"Pressing Issues"

Newsletter of the Saskatchewan Professional Drycleaner's Association

Contents

Our 12th Annual convention is set for:

    MARCH 8 - 9, 2002
    SASKATOON, SASKATCHEWAN

NEW FEDERAL REGULATIONS WILL REDUCE
EMISSIONS FROM DRY CLEANING OPERATIONS

OTTAWA, August 28, 2001 - Proposed regulations to dry cleaning operations under the new Canadian Environmental Protection Act (CEPA) will significantly reduce the release of a toxic substance called tetrachloroethylene (PERC).

The proposed Tetrachloroethylene Regulations, Used in Dry Cleaning, will require dry cleaners across Canada to meet new national performance requirements.

“These proposed regulations will bring cleaner air, less toxic contamination in our communities and promote recycling of used solvent, as well as improve the quality of the workplace environment,” said Environment Minister David Anderson.  “While many dry cleaners are already greening their operations through new technologies and improved waste management, these regulations accelerate that trend, create a level playing field for the industry and ensure that public health and safety standards are met across Canada.”

The use of new technology by the dry cleaning industry has reduced releases of PERC by about 50 per cent from 1994, according to a 1998 study carried out by Environment Canada.  The proposed regulations will mean a further 20 per cent reduction.  Other regulations under CEPA to reduce environmental releases from solvent degreasing operations, the other major source of tetrachloroethylene, are being developed.

The proposed regulations, published in the Canada Gazette, Part 1 for a 60-day public comment period, contain the following key provisions:

· the phase out of old technology dry cleaning machines by 2002;
· the use of cleaning machines which consume less toxic solvent by 2002;
· a stewardship provision for solvent suppliers to c collect contaminated waste and waste water from dry cleaners; and
· an option for dry cleaners to manage and treat their own contaminated waste.

The regulations also fulfill the Government of Canada’s obligation to develop control measures for the life-cycle management of tetrachloroethylene, which has been found to be toxic to the environment as defined under CEPA.  Almost all of the solvent used in dry cleaning is lost to the environment as emissions during the cleaning process, or from spills or improper disposal of waste and waste water.

Both short and long term exposure to tetrachloroethylene can affect the health of humans.  Possible symptoms range from respiratory and ocular irritation to headaches and loss of memory.  More serious cases can result in neurological impairment, liver and kidney damage and cardiac ailments.

The toxic can also adversely affect plants and aquatic organisms, such as fish.  It will disappear when concentrations in the environment are lowered and eventually degrade due to sunlight.

Tetrachloroethylene enters the atmosphere mainly through evaporation and may be transported for considerable distances until deposited with precipitation.  Levels of the substance found in groundwater and springs were identified as a concern, particularly in contaminated areas caused by inappropriate disposal of tetrachloroethylene.

The new regulations can be found on
Environment Canada’s Green Lane at:
http://www.ec.gc.ca/CEPARegistry.

The new regulations are expected to be in force in early 2002.     ?
 

Some comments in response to this News Release are as follows:

...The impending legislation will have a great impact on our industry.  We believe that a joint response form the provincial associations will have a greater impact than individual responses.

...B.C.F.A. will meet and formulate a response, if any is deemed needed, to the publication in Canada Gazette, Part 1.

...There are some technical problems and inaccuracies in the preamble and some erroneous assumptions in the financial model.

... Those operators for whom the impact will be greatest are those who have not, for whatever reason, kept their knowledge, equipment and operations up-to-date.

... With the probable exception of Saskatchewan Professional Drycleaners Association (S.P.D.A.), there is no provincial association that can accurately claim to represent a majority of operators in any province. ?

YOUR executive has been working diligently
in an attempt to amend
The Provincial Sales Tax Act.

Thank you to all those involved
for your hard work in achieving this endeavor.

Following several unsuccessful attempts to meet with the Finance Department, a meeting was scheduled for July 18, 2001.

Our purpose was to open discussions with the Finance Department regarding application of Provincial Sales Tax collected by our industry.  We submitted that some of our supplies should be PST Exempt as they are covered in the PST collected when we  complete a transaction.  These supplies are PST Exempt in many other provinces, such as Manitoba, British Columbia and Ontario (Alberta not applicable).

We proposed that supplies should be PST exempt when they “come in direct contact with the clothes”.  This would not be the same format as GST style exemption, where all costs are GST exempt; rather, supplies coming in direct contact with clothes would be PST exempt at source, when identified by the purchaser or the vendor.  Some of these supplies would include:
· drycleaning solvents
· soaps and additives to wet and drycleaning
· stain removal chemicals
· mark-in supplies (tags, staples, pins, etc .)
· packaging supplies (hangers, plastic covers, etc.)

We also suggested that capital costs for equipment that comes in direct contact with clothes should be PST exempt.  This would be consistent with all the same principles as the above supplies.

We have some associated services that do not appear to be PST Collectable.  Many of our members are collecting and submitting the PST on these items simply because it is too difficult to separate these items and handle differently.  The software is not readily available for this type of separate accounting within our industry.  If we are competing directly with a specialist in their particular field, we are at a 6% disadvantage.  This includes items like:
¨ blind cleaning
¨ rug cleaning
¨ repairs and alterations

We suggested that the Finance Department make all supplies “directly in contact with clothes” PST exempt, immediately.  Other issues can be discussed and dealt with at a later date.      ?
           Information
Saskatchewan  Finance Revenue Division   Bulletin
      2350 Albert Street
      Regina, Sask.
      S4P 4A6

Originated:  March 30, 2000       No. PST-53
Revised:      August 2001

RE:  THE PROVINCIAL SALES TAX ACT

INFORMATION FOR LAUNDERERS AND DRY CLEANERS

This bulletin has been prepared to help you apply and collect the Provincial Sales Tax.  It is a general guide and not a substitute for the legislation.

The rate of tax is 6%.  The tax applies before the addition of the GST.

The changes in this Bulletin are indicated by a (l).

LAUNDRY AND DRY CLEANING SERVICES

Laundry and dry cleaning services are subject to Provincial Sales Tax.  Businesses that provide these services must collect tax on the charges for cleaning and laundering clothing, bedding, drapes, blinds, rugs and similar items.

Businesses that purchase these services for resale may purchase the services tax exempt by quoting their Provincial Sales Tax licence number to their suppliers.

DRY CLEANING SALES AGENTS

Dry cleaners who establish agents throughout an area for pick-up and drop-off of items for cleaning may account for tax using one of two methods:

· If the agent sells the services as an independent firm, the agent must collect the tax.  The agent can purchase the dry cleaning services tax exempt by providing the drycleaner with their Provincial Sales Tax licence number.

· If the agent sells the services on behalf of the dry cleaner, the dry cleaner must collect and remit the tax.

ALTERATIONS AND REPAIRS

Businesses that provide these services must collect tax on the total charge to their customers for alteration charges, such as mending, hemming, zipper replacement and sewing.  Tax does not apply to the materials used in the repair.  You may purchase the repair materials tax exempt by providing your vendor’s licence number to the supplier.

Alterations or repairs to children’s clothing are not subject to tax.

Businesses that purchase alterations and repair services for resale may purchase the services tax exempt by providing their Provincial Sales Tax licence number to their supplier.

PACKAGING MATERIALS

Effective August 1, 2001 all purchases of containers, labels, hangers, plastic covers, pins, tags and similar supplies provided to the customer with laundry and dry cleaning services are exempt from tax.  You may purchase the materials tax exempt by providing your Provincial Sales Tax licence number to the supplier.

EXEMPT SERVICES

Businesses that provide self-service coin-operated laundry services are not required to collect tax.

LOST OR DAMAGED GOODS

Launderers and dry cleaners who replace lost or damaged goods for their customers are responsible for tax on the purchase of the replacement goods.

SALES OF USED BUSINESS ASSETS

Businesses are required to pay tax on purchases of equipment, services, and supplies used in their business.  If they are purchased from a licensed supplier, the tax must be paid to the supplier.  If they are purchased from an unlicensed supplier located outside Saskatchewan, the tax must be submitted with the return on the laid down cost, which includes exchange, transportation charges, customs and excise duties, and importation charges, but not the GST.

Goods and services on which the tax must be paid include:

· Equipment, tools, furnishings, repair parts, repair labour and stationery.

· Cleaning supplies, including chemicals, soaps and solvents.

FOR FURTHER INFORMATION

Write:   Saskatchewan Finance  Telephone:   Toll Free 1-800-667-6102
   Revenue Division     Regina 306-787-6645
   2350 Albert Street
   Regina, Saskatchewan  Fax:  306-787-9644
   S4P 4A6

Information bulletins and publications are available on the Internet at:
www.gov.sk.ca/finance

COUNCIL  GIVES  PERC  CLEAN  BILL  OF  HEALTH

The American Council on Sciences and Health based in New York City, has concluded the drycleaning fluid perchloroethylene (also called perc) is not hazardous to humans at typical levels of use.

Activists have frequently warned consumers to air drycleaned clothes thoroughly before wearing them to rid them of any perc residue.

The new report “The Scientific Facts About the Drycleaning Chemical Perc,” notes there is no need for consumers to far adverse health consequences from exposure to recently drycleaned clothes or from living near a drycleaning establishment.

The new report examines the data behind claims that perc is a health hazard - both in terms of possible toxic effects and with respect to the possibility that it is a carcinogen.

While industrial workers exposed to perc on the job have been known to experience effects such as nausea, headaches and dizziness, these effects are not seen in persons exposed to perc at typical environmental levels.

Claims that perc can cause cancer are largely based on studies of mice and rats in which they are exposed to very high levels of the chemical every day for a lifetime.  Such exposures have resulted in liver cancers in mice and kidney cancers in male rats.

Importantly, rodents metabolize perc differently than humans and available data does not support extrapolation of this effect to humans – especially at the low concentrations in which consumers are typically exposed.

Several governmental agencies have investigated the possible risks of perc, but don’t agree on the extent of the risks it might pose.  Analyses of the most complete data sets do not support charges that perc poses any risk to the general public.

ACSH president Dr. Elizabeth Whelan states:  “A careful analysis of the scientific data does not support the idea that perc is an imminent hazard to the public.  Claims that it is are simply examples of how science is often inclined to generate unwarranted concerns.”

The American Council on Science and Health is a consortium of more than 350 scientists and physicians dedicated to consumer education of public health issues, such as the environment, nutrition and pharmaceuticals.  ACSH attempts to illuminate the difference between real health risks and hypothetical or trivial health scares.      ?
 

S P O T    N E W S

HSIA  Studies  Underway:  A  Conversation  with  Dr.  Paul  H.  Dugard

The Halogenated Solvents Industry Alliance (HSIA) has begun two important and potentially impactful studies on perchloroethylene (perc).  One is a “mechanistic” study that seeks to determine the differences between rodents and humans when each species is exposed to high doses of perc.  The other is an “epidemiology” study of drycleaning populations to find any association between their health and their exposure to perc over an extended period of time.  The findings of these studies could greatly influence not only research into the causes and effects of human cancer, but also new regulations developed by the Occupational, Safety and Health Administration (OSHA) and the Environmental Protection Agency (EPA).

We spoke with Dr. Paul Dugard, Director of Scientific Programs, HSIA, in Washington, D. C. about the history, the science, and the significance these two HSIA-sponsored studies could have on chemical producers and distributors, as well as on drycleaners and their businesses.

Spot News:  To begin, Dr. Dugard, we would like to thank you for taking some time out to speak with us.  Would you give us some background on the two perchloroenthylene studies HSIA has undertaken?

Dugard:  My pleasure.  As your readers may be aware, perchloroenthylene has been around for quite some time now, and much work ahs been done on the possible effects perc may have in both humans and animals.  The potential for perc to cause cancer began to be investigated seriously between the late 1970’s and mid-1980’s.  Around that time, the National Toxicology Program (NTP) began studies to test for cancer in rats and mice.  This has led to the “mechanistic” type of study that HSIA is undertaking now.  We have also begun an “epidemiology” study, a scientific investigation into a population of humans.  In this case we’re studying a population of drycleaners that were exposed to perc over an extended period of time.  These are the two studies I will discuss in greater detail.

Spot News:  There’s been news about another epidemiological study recently, hasn’t there?

Dugard:  Yes, a study was recently published by the National Institute of Occupational Safety and Health (NIOSH), a non-regulatory government agency that develops scientific issues for agencies like OSHA.  Like the other existing studies on perc or on drycleaners, this study has limitations that are freely acknowledged by the authors, which belie their controversial interoperation of the results.  Even though we have some good information from this study, the fact remains that it’s not definitive and questions remain unanswered.

Spot News:  Before we discuss the HSIA studies, what is the current situation on the regulatory side?

Dugard:  Well, OSHA is working on a perc standard, and the EPA is updating their IRIS (Integrated Risk Information System) database.  This is significant because this database determines the EPA’s definitive position on the toxicity of a given chemical.  The National Emission Standards for Hazardous Air Pollutants (NESHAP), brought out under the Clean Air Act, already applies to drycleaning, as your readers are aware.  The NESHAP, you may recall, defines the quality of equipment that should be used by drycleaners.  The next stage of the NESHAP process considers the success of the program by assessing “residual risk,” and this will be based on the information in the IRIS database.  Both OSHA and the EPA are currently doing risk assessments for cancer, both operate under a conservative mode, both will assume the worst where there are uncertainties, and both will do their calculations accordingly.

Spot News:  Let’s discuss the science behind the HSIA-sponsored mechanistic study.

Dugard:  Thus far, In terms of mechanism, we know that perc is not genotoxic — it does not attack DNA directly.  Therefore, we can say with certainty that perc, or materials crated from perc in the body, do not create mutations that may lead to cancer.  The most important by-product of perc metabolism is trichloroacetic acid (TCA) in both the human body and in animals.  This is a member of a class of chemicals that cause certain organelles to proliferate or multiply in rodents.  This is called “peroxisome proliferation.”

It is interesting to note that a number of commonly used human drugs are potent peroxisome proliferators.  In comparison, perc and TCA are very weak agents in this process.  However, at very high exposure levels they, like other peroxisome proliferators, have been found to cause liver tumors and cancers in mice.  The more potent peroxisome proliferators cause liver tumors in both rats and mice.  Interestingly enough, higher species of animals, even species like hamsters, do not develop these tumors.  Thus, there are o signs that perc causes peroxisome proliferation in humans, and there is no evidence that peroxisome proliferators, no matter how potent they are in rodents, cause liver tumors in humans — or any other types of tumors for that matter.  In a nutshell, what this means overall is that when humans — or human liver cells in the lab, to be more specific — are exposed to perchloroethylene in the same doses as rats or mice, there is no reaction.  We get a non-response.

Spot News:  Why has the occurrence of liver tumors in rats and mice been linked to humans then?

Dugard:  First off, let me say that the difference between rats and mice and humans in these studies is very clear cut.  The Food and Drug Administration (FDA) recognizes this difference and is not concerned about peroxisome proliferation in humans.  in the same way, European agencies show low concern about the mouse liver tumors and perc causing cancers in humans because they recognize the differences between rodents and humans in these studies. OSHA and the EPA, however, in their conservative mode, still consider the occurrence of rodent liver tumors to be relevant to humans and they still plug that effect into their calculations of risk.  Although the evidence to the contrary is pretty strong, it will probably be ten to twenty years before they finally acknowledge it.

Spot News:  How does this relate to the current study undertaken by the HSIA?

Dugard:  What we are trying to do in our project is refine the basis for this risk assessment.  In other words, the information coming out of this study may allow OSHA and the EPA to do a more realistic risk assessment, since our study is founded on good science.  Of course, they may still operate conservatively, but we want the scientific and regulatory communities to understand that there is a solid foundation of fact here.

Spot News:  How is the epidemiology study different and what are you attempting to prove?

Dugard:  A number of epidemiology studies have been published with no definitive outcome.  We have been looking for a while for a way to study the U. S. population of drycleaners, or other people exposed to perc for that matter, as a way of clarifying the observations from other studies.  Our study emerged as a result of an approach used by our European sister organization, the European Chlorinated Solvents Association (ECSA).  Their original project focused primarily on Denmark, but this proved to have too few subjects exposed to perc to answer the questions being asked.  However, this led to a new project that includes the other Nordic countries as well.  This was attractive to us because those countries have cancer registries that have been running for an umber of years as well as census data that include people’s occupations, and we are fortunate enough to have access to these two databases.  This study is being run by the University of Copenhagen and is funded by HSIA.

What evolved then was this multi-country study that includes Denmark, Sweden, Finland and Norway.  Even though there are similarities between these countries, at times questionnaires will have to be used to get the additional data that is needed.  The whole point of this study is to investigate specific tumor types that people have suggested might be associated with either drycleaning or perc exposures.

Spot News:  What has been found so far?

Dugard:  The best studies that have been done so far are called “cohort” studies — studies that compare a population of drycleaners with a control population, like the US population in general.  Such a study looks at population groups and all causes of death to see if there are any associations.  Finding an association, however, is a long way from proving causation.  In a study such as this we have to take into account many additional factors, called “confounders.”  Smoking and drinking, for example, have been associated with esophageal cancer, which has been suggested by one group to be associated with perc exposure.  Thus we can’t say that perc causes esophageal cancer if we haven’t taken into account that the incidence of smoking or drinking or both.  Previous studies didn’t take such factors into account, and thus are difficult to interpret.

Spot News:  What has been the HSIA approach in solving these research problems?

Dugard:  What we are trying to do is cut through these types of problems, so we are running a case-control study.  This means that we take cases of esophageal cancer, see how those are represented in the drycleaning population, and compare this with a control population — in this case, laundry workers.  Our approach then is a case-control study across the Nordic countries, giving us a large enough population of drycleaners and laundry workers that we can make meaningful comparisons in the statistical sense.  We are trying to clarify and answer questions raised by previous human studies.

Spot News:  What types of cancers are being investigated?

Dugard:  We are investigating esophageal cancer, non-Hodgkin’s lymphoma, renal cell carcinoma, and liver, cervical, bladder and pancreatic cancers.  There is no convincing evidence that these cancers are caused by any elements in drycleaning.

Spot News:  When will these studies be finished?

Dugard:  For the mechanistic study, we have to acquire suitable human liver samples from a variety of sources, testing them as we go, and that’s about a 12-moth process in itself.  The epidemiology study will probably take about two and a half years to complete.  There is no risk assessment, as such, to follow the human study, only a straight report of whatever the findings may show.  In contrast, the end-product of the mechanistic study has to be a risk assessment, whether sponsored by HSIA or done by a government agency.

Spot News:  What will happen to the results once the studies are completed?

Dugard:  The results will be published in scientific journals, and we hope to stimulate the scientific community to support our approaches.  This will lend credibility to the projects.  The results will be made public when each study is finished.

Basically what we hope to provide to OSHA and EPA is a better basis for their calculations of risk.  Our mechanistic information should allow calculations that do a much better job of taking into account the differences between mice and humans.

Spot News:  What is HSIA doing to further the awareness of these studies now?

Dugard:  HSIA sends out a bi-monthly newsletter called the Update and posts information on its Web site, including detailed white papers.  We are talking to regulatory agencies such as OSHA and EPA and keeping them informed and updated on our progress.  They are open to good science.  We are spending a considerable amount of money for these elective studies, but our HSIA members are enthusiastic about them and are supportive of our efforts to complete them.      n

Dr. Paul H. Dugard, Director of Scientific Programs, HSIA, is responsible for devising and managing research programs, and for the preparation of scientific documents for the agency.  A native of England, Dugard received his primary degree in zoology in 1966 froom the University of Cardiff, South Wales.  He received his Ph.D. in skin physiology in 1970 from Queen’s University, Belfast, North Ireland.  He completed 3 1/2 years of postdoctoral research at the Harvard Medical School at Massachusetts General Hospital, Department of Dermatology.  He was employed by ICI for 24 years before joining HSIA, 16 of those at ICI’s Central Toxicology Laboratory.  Dugard is a Diplomat in Toxicology of the Royal College of Pathologists and has published over 30 scientific papers and book chapters.     n

Question:  What is the last resort in stain removal?

Answer:  Bleaches (no, we are not referring to scissors).

Bleaching agents can be used as an effective tool in the stain removal process.  Bleaches should be used after limited success with various dryside and wetside agents.  Also, some stains will be lightened with normal stain removal procedures, but may require the use of a bleach to remove the last traces of a stain.  Some examples of these stains may include ink and dye transfer.

Bleaches do not remove staining material.  They simply render them invisible by either adding oxygen or taking oxygen away.  It is safer for the fabric and color if stains are removed using normal stain removal procedures.  This is why bleaching is done as a last resort.

Refer to IFI “Industry Focus” #2, November, 2000
issue for more information on this subject.