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Reducing Worker Exposure to Perchloroethylene (PERC) in Dry Cleaning
U.S. Department of Labor Occupational Safety and Health Administration OSHA 3253-05N 2005 Employers are responsible for providing a safe and healthful workplace for their employees. OSHA's role is to assure the safety and health of America's workers by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual improvement in workplace safety and health. This handbook provides a general overview of a particular topic related to OSHA standards. It does not alter or determine compliance responsibilities in OSHA standards or the Occupational Safety and Health Act of 1970. Because interpretations and enforcement policy may change over time, you should consult current OSHA administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the Courts for additional guidance on OSHA compliance requirements. This publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required. This information is available to sensory impaired individuals upon request. Voice phone: (202) 6931999; teletypewriter (TTY) number: (877) 889-5627. Contents Executive Summary Introduction Health Hazards Perc Exposure Current Regulations and Recommendations Machine Design and Maintenance Ventilation PPE, Work Practices and Training Perc Air Monitoring Assistance Case Studies Appendix A. Recommended Maintenance Schedule for Dry Cleaning Machines Appendix B. International Chemical Safety Card for Tetrachloroethylene OSHA Assistance OSHA Regional Offices Executive Summary This document has been prepared by the Occupational Safety and Health Administration (OSHA) to help dry cleaning establishments reduce employee exposures to perchloroethylene (also known as perc, tetrachloroethylene, C2Cl4 or Cl2C=CCl2). The dry cleaning industry has improved the control of perchloroethylene in recent years, and modern dry cleaning equipment involves much lower exposures than older style equipment. However, there is still a need to reduce employee exposure to the chemical to reduce any possible health effects that could result from long-term exposure to the chemical. Many dry cleaning employers have found that equipment design, preventive maintenance, control of leaks in equipment, proper ventilation, and good work practices can reduce perc exposure to workers, reduce costs by recovering perc for reuse, help create a cleaner environment, and help comply with federal and state environmental regulations. This booklet is not a standard or regulation, and it creates no new legal obligations. The document is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace. The Occupational Safety and Health Act requires employers to comply with hazard-specific safety and health standards. In addition, pursuant to Section 5(a)(1), the General Duty Clause of the Act, employers must provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm. Employers can be cited for violating the General Duty Clause if there is a recognized hazard and they do not take reasonable steps to prevent or abate the hazard. However, failure to implement these recommendations is not, in itself, a violation of the General Duty Clause. Citations can only be based on standards, regulations, and the General Duty Clause. Introduction Perchloroethylene (“perc”) has long been recognized as an effective dry cleaning solvent and today it is by far the most commonly used solvent in dry cleaning shops. However, as a volatile organic solvent, perc may pose serious health hazards if exposure is not properly controlled. Dry cleaning workers who routinely breathe excessive amounts of the solvent vapor or spill perc on their skin are at risk of developing health problems. Special precautions are recommended to avoid health risks from perc exposure. The purpose of this guidance is to provide practical and effective ways for dry cleaning operators to reduce worker exposure to perc. The guidance emphasizes reducing perc exposure through a combination of using modern equipment and preventive maintenance, control of leaks in dry cleaning equipment, proper ventilation, and good work practices. Health Hazards During dry cleaning, perc primarily enters the body from inhalation of the vapors, potentially resulting in the following health hazards:
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 Primary Sources of Perc Exposure Dry cleaning employees may be exposed to perc while performing both routine tasks and machine maintenance. Activities that result in elevated exposure include the following:
Uncontrolled emissions, so-called “fugitive emissions,” from dry cleaning machines can also expose workers to high levels of perc. These include:
Other possible sources of perc exposure not directly associated with the dry cleaning equipment include:
Current Regulations and Recommendations OSHA has set mandatory permissible exposure limits (PELs) for perc, presented in Table 1. This table also lists perc exposure limits recommended by other safety and health organizations.
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. Other OSHA standards that may apply when workers are exposed to perc include: Hazard Communication (29 CFR 1910.1200); General requirements for personal protective equipment (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.) Machine Design and Maintenance Dry cleaning technology has evolved substantially over the decades. The newer machine designs (dry-to-dry, closed looped) greatly reduce the amount of perc vapor released into the air inside the shop as well as outdoors, resulting in cost savings since more perc is recovered for reuse, as well as safer working conditions and a cleaner environment. The oldest type of dry cleaning machines – transfer machines – can expose workers to high amounts of perc, particularly during transfer of solvent-laden clothing from washer to dryer. Newer equipment (dry-to-dry machines) reduces worker exposure by eliminating this transfer step (clothes enter and exit the machine dry). The first dry-to-dry equipment, dry-to-dry vented, exhausts residual solvent vapors either directly outside or first through a perc vapor recovery system. The present designs, dry-to-dry closed loop machines, recirculate perc rather than release it outdoors. The 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.  Source: NIOSH. Replacing equipment that wears out with modern equipment can reduce exposures. Also, routine machine maintenance combined with detection and timely repair of identified leaks can be extremely effective in controlling airborne levels of perc vapor. (See the Case Studies starting on page 14.) The EPA estimates that as much as 25 percent of solvent emissions can be attributed to leaks. In addition to creating unsafe airborne levels of perc, leaks are waste-ful and costly. Routine machine maintenance needs to be performed to ensure optimal operation of all components. Appropriate personal protective equipment (PPE) needs to be worn during maintenance activities to ensure protection from perc hazards. (See page 10 for more information on PPE.) Recommended machine maintenance activities include the following:
NEVER PERFORM MAINTENANCE WHILE DRY CLEANING EQUIPMENT IS OPERATING. To control perc leaks from dry cleaning equipment:
Adequate ventilation is essential for controlling perc levels within the dry cleaning shop. General ventilation, provided by equipment such as overhead fans, is useful for reducing heat and humidity, and diluting perc levels. Such ventilation can be designed to move the perc vapors away from workers and customers while continuously supplying clean, fresh air to the dry cleaning area. Local exhaust ventilation (LEV) captures perc vapor at the source of the release, removing the vapor before it enters the air inside the shop. Well-designed LEV may be provided where perc exposure is highest, for example, at the loading door. Newer dry cleaning equipment has built-in LEV designed to prevent escape of vapors during machine loading and unloading. For machines without built-in LEV, an external ventilation hood outside the machine door can be installed to control vapors when the door is open. (A study describing this method of control is summarized in Case Study #5 at page 16.) Detailed information regarding desirable configurations for general ventilation and LEV as well as recommendations on exhaust fan placement and capacity can be found in pamphlets by the International Fabricare Institute (IFI) (1989)2 and NIOSH (1998)3. PPE, Work Practices and Training Personal protective equipment (PPE) – including aprons, gloves, goggles, and respirators approved for use with organic chemicals – is used to help workers avoid perc exposure. Workers must wear respirators equipped with filters or cartridges specifically designed for organic vapors when elevated perc exposures are anticipated (29 CFR 1919.134). Tasks where elevated exposure may occur include 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. 2 IFI. 1989. Reducing Vapor Exposure: OSHA compliance. International Fabricare Institute. Vol. 13, No. 5. 3 NIOSH. 1998. Control of Exposure to Perchloroethylene in Commercial Drycleaning. NIOSH Hazard Controls. DHHS (NIOSH) Publication No. 97-154. http://www.cdc.gov/niosh/hc16.html 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 transfer operations. Other important work practices to reduce perc exposures are listed below. Work Practice Tips for Dry Cleaning Operators
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 responding 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). Perc Air Monitoring A variety of devices and instruments are available to measure perc levels in the air. Reasons for performing air monitoring include:
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 concentration 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:
Assistance OSHA has a free consultation service for small and medium-sized businesses with hazardous operations. The service is confidential and offers the expertise of qualified occupational safety and health professionals to employers who request advice and assistance. OSHA consultation is available in all 50 States, the District of Columbia, Guam, Puerto Rico, the Northern Mariana Islands and the Virgin Islands. Information on OSHA consultation services can be found at: www.osha.gov/dcsp/smallbusiness/consult.html 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 Dry cleaning shop owners have numerous options available for reducing the perc exposures of their employees. The case studies below describe the effectiveness of measures such as installing relatively low-cost machine retrofits, installing LEV, and performing routine machine maintenance and leak detection. Case Study #1: Emission Control Retrofit – Carbon Adsorber Installing a new carbon adsorber on a dry cleaning machine reduced the perc exposures of operators by 92 percent, according to a NIOSH study. The 60-pound, closed-loop carbon adsorber was installed to remove residual perc not collected by the existing refrigerated condenser on the closed-loop, dry-to-dry machine. The retrofit cost less than $5,000. Before the retrofit, the average perc exposure of operators during the one-minute machine loading and unloading process was 353 ppm. After the carbon adsorber was installed, the average exposure was 29 ppm, a reduction of approximately 92 percent. Case Study #2: Emission Control Retrofit – Refrigerated Condenser A NIOSH study found that perc exposures of dry cleaning machine operators were reduced by 60 percent after a refrigerated condenser was installed on a dry cleaning machine. 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. Case Study #3: Gasket Leak – Detection and Repair Repairing a leaking gasket on a dry cleaning machine resulted in a full-shift perc exposure reduction of 22 ppm, according to a NIOSH study of retrofit emission controls (described further in Case Study #2). The gasket at the rear of the machine being retrofitted with a new refrigerated condenser sprung a leak during the installation. Before the retrofit, TWA perc concentrations averaged 47 ppm. Measurements taken after the leak was fixed resulted in an average perc exposure of 25 ppm. Case Study #4: Distillation Unit Leak – Detection and Repair During the LEV evaluation (described in Case Study #5), NIOSH noted that the full-shift perc exposures of machine operators were up to four times higher on the day when the distillation unit was operating (about 20 ppm vs. 5 ppm when the unit was turned off). These elevated readings led to the identification and repair of a leak in the distillation system. If perc monitoring had not been conducted, the leak might not have been detected. This study underscores the importance of routine perc air monitoring to identify and repair equipment leaks. Case Study #5: Local Exhaust Ventilation A NIOSH study showed that installation of a simple, inexpensive LEV system was effective in reducing average full-shift TWA perc exposures of machine operators by 37 percent. Before the LEV installation, the average full-shift perc exposure was 4.7 ppm. The 12-year-old dry cleaning machine was a dry-todry, closed-loop design with a 50-pound capacity. The LEV system, including fabrication, installation, and electric wiring, was installed for $2,560. The LEV was positioned directly above the dry cleaning machine door and exhausted air from in front of the door only when the door was opened. The average perc exposure was reduced by about 37 percent, to 3.0 ppm, after the LEV installation. Appendix A Recommended Maintenance Schedule for Dry Cleaning Machines Daily Maintenance Tasks
Appendix B International Chemical Safety Card for Tetrachloroethylene The following International Chemical Safety Card (ICSC) for tetrachloroethylene was published in 2000. The ICSCs project is an undertaking of the International Programme on Chemical Safety (IPCS). The project is being developed in cooperation between the IPCS and the Commission of the European Communities. The IPCS is a joint activity of three cooperating international organizations: the United Nations Environment Programme (UNEP), the International Labour Office (ILO) and the World Health Organization (WHO). The main objective of the IPCS is to carry out and disseminate evaluations of the hazards posed by chemicals to human health and the environment. ICSC cards summarize essential health and safety information on chemicals for their use at the shop floor level by workers and employers. Cards are available for over 1,300 chemicals, and they are provided in several languages, including English, Korean, Spanish, Russian, French, German, Japanese and Chinese. To access the most recent ICSC card for perc, to locate the perc card in another language, or to find the card for another chemical, access the NIOSH Internet site at: http://www.cdc.gov/niosh/ipcsneng/neng0076.html. International Chemical Safety Cards
International Chemical Safety Cards
OSHA Assistance OSHA can provide extensive help through a variety of programs, including technical assistance about effective safety and health programs, state plans, workplace consultations, voluntary protection programs, strategic partnerships, training and education, and more. An overall commitment to workplace safety and health can add value to your business, to your workplace and to your life. Safety and Health Program Management Guidelines Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and their related costs. In fact, an effective safety and health program forms the basis of good worker protection and can save time and money (about $4 for every dollar spent) and increase productivity and reduce worker injuries, illnesses and related workers' compensation costs. To assist employers and employees in developing effective safety and health programs, OSHA published recommended Safety and Health Program Management Guidelines (54 Federal Register (16): 3904-3916, January 26, 1989). These voluntary guidelines apply to all places of employment covered by OSHA. The guidelines identify four general elements critical to the development of a successful safety and health management program:
State Programs The Occupational Safety and Health Act of 1970 (OSH Act) encourages states to develop and operate their own job safety and 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 delivered 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 employer's present job safety and health program. In addition, the service offers assistance to employers in developing and implementing an effective safety and health program. No penalties are proposed or citations issued for hazards identified by the consultant. OSHA provides consultation assistance to the employer with the assurance that his or her name and firm and any information 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, demonstrating 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 investigation inspections) for a period of one year. For more information concerning consultation assistance, see the OSHA website at www.osha.gov 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 successfully 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. Strategic Partnership Program OSHA's Strategic Partnership Program, the newest member of OSHA's cooperative programs, helps encourage, assist and recognize the efforts of partners to eliminate serious workplace hazards and achieve a high level of worker safety and health. Whereas OSHA's Consultation Program and VPP entail one-on-one relationships between OSHA and individual worksites, most strategic partnerships seek to have a broader impact by building cooperative relationships with groups of employers and employees. These partnerships are voluntary, cooperative relationships between OSHA, employers, employee representatives and others (e.g., trade unions, trade and professional associations, universities and other government agencies). For more information on this and other cooperative programs, contact your nearest OSHA office, or visit OSHA's website at www.osha.gov 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 advancing workplace safety and health. Groups that can form an Alliance with OSHA include employers, labor unions, trade or professional groups and educational institutions. In some cases, organizations may be building on existing relationships with OSHA that were developed through other cooperative programs. There are few formal program requirements for Alliances and the agreements do not include an enforcement component. However, OSHA and the participating organizations must define, implement and meet a set of short- and long-term goals that fall into three categories: training and education; outreach and communication; and promoting the national dialogue on workplace safety and health. OSHA Training and Education OSHA area offices offer a variety of information services, such as compliance assistance, technical advice, publications, audiovisual aids and speakers for special engagements. OSHA's Training Institute in Arlington Heights, IL, provides basic and advanced courses in safety and health for Federal and state compliance officers, state consultants, Federal agency personnel, and private sector employers, employees and their representatives. The OSHA Training Institute also has established OSHA Training Institute Education Centers to address the increased demand for its courses from the private sector and from other Federal agencies. These centers are nonprofit colleges, universities and other organizations that have been selected after a competition for participation in the program. OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training and education in subjects where OSHA believes there is a lack of workplace training. Grants are awarded annually. Grant recipients are expected to contribute 20 percent of the total grant cost. For more information on grants, training and education, contact the OSHA Training Institute, Office of Training and Education, 2020 South Arlington Heights Road, Arlington Heights, IL 60005, (847) 297-4810 or see “Outreach” on OSHA's website at www.osha.gov. For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this publication. 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 programs and compliance assistance tools walk you through challenging safety and health issues and common problems to find the best solutions for your workplace. A wide variety of OSHA materials, including standards, interpretations, 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 information on OSHA Federal and state programs by visiting OSHA's website at www.osha.gov OSHA Regional Offices Region I (CT,* ME, MA, NH, RI, VT*) JFK Federal Building, Room E340 Boston, MA 02203 (617) 565-9860 Region II (NJ,* NY,* PR,* VI*) 201 Varick Street, Room 670 NewYork, NY 10014 (212) 337-2378 Region III (DE, DC, MD,* PA, VA,* WV) The Curtis Center 170 S. Independence Mall West Suite 740 West Philadelphia, PA 19106-3309 (215) 861-4900 Region IV (AL, FL, GA, KY,* MS, NC,* SC,*TN*) 61 Forsyth Street, SW Atlanta, GA 30303 (404) 562-2300 Region V (IL, IN,* MI,* MN,* OH, WI) 230 South Dearborn Street Room 3244 Chicago, IL 60604 (312) 353-2220 Region VI (AR, LA, NM,* OK,TX) 525 Griffin Street, Room 602 Dallas, TX 75202 (214) 767-4731 or 4736 x224 Region VII (IA,* KS, MO, NE) City Center Square 1100 Main Street, Suite 800 Kansas City, MO 64105 (816) 426-5861 Region VIII (CO, MT, ND, SD, UT,* WY*) 1999 Broadway, Suite 1690 PO Box 46550 Denver, CO 80202-5716 (720) 264-6550 Region IX (American Samoa, AZ,* CA,* HI,* NV,* Northern Mariana Islands) 71 Stevenson Street, Room 420 San Francisco, CA 94105 (415) 975-4310 Region X (AK,* ID, OR,* WA*) Third Avenue, Suite 715 Seattle, WA 98101-3212 (206) 553-5930 * These states and territories operate their own OSHA-approved job safety and health programs (Connecticut, New Jersey and NewYork plans cover public employees only). States with approved programs must have a standard that is identical to, or at least as effective as, the Federal standard. Note: To get contact information for OSHA Area Offices, OSHA-approved State Plans and OSHA Consultation Projects, please visit us online at www.osha.gov or call us at 1-800-321-OSHA. |
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