The Environmental Protection Agency is postponing indefinitely a proposed ban on the use of trichloroethylene (TCE) as a drycleaning spotting chemical, according to a report in The New York Times. The report comes a year after EPA an- nounced that TCE was among chemicals on fast-track to be banned, possibly as early as the end of 2017. EPA now has placed a ban of TCE on a list of “long-term actions’’ without a set deadline. TCE and perchloroethylene were both on a list of 10 chemicals that EPA said it would be reviewing under the revised Toxic Substance Control Act passed by Congress in 2016. That legislation required EPA to publish a list of chemicals to evaluate for potential risks to human health and the en- vironment. Publication of the list triggered a statu- tory deadline for EPA to complete risk eval- uations for these chemicals within three years.  If an evaluation determined that a chemical presents an unreasonable risk to humans and the environment, EPA would need to mitigate that risk within two years. So far EPA has published only a “scop- ing document” for perc and action on that chemical could take a few years. But soon after publishing the list, EPA announced  that it was proceeding with a ban on TCE when used as a degreaser and a spot removal agent in drycleaning. Specifically, EPA said it wanted to pro- hibit the manufacturing, importing, pro- cessing and distribution of TCE for use in aerosol degreasing and spot cleaning in drycleaning. The agency said it had identified serious risks to workers and consumers associated with TCE uses in a 2014 assessment that concluded that the chemical can cause a range of adverse health effects, including cancer, development and neurotoxicologi- cal effects, and toxicity to the liver. According to the EPA, the majority of TCE is used as an intermediate for manu- facturing refrigerants. Much of the remain- der — about 15 percent — is used as a sol- vent for metals degreasing. Other uses include as a spotting agent in drycleaning and in consumer products. The proposal drew criticism from the Drycleaning and Laundry Institute, the Na- tional Cleaners Association and the Halo- granted Solvents Inustry Alliance. In comments to EPA on the proposed ban, the HSIA said it “is based on a very deficient risk assessment completed before TSCA was revised.” “The better course would be to assess the risks from spot cleaning and aerosol degreasing as part of the required upcoming TCE assessment,” HSIA said. HSIA said that EPA had given no notice that its 2014 assessment would address TCE’s use as spot cleaner in drycleaning, thus there was no participation by drycleaner representatives and no peer re- view of the spot cleaning assessment. Nor was there a Small Business Advocacy Re- view, even though spot cleaning is done by drycleaners who are virtually all small busi- nesses. HSIA also questioned EPA’s claim that the rule would have no significant eco- nomic impact on drycleaners. In proposing the ban, EPA said drycleaners have avail- able a number substitutes that are compa- rably priced. In comments to EPA, DLI’s Jon Meijer said that while alternatives are available, they aren’t necessarily equally effective. “Alternatives to TCE require more time on the spotting board in an attempt to re- move the same stain from the garment,” Meijer said. Alan Spielvogel of NCA said the ban could negatively effect a drycleaner’s bot- tom line. Alternatives to TCE are not as ef- fective, present risks to the garment that do not exist with TCE and are more time con- suming to use in order to achieve similar results, he said. “Our position is that between labor and utilities, an increased cost as a percentage of gross sales of between four and five per- cent of gross sales can be expected if TCE’s use is prohibited as a spot cleaner in the in- dustry,” Spielvogel said. Last summer, the U.S. House Appropri- ations Committee urged EPA to back off its proposed TCE ban. “Rather than continuing with those rule- makings, the committee encourages EPA to consider those chemical uses as part of the risk evaluation process for the ten pri- ority compounds recently designated by EPA under TSCA section, which include the chemicals in question,” the committee report stated. Disruptor of drycleaning January 2018 Volume 59 Number 4 www.natclo.com Sneak Peek That collar cone 24 What do you do when things around you change? Sell out? Move away? Improve in place? Or just stand pat? 36Who’s calling? 20 Collar cones have many uses, some good and some not. Don Desrosiers asks, how do you use yours? Mobile phones are everywhere now, including the workplace. Frank Kollman says business owners need to address their use. Winds of change National Clothesline EPAsaid to put brakes on banning TCE Charles Ickes former chief logistics officer for Rent the Runway, discussed the drycleaning op- eration of the garment rental company during a session at NCA’s recent Texcare show in Secaucus. James Peuster checks his crystal ball for what changes could be coming in the route business in 2018. 30What’s up for 2018? Imagine a competitor with a 200,00-sq.-ft. plant that can process 5,000 pieces per hour, targets high income customers in the 25 to 40 age group. This competitor has already raised $130,000 million to fund its growing busi- ness and has the goal of capturing 10 percent of the $7 billion U.S. drycleaning market. This is not an imaginary competitor. It’s Rent the Runway, which aims to replace the closet in the home with a closet in the cloud. A look inside this operation was provided by Charles Ickes, former chief logistics officer of New York-based Rent the Runway, who spoke during the National Clean- ers Association’s Texcare event in Secaucus, NJ, in Oc- tober. The company was started in 2009 by two Harvard Business School classmates, Jennifer Fleiss and Jennifer Hyman, who thought women might be interested in rent- ing rather than owning high-fashion attire. The company was still relatively small by the time Ickes joined it in 2011, handling 150,000 pieces per year with all the drycleaning outsourced. He brought with him a background in drycleaning having worked for Madame Paulette in New York and Dependable Cleaners in Massachusetts. Now he said the company’s drycleaning facility near Secaucus is the largest in the world with enough business to keep its 78 drycleaning machines spinning through two shifts a day with four million pieces cleaned in 2017. Rent the Runway’s customers can make their selection on-line at renttherunway.com or at one of the company’s brick-and-mortar stores in New York, Chicago, Wash- ington, San Francisco and Los Angeles. The price of the rental is a fraction of what it would cost to buy the gar- ment outright and that price includes shipping to and from the customer and, of course, the drycleaning. “Drycleaning is not something that is really important to Rent the Runway,” he said. “It’s something they do on the side. They’re really out to disrupt fast fashion but you, the drycleaner, will probably be collateral damage.” While drycleaning is not the focus of Rent the Run- way, it’s important to have the cleaning operation opti- mized to handle that many garments quickly and effec- tively. The company’s investment in a $60 million inventory requires that the returned garments can be made like-new as fast as possible to be ready to rent again. When Ickes started with Rent the Runway, garments had four-day turnaround from when they were first re- ceived to when they could go out again. That wasn’t sus- tainable, he said. Since they are dealing with many cus- tomers who want garments for weekend occasions, they would essentially lose a week of rental possibilities if garments took that long which would require having twice the inventory just to maintain the rental rates where they want them. This led Ickes to explore and experiment with every aspect of the process, from marking in to cleaning, fin- Continued on page 8