differing opinions and viewpoints.

      There is a potential way, however, to drive the evaluation process towards being as objective
      as possible.  This would involve development of a matrix of properties and performance
      criteria, so that existing and new processes can be evaluated on a side-by-side basis as much
      as is possible.  The development and use of such a matrix achieves two major objectives:
      First, it immediately identifies when information is not available for a process—and for which
      answers must be found before a true evaluation can be made. Second, it provides  a method
      for evaluation as to whether one (or several) major characteristics of a process are sufficiently
      unacceptable so as to eliminate consideration of that process as a realistic substitute for
      perchloroethylene systems.

      A very rough draft of this concept is attached. If the need to establish minimal acceptable
      performance criteria for new processes is a strategic  goal which should be  pursued,
      development and completion of the matrix would of necessity be shared by the Drycleaning
      Workgroup and the Technology Workgroup—and possibly other workgroups as well.
B.    What Are the Economics of New Processess. and Are They Affordable?

      If the first "simple" question is whether an alternative process can satisfactorily clean clothes
      that are that currently drycleaned, then the second key question is "Can I afford this system?"
     Again, a simple question to ask, but one which is difficult to answer.  The question of
     affordabiliry is comprised of several key issues: First, how much does the system cost—is the
     price low enough for me to able to purchase it?  Second, what is my own current financial
     situation, and am I still paying for new perc equipment? Third, where am I going to get the
     money to pay for this equipment?

     The drycleaning industry in the United States is made up of approximately 30,000 operating
     plant  establishments, with approximately one-third of those   plants owned by Korean
     entrepreneurs who may not have full access to traditional financing avenues. Additionally,
     the industry is made up of plants of widely-differing sizes, so that what is affordable to one
     operation may be out of the question for another.

     The attached table and graph, taken from the U.S. Census of Service Industries data for retail
     drycleaning plants (SIC 7216) for 1992, gives a better appreciation for the range of average
     receipts as they exist today in our industry.  The small size of a large portion of our industry
     leads to the question of whether a regulatory policy should be considered acceptable (by
     regulators_and/or industry members) if a major portion of the industry is not able to afford a
     new process.

       In searching for answers to the questions of affordabilhy of new processes for the drycleaning
       industry, issues that need to be addressed include the potential availability of guaranteed low-
       cost loans, business tax credits, accelerated depreciation and/or other innovative solutions.
  C.   What  Can be  Done Now to  Reduce Pert  Consumption, Without  Equipment

       Arguably, the industry needs to continue in the direction of reducing consumption and usage
       of perchloroethylene, while answers are found to the  dual questions of the viability of
       alternative processes, and whether the processes are affordable.

       The first questions relative to reduction of perc consumption would apply to plants which
       continue to maintain perc-only operations.  Specifically, what can be done on the equipment
       side to reduce consumption, and what can be done on the operational end and training sides
       to reduce consumption?

       The second questions are relative to what can be done to  reduce perc consumption by using
       other systems as supplemental or auxiliary processes to handle a portion of the articles
       received for cleaning.   Specifically, what supplemental  processes are satisfactory and
       affordable, so that they could be used to handle a portion of the garments which are currently
In summary, the three broad areas given above may  provide a framework—or may generate
discussion—helping us to move towards the development of strategic goals related to evaluating the
technical feasibility and the economic affordability of potential alternative processes, while allowing
and encouraging the industry to continue to increase its environmental responsibility.

                                                             •> mr IF1 / JAMUAirr g. 1998
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                             INTERNATIONAL  FABRICARE INSTITUTE  —
                            12251 Tech Road, Silver Spring, Maryland 20904
 Characteristics of  Drycleaning  Solvents
   Three types of solvents are used for drycleaning.
 While all are organic chemicals, their structures and
 properties are different in many respects. Chlori-
 nated hydrocarbon solvents are the most widely used
 drycleaning solvents in the U.S. The next most com-
 mon are the several classes of petroleum solvent.
 followed by fluorocarbon solvents (cholorinated and
 fluorinated hydrocarbons). This  bulletin compares
 the properties and characteristics of each solvent.

 Desirable Properties

   Not all organic liquids are satisfactory as dry-
 cleaning solvents. To be  appropriate  for use in
 drycleaning, a solvent must possess a number of
   1. Its  "solvent power" must be in the range that
 balances possible detrimental effects on common
 textile fibers and dyes against the solvent's ability to
 remove  fats. oils, and greases.
   2. An acceptable drycleaning solvent must be free
 of objectionable odors, and certainly must not leave
 a residual odor in garments after drying.
   3. The solvent must be noncorrosive toward the
 ordinary metals used in  machine, pipe, and pump
 construction or used only in equipment designed for
 that particular solvent. The solvent should also not
 swell or dissolve a  wide range of flexible gasket
 materials or tubing used in the construction of most
 drycleaning equipment.
  4. The solvent must be  sufficiently volatile to
 allow rapid and safe drying, as  well as to permit
 economical reclamation by distillation.
  5. One must be able to effectively use detergents
 in the solvent,  and  the detergent/solvent solution
 should be capable of carrying moisture. (The  par-
 ticular detergent used and its concentration  will
 affect the amount of moisture available for removal
of water-soluble soil.) Many common detergents
don't work in all solvents even though they may dis-
solve in  them.
 Drycleaning Solvents
 Perchloroethylene and 1,1,1-trichloroethane

   Perchloroethylene and a l.l.l.-trichloroethane are
 chlorinated hydrocarbons: they are manufactured by
 a process of adding chlorine to a base hydrocarbon.
 While all grades of each of these chemicals are the
 same basic chemical, they contain different corro-
 sion inhibitors, depending on their end use in various
 industries. Also, acceptable levels of impurities can
 vary from one type of use to another. Thus perc or
 1.1.1 manufactured for other industries may not be
 suitable for drycleaning use.

 Petroleum Solvent

   Petroleum solvents are obtained during the refin-
 ing of crude oil and fall structurally between gasoline
 and kerosene. Since these  solvents are mixtures of
 hydrocarbons,  they contain  only hydrogen  and
   Four types of petroleum solvents  are manufac-
 tured. "Stoddard solvent" is the name of one of these
 types. The other three are called "140F solvent."
 "odorless solvent" and "fast  dry solvent". All pe-
 troleum solvents are blends. The flash point of any
 petroleum solvent should never be lower than 100"
 F. However. 140F  solvent has a minimum flash
 point of 140° F.

 Fluorocarbon Solvent

  Solvent F-113 belongs to  a class of extremely sta-
 ble chemicals called fluorqcarbons. Solvent F-113
contains fluorine, chlorine, and carbon. For dry-
cleaning use in the U.S.. F-113 (plus detergents and
additives) has been known  by DuPont's trade name
of "Valclene." The  base solvent is now available
from other companies. F-113 is usually produced
from perc.

   The Europeans  have  also  experimented  with
 another fluorocarbon which they call "Solvent F-
 11." As F-ll is a moderately aggressive solvent (it
  has about double the solvent power of F-ii3). it has
  not made any  inroads in the U.S.  dryciear.:r.£
                                      Comparison of Solvent Properties
boilini pouil
latent neat of vaporization
solvent power
tnreinold limit value
surface tension
flash point
solubility of water in solvent
Ino detergent!

use in drycleanmj
(BTU/1 Ib)
(K.B. Value)
|mmtm«tm tet&p. "F)


230 165 1300-400 1117.8
27 • 91 6 :2BO.O
102 ! 122 63.D
27-45 31.0
6.47 ! 13.16
3SO 1200 iinnn
32.3 ; 2.56
0.01 ', 0.05
chlorinated chlorinated
hydrocaroon i hydrocaroon


27.6 19.6
100.140 > none


hydrocaroon ! chlorinated



i none

i none


hydrocaroon i
 Explanation of Terms in Table

   Petroleum solvent is a mixture, so its properties
 are variable. The numbers in the petroleum column
 should be regarded as "ball park figures."
   Volatility is a measurement of the relative evapo-
 ration rate of  a  solvent.  Carbon tetrachloride—
 CC1«—is used as a reference, with a rating of 100.
 The higher the volatility, the faster a solvent will
 evaporate. In practical terms, a solvent with a high
 volatility will be removed from textiles in less time
 than a solvent  with a low volatility  at the same
  The latent heat of vaporization is the amount of
 energy,  in British  thermal  units (BTU). required to
 convert  a pound of liquid,  at its boiling point, into
 vapor. The more BTU's needed, the more heat energy
(higher temperatures or longer times) must be sup-
 plied to  convert the liquid solvent into a vapor.
  Relative solvent power of liquids is expressed by
the index  number  called  Kauri-Butanol  Value
(KBV). On this scale, benzene is equal to 100 and all
other liquids are compared to it. The higher the KBV.
the stronger the solvent. A high KBV is usually more
effective in removing oil and grease stains, but a
lower KBV may be safer on some dyes, vinyls, and
other solvent-soluble items.
   Density is expressed as an index number, known
 as specific gravity, by dividing by the density of
 water, which is 6.33 pounds per gallon.
   Threshold limit value (TLV) is measured in terms
 of the maximum allowable concentration of the sol-
 vent vapors in the air. The measurement is expressed
 as parts per million (ppm). The TLVs  are set by a
 group of industrial hygienists and are currently use11
 by OSHA as its limits for 8-hour exposure.
   Surface tension is a measure of the energy that is
 holding the molecules of a liquid together in the sur-
 face of a liquid. The lower the surface or a fabric.
 Water, with a surface tension of 72. can be used  for
 comparison purposes. Wetting is  the first  step  in
 detergent or solvent action.
   As a solvent is heated, it releases more and more
 vapors. The flash point is the temperature at which
 these vapors will ignite  if a  spark is  present.  For
 example,  the vapors from Stoddard solvent heated to
 '.00° F could be not enough to ignite. Some liquids do
 not have flash points since their vapors do not form
 combustible mixtures with air.
   The solubility of water in solvent refers to how
 much water will dissolve in the solvent without the
 addition of detergent. Moisture above this limit will
.cause a cloudy mixture to form
                                              This bulletin was written fay Cindi Busier. Director of Research

              No. .4 SEPTEMBER 199?
T^erchloroethvlene (perc) is the most widelv used drvcleamng solvent.
A. The chemical is heavily regulated and is likelv to be even more stnn-
gentiv regulated in the future. In fact, in some states, the regulations are
putting an increasing burden on drycleaners to purchase new, lower-emit-
ting equipment, to report usage levels, and to train workers. Drvcleaners
would welcome a viable alternative to perc that would be more acceptable
to the regulators; one that would not require expensive regulatory invest-
ments. Is such an alternative available today or is such an alternative likelv
to emerge in the future?
 This paper attempts to answer that important question and the answer is
likelv to disappoint most drvcleaners and those of us who work on environ-
mental issues. Although many chemicals and processes are being heralded
as alternatives to perc drycleaning, none is really viable at this time. There
are five desirable properties that all drycleaning solvents must have to be
used in the drycleaning system. They are:
  cleaning power,
  no objectionable odors,
  noncorrosive to ordinary metals,
  sufficiently volatile, and
  liquid at room temperature.
 These properties are necessary to provide the best quality cleaning and
care for garments. Not all organic liquids are suitable as drycleaning fluids
so these properties were sought in establishing the current drvcleaning fluids
in use. Manv believe that the abilitv of the chemical industry is vast and
that eventually, given advanced technology, the chemical industry will
devise a chemical that will prove to be the answer. This paper demonstrates
that it is unlikely that suchan alternative will ever emerge. There are several
genenc chemical classes in which all existing and new chemicals can be
classified. The chemical class defines the physical properties and. thus, the
performance ability of the chemical. It also defines the  environmental
characteristics of any member chemical. Alternative processes are being
proposed and investigated as replacements for perc drvcleaning as well. One
of these—wetcleaning—holds some promise and. indeed, is practiced or
should be practiced by drycleaners to some extent today.
 On balance then, the conclusion of this analysis is that no existing or
emerging chemical and no process will replace  perc drycleaning on a
widespread scale, and perc will continue to be used by the industry in the
years to come. The road ahead will be more difficult, however, because the
regulations will become more burdensome and the industry will have to
accept the fact that perc is tagged as a chemical that poses potential human
health and environmental problems.         ,
 Only certain chemical classes can be tapped for commercial production;
that is, some chemicals would be extremely expensive because they are
difficult to manufacture. Thus, the classes of chemicals that might contain
chemicals suitable as drycleaning agents are limited and all of those classes
are considered here.
       TO  PERCIN
          ARE THEY

   Imluitry f»*»» / Suftmmhmr 1993
Table 1
Characteristics of Generic Alternatives
Petroleum Solvent
Dibasic Esters
CT, Perc
'see text tor lull names
   Generic chemical classes have certain characteristics. Once
 these characteristics are known, any chemical that talk into that
 class will have those characteristics. The balance of this section
 presents certain rules that can be applied to chemical classes.
   Some chemicals have short atmospheric lifetimes. That is. they
 break down readilv in the lower atmosphere. These chemicals
 form precursors that contribute to photochemical smog. Such
 chemicals are referred to as volatile organic chemicals (VOCs).
   Other chemicals have bng atmospheric lifetimes, in the range
 of five to several thousand years. All of these chemicals contain
 the so-called  halogens  which include fluorine, chlorine,  and
 bromine. Thev do noc break down readilv in the lower atmo-
 sphere. Some of these chemicals—chose contaimna chlorine or
 bromine—make their way to the upper atmosphere where thev
 contribute to stratosphenc o:on5 depletion. These chemicals also
 contribute to global warming. Other chemicals—those contain-
 ing only fluorine—Jo not cause ccone depletion but do cause
 global u-arming.
   The presence of a  halogen, like fluorine or chlonne. in a
 chemical  suppresses its flammability and most chemicals con-
 taining  halogens do not have flash points.  The presence of
 chlonne in a chemical makes it a good cleaner: the presence of
 fluonne alone in a chemical makes it a very poor cleaner. Chem-
 icals containing only halogens are generally relatively nontoxic.
 Chemicals containing hydrogen in addition to halogens  are
 relatively more toxic. All organic chemicals that do not contain
 halogens are classified as VOCs. Some chemicals containing
 chlonne are classified as VOCs.

  Table 1 summarizes the characteristics of the genenc chemical
classes. Examples of chemicals that fall into the first class—flam-
mable solvents—are kerosene and petroleum solvent. These are
 organic solvents that do not contain chlonne or fluonne. Flam-
 mable solvents have flash points in the flammable range, below
 about 140*F. This is a  major drawback since fire  regulations
 restrict their use. Equipment must be explosion proof and storage
 requirements are strict. Flammable solvents have high vapor
 pressures which means they are volatile and evaporate readilv.
 This is an advantage because the garment will drv rapidlv. Flam-
 mable solvents are classified as VOCs and contnbute to smog
 because thev have  short atmospheric lifetimes. As a conse-
 quence, they do  not cause ozone depletion or global warming.
 Flammable solvents are good cleaners.
   Combustible solvents include terpenes. dibasic esters, and vanous
 other hvdrocarbon solvents. Like flammable solvenrs. thev are
 organic solvents that do not contain fluonne or chlonne. Thev differ
 from flammable solvents in drat their flash point is higher: that is.
 they are  not as flammable but thev are combustible and rhev will
 bum and explode. For this reason, thev could not be used in perc
 drvcleaning equipment. They have low'vapor pressures so thev are
 not volatile and do not evaporate readily. Combustible solvents
 would not drv readilv and thev would require higher energy use to
 ensure drv clothing.  Combustible  solvenrs  cause smog and  are
 classified as VOCs. They do not cause o:one depletion or global
 warming and they are good cleaners.
   Chlonnated solvents include carbon tetrachloride (CT) and
 trichloroethylene  (TCE), both of which  were once used in
 drycleaning; 1,1.1 -trichloroethane (TCA), which is used by a few
 drycleaners today; and perc. Because these chemicals contain
 chlorine, they do not have flash points. Thev have high vapor
 pressures and so arc volatile; they evaporate readily, leaving the
 clothing dry. Perc and TCE are currently classified as VOCs. but
 the EPA has proposed exempting perc from this classification.
 CT and TCA have long atmospheric lifetimes and, since they
 contain chlorine, they contribute to ozone depletion and global
 warming. Production of the two chemicals will be banned on
January 1. 1996, because they cause ozone depletion. The chlo-

Industry F»cu»
                     mkmr 1993
Table 2
Health and Environmental
Potential Chemical
PEL (ppm)
a ODP is Ozone Depletion Potential
c Contains Benzene
Characteristics of
TAG Flammable
Yes —
, — —
Yes —
~Yesc Yes
— —
^^^__ ^^^
— —

• —

GWP is Greenhouse Wanning Potential
na means not available
rinated solvents are good cleaners.
  Two  CFCs—CFC-11 and CFC-113—have been used in
drycleaning. CFC-11 was once used in Europe and CFC-113 is
marketed as Valclene® today. Because they contain fluorine and
chlorine, which suppress flammability, the CFCs have no flash
points. They have high vapor pressures, are volatile, and evapo-
rate readily. Because they have long atmospheric lifetimes, they
are not VOCs, but they do cause ozone depletion and global
warming. Production of the CFCs. like CT and TCA. will be
banned on January 1, 1996. CFC-113 is a gentle, rather than an
aggressive, cleaner.
  The hvdrochbrofluorocarbons (HCFCs)  arc like the CFCs
except that they contain hydrogen. The hydrogen makes them
have shorter atmospheric lifetimes. They still contribute to ozone
depletion and global warming but less so than the CFCs because
of their shorter lifetime. Production of the HCFCs will be banned
later than CFCs. The HCFCs have no flash points because thev
contain fluorine and chlorine. Thev are volatile and  evaporate
readilv. Because they have relatively long atmospheric lifetimes.
thev are not classified as VOCs. They are good cleaners.
  The hydrofluorocarbons (HFCs) are  not yet commercially
available but may be in the future. They contain fluorine but not
chlorine. HFCs have no flash points and are volatile. Because
they contain fluorine, they have relatively long atmospheric
lifetimes and so do not contribute to smog. Since they contain
no chlorine, they do not cause ozone depletion, but. because of
their long lifetimes, they do cause global wanning. The fact that
they contain no chlorine makes them poor cleaners. They could
not be used alone for drycleaning; they would have to be com-
bined with a better cleaning agent.
  The fluorocarbons (PCs) contain fluorine and have extremely
long atmospheric  lifetimes. They contribute substantially to
global wanning. Because they do not contain chlorine, they do
not cause ozone depletion. They have no flash points and are
volatile. Because of their long lifetimes, they are not classified as
VOCs. Since they contain only fluorine, they are  very poor
cleaners. They do not combine well with other solvents and thev
are probably not suitable for drvcleantng from a technical stand-
point. Furthermore, they are likely to be regulated eventually
because of their strong global wanning properties.

  Table 2 presents a comparison of the health and environmental
characteristics of several chemicals with perc. These chemicals
are either used as drycleaning agents today or they are possible
candidates. All of them fall into the generic categories of Table
1. They include perc, which is the solvent of choice and the basis
for comparison; CFC-113, a CFC that is used for drvcleaning
today; TCA,  a chlorinated solvent used by a few drycleaners
presently; stoddard solvent, a flammable solvent, used bv manv
drycleaners today; three HCFCs which arc just becoming com-
mercially available: and one HFC that will not be commercially
available for some three vears.
  The first column of Table 2 shows the permissible exposure
level (PEL),  the exposure  level in the  workplace set by  the
Occupational Safety and Health Administration (OSHA). In
general, the more toxic the chemical, the lower the PEL. OSHA
set the PEL for perc at 25 ppm some years ago but the level  has
been overturned. Even so, most users are still attempting to meet
the PEL of 25. CFC-113, a relatively nontoxic chemical, has a
PEL of 1.000 ppm, the highest value assigned to any chemical.
TCA has a PEL of 350 ppm, and stoddard solvent has a rairiy low
PEL of 100 ppm. The PELs for the HCFCs and HFCs have not
been set by law; the manufacturer's  recommended levels  are
specified in the table but are placed in parentheses to indicate
theyarc not legal PELs. The PELfor HCFC-123 is only lO.a very
low value,  because, in long term animal testing, the chemical
-caused benign pancreatic and testicular tumors in male rats.
  The second column of Table 2 indicates whether the chemical
is a VOC and contributes to smog. Perc is currently classified as
a VOG, but the EPA plans to exempt it from smog regulations.

           Fxm /S«p«»«»b»r 1993
     The oniv ocher chemical in the table classified as a V'OC is
   petroleum solvent which rails into the eenenc class of"flamrnable
   solvents." CFC-113. TCA. the HCFG,. and HFCs have longer
   atmospheric lifetimes so thev are not considered VOCs.
    The third column in the table indicates whether the chemical
   is considered a hazardous air pollutant (HAP). Perc is regulated
   under the Clean Air Act as a HAP and. in California, as a toxic
  air contaminant. Stoddard solvent contains benzene fractions
  and benzene is considered to be toxic. TCA is classified as a HAP
  in the Clean Air Act.
    The fourth column indicates which chemicals have flash poincs.
  The oniv listed chemical that is flammable is stoddard solvent. The
  other chemicals do not have flash points  because they contain
  fluonne or chlorine, which suppresses flammability.
   The fifth column lists the Ozone Depletion Potential (OOP)
  of the chemicals. This  is  a relative measure of the depletion
  potential of a substance. CFC-113 has a high OOP; TCA has a
  more modest OOP. Production of both chemicals will be banned
  worldwide on January 1, 1996. for this reason.  HCFC-141b has
  a verv high ODP and it is slated to be banned in the year 2003;
  EPA will not allow its use insolvent applications where it would
  replace a chemical with a lower ODP. This means it cannot be
 substituted forperc. HCFC-123 and HCFC-225 will eventually
 be banned because of their ozone depletion,  but at a later date.
 Thev would require new. tighter equipment and. since they will
 be banned, new equipment would not be a good investment.
 HFO43-IO has no ODP since it contains no chlorine.
   The sixth column lists the Global Warming Potential (GWP)
 of the chemicals. Of the chemicals listed, only perc and stoddard
 solvent have no GWP. There may eventually be regulations on
 chemicals that cause global warming.
   Of the chemicals listed in Table 2. none is a promising substi-
 tute for perc. CFC-113 and TCA will be banned soon: all three
 of the HCFCs are slated to be banned eventually. Stoddard
 solvent cannot be used widely because of fire  regulations. HFC-
 43-10 is a potential alternative but it is a verv poor cleaner. It
 would have to be combined with another chemical to be techni-
 cally suitable and then the other chemical would have to be
 evaluated for its health and environmental effects.
   All specific chemicals can be placed into the generic categones
 of Table 1. Flammable and combustible chemicals probablv cannot
 replace perc because they are controlled by fire regulations. Com-
 busnWesolvems have the added problem of not drying readily. CFCs
 and HCFCs will be banned because of ozone depletion. HFCs and
 PCs are poor cleaners and the FCs have extremely high GWPs and
 may  eventually be banned for that reason.  An  HFC might  be
 acceptable from a health and environmental standpoint but, unless
 it was combined with a stronger solvent, it could not perform well
 technically. The stronger solvent would likely have health and/or
environmental problems.

  Several other processes have been suggested as potential alter-
natives to perc drycleaning. These would  include petroleum
   solvent with nitrogen  merttne. supercritical or iiauiJ career.
   Jioxide. and wetcleanmc-
     Perroleum or stoddard solvent can be used in equipment that
   has a nirroeen blanket. The nitrogen replaces the oxveen which
   is needed for the petroleum to ignite or explode. The nitrogen
   acts as an "inemng" medium that prevents fire or expioston. One
   disadvantage of this option is that nitrogen merting is expensive.
   Another disadvantage is that the petroleum solvent would still
   have to be stored and the storage aione is often enough to cause
   the fire marshal to forbid its use in manv locations.
    At the supercritical point—verv high pressure and room tem-
  perature—carbon dioxide behaves like both a liquid and a gas
  and is an excellent solvent. It can oniv remove oil-based contam-
  inants, however, and parnculates and lipstick and manv other
  types of contaminants could not be removed with the process.
  Pressure vessels are required for supercritical carbon dioxide and
  such a vessel fordrvcleamng at this time mav be cost prohibitive.
  Lower pressure could be used  for liquid carbon dioxide and  it
  would be somewhat less expensive. A liquid process was patented
  some years ago  for drvcleamng. It was never commercialized.
  however, presumably because of the technical problems and the
  cost, although research is ongoing.
    Water-based methods are being heavily  investigated todav.
  One water-based method under investigation employs a number
  of treatments. The most suitable treatment method is used on a
  garment  by  garment basis. The treatments include spotting.
  tumble  drying,  or  laundering.  Manv  drycleaners  employ
  wetcleaning to some extent today and it could be exercised more
  widely and extensively. This would allow a portion of  the perc
 drycleaning to be replaced.

   All potential chemical alternatives to perc can be classified
 into generic categones. The generic categories of chemicals have
 defined properties and they have certain environmental charac-
 tenstics. If the chemical category for a particular chemical is
 known, then the properties and environmental charactenstics of
 the chemical are  known rrom the outset. All generic categones
 have disadvantages. The flammable and combustible chemicals
 pose workers danger because of possible fire and explosion; thev
 are also VOCs and the combustible solvents do not dry readilv.
 The CFCs and HCFCs will be banned because thev cause ozone
 depletion. The FCs cause extensive global warming and they may
 eventually be regulated. The HFCs are possible substitutes but
 they are poor cleaners.
   All emerging chemicals and all possible future chemicals that
 could be considered  for drycleaning  will fall into one of the
 generic chemical categories discussed here. Since these catego-
 ries all have strong class disadvantages, it is safe to conclude that
 there is not and there is not likely to be a chemical that will
substitute  widely for perc in drycleaning. The alternative pro-
cesses to perc drycleaning which include petroleum solvent
drycleaning also have limitations; the only one that may replace
perc drycleaning to some extent in the years to come is wetclean-
ing garments that can be laundered. 3
                                                      Written by Katy Wolf, Institute for Research and Technical Assistance.

          Bulletux     9erviee~
                                                                       N.A.D.C. I
No.  T-143
            ••••••BBseW           SH.VBB SPRING, MARYLAND           ^B^HBHB
                        Wetcleaning   Problems
                In too many plants the wetoleoning department is given little  or no thought.
            Because it it an extra operation and increase* coats in other departments,  it IB
            looked upon as a necessary evil.   For eons unknown reason,  it is  usually  put in
            the darkest corner of the plant, and too often becomes a dumping ground for inex-
            perienced and careless employees.  Actually, no other department requires a high-
            er skilled operator,  and in no other department can as much damage occur through
            inexperience  or carelessness.   Although There are many,  we will  discuss  seven
            primary problems of the wetoleaning department tnat are most often  overlooked in
            many plants.
    Shrinkagei  As pointed  out in bulletin T-142,
there are four factors that cause shrinkage:  mois-
ture, mechanical action, heat,  and alkali. The more
these factors are in evidence and the  more in com-
bination, the greater is the tendency toward shrink-
age. Considering each of these factors as they per-
tain  to the weteleaning department, we can  ascer-
tain such  practices  as may  be expected to  cause
    The  first factor—moisture--is  a Tory neces-
sary part of wetoleaning,  and cannot be reduced or
avoided.   Since shrinkage is caused not so much by
any one thing  alone as by a combination of factors,
it becomes increasingly important  to take all pos-
sible precautions  to minimise the presence  of the
remaining three factors.
     The second factor—meohanical action—is some-
thing  that can be  at least reduced, although not en-
tirely eliminaxed._  Wringing  and squeezing give a
certain degree of  mechanical action.   Machine wet-
cleaning increases the possibility   of  shrinkage,
because of the increased mechanical  action.   If a
loo  water level   is maintained  and  the machine is
allowed to run during the draining period, the ex-
cessiv* pounding   will  increase  still   more  the
shrinkage  possibilities.    The speed of the washer
likewise it  important,   sinoe increased  speed in-
creases mechanical action.
     Tumbling  wetcleaned - work still  further  in-
creases shrinkage  tendency because,here we not  only
have the factors   of moisture  and mechanical  action
present,  but also the third factor—heat.  Thus if
there is a potential shrinkage  problem present—that
 is if the  garment has a tendency  to shrink—we can
expect excessive  difficulty where wetcleaned   work
 is dried by tumbling.   Another source of shrinkage
 due  to the presence of heat is in  the use of too
 hot miter,  or uneven change of temperatures of the
 rinses.  Extremely  cold water also  will result in
 shrinkage.   Even, the change  of temperature from a
 final warm rinse to the cold air in  extraction has
been known to cause shrinkage in oold climates.
     The fourth  factor—alkali—is  often  present
in many wetoleaning operations,  either in the form
of soap  or as a builder.   However, it can be kept
at a minimum by the use  of a wetting agent on those
garments  that are  suspected  of having shrinkage
possibilities.-  Thus  the careful wetcleaner can do
mieh to  minimize the  possibility of  shrinkage on
garments suspected of having a pronounced shrinkage
tendency, by endeavoring to avoid as much as possi-
ble the three factors of shrinkage that can be at
least partially controlled.
     Topping Dyesi Some  manufacturers resort to the
use of "topping dyes",   for several reasons.  Some-
times a material has been dyed an off-shade through
faulty dyeing practice.   By "topping-off  with a
slight amount of  another color,  it is  possible to
correct the original mistake and bring the material
to the desired shade.  Then again, sometimes certain
shades do not sell well,  or go out of style before
being placed on the market.   By resorting to "top-
dyeing" a n«w shade or color, in popular  demand,  can
be produced.
     Material dyed with  acid dyes maybe topped with
a basic dye to get added depth and brilliance.  Or,
on the other hand, style trends may call for a dull
or dusty  appearance whioh  can be  accomplished by
topping with another  color to dull the   brilliance
of the original dye.  Further, top-dyeing is often
used to produce fancy or unusual shades.  This  is
done  by first dyeing  the fabric to an approximate
shade of the color desired, and then by passing the
fabric through  a dilute bath of another color,  an
overtone is brought out, resulting in an unusual or
"different-from-everage" shade.
     This process might  be compared somewhat to the
practice of blueing white work in laundry practice.
Actually the blueing is  a  topping dye that offsets
the yellow  cast of the  washed work,  to produce a
pure white color.  For example,  this  summer there
have appeared on the market a large number of men's

  its,  juamsr suits  whlon had  oeen top-dyed with  a
  dilute fugitive  yellow.   The  trousers of  summer
  suits often need wetoleaning.  but when  the»e gar-
  ntnti  ware weteleaned  in the usual  manner,    the
  yellow topping dye was removed, leaving the  trousers
  a decided gray that wa« entirely different  from the
  coa« which had not been wetcleaned.    Kany  of  these
  sac suits also were found to hare been  topped with
  a dilute   green to dull the brilliance of "tne tan.
  After wetcleanlng,   a decided reddish  cast  resulted
  due to the removal  of this  green.  This  same diffi-
  culty was encountered ia planti using a water carry-
  ing soap  ia dryoleanlng.  and where the  practice is
  to separate  the trousers from the coats  and  oleaa
  them with a greatly  increased  percentage of moisture,
  Usually suoh topping  dyos   are not properly set and
  are  easily razored.   When once  removed the  only
  remedy is to put the garment through a topping bath
  again.   However this is not always possible due to
  tne linings and trimmings.
      The wetoleaaer. should be trained to recognize
  garments which have a "suspicious" look.  Unusually
  brilliant fabrio*.  unusually dull fabrics,   or un-
  usual color* that appear  "off-shade"  should always
  be  viewed with suspicion and tested before wetelean-
  iag.   Such fabric* should  be tested with the  three
  reageat*--10jC aoetio aold.lOS ammonia, and  a saline
  solution.  It  will be  found in practically   every
  case that if one  of theso  three  reagents  causes a
  discharge of color on a white blotter,  another one
  of the three will be found to hold or set the color.
  Then it is possible to use this color-setting agent
  together with a synthetic  wetting agent instead of
  soap,   and wetolean  the garment  without  loss of
 color. The same color setting agent should be  used
 in the rinse*  as well as the suds operation.
      Color Changes! Is addition to ooior change due
 to  loss of topping-dye,  many case*  are due to  a
 separation of  the dyestuff.    This may occur in any
 blended shade,  where the color was obtained  by  dye-
 icg  with a combination  of dyes.    For example,   a
 green sight be  obtained by  the use  of a yellow and
 a blue dye. If,  however,  the yellow was fugitive to
 alicali,  the result  after wetcleaning with soap and
 an  alkaline builder  would  be the removal  of   the
 yellow component  of the  green,   leaving a  blue  or
 bluish fabric.   The  prevention of  such  damage is  by
 testing suspected fabrics  a* above. The experienced
 wetcleaner  learns   to  recognixe  such   potential
 trouble-aakers  instantly. -

      Other  color changes   are  often due  to  the use
 of dyes  that change color in  the  presence of acids
 or  alkalies.   However.  *uoh changes can  usually be
 corrected by neutraliting,   unless the  reagent  that
 caused the  color change wa**o«trong as to actually
 damage the  fabric.  Recently there have been a  num-
 ber   of case* of trmy officer*•  «hirts  that  have
 turned color ia  streaks  due to perspiration.   Be-
 cause  many of these   *hirt« are  labeled "dryclean
 only",  sea* cleaners  have refrained from wetelean-
 ing  them.   It is th« contention of the  Association,
 and  many of th» manufacturer*, that the wetcleaning
 process is an  integral step in  dryoleaning  proce-
 dure  and therefor*  is «till  within the  scope of
 such a label.   Hany manufacturers  state that the
 purpose of suoh a label  i«  for the guidance  of the
 purcha*er *o  that th» garment would not receive an
 ordinary washing or laundry,  process,  but  would be
 sent  to a drycl»an«r  to  process in the  accepted
       The removal  c" dressing one  often gives tne
  appearance of  a loss of color.   Occasionally, tne
  manufacturer tises a  dressing oil to increase lig.-.t
  reflection,   which  makes the  fabric  appear  sore
  brillant and  lustrous.    In oases  of poor  dyeing
  that dressing oil alone  could  not cover, dyestuffs
  are  incorporated  with the oil to overcome the dull
  appearance.   Many of these oils are removed in .dry-
  cleaning and otneri in wetolea.iir.g, with subsequent
  loss  of color.    Usually auer,  a condition  car. b«
  overcome by a re-oiling  process.   Although a solu-
  tion of  ono-half pint  of white mineral  o'il -to a
  gallon of solvent  has been the accepted  method of
  re-oiling and works satisfactorily.reoently the use
  of wax-type   water repellents  on the dry side have
  mat  with increased popularity ir. dryeleaning plant*
  for  re-oiling and dry siting many fabrics.
       Loss of Sitingt  One of  tno most  common com-
  plaints fromcustomers  in regard  to garments that
  have been wetcleaned is  the failure to replace six-
  ings removed in  wetoleanir.g,  with resultant loss of
  feel and drape to the garment.   Because of the pre-
  sent demand  for  a fabric  of good "feel" and "drape"
  rather  than  stiffae**, the use  of the new water  re-
  pellents as  siting  has gained  in use.   (The subject
  of sitings,  the  different  types,  and methods  of  us-
  ing, was_covered ia bulletin T-39)
      Fugitive Dyesi  A* pointed  out  above an expar-
  ienced wetcieaner is able to recognite  those colors
  th»t are most likely to oause trouble.  In addition.
 he should be on the alert  to notice black-buchraa or
 crinoline  backing and  innerlinings,   and  special
 trimmings that might bleed  and cause trouble.   Be
 should then test the dyes  as mentioned under topping-
 dyes.   This does not mean that it is  necessary to
 *••*  all colors.    Probably not over 6% of the gar-
 ments  handled would  fall  into  this  "suspected"
 class.  After determining which color* are fugitive
 and to what  reagent they are fast,  the wetoleaner
 can  then use  a  synthetic wetting agent,  plus the
 setting reagent,  and wetolean the garment with com-
 parative safety.
      Digestive Agents; Few wetcleaners really know
 ti« vaiue and application of digestive agents.  The
 scope of this  subject covers  considerable detail,
 and for this  reason a separate  bulletin will be de-
 voted to it.
      Excess  finishing Difficultiesi   One  thought
 that  should be uppermost in  the wetoleaner'• mind .
 is  that he should always  consider the finishing in-
 volved  on any garment  which  passes  through  his
 hands.  Often  five minutes  extra, time spent in care-
 ful handling in the weteleaning  department will save
 hours of time in  the finishing  department.   In some
 plants  the wetcleaned work  reaches the finisher*  in
 such  condition that  it is  difficult to  di*tingui*h
 it  from drycleaned work.  However in too many plants,
 such  work  i* limp,   lifeless,   and badly wrinkled.
 There  are seven   precaution* that  the  wetoleaner
 should observe to minimise  finishing difficultiesi
      1.   Extract  lightly—to avoid "extractor
      2.   Do not overcrowd tubs
    —3.   Keep garments well  opened up
      4.   Avoid excessive  squeexing.  wring-
            ing, and  twisting
      5.   Process  taffeta* and satins  entirely
            on the  table,  including rinsing
      8.   Drip dry—never extract or squeete—
            satins, taffetas,  sharkskins
	    7.   Re-site  garments which  require siting

 The Association of Professional Drydeaners and LaundereTS

Receipts Size of Firms Subject to Federal Income Tax:  1992
       Source: 1992 U.S. Census of Business, Service Industries Subject Series
                 Prepared by William E. Fisher, January 11,1998

Witn Annuii Rcettoa ot
S100.000.000 or more
S1 .000.000-S2.499.999
Leu man $100.000

19.765 23.313
17416 20.837 S4.867.339.000 $1.753108.000

_ — — —
_ — — —
32 833 $327.931.000 S124.197.000
83 585 $285.028.000 S106 469.000
450 1.266 S64S.462.000 S272.821.000
1.331 1.999 $895.125.000 $376.057.000
3.452 3.946 S1.174.284.000 S435.268.000
7.784 7.907 S1.2S7.620.000 S367.024.000
4,284 4.301 S281. 889.000 S70.272.000

•/. of Firms


% of

6 1%
. 37.9%

Operated Entire Year->
Witn Annul* Receipts of
$100.000.000 ot more
Less man S100.000
Avg. Receipt*
S1. 434.360
Avg. Payroll
Avg. Receipt*
S1S9.051 •

Avg. Payroll
S149 096
S1 10.560

Avg Payroll/
Avg Rcpts

         Distribution of Drycieaning Establishments by Their Receipt Size
              » 7.907



6.000 .3
    c i
4.000 1
3.000 w


    S65.540    S159.0S1    $297.588    $447.786    $509.8*4

                           Average Receipts
  12251 Tech Road Silver Spring, Maryland 20904  13  (301) 622-1900 C FAX (301) 236-9320

                                Textile Industry Perspective

                                           Kay M. Villa
                             American Textile Manufacturer Association

         Kay Villa  is currently  Assistant Director  for the Product Services Division of the
         American Textile Manufacturer's Institute.   She is the author of numerous publications
         related to textile standards, and is on the Board of Directors of ASTM.

         Good morning.

         This morning I would like to cover a couple of issues.  First of all, I would like to tell you more
 about ATMI. I also have a few comments about the Care Labeling Rule. Then I want to talk very briefly
 about alternative cleaning technologies and their relationship as I see it—or as ATMI sees it—to the Care
 Labeling Rule.

         To qualify for membership in our organization, a company must be involved in manufacturing of
 textiles. That can include creating or spinning a yam, taking it and weaving it into a fabric,—or for that
 matter, printing or finishing.  Thus, a company must be involved in some aspect of actually creating a
 textile product.

        Our members typically make fabrics, but they also make literally thousands of different products.
 They make anything from yams to thread to geotextiles and filtration systems. But we have a large
 number of members, in fact, that make end products.  We also have a few rare companies that actually do
 the textile manufacturing and also make an apparel item. We do not represent apparel interests, however,
 some members are manufacturers that are involved in the manufacturing of home furnishing products,
 such as floor coverings, rugs, carpets, sheets, pillow cases, and towels.

        To give you some idea of the scale of our industry, we currently represent about 75 percent of all
 fiber consumption used in textile mill operations in the United States. Our sales were 60 billion in 1995.
 Our shipments were $70 billion and we currently are modernizing at about $2  billion annually. And that
 is a very large number. But when you start looking at the capital expenditures that go into textile
 manufacturing, that number diminishes very quickly.  A typical loom runs anywhere  from a hundred
 thousand to a quarter of a million dollars.

        In order to put in a finishing line if we wanted  to modify some aspect of the production, the cost
 ranges from half a million dollars to $6 million, depending on the operations.   In relative scale to the
 world in terms of world fiber consumption, the U.S. textile industry produces only about 5 percent  of all
 manufactured wool fibers. It represents less than 1 percent, probably around half a percent, of all silk that
 is utilized.

        For the overall synthetics picture, about 25 percent of all broad-based synthetics are utilized in
U.S. textile mill operations. Remember, though, that this figure includes polyester, nylon, polyolefin, and
a number of other fibers. I know that many of you are interested in  rayon and acetate. Right now, the
data doesn't break it down specifically. This is purely a guess— but I would guess that U.S. rayon and
acetate production is probably somewhere within the 10 percent range of world production.

       You have seen several versions of this diagram over the last couple of days, but let us see where
we fit into the whole broad picture.  If you look at the green boxes near the top of the pipeline, this is
essentially where ATMI members fall.

       ATMI has two programs that we would like to describe to you.  Our industry, in fact, is currently
using pollution prevention programs. We have a program called E3, Encouraging Environmental
Excellence.  I have literature on it.  If you would like more of this literature, please give me your business
card afterwards.

       This program is voluntary and more than half of our members are enrolled in it. Member
companies are required to develop a management system program for their environmental policies and
must exceed EPA local, Federal, and state regulations.  In essence, what happens is that the company
meets ISO-14,000. I am not going to say they absolutely meet that standard, but it is a parallel program to
the ISO-14,001.  If the company brings in-an outside third party certifier, they, in fact, would qualify for

       We also have a parallel system for worker safety and health called Quest for the Best in Textiles.
It is  a similar type of management program. However, in this case, it is an eight-point program.

       The Care Labeling Rule was promulgated in 1971 and requires disclosure of various types of
information on the product label. For apparel and retail roll goods, for example, when you go to a retail
store and buy a bolt of fabric, information must be provided to the consumer at the point of sale on how to
care for that product. Many of you may not be aware of this requirement. The industry has been doing
this voluntarily since 1971. There is no mandatory requirement for labeling of home furnishings.

        There are no specific requirements for industrial products.  There are no requirements to tell you
how to take care of your tents or your gym bags, but textile manufacturers are required by law to provide
information to our downstream customers about the care of that product. If I were a manufacturer
providing a raw good, and selling it downstream to someone in the apparel sector, I would be required on
the disclosure of the sale (with the invoice) to provide information to my downstream customer on the
care of that product.

        ATMI supports the use of the Care Labeling Rule.  We think it is beneficial to both consumers
and manufacturers and retailers. It provides manufacturers with a product that has a longer overall life
and it protects their investment in that product. For manufacturers and retailers, it is important to us
because we know if consumers are, in fact, pleased with that product and the care of that product, they
will be a repeat customer. The Rule also gives us more freedom with our resources because we do not
have to address specific questions from consumers saying they purchased something but don't know how
to care for it.

        We were pleased in January of 1997 to see the FTC amend the Rule to allow the use of symbols.
 This is extremely important in our global marketplace and we all know that textiles are a global product.
 It is very easy to take a product and move it— a commodity, roll goods, or an apparel item or home
 furnishing item—from one country to another.

         The use of the symbols helps us  do this.  Regarding alternative planning technologies, there are a
 couple of forerunners that are out right now and I know there are a number of others that are emerging

   into the marketplace right now. The primary ones that we have been talking about or focusing on over the
   last three conferences have been on the eco or wetcleaning techniques. They are entering into the
   commercial marketplace.

         Carbon dioxide and ultrasonics at this point are really still in the exploratory stages. One thing
  that we as a textile industry really need from all of you is data. We need to know what fabrics work.  We
  need to know what fabrics aren't working.  We need to know the problems you are having with fabrics or
  apparel items, so that we can try to address those issues of integrating our products into these new
  cleaning technologies.

         But this also requires all of us to provide both qualitative and quantitative analyses, tools and
  standards, and methods in order to do this.  It is one thing to say it shrunk.  Well, how much did it shrink?
  Did you use a standardized procedure? That is the only way that we as manufacturers can qualify our
  products as we go about developing them.

         We believe that the new technologies should be integrated into the Rule, but I also would
  stipulate that it really depends on commercial availability.  We do not support a mandatory requirement to
  list all types of care instructions on labels. Let me give you an example.  To make us go about our job of
  testing the Rule against 15 different technologies becomes cost prohibitive.  Those costs are going to be
  passed on to the consumers and in a price competitive marketplace, that makes it extremely difficult for

         Let me give you another example. I brought a few props with me.  This is a wash cloth.  Now
  this is a voluntarily labeled product. This is a pre-NAFTA product given to me by my mother about 15
 years ago. It has one very, very small label and the care instructions on this label are only about three
 quarters of an inch by three eighths of an inch.

        I recently purchased a new set of towels and the label is now about two inches by one inch. The
 reason why the label size went up—the care instructions are basically exactly the same—was that, for this
 company to market its product through NAFTA, it is now required to put the instructions in English,
 Spanish, and French.  We have gone up about four times the size in order to provide this information to
 the consumer.

        If you require us to test this product against all types of cleaning technologies, we would then
 have to dryclean this product which, in my opinion, only increases the use of perc. I don't think that is the
 goal of this group. Then suppose we move to 15 different types of care symbols or care techniques, and I
 want to market that product internationally and I need to have it in 12 languages, I could end up with a
 label that is almost as large as the product.

        We know for a fact that consumers hate these large labels. We hear it constantly from them.
 They ask us to please make them smaller, please make them more concise.  This has even become a
 safety issue.  We had a member who was sued because a consumer had scratched an eye on a product
 label. Therefore, it is imperative for us to try to keep those labels as small as possible and we would
 certainly appreciate any assistance that you can give to us in that regard.

        Finally, we have one other concern about the potential licensing or trademarking of particular
types of processes with regard to symbols. That is, if I want to convey the information to the consumer
on the product label, we prefer not to see a licensing agreement or a trademark being carried on that

symbol. I have worked very diligently over the last five years with everyone at this table, on care labeling
issues related to our recent NAFTA agreement. One of the biggest stumbling blocks for us has been the
international care symbol system because there is no licensing or an intellectual market held on that
system and it actually forced the United States to go to another care labeling symbol system.

       We would very much like to integrate all of this at an international level, not just here
domestically within the United States.

       I thank you for your attention.

                                    Consumer Perspective

                                       Nancy L. Cassill, Ph.D.
                             UNC School of Human Environmental Studies

          Dr.  Nancy Cassill  serves  as  President of the  International  Textile and  Apparel
          Association and is a member of the American Collegiate Retailing Association and the
          Fashion  Group.  She is  Associate Professor  of  Textile Products  Marketing in the
          Department of Textile  Products Design and Marketing at the University of North
          Carolina at Greensboro (UNCG).
  ,   ..     21  you for ^ opportunity to participate in today's panel on care labeling. Two session goals
  for this 15-mmute presentation relate first of all to sharing with you some insights regarding today's
  consumers, including care labeling.

         The second goal is to propose some action plans to move consumer awareness and understanding
  forward. To address  the first goal, I would like to begin by sharing some consumer insights with an
  environmental scan of today's consumers and then narrow the focus to include consumers and care
         IWIN is an acronym meaning "I want it now" that is used by Kurt Salmon Associates KSA
  known to some of you, to coin today's consumer.  "I want it now" refers to consumers wanting products
  services, and satisfaction with textile and apparel products and services. Consumers are demanding    '
  Consumers are vocal and the winners— the fiber producers, the mills, the manufacturers, contractors
  retailers and fabncare specialists— are companies with the strongest consumer loyalty. That means thev
  are meeting consumer demand now.                                   ,

        Today's consumers know for the most part what they want and they are tough critics in the
 marketplace. For example, a recent study completed at UNCG found that in working with a department
 store in apparel sportswear, the most loyal consumers were also those who were the most dissatisfied
 We reached the conclusion, at least with this sample, in working with this department store unit that
 familiarity can breed contempt.

        Apparel consumers are making savvy purchases and are value driven spenders. Some consumers
 are practical thinkers, going through a very detailed thought process. For example, for some consumers
  dryclean only  requires a considerable thought process prior to purchasing a product.'

       Today's consumers are also seeking value for the dollar, and value and value-added strategies are
 two concepts that have been discussed in various sessions  at this conference. Consumers are also
 selecting apparel products that fit various lifestyle choices. Thus, we have seen an increase in the
 marketplace in outdoor apparel products and many have innovative performance fabrics.

       Consumers are time starved, with some consumers shopping less than, believe it or not, one hour
per month. In contrast, some teenagers are shopping in excess  of 12 hours per month and they have the
discretionary income to both shop and purchase during those 12 plus hours

       Let's narrow the focus on consumers and look at consumer apparel preferences. Today's
consumers are seeking, in general, comfort over couture and they have apparel preferences for versatile,
comfortable and affordable apparel. There has been the continuation of the casual workplace and the
introduction m the last 18 months of what is known as the third wardrobe. This third wardrobe is
something that has occurred since I reported at the EPA conference in 1996. A third wardrobe is a
wardrobe that facilitates transition from the office or the business environment to the social environment.

       What is encouraging to the fabricare specialists is that a high percentage of this third wardrobe is
dryclean only and offers some drycleaning and wetcleaning opportunities for the fabricare specialist.
There has also been continued growth in terms of performance fibers and fabrics.

       Now, my home town is Greensboro, North Carolina, and I am proud to say that we have a
Significant amount of fiber and fabric and manufacturing innovation occurring in Greensboro. Many of
these companies that have made significant investments, not only in capital but also in human resources,
are really leading the way in the global marketplace with fibers, fabrics, finishes and end use
manufacturing. Many of these innovations are going to produce some interesting challenges and
opportunities for the fabricare industry.

        Value is also a word that is heard frequently.  Research conducted at UNCG has found an
interesting apparel value equation. The numerator and denominator are no longer price value
relationships with apparel products for consumers. In the numerator, you have issues that are not only
product attributes, but marketing issues, and then the social psychological aspects in terms of nsk and
self-confidence factors. In the denominator, for the consumer's value equation, are the cost factors. But
this is not just the cost of the product; consumers are factoring in the continual cost of the care processes
that must be required for  the product.

        The term "value" is still both overused and underused, especially as it relates to consumer's care.
Let's look at  care labeling as it relates to consumers because care labeling and consumers' understanding
of it remain a very challenging research area.  Today's consumers are educated and are, for the most part,
label conscious. For these consumers, care is an important criterion as they enter the marketplace to
evaluate apparel products.

        However, for these consumers, care may not be the most important criterion; it may come into
 consideration but the final decision in terms of purchasing a product may not be primarily for the care
 requirement. Brands are still strong in the marketplace and, since 1996, we have seen a growth m what
 we would call the non-traditional brands.  We have seen real excitement but also growth in the private
 label programs at department stores.  I think Arizona brand is a classic example of those, as well as the
 private labels of some of the specialty stores, such as the Gap and in the Limited's array of their products.

        These brands are strong, have grown over time, and continue to have the implications of being
 even stronger. Thus, it is extremely important that the private label retail representatives be brought into
 your discussions because they are making decisions related to care issues.

         Other issues about labeling relate to country of origin and fiber content. You are aware that as of
 July 1st 1997 care symbols can be used with care requirements on care labels. You have already heard
 some issues expressed by other panel members related to additional cost, as well as consumers' frustration
 with adding both more labels and larger labels.

          A recent focus group at UNC Greensboro found that consumers did notice care symbols, but were
  not knowledgeable about what they represented in terms of care requirements. As a result, a challenge
  exists for alternative cleaning methods, such as wetcleaning when, in fact, there is little known from the
  consumer's point of view about existing care requirements, such as drycleaning and hand wash only or
  hand wash. Consumers are distrustful in part with low labeling, and some just do not trust any labeling at

         Let's take care a step further and look at some of the fabricare services.  "Just Do It" is a slogan
  that is used by Nike, but it is also used by consumers seeking professional fabricare services.  When
  consumers fear care labels, they are not educated about the differences between drycleaning and
  professional laundry services. Nor are they educated about the differences between wetcleaning and
  professional laundry and home laundry. I reported this information in 1996 at the EPA conference, and
  there has been little change in consumers' understanding of fabricare services, except for the brief pilot
  studies that have been shared at this conference.

         Another care labeling issue relates to care responsibilities. The female is the predominant fabric
  caregiver. She is also making 70 plus percent of all apparel product purchases in the marketplace. With
  new technology and new and improved agents and developments, there  are more opportunities for home
  laundry for today's products.

        Earlier I mentioned performance fabric innovation. We are seeing more and more performance
  fabrics in the marketplace; and many of these lend themselves to home laundry. However, opportunities
  do exist for the approximately 55 to 65 percent of the population that use some degree of professional
  fabricare services.

        Remember that today's consumers have time compression, the need for a professional
 appearance, are again purchasing business apparel that supplements their casual business wardrobe, and
 are open to product newness. We have seen product sameness in the marketplace for several years and
 now we are seeing some product innovation in the textile and apparel area.  Consequently, there are still
 opportunities for this.

        Where do consumers learn about care requirements?  From two sources.  One is personal sources
 and experience. The second relates to nonpersonal sources. Personal sources include history, such as
 personal or parental or family influence, and consultation with personnel and the retailer, the work
 environment. Non-personal sources include some care information, including the hang tags and the care

        Where  do consumers get help with care questions? Again, from  personal sources, the fabricare
 professional, friends, family, work and sales associates, and non-personal print sources. Personal and
 nonpersonal approaches should be used in implementing educational strategies that are discussed in your
 work groups.

       Manfred Wentz has proposed a textile spectrum and I want to propose a consumer spectrum for
addressing consumer care label issues.  A mass market approach to this important issue—meaning that
you would be trying to address issues and concerns of all consumers—would be both an ambitious and a
very frustrating experience.

       Research at UNCG has found that there are three demographics that provide one way to segment
consumers regarding care issues: age, income and employment. Those of you in the audience with some
consumer research in your background recognize that using demographics as a segmentation tool will
give you a prediction power of only about 10 percent, predicting about 10 percent of what consumers will

       Therefore, you can add another marketing tool called psychographics.  These are the lifestyle
issues related to how consumers spend their time and their money. That bolsters your predictability,
perhaps up to 20 or 30 percent, depending upon the variables in your consumer sample. In this
example—and this is one of many that can be discussed in the workgroups as well as the general session,
we have taken just a psychographic in terms of taking employment a step further and learned from those
employed consumers their orientation to employment.

        Is it a professional orientation in terms of a career or is it considered more than just a job? I
would propose, and past research has found, there are some real market opportunities for the fabricare
industry, especially with alternative cleaning methods for the professional  or career segment. This
happens to be a segment that, both in history and today, is outsourcing the business apparel and the
business casual with the fabricare specialists.

        Ed Barlow's presentation on Tuesday morning challenged conference participants to understand
and take action regarding six 21st Century success dynamics.  Two of these dynamics, real time
responsiveness and obsession with customer satisfaction, merit attention in researching today and
tomorrow's fabricare consumer.

        I would like to briefly propose five action plans for consideration and discussion.  The first one is
get to know your consumer. How do you do that? Ask the consumer.  A large consumer study needs to
be undertaken to find out the issues, the answers, and the level of education of consumers in the

        Who is and who should be buying care services? In addition to asking the consumer, explore data
mining opportunities. Well, your question is how do you data mine, perhaps, or where can we get data
that assist us? Some of the representatives here at the conference have already offered to share some of
the data that they have in-house or from their studies.

        Go to your fabricare specialists in your plants for data that they have collected. Don't forget
about your partners in retail, who are very efficiently mining their databases, predominantly their credit
card data in terms of product purchases, as well as expenditures. And you can tie that back to SKUs in
terms of style types and care requirements.  Don't forget about your apparel producers. Who are also data
mining. They have access because of category management programs that they have with retailers and
have a significant amount of data.  Mills are also becoming more vertical and have great information.
While it may be more qualitative information, that would be helpful to you as well.

        What is driving the decision? We must answer this question. That seems to be a question that
perhaps is a source of unknown information and may be a source of frustration.

        What attitudes do consumers have about environmental actions with apparel products? Do we
 know the answer to that question? How do these attitudes translate and when do they translate into
 behaviors, such as purchasing behavior and care behaviors?

       , You must know consumer awareness before you know the proper way to educate the consumers.
 After completing action plan 1,1 would propose action plan 2, to find ways to creatively create consumer
 pull through. Wetcleaning pilot data has been shared at this conference.  Collect and use consumer
 research to establish and implement strategic plans to market wetcleaning to consumers.

       The third action plan is to invest in building and maintaining customer loyalty. We all know the
 adage that maintaining a current customer is more cost effective than recruiting a new customer.
 Completion, I propose, of action plans 1 and 1, can lead to customer loyalty strategies. This then can be
 factored into the system in the various workgroups to build consumer-focused processes and to give the
 group insights in terms of marketing, especially alternate care services. And then, finally, structure the
plan around consumers' needs, preferences, and behaviors.

       Thank you.

               Consumer Perspectives:  Care
               Nancy L Cassill, Ph.D.
               Textile Products Design and
               University of North Carolina at
               "Age of the Consumer" (KSA,
               • I WIN CI_WANT]T NOW")
               • Demand dictates supply
               • WINNERS: Companies with strongest
                 consumer loyalty
Consumer Perspectives: Care Labeling

             If  Insight: Today's Consumer

                    - Know what they want
                    - Tough Critics
                    - Savvy Purchases
                    - Value Driven Spenders
                    — Practical Thinkers
                 InsightrToday's Consumer
                   - Greater Demand for their Dollar
                   - Apparel vs. Lifestyle Choices
                   - "Time Starved"
Consumer Perspectives: Care Labeling


                  Insight:  Apparel Preferences

                  • Comfort over couture
                    - Versatile
                    - Affordable
                  • Continuation"of Casual Workplace
                  • Growth of Performance Fabrics
                  • Value: Care is part of cost
                  Insight:  Care Labeling

                  • Educated consumers who are label
                    - Care is important criteria
                    - Care labels are important
                    - Brands are still strong
                      • "Non-traditional" brands even stronger
                    - Country of origin
                    - Fiber Content
Consumer Perspectives: Care Labeling

                  Insight:  Care Labeling

                  • Notice care symbols but do not
                  • Distrust with "low labeling"
                  • Distrust with all labeling
                 Insight: Fabricate Services

                 • Not educated about difference between
                   dry cleaning and professional laundry
                 • Not educated about difference between
                   wet cleaning and professional
                   laundry/home laundry
Consumer Perspectives: Care Labeling

                Insight: Care Responsibilities

                • More possibilities for home laundry
                  (today's fabrics)
                • Reality-PROFESSIONAL
                   - Time Compression
                   - Professional Appearance
                   - Resurgence in Business Apparel
                   - Blends/Product Innovation
.'-'.-' i»
                 Insight:  Where Learn About
                 • History ("Parental Influence")
                 • Trial and Error
                 • Care Label
                 • Consultation (Retail Sales, Friends,
Consumer Perspectives: Care Labeling

L. -TV to
                 Insight:  Help with Questions
                   - Care Label
                   - Detergent Package
                   - Fabricare Professional
                   — Associates
                 Insight:  Care Consumer
                 Segmentation (CCS)
                 • Age
                 • Income
                 • Employment
Consumer Perspectives: Care Labeling

                 Insight:  Employment

                 "Outsourcing for
                  Business Apparel
                  Business Casual
vs.      Service

  *Home Laundry
                 Insight:  Action Plans

                 #1 Get to Know Your Consumer
                   - Who is/should be buying care services?
                   - What is driving the decision?
                   - How can you reach?
Consumer Perspectives: Care Labeling

                   Insight:  Action Plans

                   #2 Find Ways to Create Consumer Pull-
                     - Use insights to predict care needs
               fe  3/20/98
                  Insight: Action Plans

                  #3 Invest in Building and Maintaining
                    Consumer Loyalty
                    - Satisfy current consumers before attracting
                      new consumers
Consumer Perspectives: Care Labeling

'. r-e.-asvt
                  Insight:  Action Plans

                  #4 Build Consumer-Focused Processes
                    - Use Insights in marketing (care services)

                 Insight: Action Plans

                 #5 Structure Plan around Consumers'
                   Needs, Preferences, User-behavior
Consumer Perspectives: Care Labeling

             Report from Apparel-Retail-Consumer Discussion Group
                                     Barbara Warren, Chair
               Well, the first bit of news is that the Apparel-Retail-Consumer Discussion Group met and
we are now a workgroup, I guess, and we also, interestingly, had some discussion and decided after the
whole session to stay together. So, I think that is an interesting development.

               At first, we thought that it might be more appropriate that the consumer be split off from
apparel and retail. But we had enough issues in common to feel that it might be useful for us to stay
together, at least at this point.

               So, we have two co-chairs, Margit Machacek, and me, Barbara Warren. I hope I am
saying it right. We found it very useful to list issues that were consumer issues, retail issues, and apparel
issues. We brought up things that have been brought up before in some of the other workgroups, such as
the labeling issue, proper garment care, quality of the services, education at all levels testing, test methods
in terms of industrial ecology, and the design and construction of the garments and the importance of
design and construction.

               We even got into the  education of the buyers; independent testing labs.  One common
issue was the information pipeline.  I think the information pipeline is a very interesting issue.

               Finally, we talked about—you have to remember this is our first time together—about
getting additional parties involved.  I think each person who was with a consumer organization, either
retail or apparel, is sort of charged with trying to think about who else needs to be involved in this

               At our next meeting, hopefully, we will identify some goals for our work group.

                 Report from Outreach and Education Workgroup
                                   Sylvia Ewing-Hoover, Chair
        The Education and Outreach Committee had, I think, a very productive meeting and we have a
couple of date lines for people who are participating that you may want to share in the general body.  By
the 10th of April we wanted to start collecting education and outreach-related materials that you may have
in-house.  We found that people here didn't know about some of the resources that exist. So, in keeping
with our goal, our first goal of being a clearinghouse for information, if you have materials that you think
we should have, please send them to CNT by April  10th, to the attention of Anthony Star.

        On the 17th of April, in keeping with another one of our goals, please send to Sid Leiken of
Prestige Cleaners any material related to certification. We know that this goes across the workgroups, but
we wanted to, again, start to be a clearinghouse for information on how states have handled outreach and
education. Steve Risotto and other people are going to share information from Canada and other places.

        Our main strategy and first goal is to educate cleaners and to help them educate their customers.  •
We know that we will probably be working with a consumer group, but our main focus is not yet the
broader population, but rather people who are customers or whom the cleaners hope will be customers of
their shops.  To that end, we want to put together generic marketing material and work on a definition of
wetcleaning. This is not technical information for the technical people, but rather information to help
cleaners explain how what they do is different from laundry and to help their customers understand why it
is done in a professional setting.

        So, again, we will be working in synergy with people who are probably developing that kind of
definition for a more technical purpose in the long run, but our main focus is marketing and consumer
education and customer education purposes.

        Participants strongly expressed the need for two things. One was a matrix, but a quick and
accessible one.  Some of the other committees will be working on this also.  We wanted to make sure that
we could at least have a collection of some alternative packages of materials so that cleaners soon would
be able to get the last IFI matrix and whatever other matrices are available, as well as the latest
information on the pros and cons of wetcleaning and other alternatives.  So, that is something that we
wanted to see happen quickly and we have a committee working on that. We haven't set a deadline, but
we will because I know Mary Ellen wants one.

       Overall, the focus of our committee, again, is to make cleaners successful by having information
to help them do their job better, explain it better, and keep customers coming in.  And that is the first step
of our committee.

       Thank you.

                             Report from Textile Workgroup
                                         Kay Villa, Chair
        I represent the Textile Working Group. I would like to show you the goals. We had 11
 participants in our working group and we devised these goals.  We modified our original goals and, in
 fact, made a couple of other modifications, additions, and editorial changes.

        But this gives you a rank order of what we really foresee as where we are going and what we
 want to do. As a first goal, we definitely need a definition for alternative cleaning practices and
 wetcleaning. That is imperative to the textile and apparel sectors. If we don't know what we are talking
 about, we don't know how to begin to change and modify the product so that these items or our fabrics or
 components, in fact, can be cleaned through these new technologies.

        The second goal was to develop test methods and accompanying definitions, so that we can do
 the assessment.

        Then the third goal was to identify issues related to care labeling practices in general.

        The fourth goal was to create and implement methods of communications throughout the entire
 pipeline, from the fiber side of the business, all the way down through the consumer to the fabricare

        Alternative Cleaning Procedures (ACPs) should be developed in an environmentally friendly and
 cost effective manner. Economics is really what is going to drive this. So, we want to make it viable for
 all parties and for consumers to make sure that these new technologies, in fact, can coincide with business
 practices. We felt it was important that retailers are really a central stakeholder in all of this because as a
 textile representative, it doesn't matter what someone wants me to do. It is really what the customer is
 going to buy. The ultimate group that makes the decisions on what is sold is the retailer. So, it is
 imperative, in fact, that retailers be informed about these new practices and can begin to take some steps
 to implement or make decisions on products.

       That, in turn, forces us, as textile manufacturers, to  try to be working along this pipesrream to
 make sure that all of the products that we are putting out there are compatible. You can't make a  leap of
 faith from fabricare all the way up to the textile sector; everyone else in between must be involved. But
 the retailers are a key player in all of this.

       The last goal involves ways to incorporate environmental life cycle considerations into academic
programs, academic programs for textile manufacturing, apparel and retail. If we want to see this
continuum all along the pipeline, our new people coming through our new replacements into our jobs and
into careers in the field, in fact, must be aware of these considerations.

       So, these are the goals. A specific work item that we have identified to be worked on
immediately is a recommendation that a definition of wetcleaning be developed by the American
Association of Textile Chemists and Colorists in their Research Committee RA43.

       They will be meeting during, the last week of May in Baltimore, Maryland.  If you want more
information on the meeting, their phone number is 919-549-8141. We really would like to see companies
with new technologies or operating wetcleaning operations to attend those meetings so you can begin to
convey information to us and we can develop those test methods.

       The second thing we talked about was more specific, developing different types of test methods,
not only for a component, but also for the end article. It is not just a matter of testing the shrinkage of a
fabric, but also the shrinkage of an entire garment. What we are talking about is long-term performance
standards for end items. That is a long-term commitment but that work will be ongoing.

       We recommend that AATCC hold a forum in the  near future to bring together the companies or
parties involved in these new  alternative cleaning processes to meet with the technical people who are
involved in developing test methods and standards. In many ways, if you do that, you will reach
members of the apparel and retail and textile communities.

       We also recommend development of a database of problems. For instance, one item that was
suggested is that a survey could be developed to be handed out to new alternative cleaning processing
organizations or companies. Where you are having problems, fill out a form and explain the problem.

       As a textile manufacturer, if you tell me rayon is a problem, I will say, well, okay, rayon is a
problem. If you tell me a rayon crepe with a turquoise dye is the problem, then it becomes much more
tangible for me to identify specific types of processes that, in fact, may have to be modified.

       Our fifth recommendation is to try to get more retail organizations and retailers and importers
involved in all of this. The last recommendation was to try to establish some linkage between fabricare
interests and the sundries manufacturers and that is one key stakeholder we think'is really missing—that
is, the interface in spots and zippers. Those types of companies, in fact, that produce those products are
not involved in this process also need to be involved.

       And that ends my report.

                  Report from Science and Technology Workgroup
                                     Manfred Wentz, Chair
        I am reporting on the Science and Technology Workgroup.

        There were 24 participants at the workgroup meeting.  We began by reviewing the document
 from the January conference and spent a great deal of time discussing real world studies in comparison
 with laboratory studies. We recognize that there is a need for both of them and that laboratory studies
 would be used to establish a baseline, but, that whatever that baseline is, it needs to be put into the real
 world in order to be evaluated.

        So, we redefined the goals of the committee. There were five goals identified at the January
 meeting and we decided that the most important and the predominant goal of the committee was to
 develop an objective way of assessing emerging technologies.  The group decided to start with the EFI
 matrix, look at the criteria and the technologies to be evaluated, and try to find both criteria and

        We vowed to have this done. Each person in the workgroup would have this done and submit it
 to EPA by a June/July time frame and then Cindy Stroup would compile that and pass that around to all
 of us in the workgroup and we would refine it. This way we can all be on the same page talking about the
 same thing when we are talking about technology assessment.

        The second goal we identified was to develop an outreach program. We thought that it would
 best be handled by another committee but that our committee would generate the science or the
 technology that it was based upon, so that it is based upon sound science. Thus, we would be responsible
 for developing that.

        The third goal was to change care labels, to recognize alternative cleaning technologies and each
 individual committee member will respond to FTC because, obviously, they are the ones who will change
 the care labeling requirements. But we have an obligation to respond to the FTC and to give them our

        The fourth goal was to develop a standard definition of wetcleaning and each member made a
 commitment to respond to the FTC on the definition of wetcleaning and to give input, so that one
 standardized definition can be developed.

        Goal five, finally, is to maintain regulatory stability, which seemed like a good idea to all of us in
the committee. However, we realized that this is out of our domain, so we removed that as one of the
goals of the committee.

        Essentially, that is what we accomplished.

                        Report from Dry Cleaners Workgroup
                                        Bill Seitz, Chair
        Before I get into my remarks or the committee remarks, I would just like to at least speak for
 myself and say that I thought that the time that we have spent here was very, very well spent.

        I would like to thank Mary Ellen Weber for the fine job she did in stepping in for Cindy Stroup,
 who unfortunately couldn't be with us.  And I personally think you did an excellent job.

        I would like to thank Cindy Stroup for all the work that she did in preparation, and the excellent
job of EPA staff and the staff of Westat, who did an excellent job and I think we want to thank them.

        And from an industry perspective, I don't know how many of you know how these things get
 together, but there was a key person from industry, who helped coordinate this program and I would like
 to thank Manfred Wentz for the excellent job that he did behind the scenes in helping make this the great
 success that it has been.

        There was some frustration with the group that I was involved in and it just wasn't with me.  I
 have to quote my good friend Manfred's comments yesterday that frustration isn't bad if you can turn it
 into a positive action.  That is what we tried to do.

        Probably the most important part of what was discussed was the need to reach the people who we
have all been talking about, but unfortunately didn't show up in large numbers and that is the drycleaner.
The reasons are obvious.  It was a weekday. It was very expensive. These fellows and gals are working.

        But unless we find a way of communicating all the things that we accomplished or hoped to
accomplish with the grassroots, then we will have not wasted our time, but will not have taken advantage
of our time as well as we could.

        So, for the short term, the primary objective is to reach the grassroots. How do we get out the
message?  The message has got to be more than just the printed pamphlet, a brochure. It has got to be
some way of communicating with these people on an eyeball to eyeball, one to one, or a group basis.
Some of the suggestions were to work more closely with the allied trades in getting that message across
the possibility of holding area meetings so that we can talk to the people who are most affected by the
actions that we are taking.

        Other issues include the concerns of the drycleaner, the uncertainty of what he or she has to do
about the future, and dealing with the reality of problems that exist, the environmental problems, the
remediation problem, the legislation that is pending—HR1711—and how government feels about that and
whether it is prepared to support that action.

       We also need to find a way of keeping the momentum and the synergy of working with all of the
other groups that are sitting at this table; developing a matrix, the objective evaluation of alternative
technology, the equipment and the effectiveness of the equipment;  financial assistance to small business
in being able to afford the equipment we also need a technical evaluation of the equipment, that is, the
feasibility, depending upon size, economics, the nature of the business, the health and environmental

considerations of making these new changes work, and certainly the importance of care labeling and the
clarity and practicality of what comes out in terms of guidance for the industry.

       That was kind of short term, mid term; long term—a certification program, a certification of
equipment, a certification of operators and a certification of the facilities. If we can do that all by the end
of next week, we will have accomplished our objective.

       Thank you.


                                           EPA Dfe GTCP
                                      1998 Conference Attendees
 Mr. Adamson, Ken C.
 General Manager

 Langley Parisian Fabricare Services
 12 Walnut Street. South Hamilton, Ontario  L8N 2K7
 Business Phone: (905) 522-4651
 Business Fax: (905) 529-5856
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Barlow, Ed

 Creating the Future, Inc.
 Suite 100 St. Josephs, MI 49085
 Business Phone: 616/429-2601
 Business Fax: 616/429-2603
 Home Phone:
 Home Fax:
 E-Mail: barlow@QTM.NET
 Web Site:
 Mr. Aldridge, Mahlon
 Director, Pollution Prevention Programs

 Ecology Action, Inc.
 P.O. Box 1188 Santa Cruz, CA 95061-1188  USA
 Business Phone: 408-426-5925 x!6
 Business Fax: 408/425-1404
 Home Phone: 408/457-9275
 Home Fax: 408/426-2533
 Web Site:
 Ms. Barnert, Debbie
 Director-District Four

 International Fabricare Institute (IF1)
 The Washboard
 7031 E. 10th Street Indianapolis, IN 46219
 Business Phone: 317/353-1286
 Business Fax: 317/322-0132
 Home Phone:
 Home Fax:
 Web Site:
Dr. Allenby, Braden R.
Vice President

AT&T Environment, Health & Safety
20 Independence Blvd.
Rm# 4B42 Warren, NJ  07059
Business Phone: 908/580-5800
Business Fax: 908/580-6633
Home Phone:
Home Fax:
Web Site:
Dr. Bates, Stephen

Rynex Holdings, Ltd.
7600 Jericho Turnpike Woodbury, NY  11797  USA
Business Phone: 516/364-8993 ext.18
Business Fax: 516/364-0802
Home Phone:
Home Fax:
Web Site:
Ms. Armbruster, Melinda

505 King Ave Columbus, OH 43201
Business Phone: 614/424-4911
Business Fax: 614/424-4250
Home Phone:
Home Fax:
Web Site:
Mr. Battiston, Jeffrey

Battiston Cleaners
565 New Park Ave. W. Hartford, CT 06110
Business Phone: 860/232-6930
Business Fax: 860/231-9245
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Mr. Beard, Ross

R. R. Street & Co., Inc.
184ShumanBlvd.Naperville, IL 60563-8464  USA
Business Phone: 630-416-4244 ext200
Business Fax: 630-416-4150
Home Phone:
Home Fax:
Web Site:
Mr. Belluscio, Jack

Global Technologies
222 North Sepulveda Blvd., Suite 2200 El Segundo, CA
90245 USA
Business Phone: (310) 414-9684
Business Fax: (310) 414-9682
Home Phone:
Home Fax:
Web Site:
Mr. Becker, Paul

Rynex Holdings, Inc.
222 Wellington Road Mineola, NY 11501
Business Phone: 516/739-8843
Business Fax:
Home Phone:
Home Fax:
Web Site:
Ms. Bering, Merry

Michigan Institute of Laundering & Drycleaning, Inc.
PO Box 14044 Lansing, MI 48901
Business Phone: 517-337-2909
Business Fax: 517-337-2811
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Mr. Beckman, John T.
Chemical Product Manager

Laidlaw, Inc.
1212 East 5th Street
P.O. Box 480 Metropolis, IL 62960
Business Phone: 800/851-7731 ext.210
Business Fax: 618/524-2776
Home Phone:
Home Fax:
Web Site:
 Mr. Bell, Buster

 Bell Laundry and Cleaners
 448 Marion Ave. Spartanburg, SC 29306 USA
 Business Phone: 864-583-8668
 Business Fax: 864-583-0202
 Home Phone:
 Home Fax:
 E-Mail: no email
 Web Site:
Ms. Berlin-Blackman, Ann

University of Massachusettes Lowell
1 University Ave. Lowell, MA  01854 USA
Business Phone: 978/934-3124
Business Fax: 978/934-3050
Home Phone:
Home Fax:
Web Site:
 Dr. Berning, Carol K.
 Research Fellow

 The Procter & Gamble Company
 6060 Center Hill Ave. Cincinnati, OH 45224
 Business Phone: 513/634-6180
 Business Fax: 513/634-6103
 Home Phone:
 Home Fax:
 Web Site:

                                            EPA Dfe GTCP
                                      1998 Conference Attendees
 Ms. Birnbaum, Nancy
 Environmental Protection Specialist

 US EPA Office of Reinvention
 401 M Street SW( 1802) Washington, DC 20460
 Business Phone: 202/260-2601
 Business Fax: 202/401-2474
 Home Phone:
 Home Fax:
 E-Mail: birnbaum,
 Web Site:
                                                   Ms. Boorstein, Ruth

                                                   Prestige...Exceptional Fabricare
                                                   9420 Georgia Ave. Silver Spring, MD 20910-1434
                                                   Business Phone: 301/588-0333
                                                   Business Fax: 301/588-7914
                                                   Home Phone:
                                                   Home Fax:
                                                   Web Site:
 Mr. Bogert, John
 South Central Sales Manager

 Boewe Permac (BUFA)
 13628 Beta Road Dallas, TX 75244
 Business Phone: 972/317-9686
 Business Fax: 972/317-0843
 Home Phone:
 Home Fax:
 Web Site:
                                                  Mr. Boyle, Joseph
                                                  Environmental Specialist

                                                  US EPA
                                                  401 M. Street SW (7408)
                                                  WSM E511C Washington, DC 20460
                                                  Business Phone: 202/260-1802
                                                  Business Fax: 202/260-2219
                                                  Home Phone:
                                                  Home Fax:
                                                  Web Site:
Mr. Bolon, Paul
Director of Policy

OSHA- US Labor Dept
200 Constitution Ave. NW, Room N3627 Washington,
20210 USA
Business Phone: 202/693-1960
Business Fax: 202/693-1641
Home Phone:
Home Fax:
Web Site:
                                                  Dr. Breen, Joseph
                                                  Executive Director

                                                  Green Chemistry Institute
                                                  1650 Research Blvd Rockville, MD 20850
                                                  Business Phone: (301) 294-2854
                                                  Business Fax: (301) 294-2829
                                                  Home Phone: (703) 243-1248
                                                  Home Fax:
                                                  Web Site:
Mr. Boorstein, Edward

Prestige...Exceptional Fabricare
9420 Georgia Ave. Silver Spring, MD 20910-1434 USA
Business Phone: 301-588-0333
Business Fax: 301/588-7914
Home Phone: 301/493-5060
Home Fax:
Web Site:
                                                 Mr. Burt, Robert
                                                 Acting Director

                                                 OSHA / Office of Regulatory Analysis
                                                 200 Constitution Ave.
                                                 N3627 Washington, DC 20210-0001
                                                 Business Phone: 202/219-4690 ext.139
                                                 Business Fax: 202/219-4383
                                                 Home Phone:
                                                 Home Fax:
                                                 Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Dr. Buxton, Bruce

505 King Ave. Columbus, OH 43201 USA
Business Phone: 614-424-4547
Business Fax: 614-424-4250
Home Phone:
Home Fax:
Web Site:
Ms. Chadbourne, Mary
Project Coordinator

Camp, Inc.
Organochlorine Project
18554 Haskins Road Chiagrin Falls, OH 44023-1823
Business Phone: 440/543-7303
Business Fax: 440/543-7160
Home Phone:
Home Fax:
Web Site:
Mr. Carra, Joseph
Deputy Director

Office of Pollution Prevention and Toxic Substances
401 M. Street SW(7401) Washington, DC 20460
Business Phone: 202/260-1815
Business Fax: 202/260-0575
Home Phone:
Home Fax:
Web Site:
Mr. Childers, Everett
Consultant & Educator

P.O. Box 1005 Vancouver, WA 98660 USA
Business Phone: 360/750-5684
Business Fax: 360/750-5684
Home Phone:
Home Fax:
Web Site:
Dr. Cassill, Nancy

School of Human Environmental Sciences
Univ of NC, Dept of Clothing and Textiles
210 Stone Building Greensboro, NC 27412-5001 USA
Business Phone: 336/334-5250
Business Fax: 336/334-5614
Home Phone: 336/282-0166
Home Fax:
Web Site:
Mr. Cho, Abraham
Environmental Protection Advisor

Korean-American Cleaners Association of New Jersey
Mountainside Cleaners
512 Lincoln Hwy., 2nd Floor Iselin, NJ 08830 USA
Business Phone: 732/283-5135
Business Fax: 732/283-5137
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Mr. Chadbourne, Joe M.
Project Coordinator

Camp, Inc.
Organochlorine project
18554 Haskins Road Chiagrin Falls, OH  44023-1823
Business Phone: 440/543-7303
Business Fax: 440/543-7160
Home Phone:
Home Fax:
Web Site:
Ms. Cho, Jenni
Program Manager

Korean Youth and Community Center K.Y.C.C.
680 South Wilton Place Los Angeles, CA 90005  USA
Business Phone: (213) 365-7400 xl 18
Business Fax: (213) 383-1280
Home Phone:
Home Fax:
Web Site:

                                            EPA Dfe GTCP
                                       1998 Conference Attendees
 Mr. Choi, Sam
 Vice President of Asian Affairs

 International Fabricare Institute
 12251 Tech Road Silver Spring, MD 20904 USA
 Business Phone: 301-622-1900 ext.148
 Business Fax: 301-622-1568
 Home Phone:
 Home Fax:
 Web Site:
  Dr. Daniels, John
  Executive Director

  1 Davis Drive Research Triangle Park, NC 27709
  Business Phone: 919/549-8141
  Business Fax: 919/549-8933
  Home Phone:
  Home Fax:
  Web Site:
 Mr. Chun, Moon Jong

 Federation of Korean Drycleaners Associations
 Sanda II
 215 Elm Street New Canaan, CT 06840
 Business Phone: 203/966-2019
 Business Fax: (203) 966-3609
 Home Phone: 203/834-2785
 Home Fax:
 E-Mail: no email
 Web Site:
 Mr. Darvin, Charles H.

 NRMRL-APPCD (MD-61) Research Triangle Park, NC
 27711 USA
 Business Phone: (919) 541-7633
 Business Fax: (919) 541-7891
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Coffie, Dave
 Environmental Protection Specialist

 Defense Logistics Agency
 8725 John J. Kingman Road Ft. Belvoir, VA 22060-6221
 Business Phone: 703/767-2614
 Business Fax: 703/767-2628
 Home Phone:
 Home Fax:
 Web Site:
Mr. Cotter, Dave

Textile Care Allied Trades Association (TCATA)
271 Rte 46 West, Suite D203 Fairfield, NJ 07004  USA
Business Phone: 973/244-1790
Business Fax: 973/244-4455
Home Phone:
Home Fax:
Web Site:
 Ms. Davis, Debra

 Cleaner By Nature
 33I7LaCienegaLosAngeles,CA 90016 USA
 Business Phone: 310/315-1520
 Business Fax: 310/815-8405 call 1 st
 Home Phone:
 Home Fax:
 Web Site:
Dr. Davis, Mike

Westat, Inc.
1600 Research Blvd.
RA 1408 Rockville, MD 20850 USA
Business Phone: 301/294-2833
Business Fax: 301/294-2829
Home Phone:
Home Fax:
Web Site:

                                           EPA Dfe GTCP
                                     1998 Conference Attendees
Mr. Dawson, David

Textile Care Allied Trades Association (TCATA)
Suite 150 Naperville, IL 60563
Business Phone: 630/416-6716
Business Fax: 630/416-4150
Home Phone:
Home Fax:
Web Site:
Mr. Dickinson, Elden
Chief Drycleaning Program

Michigan Dept. of Environmental Quality
3423 North Martin Luther King Jr. Blvd. Lansing, MI
Business Phone: 517/335-8251
Business Fax: 517/335-9033
Home Phone:
Home Fax:
Web Site:
Ms. Delia Torre, Karen

Westat, Inc.
1600 Research Blvd.
RA 1438 Rockville, MD 20850 USA
Business Phone: 301/294-2832
Business Fax: 301/294-2829
Home Phone:
Home Fax:
Web Site:
Mr. DeRosa, Dave

417 South Dearborn Street
Suite 420 Chicago, IL 60605 USA
Business Phone: 312/554-1028
Business Fax: 312/554-1224
Home Phone:
Home Fax:
Web Site:
Mr. Deutsch, Joel
Executive Director

Southeastern Fabricare Association (SEFA)
500 Sugar Mill Rd, Suite 200-A Atlanta, GA 30350-2886
Business Phone: 800-998-7332
Business Fax: 770-998-1441
Home Phone:
Home Fax:
Web Site:
Ms. Eggert, Liz
Research Associate

The Procter & Gamble Company
Ivorydale Technical Center
5299 Spring Grove Ave. Cincinnati, OH 45217
Business Phone: 513/627-5824
Business Fax: 513/627-5690
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Ms. Engel, Eileen
Deputy Exec. Director of Nat! PETE

6601 Owen Drive
Suite 235 Pleasenton, CA  94588
Business Phone: 925/225-0069
Business Fax: 925/225-0679
Home Phone:
Home Fax:
Web Site:
Dr. Engelbach, Peggy
Assistant Professor

Indiana State University
Department of Family and Consumer Sciences Terre
Haute, IN 47809  USA
Business Phone: (812) 237-3305
Business Fax:
Home Phone:
Home Fax:
Web Site:

                                            EPA Dfe GTCP
                                       1998 Conference Attendees
  Ms. Engle, Mary K.
  Assistant Director of the Enforcement Div.

  Federal Trade Commission
  601 Pennsylvania Avenue, N.W., Room4302(S)
  Washington, D.C. 20580
  Business Phone: (202) 326-3161
  Business Fax: (202) 326-2558 or 3259
  Home Phone:
  Home Fax:
  Web Site:
  Mr. Fischer, Earl V.

  American Drycleaner
  Grain Associated Enterprises Inc.
  500 N Dearborn Chicago, IL 60610 USA
  Business Phone: 312/337-7700
  Business Fax: 312/337-8654
  Home Phone:
  Home Fax:
  Web Site:
 Ms. Ewing, Sylvia

 Center for Neighborhood Technology
 2125 West North Avenue Chicago, IL 60647 USA
 Business Phone: 773/278-4800 x!29
 Business Fax: 773/278-3840
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Fisher, Bill

 International Fabricare Institute (IFI)
 12251 Tech Road Silver Spring, MD 20904
 Business Phone: (301) 622-1900 (xl 13)
 Business Fax: (301) 236-9320
 Home Phone:
 Home Fax:
 Web Site:
 Ms. Fain, Sharon                                   Mr. Frumin, Eric
                                                   Union of Needletrades, Indus and Textile Employees
 Cuyahoga Community College                        (UNITE)
 Unified Technologies Center                          Department of Occupational Safety and Health,
 2415 Woodland Ave. Rm 240 Cleveland, OH 44115-3239 275 Seventh Ave., 6th Floor New York, NY  10001  USA
 USA                                              Business Phone: (212) 691 -1691
 Business Phone: 216/987-3086                         Business Fax: (212) 807-0874
 Business Fax: 216/987-3246                           Home Phone:
 Home Phone:                                       Home Fax:
 Home Fax:                                         E-Mail:
 E-Mail;                      Web Site:
 Web Site:
Dr. Fiksel, Joseph

505 King Ave. Columbus, OH 43201-2693 USA
Business Phone: 614-424-6424 ext5730
Business Fax: 614-424-3404
Home Phone:
Home Fax:
Web Site:
Ms. Giddings, Charlotte E.

Baise, Miller & Freer, P.C.
815 Connecticut Ave., NW
Suite 620 Washington, DC  20006
Business Phone: 202/331 -9100
Business Fax: 202/331-9060
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Dr. Goldman, Lynn
Assistant Administrator

Office of Prevention Pesticides and Toxic Substances
401 M Street SW (7101) Washington, DC 20460
Business Phone: 202/260-2902
Business Fax: 202/260-1847
Home Phone:
Home Fax:
Web Site:
Dr. Grady, Perry L.
Assoc Dean, Professional Engineer

North Carolina State University
College of Textiles
Box 8301,NCSU Raleigh, NC 27695-8301  USA
Business Phone: 919-515-6651
Business Fax: 919-515-3057
Home Phone:
Home Fax:
Web Site:
 Ms. Gomes, Filomena
 Development Chemist

 Unilever HPS-USA
 45 River Road Edgewater, NJ 07020
 Business Phone: 201/840-2578
 Business Fax: 201/840-8299
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Greco, Richard J
 National Sales Manager/Drycleaning

 Hoffman/New Yorker, Inc.
 25 Lackawanna Place Bloomfield, NJ  07003-2401
 Business Phone: 973/748-0500 ext.22
 Business Fax: 973/748-1341
 Home Phone:
 Home Fax:
 E-Mail: none
 Web Site:
 Dr. Gottlieb, Bob

 UCLA Wet Cleaning Project
 Occidental College
 1600 Campus Rd. Los Angeles, CA 90041-3314 USA
 Business Phone: 213/259-2712
 Business Fax: 213/259-2734
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Gregson, Martin F.
 Group Technical Director

 Johnson Group Management Services, Ltd.
 Mildmay Road, Bootle Liverpool, UK L20 SEW
 Business Phone: 0151 933-6161
 Business Fax: 0151 922-8089
 Home Phone:
 Home Fax:
 Web Site:
  Mr. Gouveia, Patrick A.

  Navy Clothing and Textile Research Facility
  P.O. Box 59 Natick, MA  1760 USA
  Business Phone: (508) 233-4740
  Business Fax: (508) 233-4683
  Home Phone:
  Home Fax:
  Web Site:
 Mr. Han, Tae Hee

 Korean-American Cleaners Association of New Jersey
 Mountainside Cleaners
 512 Lincoln Hwy., 2nd Floor Iselin, NJ 08830 USA
 Business Phone: 732/283-5135
 Business Fax: 732/283-5137
 Home Phone:
 Home Fax: 908/232-1261
 E-Mail: none
 Web Site:

                                             EPA Dfe GTCP
                                        1998 Conference Attendees
   Mr. Hanson, Bill

   US EPA DfE Branch
   401 M. Street, SW (7406) Washington, DC 20460 USA
   Business Phone: 202-260-0686
   Business Fax: 202-260-0981
   Home Phone:
   Home Fax:
   Web Site:
Ms. Hargrove, Ann

Ann Hargrove and Associates
8132 Salisbury Avenue Lyons, 1L 60534 USA
Business Phone: (708) 447-0879
Business Fax: 708/447-0879
Home Phone:
Home Fax:
Web Site:
 Dr. Harlan, Jerry
 Head of Research Laboratory

 ADCO, Inc.
 900 West Main Street (or)
 P.O. Box 999 Sedalia, MD 65301 USA
 Business Phone: 800/821-7556
 Business Fax: 660/826-1361
 Home Phone:
 Home Fax:
 E-Mail: none
 Web Site:
                                                  Dr. Hasselbrack, Sally
                                                  Technical Fellow

                                                  Boeing Commercial Airplane Group
                                                  Mail stop OR-TX
                                                  P.O. Box 3707 Seattle, WA 98124 USA
                                                  Business Phone: 425/342-9947
                                                  Business Fax: 425/266-9041
                                                  Home Phone:
                                                  Home Fax:
                                                  Web Site:
                                                   Dr. Helms, Tucker
                                                   Executive Director

                                                   Ecological & Toxicological Association (ETAD)
                                                   1850 M Street NW #700 Washington, DC 20036
                                                   Business Phone: 202/721-4154
                                                   Business Fax: 202/296-8120
                                                   Home Phone:
                                                   Home Fax:
                                                   Web Site:
                                                 Mr. Hoenscheid, Joe

                                                 Defense Logistics Agency
                                                 8725 John J. Kingman Road Ft. Belvoir, VA 22060-6221
                                                 Business Phone: 703/767-2643
                                                 Business Fax: 703/767-2628
                                                 Home Phone:
                                                 Home Fax:
                                                 Web Site:
 Mr. Hartley, James
 Vice President

 Phenix Supply Co.
 1920 Tampa East Blvd. Tampa, FL 33619 USA
 Business Phone: 813/623-3553
 Business Fax: 813/623-3558
 Home Phone:
Home Fax:
E-Mail: none
Web Site:
                                                Dr. Hoffmann, Thomas L.
                                                Technology Development Manager

                                                Fraunhofer Technology Center
                                                601 West 20th Street Hialeah, FL 33010
                                                Business Phone: 305/863-9096
                                                Business Fax: 305/863-9097
                                                Home Phone:
                                                Home Fax:
                                                Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Mr. Horning, Hal

National Clothesline
801 Easton Road
Suite 2 Willow Grove, PA 19090
Business Phone: 215/830-8467
Business Fax: 215/830-8490
Home Phone:
Home Fax:
Web Site:
Ms. Hough, Suzanne
Product Services Associate

American Textile Manufacturers Institute
1130 Connecticut Ave. Washington, DC 20036
Business Phone: 202/862-0500 ext. 502
Business Fax: 202/862-0570
Home Phone:
Home Fax:
Web Site:
 Ms. Hunter, Janet

 Westat, Inc.
 1600 Research Blvd.
 RA 1433 Rockville, MD 20850  USA
 Business Phone: 301/315-5996
 Business Fax: 301/294-2829
 Home Phone:
 Home Fax:
 Web Site:
 Ms. Johnson, V F
 Consumer Specialist

 Fairfax Dept. of Consumer Affairs
 12000 Government Center Parkway
 Suite 433 Fairfax, VA  22035
 Business Phone: 703/324-5959
 Business Fax: 703/222-5921
 Home Phone:
.. Home Fax:
 E-Mail: none
 Web Site:
Mr. Jones, Michael
President Nat'l Coalition of Petroleum Drycleaners

Highland Cleaners
2455 Bardston Road Louisville, KY 40205
Business Phone: 502/454-4641
Business Fax: 502/454-4646
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Mr. Jones, Robert

401 M Street SW (7405) Washington, DC 20460
Business Phone: 202/260-8150
Business Fax: 202/260-1096
Home Phone:
Home Fax:
Web Site:
 Ms. Keesee, Susan
 Editorial Director

 1 Davis Drive Research Triangle Park, NC 27709
 Business Phone: 919/549-8141
 Business Fax: 919/549-8933
 Home Phone:
 Home Fax:
 Web Site:
 Ms. Keyes, Norma M.
 Director, Fiber Quality Research

 Cotton Incorporated
 4505 Creedmoore Road Raleigh, NC 27612
 Business Phone: 919-510-6165
 Business Fax: 919-881-9874
 Home Phone:
 Home Fax:
 Web Site:

                                             EPA Dfe GTCP
                                        1998 Conference Attendees
   Mr. Kim, Chi Soo

   Korean Drycleaners Association of Atlanta
   Lux Cleaners
   5200 Jimmy Carter Blvd. Norcross, GA 30093
   Business Phone: 770/662-0063
   Business Fax:
   Home Phone: 770/729-9116
  Home Fax:
  Web Site:
   Mr. Kurz, Josef
   Business Mgr., Textile Care Research Division
  Hohenstein Institutes
  D-74357 Boennigheim Schloss Hohenstein,
  Business Phone: +49 07143-271-718
  Business Fax: 4971432718746
  Home Phone:
  Home Fax:
  Web Site:
  Mr. Kim, Hank Gil

  Federation of Korean Dry Cleaners Association (FKDA)
  25606 Alicia Parkway Laguna Hills, CA 92653
  Business Phone: (714) 770-8251
  Business Fax: (714) 770-1102
  Home Phone:
  Home Fax:
  Web Site:
  Dr. Lakritz, Julian
  Director of Technology

  Global Technologies
  222 N. Sepulveda Blvd. El Segundo, CA 90245
  Business Phone: 310/414-9680
  Business Fax: 310/414-9682
  Home Phone:
  Home Fax:
  Web Site:
 Mr. Kim, Kap Nyun
 Ms. Lapinski, Michelle
 Environmental Analyst

 .,      ..   ,                                        aP.  nc.
 Korean Drycleaners Association of Greater Washington   345 Spear Street
                                                  -  .—   -   _
 6647 B Old Dominion Drive McLean, VA 22101
 Business Phone: 703/847-9040
 Business Fax: 703/847-9040
 Home Phone:
 Home Fax:
 E-Mail: none
 Web Site:
 2nd Floor San Francisco, CA 94105-1672
 Business Phone: 415/427-3448
 Business Fax: 415/427-5242
 Home Phone:
 Home Fax:
 Web Site;
 Mr. Kinsman, Richard

 Global Technologies
222 No Sepulveda Blvd., Suite 2200 El Segundo CA
90245 USA
Business Phone: 310-414-9680
Business Fax: 310-414-9682
Home Phone:
Home Fax:
Web Site:
Mr. Latham, Steve

Westat, Inc.
1600 Research Blvd.
RA 1498 Rockville, MD 20850 USA
Business Phone: 301/294-2836
Business Fax: 301/294-2829
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Mr. Leiken, Sid

Prestige Cleaners
1460 Mohawk Blvd. Springfield, OR 97477
Business Phone: 541/746-9013
Business Fax: 541/746-2235
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Ms. Macklin, Chris
Research Associate

The Procter & Gamble Company
Winton hill Technical Center
6060 Center Hill Ave. Cincinnati, OH 45224
Business Phone: (513) 634-7285
Business Fax: (513) 634-1811
Home Phone:
Home Fax:
Web Site:
Ms. Lovelady, Andrea
Marketing Coordinator

R.R. Street & Co., Inc.
184 Shuman Blvd. Naperville, 1L 60563
Business Phone: 630/416-4244
Business Fax: 630/416-4150
Home Phone:
Home Fax:
Web Site:
Ms. Maillefer, Christiane

North Carolina State University
Dept. of Chemical Engineering
Box 7905, Room 104 Raleigh, NC 27695
Business Phone: 919/515-7054
Business Fax: 919/515-3465
Home Phone:
Home Fax:
Web Site:
Mr. Luiken, Richard
Manufacture Representative

Richards Associates
403 Lakeview Avenue Milford, DE 19963 USA
Business Phone: :800/270-1618
Business Fax: 302/422-5124
Home Phone: 302/422-3600
Home Fax:
Web Site:
Mr. Mains, Harold
Vice President Research

Fabritec International
200 Industrial Road Cold Spring, KY 41076
Business Phone: 606/781-8200
Business Fax: 606/781-8280
Home Phone:
Home Fax:
Web Site:
Dr. Machacek, Margit

JC Penney Company, Inc.
Quality Assurance Center,
1505 Wallace Drive, Suite 102 Carrollton, TX 75006
Business Phone: (972)431-9816
Business Fax: (972) 245-1147
Home Phone:
Home Fax:
Web Site:
 Mr. Markey, Raymond

 US Army Soldiers Systems Command
 Kansas Street Natick, MA 01760-5019 USA
 Business Phone: 508/233-5433
 Business Fax: 508/233-4097
 Home Phone:
 Home Fax:
 E-Mail: none
 Web Site:

                                             EPA Dfe GTCP
                                       1998 Conference Attendees
  Ms. Martin, Heather

  1150 17th Street N\V
  Suite 604 Washington, DC 20036
  Business Phone: 202/887-9201
  Business Fax: 202/887-9233
  Home Phone:
  Home Fax:
  Web Site:
  Mr. Meijer, Jon

  12251 Tech Road Silver Spring, MD 20904  USA
  Business Phone: 301/622-1900 x 145
  Business Fax: 301/236-9320
  Home Phone:
  Home Fax:
  Web Site:
  Mr. Maves, Tom
  Environmental Specialist

  OHIO EPA Office of Polution Prevention
  P.O. Box 1049 Columbus, OH  43216-1049
  Business Phone: 614/728-1261
  Business Fax: 614/728-1245
  Home Phone:
  Home Fax:
  Web Site:
 Mr. May berry, James
 Administrative Coordinator

 R.R, Street / FLARE
 184 Shuman Blvd. Naperville, IL 60563
 Business Phone: 630/416-6221
 Business Fax: 773/267-3032
 Home Phone:
 Home Fax:
 Web Site:
Dr. McClain, Jim
Vice President, Technical Development

MiCell Technologies, Inc.
7516 Precision Drive Raleigh, NC 27613
Business Phone: 919/313-2102 x 111
Business Fax: 919/313-2103
Home Phone:
Home Fax:
Web Site:
  Mr. Miller, Marshall

  Baise & Miller Law Firm
  815 Connecticut Ave.
  Suite 620 Washington, DC 20006  USA
  Business Phone: 202/331-9100
  Business Fax: 202/331-9060
  Home Phone:
  Home Fax:
  Web Site:
 Dr. Mock, Gary N.

 North Carolina State University
 Box 8301 Raleigh, NC 27695-8301
 Business Phone: 919-515-6457
 Business Fax: 919-515-6532
 Home Phone:
 Home Fax:
 Web Site:
Ms. Morgan, Jennifer

Wool Bureau, Inc.
330 Madison Ave. New York, NY  10017-5001
Business Phone: 212/499-4254
Business Fax: 212/557-5985
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Ms. Mueser, Karen
Product Engineer for Textile Home Fashion

Sears Roebuck & Co.
3333 Beverly Road
FC 575B Hoffman Estates, 1L 60169 USA
Business Phone: 847/286-5975
Business Fax: 847/286-5991
Home Phone:
Home Fax:
E-Mail: ussmgg2e@ibmmail
Mr. Norford, David

Mid Atlantic Cleaners and Launderers Association
5492 Riverview Drive King George, VA 22485 USA
Business Phone: 540/775-2525
Business Fax: 540/775-7441
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Ms. Neri, Carol J.
Supervisory Chemist/Color Science

Defense'Logistics Agency
DLA Product Test Center/Def. Person. Supp. Ctr. (FQL)
2800 S. 20th Street Philadelphia, PA  19145-5001
Business Phone: 215/737-3265
Business Fax:
Home Phone:
Home Fax:
Web Site:
Mr. Nilsen, Joe

Defense Personnel Support Center
2800 South 20th Street Philadelphia, PA  19145-5099
Business Phone: 215-737-2000 ext 3016
Business Fax: 215/773-3172
Home Phone:
Home Fax:
Web Site:
Mr. Oehlke, Norma

7506 Greenwood Drive Highland, MD 20777
Business Phone: 301/854-3977
Business Fax: none
Home Phone:
Home Fax:
Web Site:
Mr. Oh, Max

Korean Drycleaners Association of Greater Washington
Town & Country Cleaners
4715 Commerce Lane Bethesda, MD 20814 USA
Business Phone: 301/654-1500
Business Fax: 301/654-1503
Home Phone:
Home Fax:
E-Mail: none
Mr. Nolan, Mike
Textile Technologist

US Army Soldiers
Kansas Street Natick, MA 01760-5019 USA
Business Phone: 508/233-5468
Business Fax: 508/233-5496
Home Phone:
Home Fax:
E-Mail: none
Web Site:
Mr. Ouimet, Albert B.
Technical Director

Warnaco Technical Center,
Airport Industrial Park Westerly, RI 2891
Business Phone: (401) 596-2836
Business Fax: (401)596-2318
Home Phone:
Home Fax:
Web Site:

                                            EPA Dfe GTCP
                                       1998 Conference Attendees
  Dr. Overcash, Michael

  North Carolina State University
  Dept. of Chemical Engineering
  Box 7905, Room 113 Raleigh, NC 27695-7905  USA
  Business Phone: 919-515-2325
  Business Fax: 919-515-3465
  Home Phone:
  Home Fax:
  Web Site:
  Mr. Priestland, Carl H.

  American Apparel Manufacturers Association (AAMA)
  2500 Wilson Boulevard, Suite 301 Arlington, VA 22201
  Business Phone: (703) 524-1864
  Business Fax: (703) 522-6741
  Home Phone:
  Home Fax:
  Web Site:
 Mr. Patrizi, Kurt

 Westat, Inc.
 1600 Research Blvd.
 RA 1492 Rockville, MD 20850 USA
 Business Phone: 301/294-2870
 Business Fax: 301/294-2829
 Home Phone:
 Home Fax:
 Web Site:
 Dr. Rabinovich, Beth

 Westat, Inc.
 1600 Research Blvd.
 RA 1324 Rockville, MD  20850 USA
 Business Phone: 301/315-5965
 Business Fax: 301/294-2829
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Pentecost, John

 Linowes and Blocher
 1010 Wayne Ave.
 1 Oth Floor Silver Spring, MD 20910
 Business Phone; 301/650-7006
 Business Fax: 301/495-9044
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Racette, Tim
 Vice President

 R. R. Street & Co., Inc.
 184 Shuman Blvd. Naperville, IL 60563-8464
 Business Phone: 630/416-4244 x225
 Business Fax: 630/416-4150
 Home Phone:
 Home Fax:
 Web Site:
Mr. Pravs, Andrew
Technical Director, Corporate Textiles

Liz Claibome, Inc.
One Claibome Ave. North Bergen, NJ 07047
Business Phone: 201/295-6625
Business Fax: 201/295-6260
Home Phone:
Home Fax:
Web Site:
Mr. Reehorst, Bob

Reehorst Cleaners
27303 Center Ridge Westlake, OH 44145
Business Phone: 216/871-6444
Business Fax: 216/871-5129
Home Phone:
Home Fax:
E-Mail: none
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Ms. Regazzi, Marilyn
Supervisor Fabric Quality Assurance

259 West Santa Clara St. Ventura, CA 93001
Business Phone: 805/667-4775
Business Fax: 805/653-6355
Home Phone:
Home Fax:
Web Site:
                  Ms. Ruskin, Maureen

                  200 Constitution Ave. NW
                  Room N3627 Washington, DC 20210
                  Business Phone: 202/693-1955
                  Business Fax: 202/693-1641
                  Home Phone:
                  Home Fax:
                  Web Site:
Dr. Riggs, Charles
Director of Texas Res. Ctr. For Laundry & Dryclean
Texas Woman's University
P.O. Box 425529 Denton, TX 76204
Business Phone: (940) 898-2670
Business Fax: (940) 898-2711
Home Phone: 940/387-5725
Home Fax:
Web Site:
Dr. Sanders, William H.

401 M Street, S.W. (7401)
Room E-539B Washington, D.C. 20460
Business Phone: (202) 260-3810
Business Fax: (202) 260-0575
Home Phone:
Home Fax:
Web Site:
Ms. Rising, Jane

12251 Tech Road Silver Spring, MD 20904 USA
Business Phone: 301 /622-1900 x 123
Business Fax: 301/236-9320
Home Phone:
Home Fax:
Web Site:
                  Ms. Scalco, Mary

                  International Fabricare Institute (IFI)
                  12251 Tech Road Silver Spring, MD 20904  USA
                  Business Phone: (301) 622-1900 X131
                  Business Fax: (301) 236-9320
                  Home Phone:
                 . Home Fax:
                  Web Site:
 Dr. Risotto, Steve
 Executive Director
                  Dr. Schreiber, Judy
                  Research Scientist III
 Halogenated Solvents Industry Alliance                 New York State Department of Health
 2001 L St NW, Suite 506A Washington, DC  20036 USA Bureau of Toxic Substance Assessments
 Business Phone: 202-775-0232                        2 University Place, Room 240 Albany, NY 12203 USA
 Business Fax: 202/833-0381                          Business Phone: 518/458-6405
 Home Phone:                                      Business Fax: 518/458-6372
 Home Fax:                                         Home Phone:
 E-Mail:                            Home Fax:
 Web Site:                                 ,        E-Mail:
                                                  Web Site:

                                           EPA Dfe GTCP
                                      1998 Conference Attendees
  Dr. Schreiner, James L.
  Staff Mrkt. Dev. Rep. Intermediates Am.

  Exxon Chemical Company
  13501 Katy Freeway Houston, TX 77079-1398 USA
  Business Phone: 281-870-6237
  Business Fax: 281-588-2558
  Home Phone:
  Home Fax:
  E-Mail: no email
  Web Site:
  Dr. Shahady, Thomas

  Catawba Valley Community College (CVCC)
  2550 Hwy. 70 SE Hickory, NC 28602 USA
  Business Phone: 704-327-7000 ext.101
  Business Fax: 704-327-7276
  Home Phone:
  Home Fax:
  Web Site:
 Ms. Schwass, Carolyn

 Blue Ribbon Fabricare Center
 165 County Road 135 Jemison, AL 35085
 Business Phone: 205/688-2414
 Business Fax: 205/688-2414
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Silverman, Dan

 AHA Unlimited
 34891 Boheny Place Capistrano Beach, CA 926243
 Business Phone: 714/487-2042
 Business Fax: 714/487-1451
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Segrave-Daly, Richard
 Manager, Business Assistance Center

 U.S. EPA Region 3
 841 Chestnut Building Philadelphia, PA  19107-4431
 Business Phone: 800/228-8711
 Business Fax: 215/566-5103
 Home Phone:
 Home Fax:
 Web Site:
 Dr. Sinsheimer, Peter

 Occidental College
 1600 Campus Road Los Angeles, CA 90041-3314 USA
 Business Phone: 323/259-1420
 Business Fax: 323/259-2734
 Home Phone:
 Home Fax:
 Web Site:
Mr. Seitz, William
Executive Director
Ms. Snyder, Corey
Senior Engineer
Neighborhood Cleaners Association-International (NCAI) The Procter & Gamble Company
252 West 29th Street New York, NY  10001-5201 USA
Business Phone: (212) 967-3002 x231
Business Fax: (212) 967-2240
Home Phone-
Home Fax:
E-Mail:  attn: Bill Seitz
Web Site:
6060 Center Hill Road Cincinnati, OH 45224
Business Phone: 513/634-6241
Business Fax: 513/634-1811
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe GTCP
                                     1998 Conference Attendees
Mr. Snyder, Russ
Executive for NCPD

National Coalition of Petroleum Drycleaners
4041 Powder Mill Road
Suite 404 Calverton, MD 20705
Business Phone: 301/348-2014
Business Fax: 301/348-2020
Home Phone:
Home Fax:
Web Site:
Ms. Stroup, Cindy
Manager, Garment & Textile Care Program

401 M Street, SW (7406)
Room 341 Washington, DC 20460  USA
Business Phone: (202) 260-3889
Business Fax: 202/260-0981
Home Phone: 703/525-8680
Home Fax:
Web Site:
Mr. Speicher, Dale
Sales Consultant

Laidlaw Corporation
6625 N. Scottsdale Road Scottsdale, AZ 85250
Business Phone: 602/951-0003
Business Fax: 602/991-1563
Home Phone:
Home Fax:
Web Site:
Mr. Talbot, Gene
Non-adjunct Professor

Fashion Institute of Technology
15 Enness Ave. Bethpage, NY 11714
Business Phone: 212/217-8996
Business Fax: 212/217-7593
Home Phone: 516/681-9163
Home Fax: 516/681-9163
E-Mail: none
Web Site:
Mr. Star, Anthony

Center for Neighborhood Technology (CNT)
2125 West North Avenue Chicago, IL  60647 USA
Business Phone: (773) 278-4800 XI17
Business Fax: (773) 278-3840
Home Phone:
Home Fax:
Web Site:
Ms. Stephens, Jackie

12251 Tech Road Silver Spring, MD 20904 USA
Business Phone: 301/622-1900 x!26
Business Fax: 301/236-9320
Home Phone:
Home Fax:
Web Site:
Dr. Taylor, Craig M.V.
Principal Investigator

Los Alamos National Laboratory
Supercritical Fluids Facility, J964 Los Alamos, NM 87545
Business Phone: 505-665-3545
Business Fax: 505-667-6561
Home Phone:
Home Fax:
Web Site:
Mr. Trevigne, Leroy J.

Pellerin Milnor Corporation
700 Jackson St. Kenner, LA 70062 USA
Business Phone: 504-467-9591 ext435
Business Fax: 504/468-9307
Home Phone:
Home Fax:
Web Site:

                                           EPA Dfe GTCP
                                      1998 Conference Attendees
 Ms. Underly, Kristina K.
 Senior Engineer

 Whirlpool Corporation
 The Elisha Gray II Research/Engineering Ctr.
 750 Monte Road, MD 5155 Benton Harbor, MI 49022
 Business Phone: 616/923-3916
 Business Fax: 616/923-3927
 Home Phone:
 Home Fax:
 Web Site:
 Ms. Villa, Kay M.

 American Textile Manufacturers Institute
 1130 Connecticut Avenue, N.W., Suite 1200 Washington,
 D.C. 20036 USA
 Business Phone: (202) 862-0518
 Business Fax: (202) 862-0570
 Home Phone:
 Home Fax:
 Web Site:
 Mr. Vandermolen, Vic

 CanadianFabricare Association
 P.O. Box 24026 Kitchener, Ontario N2M5P1 Canada
 Business Phone: 519-576-4500
 Business Fax: 519-576-8869
 Home Phone:
 Home Fax:
 Web Site:
 Dr. Wakelyn, Phillip

 National Cotton Council
 1521 New Hampshire Ave Washington, DC 20036 USA
 Business Phone: 202/745-7805
 Business Fax: 202/483-4040
 Home Phone:
 Home Fax:
 Web Site:
Ms. Vecellio, Connie

Federal Trade Commission
601 Pennsylvania Avenue, N.W., Room 4302(S)
4th floor Washington, D.C 20580  USA
Business Phone: (202) 326-2966
Business Fax: (202) 326-2558
Home Phone:
Home Fax:
Web Site:
Ms. Warren, Barbara

Consumer's Union
101 Trurnan Avenue Yonkers, NY 10703-1057  USA
Business Phone: 914/378-2456
Business Fax: 914/378-2928
Home Phone: 718/984-6446
Home Fax: 718/984-0500
Web Site:
Mr. Vigon, Bruce

505 King Ave. Columbus, OH 43201-2693 USA
Business Phone: 614-424-4463
Business Fax: 614-424-3404
Home Phone:
Home Fax:
Web Site:
Dr. Weber, Mary Ellen

401 M Street, SW (7406)
Rm#E315B Washington, DC  20460 USA
Business Phone: 202-260-0667
Business Fax:
Home Phone:
Home Fax:
Web Site:

                                          EPA Dfe G~FCP
                                     1998 Conference Attendees
Mr. Weinberg, Jack
Senior Toxics Campaigner

417 South Dearborn Street
Suite 420 Chicago, IL 60605
Business Phone: (312) 563-6066
Business Fax: (312) 563-6099
Home Phone:.
Home Fax:
Web Site:
Mr. Won, Chris
Chairman; of the Environmental Prot. Comm.

Federation of Korean Drycleaners Association
Eastern Machinery Corp
3395 Fox Street NW Duluth, GA 30136
Business Phone: 770/497-0473
Business Fax: 770/497-0473
Home Phone:
Home Fax:
E-Mail: none               '
Ms. Weiner, Debra

Business for Social Responsibility
1612 K Street NW
Suite 706 Washington, DC 20006
Business Phone: 202/463-0826
Business Fax: 202/463-3954
Home Phone:
Home Fax:
Web Site:
Mr. Yogis, George J.
Global Manager Cleaning & Personal Care

ARCO Chemical Company
3801 West Chester Pike Newtown Square, PA 19073-2387
Business Phone: 610/359-3299
Business Fax: 610/359-5530
Home Phone:
Home Fax:
Web Site:
Dr. Wentz, Manfred

North Carolina State University
College of Textiles
2401 Research Drive Raleigh, NC 27695 USA
Business Phone: 919/513-3020
Business Fax: 919/515-6532
Home Phone:
Home Fax:
Web Site:
Mr. Wintz, Dave
Environmental Mgr

Indiana Dept of Environmental Mgt
100 North Senate Ave, P.O. Box 6015 Indianapolis, IN
Business Phone: 317/233-1194
Business Fax: 317/233-5627
Home Phone:
Home Fax:
Web Site:


EPA 744-R-98-006
3. Recipient's Accession
Not Applicable	
 4. Title and Subtitle
 Garment and Textile Care Program -- An Eye to the Future: 1998 Conference
                                            5. Report Date
 7. Author(s) As this document is a conference proceedings, it consists of the
 narratives of presentations (and slides/viewgraphs/handouts) provided by those
 individuals who gave presentations at the EPA's 1998 Garment and Textile Care
 Program National Conference. There were a total of 27 speakers who collectively
 represented public interest groups, state government, academia, fabricare
 industry, textile and garment industry, garment retail industry, equipment
 manufacturers, and EPA and other federal governmental agencies.
                                            8. Performing Organization
                                            Rept. No.   EPA 744-R-98-
 9. Performing Organization Name and Address
     U.S. Environmental Protection Agency
     Office of Pollution Prevention and Toxics (7406)
     401 M Street, S.W.
     Washington, D.C. 20460
                                            10. Project/Task/Work Unit
                                            Task No. 2-01-01
                                            11. Contract(C) or Grant(G)
                                            (C) 68-W7-0025
 12. Sponsoring Organization Name and Address
     U.S. Environmental Protection Agency
     Office of Pollution Prevention and Toxics/EETD (7406)
     401 M Street, S.W.
     Washington,  D.C. 20460	
                                            13. Type of Report & Period
                                            Covered, Final Report
 15. Supplementary Notes
 Management and overall technical direction were provided by Cindy Stroup, USEPA Design for the Environment
 Garment and Textile Care Program Manager.  Editing and document preparation support was conducted by
 Westat under the direction of Kurt Patrizi.
 16. Abstract (Limit 200 words)  The Garment and Textile Care Program - An Eye to the Future: 1998
 Conference Proceedings was developed to document the presentations provided by the 27 conference speakers.
 The purpose of the conference was to explore how decisions made by the fabricare industry, garment retailing
 industry, textile industry, fibers industry, equipment and solvent manufacturing industry affect the incorporation of
 environmentally-preferable methods into professional clothes cleaning operations. The conference was the first
 step in the efforts of the EPA Garment and Textile Care Progam to incorporate a life cycle approach into
 decisions  made throughout the fiber/textile/garment/retail/fabricare business pipeline.
 17. Document Analysis
    a. Descriptors: Drycleaning, wetcleaning, clothes cleaning, perchloroethylene, PCE, perc, chlorinated
 solvents, hydrocarbon solvents, textile production pipeline, life cycle, Design for the Environment, DfE, Garment
 and Textile Care Program, GTCP. value chain, garment care, petroleum solvents, alternative solvents, alternative
 technologies, fabricare processes, fabricare technologies, dry cleaning, wet cleaning, liquid carbon dioxide,
 Stoddard solvent, MiCELL, Rynex, Biotex, Global, Kirk's.
    b. Identifiers/Open-Ended Terms: textiles, garments, solvents, fabricare, pollution prevention, carcinogen,
 green chemistry, industrial ecology.
c. COSATI Field/Group: Not A
18. Availability Statement
Unlimited Availability
19. Security Class (This Report):
20. Security Class (This Page)
21 . No. of Pages 360
22. Price

•U.S. Government Printing Office: 1999 — 450-616/10174
                                                       (Formerly NTIS-35)
                                                 Department of Commerce