Oregon Dry Cleaners Association

The most hazardous conditions DEQ has found during their compliance inspections are the lack of secondary containment under water treatment units and hazardous waste storage.

Of the 25 or so on-site compliance inspections done by DEQ, 15 cleaners were found to not have the required secondary containment. That is 60% of those inspected. It raises the question "How many dry cleaners in the state are not in compliance". Not only are you creating a possible environmental hazard, you are risking your protection you receive under the law.

The Oregon Dry Cleaners are unique and respected for stepping up to the plate on the environmental issue, (and well deserved I might add). Let's keep that respect. If you do not have secondary containment get it done NOW! If you need help contact me 503-871-5144 or any ODCA Board Member.

Here's the page on what is required for Secondary Containment by the DEQ. http://www.deq.state.or.us/wmc/pubs/factsheets/cu/e_containment.pdf

Editors Note: There are a number of secondary containment resources, but I needed to replace my Hazardous Waste Secondary containment pan with a larger one, and I just dealt with this company called New Pig and they were amazingly helpful and I recieved my pan in record time. I dealt with this company on a recomendation from another dry cleaner. They carry everthing you need to deal with Chemicals, including Eye Wash Stations, which is something else we'll be upgrading in our plant. So I thought I'd pass this resource along .

As business owners we are all used to inspections of many kinds. If you buy an already existing business you usually inspect the actual premises and have a mechanic inspect the equipment to make sure all is working properly. You may also have your accountant and or lawyer inspect the books to make sure all the figures are in order. You then check with the county to make sure the business has a current business license and that they are not in violation with any city, county, or state regulations.

If you are building a new business you have another whole group of inspections, building, dry wall, electrical, plumbing, gas etc. and you have to wait to pass each inspection in order before you can go on to the next step.

Depending on the size of operation you have there are OSHA and or EPA inspections. They are looking at employee safety issues and pollution. Of course let us not forget the boiler inspection that has to be done during business hours and the boiler has to be broken down and in order to do that it must be cold!

Well folks we now have a new type of inspection, a compliance inspection by the DEQ. These inspections supposedly are being conducted at drycleaners who have not submitted annual reports or who have reported questionable information.

Recently I spoke with a cleaner who was inspected and I was very surprised by some of the items where they were "out of compliance".

Were you aware that your containment pan was not a collect all? Any lint, water, rags, etc. that might have been placed or fallen into the containment pan are now considered TOXIC and therefore must be measured and documented as toxic waste and disposed of properly in your hazardous waste barrel. Even if you re-clean the rags to remove any chemicals from them, they are still considered hazardous waste. That includes any rags you may use just to wipe down the machine to keep it clean! Any water from steam leaks; spillage etc. must be weighed and documented as part of your monthly waste generation. Lint inside or OUTSIDE is considered probable toxic waste unless you can prove it came form a source other that dry-cleaning.

The containment pans are supposed to be cleaned weekly and be clean enough at all times to eat off of. Any buckets you use to hold lint, wastewater, and sludge are considered toxic and must be labeled with the date first used, have lids and must have secondary containment. The inspector may ask you to prove that the welds/bolts used to hold your machine into the containment pan are still perfect and have not lost their integrity. (Not real sure how this can be done?!)

All shipping records and solvent purchases must be kept on hand and readily available to the DEQ inspector. Only originals of these documents will suffice, copies are not acceptable.

Estimation of the weight of accumulated hazardous waste is also a violation. The weight of lint, filters, cleanup rags etc. is to be weighed and documented when it is produced not when it is hauled off.

The ODCA board is currently working with DEQ to get more information on how these inspections will be handled and the type of record keeping they are looking for.

At this time I do not know what kind of fines could be leveled on a cleaner who is not in compliance, they could range from a warning to hundreds of dollars even for a first time inspection.

Better housekeeping and record keeping will go a long way in keeping the DEQ happy. If you run a drycleaner you want to make sure that is one inspector you keep happy!

http://www.registerguard.com/news/2005/02/11/d1.cr.bridalauction.0211.html - New members Bill & Debbie Height, helped organize this event, and while it's now over, I still thought it was a fun article to share.

http://www.registerguard.com/ news/2005/02/13/a1.toxic.0213.html - An article about Eugene's toxics-right-to-know law which established the only city-mandated toxics reporting system in the nation, and how they are planning on expanding it.

The idea to expand the program started because some people worried that two state court rulings were placing too big of a burden on the small businesses. For example, a business with ten employees was actually paying more than a large business because of the state mandated $2,000 cap on fees. The proposed businesses that would be added to the program would include gas stations and dry cleaners. If they used more than 2,640 pounds of hazardous chemicals a year, they would have to report and pay fees. Otherwise the firms would only have to pay fees.

Fun Links
http://www.big- boys.com/articles/tshirtfold.html – Interesting Video on Shirt Folding

http://www.puzzlebeast.com/dryclean/dr yclean_more.html - Dry Cleaning Games online.

Your ODCA members who sit on the DEQ Advisory Committee were hard at work for all Oregon Dry Cleaners last week when Cory-Ann Wind from the Northwest Air Quality division of DEQ made a presentation. Your representatives saw flaws and questioned the validity of results accumulated from a study called the Portland Air Toxics Assessment (PATA). We were then given copies of 2 DEQ Fact Sheets resulting from the PATA. These fact sheets were not only posted on the DEQ website but 1 of them had been distributed to some neighborhood associations in the Portland area, the other fact sheet was prepared for statewide distribution, which had not happened yet. The response from your members who sit on the advisory committee prompted DEQ, to their credit, to immediately remove them from the website and stop any distribution. The advisory committee is scheduled to address this issue again on March 16, 2005.

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