Comment Log Display

 


January 23, 2007


Clerk of the Board
Air Resources Board
1001 I Street, 23rd Floor
Sacramento Ca. 955814


Dear Members of the Board,

My name is Barry Bosshard and I am an owner of Off Broadway
Cleaners. We have been in the Dry-cleaning business in Sonoma for
50 years. I personally have worked in the cleaning business 40
years. In those years, I have used various solvents including
Carbon tetrachloride, Petroleum based Stoddard Solvent,
Perchlorethelene, Fluorocarbon, and Wet-cleaning. Each of these
solvents have their own benefits and problems.

It has been my experience that Perc delivers the best quality
cleaning and is the least harmful of all to the environment. The
arguments in favor of eliminating the use of this solvent, in my
understanding, are two-fold. The first argument and the most
serious is that it is a carcinogen. Numerous studies have been
performed in this regard since the early 1980’s. The general
conscientious of all these studies is that as the Federal EPA has
determined it is a Possible Human Carcinogen . This is the lowest
category of potential chemical threat to humans.

The second argument is that it is a toxic chemical. This
classification refers to the fact that overexposure to the fumes
and or liquid can be physically impairing and injurious. This, I
believe, is the real threat. Over the last 40 years, the Time
Weighted Average exposure level has been reduced from 1,000 ppm in
the 1960’s to the current level of 25 ppm in the 1990’s through
technological advances and regulations. If this level is
maintained as current regulations require, not only is there no
toxic effect experienced by employees of the facility, humans
cannot even smell it at this concentration.

In reality, any solvent can be dangerous if it is not used
sensibly and with extreme caution. The Dry-cleaning Industry has
done an outstanding job in increasing efficiency in the process.
The amount of Perc used by the industry has been reduced by over
90 percent through Best Available Control Technology. In my own
personal experience my usage has gone down from 150 gallons a week
to less than 100 gallons a year. Your statistical study of the
industry confirms this point.

The alternative solvents that you are considering as a replacement
for the industry also have their own risks and environmental
threats associated with them. Petroleum based Hydrocarbon Solvents
is highly combustible. This presents a serious and real explosive
risk. To lower this risk the newer petroleum hydrocarbon solvents
have a higher flash - point or ignition temperature. The new
equipment in some cases also removes the oxygen in the cleaning
machine and replaces it with nitrogen to lower the risk of
explosion. Although these technological improvements may reduce
the risk it does not eliminate it altogether.  Perchlorethelene is
a non-flammable liquid with no explosive risk.

Petroleum based Hydrocarbon Solvents are photo-chemically reactive
and smog producing. This is an environmentally known pollutant that
depletes the ozone layer. Why you would recommend its increased use
at a time when all other efforts of your regulations is to reduce
these emissions, does not make sense to me. Perchlorethelene on
the other hand is not photo-chemically reactive and does not
create smog.

Finally, Petroleum based Hydrocarbon Solvents are also Toxic and
depending on the chemical make-up possible, if not probable, human
carcinogens if they contain Benzene, Radon or other carcinogens
that are common in petroleum based products. These are all
environmental reasons the dry-cleaning industry has adopted this
solvent as the best cleaning solvent with the least environmental
and physical risk factors.

The other alternative solvents that are being considered also have
environmental and physical risks associated with them. I must say
that I am confused, when daily I read of the environmental impact
of Carbon Dioxide to the environment, and the recent legislation
that we need to reduce its emissions and your document considers
it as an alternative for the dry-cleaning industry.

 Wet-cleaning processes can clean up to a maximum of 33 percent of
the garments we process. This does not consider how we are to clean
the other 67 percent of our cleaning volume. I also do not see in
your consideration the environmental impact of the wastewater
generated by these processes and the chemical additives. This
wastewater will be released into the sewer system and groundwater
eco-system.

I strongly suggest that you reconsider this proposed amended
regulation until all the environmental effects of the proposed
alternatives have been explored completely with input from all
concerned constituencies.

Respectfully,

Barry Bosshard C.E.D,  C.P.D.
President
Off Broadway Cleaners
 

19485 Sonoma Hwy. Sonoma, CA 95476 (707) 938-2327
                                Fax (707) 938-2306