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