Submission Number: 00091
Received: 9/2/2011 1:36:18 PM
Commenter: Lara Bromagen
Organization: Best Cleaners
Agency: Federal Trade Commission
Initiative: 16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
Attachments: No Attachments
Listing all appropriate methods of care would be a benefit to the fabricare professional. As the care label rule is now I accept responsibility and liability for processing a garment in a method not listed on the care label.
What modifications should be made to the Rule as to the results of impending changes in technology?
The current definition of drycleaning is very limiting and includes fluorocarbon, a solvent that was been regulated out of existence toward the end of the last century. The Care Label Rule conflicts with state laws that call for a ban on perchlorethylene, a common drycleaning solvent.
I have recently changed to a new solvent, which involved purchasing a costly new cleaning machine, but am concerned that labels will no longer provide the information we so desperately need. Testing and acceptance in labeling need to allow for updated technology. The Care Label Rule should not curtail technological advancement of the fabricare industry.
Cleaning professionals often accept garments that have been purchased outside the U.S. It would be very helpful in this business if the care instructions found on foreign and domestic labels were in agreement. We do our best to service our customers special items purchased on vacation or trips out of the us - sometimes with heart breaking results when the customer realizes not all items are manufactured with the care they expect.
The rule should include Professional Wetcleaning. More of my customers want their drycleanable garments washed, and for many reasons, including environmental impact, consumer demand and local regulations, I invested time and money in the equipment and staff training. However, I am accepting all responsibility for wetcleaning since the method is not recognized by the Care Label Rule.
I appreciate the opportunity to share my concerns with the Care Label Rule as it is now and proposed amendments. Thank you for accepting my comments. If you have any questions or would like any additional information please contact me at Best Cleaners Corporate office #405-722-7557 or via email