16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915 #00089 

Submission Number:
Sushma Bhatia
San Francisco Department of the Environment
Initiative Name:
16 CFR Part 423: Trade Regulation Rule on Care Labeling of Textile Wearing Apparel and Certain Piece Goods, FTC Project No. R511915
Mr. Donald S. Clark Secretary of the Commission Federal Trade commission 600 Pennsylvania Avenue, NW Washington, D.C. 20580 Dear Secretary Clark: We at the San Francisco Department of the Environment (SFE) are thrilled that Federal Trade Commission (FTC) is considering the development of a garment care label for professional wet cleaning. We would like to express our support for the requirement of garment manufacturers and importers to provide these helpful, clarifying wet cleaning labels. Doing so allows conscientious consumers to learn about safer, greener alternatives in the dry cleaning industry. SFE was part of a major campaign to promote wet cleaning in the City & County of San Francisco. With the support of an EPA grant, SFE was able to offer monetary grants to garment cleaners switching out old Perc equipment to new wet cleaning technologies. During the course of our campaign on dry cleaning, we worked with OEHHA to develop a comprehensive analysis of dry cleaning solvents. For this analysis, we compared not just the scientific literature on health & environmental impacts of dry cleaning solvents, but also operational costs and compliance related impacts. Our alternatives analysis (attached) clearly shows that professional wet cleaning is the most environmentally preferable option. We, then, launched a multilingual campaign to educate cleaners about the benefits of wet cleaning. However, when we talked with our local cleaners, we learned that the garment labels that direct consumers to "dry clean garments" were a severe roadblock for adoption of professional wet cleaning. This created a taboo in the local dry cleaning community around wet cleaning which can now be addressed with new wet cleaning labeling requirements. Even today, after successfully helping 4 cleaners convert to wet cleaning, we find that the converted cleaners prefer to call themselves "organic or green dry cleaners' instead of "wet cleaners" -- this makes market proliferation of this technology an uphill battle. As consumers have more exposure to wet cleaning labels on their garments, they will become more familiar with the phrase, facilitating the incorporation of wet cleaning as a suitable and appropriate green option for their garment cleaning needs. We strongly support a garment care label that introduces consumers to the concept of wet cleaning. If you have questions about our work, please call me, Sushma Bhatia at 415-355-3758 or email at sushma.bhatia@sfgov.org. I have included a link below to our Garment Cleaning webpage for further information. Thank you for your time. Sincerely, Sushma Bhatia Toxics Reduction Program Manager San Francisco Department of the Environment Garment Cleaning http://www.sfenvironment.org/our_programs/interests.html?ssi=2&ti=3&ii=27