Perchloroethylene (PERC) in Dry Cleaning: Reducing Worker Exposure To
Perchloroethylene (PERC) in Dry Cleaning: Reducing Worker Exposure To
Perchloroethylene (PERC) in Dry Cleaning: Reducing Worker Exposure To
gov
OSHA 3253-05N
2005
Contents
Executive Summary . . . 3
Introduction . . . 4
Health Hazards . . . 4
Perc Exposure . . . 5
Ventilation . . . 10
Assistance . . . 13
Case Studies . . . 14
OSHA Assistance . . . 21
2
Executive Summary
3
Introduction
Health Hazards
During dry cleaning, perc primarily enters the body from in-
halation of the vapors, potentially resulting in the following health
hazards:
■ Dizziness, drowsiness, and loss of coordination;
■ Mild loss of memory, visual perception, and reaction time
after several years of exposure; or
■ Redness and blistering of the skin after prolonged dermal
contact.
There is some evidence of an association between perc and
increased risk of certain cancers in dry cleaning workers exposed
for many years. The National Institute for Occupational Safety and
Health (NIOSH) has designated perc as a “potential occupational
carcinogen.” The National Toxicology Program has designated it as
“reasonably anticipated to be a human carcinogen.” The Inter-
national Agency for Research on Cancer (IARC) has designated perc
as a “probable human carcinogen.”
4
The possibility of these health hazards can be minimized by
reducing worker exposures to perc vapor and by avoiding skin
contact with perc.
Perc Exposure
5
■ Using a perc-based spotting agent; and
■ Using a perc-based waterproofing agent.1
1
Use of perc-based spotting or waterproofing agents is not current practice in the
dry cleaning industry. However, these operations are addressed in this document
for those few dry cleaning establishments that may continue to use these
products.
6
Other OSHA standards that may apply when workers are
exposed to perc include: Hazard Communication (29 CFR
1910.1200); General requirements for personal protective equip-
ment (29 CFR 1910.132); and Respiratory Protection (29 CFR
1910.134).
In addition to these worker exposure limits, dry cleaning
facilities must comply with EPA regulations controlling the release
of perc into the environment – air, land, and water. EPA has
developed regulations that affect many aspects of dry cleaning
operations, including machine operation and maintenance, building
design and ventilation, work practices, as well as perc storage and
disposal. There are also EPA requirements on air monitoring for
perc release, recordkeeping, and perc use reporting. (For further
information on EPA regulations, see Plain English Guide for Perc
Cleaners, EPA, 2003.)
7
latest technology incorporates a secondary vapor recovery system
on the dry-to-dry closed loop machines that most effectively
minimizes perc usage, environmental releases, and worker
exposure to perc. Figure 1, below, illustrates the perc exposure
levels of machine operators associated with the various dry
cleaning machines.
20
15
(ppm)
10
5
0
Transfer Vented Closed Closed
Looped Looped
w/ 2nd
Controls
Source: NIOSH.
8
■ Rake out still daily. (Consider installing a pump that allows
residue to be pumped directly to a safety can.)
■ Change all filters as necessary.
■ Desorb carbon adsorber before saturation point.
■ Adjust refrigerated condensers to ensure proper temperature of
drying air.
■ Maintain and repair exhaust fans.
A recommended schedule of maintenance activities is provided
in Appendix A at pages 16 -17.
9
Ventilation
10
machine maintenance, filter changes, waterproofing operations, and
loading/unloading machines (depending on the equipment in use).
Workers using transfer machines may also need to wear chemical-
resistant aprons. Spotters can wear goggles, chemical-resistant
aprons, and gloves. Spill cleanup workers always need to wear
respirators and gloves.
Work Practices – Good work practices can greatly minimize
worker exposure to perc vapors. For example, peak exposure
levels can be reduced by several hundred parts per million simply
by proper positioning of the worker’s head and body during trans-
fer operations. Other important work practices to reduce perc
exposures are listed below.
11
Training – Dry cleaning employees need training on how to
protect themselves from the hazards of perc (OSHA Hazard
Communication standard, 29 CFR 1910.1200). Employees should be
trained in proper work practices for all of their expected tasks –
operating and maintaining machines, spotting, waterproofing,
housekeeping, and perc transfer and storage.
Workers must be trained on the health hazards and symptoms
associated with perc exposure. Workers should become familiar
with Material Safety Data Sheets (MSDS) and container labels for
perc (OSHA Hazard Communication standard, 29 CFR 1910.1200).
The International Chemical Safety Card for perc can be found in
Appendix B on pages 18-20 of this publication to help with this
training.
In addition, workers should be familiar with the location and
proper use of eyewash stations as well as procedures for re-
sponding to first aid emergencies, such as eye splashes and skin
contamination. OSHA requires employers to train their employees
about hazards and methods to prevent exposure to chemicals used
in the workplace (OSHA Hazard Communication standard, 29 CFR
1910.1200). Workers must also be trained on the proper use of
respirators (Respiratory Protection standard, 29 CFR 1910.134).
12
the perc exposures of individual workers, a sample can be obtained
by clipping a monitoring device to the worker’s collar either with a
battery-powered pump or a simple monitoring badge.
The samples are then sent to a qualified laboratory to analyze
the perc concentration. The results can be compared with the
OSHA PEL and other recommended exposure limits for perc (listed
in Table 1, on page 6).
For detecting equipment leaks and other emissions, portable,
direct-reading devices provide either a visual/audible indication of a
leak or an instantaneous measurement of the perc vapor concentra-
tion at the source of the emission. These instruments vary in terms
of cost, accuracy, and ease of use.
Two relatively inexpensive, easy to use leak-detection devices
are:
■ Small, hand-held refrigerant leak detectors that indicate a perc
leak by a visual and audible signal; and
■ Colorimetric detector tubes (used with small, hand-operated
pumps) that change color depending on the perc vapor concen-
tration.
More sophisticated types of direct reading devices include infra-
red analyzers and photoionization detectors that provide accurate
measurements of perc concentration, but are more expensive and
require technical expertise to operate.
Assistance
13
For assistance with perc monitoring, consult your perc
supplier's product stewardship program or a professional dry
cleaning association, such as the International Fabricare Institute.
If you need the technical expertise of an industrial hygienist, the
American Industrial Hygiene Association (AIHA) offers a listing of
qualified consultants at:
http://www.aiha.org/ConsultantsConsumers/html/consultants
client.asp
Case Studies
14
A 5-ton cooling capacity refrigerated condenser was installed on
a vented, dry-to-dry machine in place of its original water-cooled
condenser and single-pass carbon adsorber. The retrofit cost less
than $5,000. Before the installation of the refrigerated condenser,
the average perc exposure of machine operators during the one-
minute machine loading and unloading phase was 1,139 ppm. After
the retrofit, the average exposure was 456 ppm, a reduction of
about 60 percent. NIOSH cautioned that only dry cleaning machines
in good repair with few leaks should be considered for retrofitting.
Although this technology significantly reduced perc exposure in this
case, it does not eliminate it and additional controls would be
needed to achieve further reductions.
15
Case Study #5: Local Exhaust Ventilation
Appendix A
Recommended Maintenance Schedule for
Dry Cleaning Machines
16
■ Rake out the still of the distillation unit (or daily as needed).
■ Clean the separator tank of the water separator and perform leak
checks.
■ Measure the exhaust temperature of the refrigerated condenser.
■ Measure perc in the exhaust system.
■ Perform leak checks on hose and pipe connections, fittings,
couplings, and valves.
Other
■ Clean and change filters according to the manufacturer’s
schedule.
*Note: The EPA requires weekly leak detection and repair for large dry cleaners and
bimonthly leak detection and repair for small dry cleaners. The type of machine (dry-
to-dry or transfer) and the amount of perc purchased each year determines whether
a dry cleaner is large or small. Refer to the Plain English Guide for Perc Cleaners for
details (http://www.epa.gov/opptintr/dfe/pubs/garment/perc/).
17
Appendix B
International Chemical Safety Card
for Tetrachloroethylene
18
SPILLAGE DISPOSAL
19
20
OSHA Assistance
State Programs
The Occupational Safety and Health Act of 1970 (OSH Act) en-
courages states to develop and operate their own job safety and
21
health plans. OSHA approves and monitors these plans. Twenty-
four states, Puerto Rico and the Virgin Islands currently operate
approved state plans: 23 cover both private and public (state and
local government) employment; 3 states, Connecticut, New Jersey
and New York, cover the public sector only. States and territories
with their own OSHA-approved occupational safety and health
plans must adopt standards identical to, or at least as effective as,
the Federal standards.
Consultation Services
Consultation assistance is available on request to employers
who want help in establishing and maintaining a safe and healthful
workplace. Largely funded by OSHA, the service is provided at no
cost to the employer. Primarily developed for smaller employers
with more hazardous operations, the consultation service is de-
livered by state governments employing professional safety and
health consultants. Comprehensive assistance includes an appraisal
of all mechanical systems, work practices and occupational safety
and health hazards of the workplace and all aspects of the em-
ployer’s present job safety and health program. In addition, the
service offers assistance to employers in developing and imple-
menting an effective safety and health program. No penalties are
proposed or citations issued for hazards identified by the con-
sultant. OSHA provides consultation assistance to the employer
with the assurance that his or her name and firm and any infor-
mation about the workplace will not be routinely reported to OSHA
enforcement staff.
Under the consultation program, certain exemplary employers
may request participation in OSHA’s Safety and Health Achievement
Recognition Program (SHARP). Eligibility for participation in SHARP
includes receiving a comprehensive consultation visit, demonstrat-
ing exemplary achievements in workplace safety and health by
abating all identified hazards and developing an excellent safety
and health program.
Employers accepted into SHARP may receive an exemption
from programmed inspections (not complaint or accident investiga-
tion inspections) for a period of one year. For more information
concerning consultation assistance, see the OSHA website at
www.osha.gov
22
Voluntary Protection Programs (VPP)
Voluntary Protection Programs and on-site consultation services,
when coupled with an effective enforcement program, expand
worker protection to help meet the goals of the OSH Act. The
three levels of VPP are Star, Merit, and Demonstration designed to
recognize outstanding achievements by companies that have suc-
cessfully incorporated comprehensive safety and health programs
into their total management system. The VPPs motivate others to
achieve excellent safety and health results in the same outstanding
way as they establish a cooperative relationship between employers,
employees and OSHA.
For additional information on VPP and how to apply, contact the
OSHA regional offices listed at the end of this publication.
Alliance Programs
The Alliances Program enables organizations committed to
workplace safety and health to collaborate with OSHA to prevent
injuries and illnesses in the workplace. OSHA and the Alliance
participants work together to reach out to, educate and lead the
nation’s employers and their employees in improving and advanc-
ing workplace safety and health.
23
Groups that can form an Alliance with OSHA include employers,
labor unions, trade or professional groups and educational institu-
tions. In some cases, organizations may be building on existing
relationships with OSHA that were developed through other coop-
erative programs.
There are few formal program requirements for Alliances and
the agreements do not include an enforcement component. How-
ever, OSHA and the participating organizations must define, im-
plement and meet a set of short- and long-term goals that fall into
three categories: training and education; outreach and communica-
tion; and promoting the national dialogue on workplace safety and
health.
24
Information Available Electronically
OSHA has a variety of materials and tools available on its
website at www.osha.gov. These include e-Tools such as Expert
Advisors, Electronic Compliance Assistance Tools (e-cats), Technical
Links; regulations, directives and publications; videos and other
information for employers and employees. OSHA’s software pro-
grams and compliance assistance tools walk you through challeng-
ing safety and health issues and common problems to find the best
solutions for your workplace.
A wide variety of OSHA materials, including standards, interpre-
tations, directives, and more, can be purchased on CD-ROM from
the U.S. Government Printing Office, Superintendent of Documents,
phone toll-free (866) 512-1800.
OSHA Publications
OSHA has an extensive publications program. For a listing of
free or sales items, visit OSHA’s website at www.osha.gov or
contact the OSHA Publications Office, U.S. Department of Labor,
200 Constitution Avenue, NW, N-3101, Washington, DC 20210.
Telephone (202) 693-1888 or fax to (202) 693-2498.
Contacting OSHA
To report an emergency, file a complaint or seek OSHA advice,
assistance or products, call (800) 321-OSHA or contact your nearest
OSHA regional or area office listed at the end of this publication.
The teletypewriter (TTY) number is (877) 889-5627.
You can also file a complaint online and obtain more infor-
mation on OSHA Federal and state programs by visiting OSHA’s
website at www.osha.gov
25
OSHA Regional Offices
Region I Region VI
(CT,* ME, MA, NH, RI, VT*) (AR, LA, NM,* OK, TX)
JFK Federal Building, Room E340 525 Griffin Street, Room 602
Boston, MA 02203 Dallas, TX 75202
(617) 565-9860 (214) 767-4731 or 4736 x224
Region IV Region IX
(AL, FL, GA, KY,* MS, NC,* SC,* TN*) (American Samoa, AZ,* CA,* HI,* NV,*
61 Forsyth Street, SW Northern Mariana Islands)
Atlanta, GA 30303 71 Stevenson Street, Room 420
(404) 562-2300 San Francisco, CA 94105
(415) 975-4310
Region V
(IL, IN,* MI,* MN,* OH, WI) Region X
230 South Dearborn Street (AK,* ID, OR,* WA*)
Room 3244 1111 Third Avenue, Suite 715
Chicago, IL 60604 Seattle, WA 98101-3212
(312) 353-2220 (206) 553-5930