What to do About PCE in Dry Cleaning?

In 1997, New York State and New York City adopted regulations to control perchloroethylene (PCE) emissions from dry cleaners located in residential and other buildings. From 2001 to 2003, the New York State Department of Health (NYSDOH) measured indoor air concentrations of PCE in apartments located in buildings in New York City where dry cleaners used PCE on site. While PCE exposures are widespread in the U.S. population, previous studies have shown that the most significant non-occupational exposures occurs in residences located over or adjacent to dry cleaners.

Mean indoor air PCE concentrations have decreased by about 10-fold since 1997, when additional dry cleaner regulations were implemented. Despite these accomplishments, PCE concentrations in several of the sampled apartments still exceeded the NYSDOH residential air guideline of 100 ug/m3. PCE concentrations in a few apartments exceeded the 1,000 ug/m3 action level set by NYSDOH. Moreover, the mean indoor air PCE concentrations in minority neighborhoods (75 ug/m3) were four times higher than in nonminority households (19 ug/m3). The mean PCE concentrations were > 10 times higher in low-income neighborhoods (256 ug/m3) than in higher income neighborhoods (23 ug/m3).

The study concluded that "[f]actors that may be contributing to the elevated perc levels detected, especially in minority and low-income neighborhoods, are being explored".

It doesn't take a lot of looking around to come up with a plausible explanation for why low-income neighborhoods (which would substantially overlap with minority neighborhoods) have higher PCE exposures. Dry cleaning is not a high-margin industry. According to the International Fabricare Institute, most commercial drycleaners are single facility, family-owned operations. An average number of five employees work at a plant. Commercial dry cleaning may not generate large profit with median annual revenues below $250,000. Bureau of Census statistics essentially confirm the industry figure. Bureau of Labor Statistics figures show that mean annual incomes of dry cleaning workers is $8.80 per hour ($18,290 per year). EPA’s draft dry cleaning NESHAP from 1993 cited the capital cost of secondary controls (a refrigerated condenser) at $6,300 with annual costs of $1,000 for process vent controls. The California ARB’s recent report on the dry cleaning industry also cites similar costs for installation of secondary controls.

Even before doing the arithmetic, it appears reasonable that many dry cleaning facilities would find installation of emission controls to be an economic burden, worth the risk of non-compliance. If it’s assumed that the dry cleaners in the lower-income neighborhoods have revenues lower than the median, the burden of emissions controls would be proportionately greater, the proportion of non-compliance greater, hence higher PCE exposures in lower income neighborhoods.

Whether we should continue to use PCE to dry clean clothes involves a balancing of the risks versus the benefits, and balancing competing risks. Beyond that, it involves balancing who is reaping the benefits versus who is being subjected to the risks. How significant are those risks? Are the costs for controlling PCE emissions an economic burden to dry cleaners? Are the risks and costs for control significant enough to warrant finding alternatives to PCE for dry cleaning? A further question is what kinds of alternatives are there to dry cleaning with PCE? Are these more “environmentally friendly”? Do they provide suitable quality in fabric care? What kinds of economic impacts are there to the dry cleaning industry with switching from PCE?

PCE use in dry cleaning is a laboratory experiment for implementation of the precautionary principle. In this case, some harm potentially has been done from PCE exposure (more on this topic later), and more harm may be averted through finding alternatives to PCE in dry cleaning. However, other types of harm such as economic dislocation, unemployment and poverty for some, which have their attendant health risks, might be created by forcing the replacement of PCE as a dry cleaning solvent, indicating the need for a more nuanced view of the precautionary principle than “just don’t use it”. Navigating through this maze and solving the problem of replacing PCE in dry cleaning might provide lessons in toxic substance use reduction that could be applied elsewhere.