16 CFR Part 423 - Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods (the “Care Labeling Rule”), Project No. R511915 #00033 

Submission Number:
00033 
Commenter:
James Douglas
Organization:
Prestige Cleaners
State:
California
Initiative Name:
16 CFR Part 423 - Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods (the “Care Labeling Rule”), Project No. R511915

I have been working in the textile care industry since 1969. I was president of Swanson Cleaners that employed more than 400 great people. We used Stoddard Solvent which had to be removed due to UST by 1989. In preparation for this we tested every viable cleaning proces available, Valclene (elliminated by Montreal Compact), Dow LS, Wet Cleaning, Perc and finally GreenEarth. Our current plant has operated with GreenEarth since 1998. I sat on the ACTM Task Force for California and held a DCCM postion with DLI, and I am currently a Director for CCA. I am also certified as an CED, CPD and CPW (wet-cleaning). I believe my perspective having tested as many solvents as I have gives me a unique view as to how best to serve the dry cleaning customer and in turn the manufactuer of textile. The most common charateristic that results in the majority of textile claims of the different processes that we have seen and used is the aggressivity of a solvent. This charateristic identified by the KBV of the solvent is known and is an assigned value that can be tested for. The current position I believe FTC has taken is to recognize GreenEarth as an alternative solvent, we are in aggreement with this postion. The new rule also advises manufacturers to use symbols from the ASTM's 2007 guidelines which only recognizes hydrocarbon and perc. We ask that you update this to be consistent and compatible. The phrase of one step forward 2 steps back seems to be the direction that is being taken. We strongly suggest that dry cleaning solvent processes be evaluated by the KBV assigned to the specific solvent. We have seen too many solvents introduced into the cleaning industry and then later either removed by regulatory pressure such as Valclene & Perc (in California), or abandoned support such as Liquid CO2. Why continue to identify solvents by their name as they come and go, as opposed to a single chemical charateristic which is directly related to the potential of textile damage. We ask that you review the proposed suggestion of using KBV to determine the proper process, this was submitted in September of 2011. Thank you for the efforts you are making and I stand ready to help in any way. James Douglas