FTC Care Labeling Rule Roundtable

March 28, 2014

Segment 3

Transcript

ROBERT FRISBY: It looks like everyone is here, except for Amanda. Let me start by 

introducing our group here, at the tables. 

First, we have Marie D'Avignon from the American Apparel & Footwear Association. We have 

Ann Hargrove from the National Cleaners Association, Adam Mansell from overseas, the UK 

Fashion & Textile Association, Paul Matthai from the EPA, Julie Mo from the Professional Wet 

Cleaners Association, Joy Onasch from the University of Massachusetts' Toxics Use Reduction 

Institute, of course, our presenter, Charles Riggs, Professor at Texas Woman's University, Mary 

Scalco from the Drycleaning & Laundry Institute. And, of course, our other presenter, Peter 

Sinsheimer from UCLA. 

I'd just like to start by saying that I understand that Peter is going to be providing his consumer 

study to the FTC so that we can look at it more closely. We appreciate that. 

Before we get into the issues of deception and unfairness that Peter raised, I want to very briefly 

give all of the members of the discussion group just a minute or so if they want to provide any 

general impressions about the presentations. If you prefer to wait and comment when we get to 

the issues, that's fine too, but why don't we start with the seven who did not present. And we'll 

start alphabetically. 

MARIE D'AVIGNON: Sure. Hi everyone, and thank you for having me today. 

I won't pretend that I'm a complete expert on the wet cleaning process. I represent the interests of 

apparel companies who deal with the compliance of actually putting the label on their products. 

So they need to know how to wash them or how to care for them, so they can share that 

information with the consumers. But again, I'm not a chemist, so it goes a little bit above my 

head. 

From the research I've done though, I do understand that wet cleaning can be an effective process 

and can have environmental benefits. So I think it would be great to consider it as an option for 

cleaning, but I would like to underline the fact that I think it should be only an option. Having it 

be required that companies would have to test for it and have to consider it for their labels, I 

think, is unnecessary at this point. 

ROBERT FRISBY: Thank you. Ann, do you want to say anything now? 

ANN HARGROVE: Sure. I come at this from a different angle. I was a dry cleaner, a perc dry 

cleaner. And then I became a wet cleaner. I ran the first 100% wet cleaning store in the country, 

and I think it should be an adjunct. I really believe that after working with the clothes-- and I 
understand where Peter's coming from when he uses that figure, 99%. I do not agree at all, not at 

all. 

ROBERT FRISBY: Thank you. Adam? 

ADAM MANSELL: Just a couple of comments on Peter's presentation, particularly on the bit 

about the manufacturers and retailers not using the optional W symbol in the UK and in Europe. 

There are a number of reasons for that. One, there is a very limited take up of the wet cleaning 

facilities, certainly within the UK. 

And secondly, although some of those people listed on that slide are my members, I can pretty 

much guarantee you that 99% of them won't have tested for anything. They'd have put the dry 

cleaning symbol on there without testing for it. They won't have put a bleaching symbol on there 

when bleaching can damage the garments. 

My view is that the optional way is certainly the best way to go forward. I think requiring 

manufacturers and retailers to test absolutely everything all the time will make it very difficult 

for those manufacturers and suppliers. There's a lot of additional cost in there. 

ROBERT FRISBY: Thank you. Paul? 

PAUL MATTHAI: Yes, I'm Paul Matthai. I am at the EPA. I work in the Pollution Prevention 

program. We look mostly at the toxicity and risk for human health and environmental issues. I 

work across the agency on regulations. And I look at alternative options to put into regulations. 

And for the Office of Air, which is a lot of the solvents, they try to regulate in terms of the 

emissions. I look at it in terms of, oh, there are other ways to do that and reduce your emissions, 

and also achieve environmental and human health reductions in exposures to toxic chemicals? 

And I'm looking at all the solvents and also the wet process. 

ROBERT FRISBY: Great. Julie? 

JULIE MO: Please excuse my voice. I have laryngitis. We have been a dedicated professional 

wet cleaner since July of 2008. And we believe that the wet cleaning care label should be a 

mandatory requirement. 

ROBERT FRISBY: All right. Joy? 

JOY ONASCH: Joy Onasch with the Toxics Use Reduction Institute at UMass Lowell, and we 

have been working with dry cleaners across the state of Massachusetts to help convert them to 

dedicated wet cleaning. We have collected significant data and testimonials from those cleaners 

that I believe counter what Mr. Riggs presented. 

And it does show the environmental benefits of wet cleaning. And in fact, significant reduction 

in the use of water at the facilities where we've collected data on their water use between perc 

usage and professional wet cleaning. And also, not necessarily data collected but significant 
testimonials, to the health effects that have dramatically changed from perc usage to professional 

wet cleaning services. 

The testimonials, with regards to headaches, ill feelings, using the perc, compared. So the fact 

that everything is collected from a perc machine just doesn't seem to hold up to those 

testimonials. 

ROBERT FRISBY: All right. Mary. 

MARY SCALCO: Yes. I thank you, again, for having me. And I certainly agree that wet 

cleaning on the care label should be an option. I don't think that particular requirement, that that 

particular instruction, should be required any more than any of the other possible care methods 

should be required. 

It's not required to put dry cleaning on the label. It's not required to put machine wash on the 

label. That is the purview of-- the FTC Care Label Rule doesn't require the manufacturer to do 

anything. But certainly wet cleaning now, at this point in time-- back when we looked at this in 

the late '80s and early '90s, wet cleaning was not a viable option. It certainly is a viable option. 

And I think those in the room that represent dry cleaning interests would tell you that most of the 

facilities have the capability of doing both, and they use their professional judgment when it 

comes to it. If it's a garment, as Dr. Riggs said-- imagine if you have a garment that you have a 

soil on it where you spilled something on it that doesn't come out in dry cleaning. You have to 

wet clean it. Otherwise you cannot give it back to the consumer so that they can wear it again. 

The same way, if you have something that says wash on it, or wet clean on it, if it has a soil on 

there that does not come out in wet cleaning, the appropriate care method is dry cleaning. So 

having that option. 

ROBERT FRISBY: All right. Peter, do you want to comment on Charles' presentation? 

PETER SINSHEIMER: I had one comment on Charles' that I'd like to pose to a professional wet 

cleaner. Julie has laryngitis. But there are other wet cleaners in the audience. So it depends, Julie 

could answer, or other wet cleaners in the audience. 

But you mentioned that this issue about repeated cleaning of wool garments and use of 

tensioning equipment that would cause damage. Based on your experience or expertise, what's 

your experience and expertise with respect to repeatedly cleaning wool garments using the full 

range of finishing, or mainly, cleaning tensioning equipment? 

JULIE MO: With proper equipment and training, you shouldn't have an issue with those items. 

For us, when we feel, from our professional judgment, that an item should be measured 

beforehand, then we measure it. And we double check to make sure that there has not been any 

shrinkage issues. 
MARY SCALCO: Can I interrupt? Can I ask a question? I think what Dr. Riggs was saying--

and maybe you can attest to this-- where you've cleaned that same garment three or four times 

and after the fourth or fifth time, are you able to get it back to its shape? 

I understand that the first time-- because I am also a textile chemist, so we all get that fiber 

history, and we understand how the fibers work. I think that the question he pointed out was that 

after repeated cleaning, over and over again, is that not only going to go back to the same shape, 

but is it going to have the same hand and feel and look to the garment? 

JULIE MO: Well, with any garment, over time, you're going to have wear and tear, as well. So 

with our system, we have had clients with us for years. And they normally bring in the same 

garments repeatedly. We have had wool, and cashmere, and different types of garments that 

we've cleaned. And aside from the normal wear and tear that we see, we haven't had any major 

issues. Customers have not complained. 

ROBERT FRISBY: Thank you. Charles, do you want to comment on Peter's presentation, 

briefly? 

CHARLES RIGGS: I'll just comment on the ongoing discussion line. What we've found is, in 

wool garments, quite often, they're-- in fact, the most common wool fabric out there is a 45% 

wool, 55% synthetic fiber blend-- and that blend comment, the blending of the fibers disrupts 

that felting action. So you could, in fact, do those blends repeatedly. 

The IWS standard wool test fabric, which is what we use providing with the cleaning methods, 

we could not-- you know, it would show a change in surface character. It would show shrinkage 

that we could recover the first time, but we could not the third time. And that's a recognized, 

international test standard fabric. 

ROBERT FRISBY: All right. Now I'd like to go on to Peter's argument that the Commission 

should amend the Rule to require a wet cleaning instruction to prevent deception and unfairness. 

I'd like to start with the deception argument. Let's assume, for the sake of argument, that the dry 

clean instruction that the Rule envisions is deceptive in some ways. If that's the case, why not 

just amend the Rule to correct the dry cleaning instruction? Does anyone have any thoughts 

about that issue? 

MARY SCALCO: I guess I don't understand. 

ROBERT FRISBY: Well, let me unpack it a little bit. If the problem with the dry cleaning 

instruction is that it implies falsely that the garment cannot be wet cleaned or home washed, is 

there a way to correct the dry clean instruction so it doesn't make any false implication about 

other types of cleaning methods? Is there a way to do that? 

CHARLES RIGGS: I think, in general, we have poor education about just exactly how the Care 

Label Rule is structured for the consumers. And I base this on 40 years of classroom experience 

with students who are majoring in a textiles area. They, from a consumer standpoint, probably 
have a keener interest in the label than the average consumer. And they don't know, until they 

have it in class, what the requirement for the label is. Not all care procedures are required. Not 

the best care procedure is required. A care procedure is required. That's all the requirement is. 

So there's a difference between-- and they don't realize this until I explain it to them-- a label that 

says dry clean only. The only is a cautionary word. That means you can't do anything else. 

Versus a label that says dry clean. That says the manufacturer says you can dry clean this 

garment. That does not indicate that you might be able to wash it at home. You might be able to 

wet clean it. 

My explanation to the students is that it's basically only tested for dry cleaning. Or the reasonable 

basis may be because of a long history of success. Dry cleaning that particular fabric, for years 

and years, satisfies the reasonable basis requirement. 

You could argue that the whole care label procedure is deceptive, because we require a method, 

not all methods, not the best method. In a perfect world, I would like to see all labels required. 

And then you have a full range of consumer knowledge. But that's unreasonable from a cost of 

testing garments place. So I think you either require all, or you keep it like it is where the 

manufacturer chooses which one they want to list. They can't use the word only unless they have 

reasonable basis for excluding all others. 

ROBERT FRISBY: Let me just throw out some hypothetical approaches. Let's say you had a 

label that said, "can be dry cleaned, other methods not tested." I'm just throwing that out, as an 

example. If anyone has a better suggestion of how the rule might be amended to address the 

deception that Peter pointed out--

MARY SCALCO: I guess where I'm confused is that deception also exists for home laundering. 

If it says machine wash on it, that doesn't mean you can't dry clean it. So you're deceptive in that 

regard, just as easily. 

I think I'm saying what Dr. Riggs said. The rule is structured to only give one method of care. 

That may not be the best. It may not be the most appropriate. It may not be the most 

environmentally friendly, if you want to say environmentally friendly. It only gives one method 

of care. 

ROBERT FRISBY: Granted, but what I'm trying to get at-- is there a way to improve the rule so 

that the dry clean instruction does not deceive people in the way that the study suggested it did? 

Does anyone have any ideas about how the rule might be amended to address that? I threw out 

one example. 

MARY SCALCO: Well, you would require all appropriate methods of care, whatever that is, to 

be on the label. 

ROBERT FRISBY: But is that the only method of addressing this option? That's my question. 
CHARLES RIGGS: I think the bigger deception I see is the label "hand wash in cold water," 

which rarely gets anything clean. In most cases, you can use machine wash in warm water. So 

the deception is not just with this dry clean, wet clean issue. It's across the entire subject of--

whatever the label is, it is not excluding others, but it may be perceived that way from the 

consumer. 

ROBERT FRISBY: Yeah. What I'm getting at is-- is there a way to prevent that misconception 

from being conveyed? 

MARIE D'AVIGNON: I would actually argue that it doesn't necessarily need to be addressed 

because the brand manufacturer is offering up a recommendation of how they want this garment 

to be cared for. It doesn't necessarily mean that they're deceiving the customer. 

Perhaps that's their prerogative as a brand to say, I want to sell my product as hand wash only 

because I'm marketing it to people who are more likely to have lower income and want to wash 

things at home. They want to have an easier time about it. And as long as it's true, and it can be 

washed at home in a way that doesn't hurt the garment, it's the prerogative of that company to be 

able to make that decision. 

At the same time, if it's a higher end company that wants to give off the brand image of being 

very high class and you should dry clean everything, they give off that image. If we want to say 

we're a very environmentally friendly company. We want it wet cleaned. They give off that 

image. It's the prerogative of the brand. As long as they're giving truthful information that's not 

going to harm the product, I don't see the point in addressing it. 

ROBERT FRISBY: I want to move on to the unfairness issue, in a moment. But before I do that, 

I want to get at this question another way. The Federal Trade Commission Act prohibits 

deceptive practices regarding environmental claims, deceptive claims of environmental benefit, 

but it doesn't ordinarily require companies to tout the environmental benefits of their products. 

And I guess one question here is-- why is wet cleaning different? I'd like to just throw that 

question out to everyone on the panel if they want to address it. 

MARY SCALCO: It's not any different. I could sit here and argue that there are environmental 

benefits to dry cleaning with the current dry cleaning that there is today. There are new methods 

coming on that are environmentally friendly. As Dr. Riggs presentation showed, it's in a dry to 

dry. It's all done in the same machine. It's not environmentally hazardous. 

It was with the old dry cleaning. In the old method, it was much like wet cleaning is today. You 

transferred, and you had a solvent going into the ground. There was that hazard. So I could argue 

that it is environmentally friendly, and that wet cleaning is not any more environmentally 

friendly than current dry cleaning. 

I don't think you can paint all dry cleaning methods with the same brush. You can't say 

everything is the same. And the industry, and there are certainly manufacturers in here of new, 

alternative solvents. That's why we're addressing that issue. That's why they came on the market. 
I could not make that blanket statement because I could easily say that wet cleaning, in certain 

facilities, could be just as environmentally damaging. 

ROBERT FRISBY: Joy, do you want to jump in?

JOY ONASCH: Yeah, I think that claim would work as long as you looked at one certain aspect 

of environmentally friendly. I'd like to remind you of the slide that Peter showed that had the 

color coded comparison of different alternatives. I believe that was adapted from San Francisco 

and does a range of comparisons. 

My organization, TURI, has recently done and published a study, a full alternative assessment, 

on all the different, including the new, solvents on the market. We looked at it from many 

different perspectives-- with human health, environmental resource use, cost effectiveness, 

technical feasibility-- and we came up with the same color coding spread, if you will, that San 

Francisco did with regards to perc and nPB being the least environmentally friendly across all of 

those measures, not just looking at one at a time. CO2 and professional wet cleaning were the 

most green of those, with the other solvents falling somewhere in between. 

And I have a copy of our study, similar San Francisco's, if anyone would like a copy. 

ROBERT FRISBY: I think we're already segue way-- I'm sorry, Peter. Go ahead. 

PETER SINSHEIMER: I just wanted to respond to your hypothetical. Your hypothetical said 

that dry cleaning can be used but other methods are not tested, or something like that. So you still 

have the word dry cleaning in that symbol. There's a lot of words in that for a care label. That's 

where the whole problem lies. 

Consumers aren't aware of professional wet cleaning. So you're not solving your problem by

adding those additional words because in the survey that we did, it was adding the words 

professional wet clean-- if cleaners were interested in having their garment wet cleaned, it was 

those words that made them more likely to clean. So your hypothetical doesn't really solve that 

particular problem. And therefore, the deception issue is still there. 

ROBERT FRISBY: Does anyone want to respond to that before we move on to the unfairness 

argument? We've already covered that to some extent. 

Let's move on to the unfairness issue. Let's start with the benefits of requiring a wet cleaning 

instruction, which is one of the topics that Peter addressed in detail. I think some of you have 

already touched on that. 

Why don't we start with the environmental benefits. One question I want to pose is-- are there are 

circumstances where dry cleaning is as good as wet cleaning? It sounds like some you think that 

there are, and I'd like to get views on that. Anyone over on this side want to--

ANN HARGROVE: You know, in Massachusetts the DEP-- basically what they did is they went 

around testing some of the wet cleaners. And when they tested the water, they found they were 
not spotting properly. They were using dry side chemicals, and they were finding it in the water. 

So if you were on septic, you couldn't be a wet cleaner. 

I think that we have good wet cleaners out there, and we have bad wet cleaners out there. They're 

not the same, and there's a whole educational process here. I keep saying it. I think wet cleaning 

is wonderful. And I think there's a place for it, but I think the place is as an adjunct. 

ROBERT FRISBY: Does anyone else want to weigh in on this point? 

ANN HARGROVE: Can you repose the question? 

ROBERT FRISBY: Just whether there are situations or circumstances where dry cleaning is not 

environmentally inferior to wet cleaning. 

MARY SCALCO: I think that you're going to get different perspectives depending on who you 

represent. I think that's why we have the technology that we have. The industry has moved 

forward in different technology, so it's all self-contained. We have different solvents. We have 

different methods. All of that takes place. 

Again, I don't think you can just paint the brush that dry cleaning is all the same. As you said, 

there are different levels depending upon different solvents of what is environmentally friendly. I 

don't think I could sit here and say that there are cases where it's not, and cases where there are. 

PETER SINSHEIMER: I can expand on that a little bit. I don't want to monopolize. I think 

Mary's point is an interesting one. 

There are a range of dry cleaning solvents, some of which have other particular attributes that are 

favorable, relative to other dry cleaning solvents. For example, perchloroethylene is not a 

combustible solvent. So if you are switching between perchloroethylene and hydrocarbon, which 

is a combustible solvent, you could see there would be a tradeoff between something that is 

clearly toxic and has been shown to be toxic in perchloroethylene and something that is a fire 

hazard. So within dry cleaning, there are various tradeoffs.

Between dry cleaning and wet cleaning, I don't see those tradeoffs at all. In fact, there are 

intrinsic things about wet cleaning that just make it inherently environmentally preferable. 

Certainly the EPA brought over wet cleaning from Europe in the early 1990s because of this 

issue. It has supported this both with funding that we've received, that Joy has received, in order 

to promote the diffusion of the technology. 

MARY SCALCO: I think, as Ann pointed out, there's chemistry that's involved with wet 

cleaning that you need. There could be an issue. That's why it's not allowed to go to certain 

septic systems. This is an industry that is changing rapidly, and probably for the better. That 

allows all these technologies to come on, but there is chemistry involved in all of this. 

It's not just the use of water. If it was just the use of water, you could hand wash it the way we 

used to do it. But you're trying to take a wool garment, so you put different chemicals in there. 
You put different spotting agents in there. There is a whole level of training that needs to be done 

of the industry, itself. Not only of consumers-- and consumers have no idea what wet cleaning is-

- and I'm not sure that that matters. 

If I got consumers altogether and said, what is dry cleaning? I bet you they couldn't tell me what 

that was, either. They just know they pay for that service, but they don't know what dry cleaning 

is, either. 

ROBERT FRISBY: All right. Paul, I think you wanted to jump in. 

PAUL MATTHAI: To EPA, there are two areas of interest. One of them is the environmental 

interest. And that breaks down into two areas. One of them is for wet processing. The release is 

down the drain, whether it goes to a septic system or a POTW. The other one would be the 

releases to the environment through venting. And that wouldn't be mostly for in the wet process. 

That would be for the hydrocarbon compounds. 

Then there's the other side, which is the human health effects. And then, the environmental 

effects, so human health effects-- probably the people that are at the highest risk of any kind of 

impact to toxic exposures and risk to certain types of problems are the workers in the dry 

industry. And to a secondary effect, people that are taking their clean clothes home, that are in 

the plastic bags-- there is some off gassing of some of the cleaners that are used, if there are 

solvent cleaners. 

So when you look at the big picture, the biggest risk is to the workers that are in the dry cleaners. 

And even in the wet cleaners, there's the spotting, which can also have hydrocarbons in there, 

which are something that we're looking at, as well. 

There's an interesting thing here, though. Across the country-- with California being first that has 

already banned perc-- -- there are other state governments that are looking at the opportunity to 

see if they can phase out certain types of processes to reduce environmental releases and also 

human health exposures. And I'm in the process of trying to figure out what states and where 

they are on that process. 

I think the state of Illinois is looking at that. They've already enacted legislation. I know they're 

looking at the alternatives to perc. EPA, by the way-- I want to go on record-- is not going to ban 

perc in this industry. I've already been told that by the Office of Air. However, there is a TEC 

risk assessment out there. And that does identify human health effects. And it goes through the 

risk analysis on, who is the highest exposure? There's also NIJ's stuff in certain areas on off 

gassing, depending on the facility. 

The facilities for this particular industry, if you realize, they're all over the place. There are some 

wealthy ones. There are some ones that are just struggling along. They have brand new 

machines. They have old machines. So they fill the whole array of where they are out there. So 

some of them are really clean. Some of them are not. A lot of them are in between, and they're in 

the transition period of maybe upgrading their process. 
And maybe they're out there looking at it not in terms of-- we have to wait for legislation to go 

through to find out where we go. It could be, I'm just struggling, and it doesn't matter to me 

where they're going. I'm just trying to make a living. 

I also want to point out that I'm on a work committee on alternatives to perc. One of them is npropyl bromide or 1-bromopropane. It's the same compound. Within the next six months to a 

year, the agency will be releasing, for public comment, a risk assessment on nPB, or on 1-

bromopropane. 

Based on that-- and there are some major issues in there-- of the three different sectors that we're 

looking at, dry cleaning is the second highest exposure. The biggest one is for foam blowing. 

And then the last one would be for de-greasing mostly in the aerospace industry. But because it's 

such a large industry, and they have opportunities for mechanical equipment changes, that 

reduces the exposure. 

But we're really focusing on the dry cleaners. So with that, we have some ideas in mind. And 

maybe we ask the Office of Air to add 1-BP onto the HAP list, so that they might look at those 

regulations. Anyway, it goes on and on. I don't want to take the entire panel up. If anyone has a 

question for me, please ask me. 

ROBERT FRISBY: Great. Let's go to Adam, and then Ann, on this point. 

ADAM MANSELL: Just a general point, a note of caution on thinking about environmental 

issues-- what we're actually talking about is how to best clean a garment and care for a garment. 

If you want to start looking at the environmental performance of that, then you'll probably have 

put "do not tumble dry" on all of your garments because the energy used in tumble dry is 

significant. You also would then start to look at the washing performance at home. 

And in Europe, at the moment, we've got a massive problem with nonylphenol ethoxylates. A 

nasty chemical. They're coming off in domestic washing on imported textiles. So you just need 

to be-- I think you probably need to bring your focus a little bit back to it. It's about cleansing 

and caring for the garment. And we all want to do the right thing for the environment, of course 

we do. But we need to make sure that we're also talking about what the consumers know and can 

do. And it's about cleansing and looking after the garment in this particular case. 

ROBERT FRISBY: Thank you. Ann do you want to chime in? 

ANN HARGROVE: Again it's a general comment. I've been involved with wet cleaning since 

the beginning here in the US. If it was without problems, if it was without problems for the 

garments, we would have thousands and thousands of wet cleaners. We don't. 

I can give you the names of hundreds who are no longer in business. I think there are issues with 

wet cleaning. There are people who are doing it successfully. And they're doing it fine. But if 

you go back around, and you look at their conveyors, go back into their stores a year later, you 

don't see a lot of suits, unless they're the suits with the mixed blends that come out OK. But you 

don't see them. When I do a wet cleaning class, I'm going to tell you what garment manufacturers 
their clothes are going to get ruined in wet cleaning. And so there are issues here with the 

labeling. 

ROBERT FRISBY: Thank you. I think now we need to move on to my next issue. And I want to 

spend a little bit of time on the financial costs to consumers for wet cleaning versus dry cleaning. 

Peter alleged or asserted in his presentation that the costs were comparable to consumers. And 

we have a report that was submitted by actually Joy's organization, which seems to have some 

different figures on the cleaning costs the consumers would pay. The average cost per pound for 

wet cleaning was $1.10, but it was $1.02 for perc, $0.88 for high flash hydrocarbons. And so I'm 

wondering if someone can reconcile these figures or if anyone has views on the costs the 

consumers would incur were they to do wet cleaning instead of dry cleaning. Joy, do you want to 

talk? 

JOY ONASCH: Perhaps I could address perhaps the reason for the differences may have been 

that different factors may have been included to come up with those costs per pound. I recently 

collected data from a user in Massachusetts of each of the different alternatives. And I can't 

remember, again I have report with me, exactly the number per pound. But wet cleaning came 

out to be the lowest cost. And also, I guess somewhat anecdotally, each of the eight wet cleaners 

we've helped to convert to dedicated wet cleaning in Massachusetts have not raised their prices 

to consumers, but are in fact saving money on their monthly bills because, of the reduced use of 

resources, water and electricity, and reduced payroll, reduced health costs. So the cost has come 

out. That may have been old information and slightly different parameters than was considered 

in the figures. 

ROBERT FRISBY: The figures I mentioned were from a report from June of 2012. So it is 

almost a couple of years old. You're saying more recent data is different? 

JOY ONASCH: I've collected even more recent data from the users of each of the different 

alternatives. And it actually can be found in the Massachusetts' DEP guidance document for the 

dry cleaners in Massachusetts who are completing their Massachusetts environmental results 

program certification. Each year we provide it as guidance for them to look at the different 

alternatives and the data that's collected from real life users of the alternatives. 

ROBERT FRISBY: Does anyone else have data on what prices consumers pay for various 

services? Yeah, Charles. 

CHARLES L RIGGS: I don't have the data. I was going to make an observation that I would hate 

to design that study. My observation is that the prices charged vary, not only by what technology 

they use to clean, but what's the price range of the garments they're cleaning? In the high end 

neighborhoods in Dallas, for example, cleaning costs more. But the cleaners, in fact, are running 

a bigger liability risk cleaning those high-end garments. Where they may have a garment in there 

that's a $10,000 garment. They're not going to clean it for $0.80 a pound, because there's a 

liability just by taking it in and agreeing to clean it. 

So I can't imagine how you can do that kind of a comparison. If you had some test garments, and 

we did, in fact, have some test garments in the laboratory correlations. I think we purchased, or 
Manfred Wentz purchased $15,000 worth of garments from Europe. And all did the same 

garments. But I don't recall any cost analysis done with that study. And, of course, the cleaning 

was done with laboratory personnel, rather than labor wages. 

ROBERT FRISBY: Let's hear from Julie next, on this. 

JULIE MO: Before we installed our professional wet cleaning system, we were using 

hydrocarbon. And at that time, we had our machines turned on for about four or five hours a day, 

three times a week. And our PG&E bill was about $800 month. 

When we installed our system, we have been using our system every day for about eight hours, 

at least. And on Saturdays, we also have to turn on our system for about five to six hours. Our 

PG&E bill is still under $800. And our water bill, compared to then and now, there's a $10 

difference. And our sales have increased six-fold. And we have not changed our prices for our 

consumers. They're still paying the same prices that they have been paying us since July of 2008. 

ROBERT FRISBY: Joy, did you want to--

JOY ONASCH: I was going to just comment that, yes, of course, I'm creating a study to account 

for all the different variability. And factors would be difficult. And that's why I think the 

testimonial of cleaners, like Julie, and the cleaners that we've worked with in Massachusetts, that 

compare what they did with perc, and what they do now with wet cleaning, and have not had to 

raise their prices, and have excellent quality in their cleaning is a study. 

ROBERT FRISBY: Paul, did you want to add something? 

PAUL MATTHAI: Yes, I do. I actually want to ask a question. There are other costs associated 

with either process. And I'm wondering if, by going to the wet process, do you lower your 

occupational insurance costs, because you're no longer having your workers exposed to high 

levels of the hydrocarbons that have human health issues, as opposed to the wet process? Or 

have you even thought about going back and renegotiating with your insurance company on that? 

JULIE MO: When we had asked our insurance company if they had a special rate because of 

that, they said that there is no special professional wet cleaning division for their insurance yet. 

So the only other option would be to label us as a laundering facility, like a coin-operated 

laundry. But that's not what we are. So have to pay the same price. 

ANN HARGROVE: And I would recommend anybody not doing that, because your insurance 

costs will go up. 

ROBERT FRISBY: All right. I'd like to switch focus a bit and look at the potential costs. 

CHARLES L RIGGS: Before you do that, could I make a comment, because I've seen a lot of 

these comparison studies done within an individual plant. And in every case it's a matter of 

taking old, outdated equipment and replacing it with the new. So I've seen cost savings switching 

from one thing to another, cost of savings of switching from dry cleaning to wet cleaning. And 
quite often it's a matter of switching more than just the solvent, it's the whole technology 

involved. An old dry cleaning machine, for example, probably used a water cooled condenser, 

which would consume a lot of water. A new individual refrigerator wouldn't consume any. So 

the comparison of old to new is probably not a good way to do the cost comparison. 

ROBERT FRISBY: I think we need to move on to our next issue. If we have time later, we'll 

come back to this. But I would like to talk about the potential cost to requiring a wet cleaning 

instruction. During Peter's presentation, he indicated that it might be possible to determine 

whether wet cleaning was possible for $50 an item unless testing is needed, in which case it was 

$100. And I'm wondering if the rest of you have any data on this point or views about what cost 

requiring this instruction would entail for industry. 

MARY SCALCO: I'm assuming that if you're going to require testing, it would be the same sort 

of standardized testing that is required if you put a dry clean label on there, or if you put a home 

washing label on there. It would be as Dr. Rigg said. They are our test methods designed that you 

test a garment per this method, and you have to test it three times for whatever label you put on. 

So I would assume you couldn't just take it to your-- you don't want to just take it to-- for dry 

cleaning, you don't take it to your dry cleaner to figure out if you can dry clean it. You have a 

standardized test method. For professional wet cleaning if you want to put that on the label, I 

would think you would use that same sort of standard test method. And you would have to go to 

a testing house the same way you do a dry cleaning and have it run that way or do it internally. 

CHARLES L RIGGS: ISO 3175. 

ROBERT FRISBY: Right. Peter. 

PETER SINSHEIMER: I just want to clarify, because I had half an hour and I was below my 

half an hour. 

ROBERT FRISBY: You definitely were. 

PETER SINSHEIMER: But I cut out a lot of detail, because I knew you'd get it below half and 

hour. I did a survey of a number of the professional wet cleaners about that question about their 

expert judgment. So if they use their expert judgement, which can be used as a reasonable basis, 

experience and expertise. What would they charge? And included in that $50 charged, we were 

very specific to share this with the FTC in terms of the survey instrument that we used. we said 

well, you will be given a checklist, that includes an ISO, essentially that specifies the kind of 

damage that you would anticipate happening with that garment. And then what they would do is 

the garment would be sent to them. They would observe the garment, and based on their 

experience and expertise, make a judgment. They make that judgment every day. Julie will 

testify. Other cleaners here will testify. Every day new garments come in, and they make a 

judgment. And they are extremely good at making an expert judgement and whether the garment 

can successfully be wet cleaned. So the idea is use that experience and expertise that's been 

generated, and the average cost we got was $50 to just observe it. And so reasonable basis, 

experience and expertise, they could also test it, which is the three time. So the idea here is we 

use the same ISO methodology for testing three times through. And then the same kind of 
checklist would be used. Clearly, we want to be able to make sure that the standards are 

comparable to ISO with respect to determining a reasonable basis. What makes the most sense to 

me would be to use the expertise and experience of 100% dedicated cleaners who have years of 

experience and expertise to make the judgment. 

MARY SCALCO: If I can just add to that point. Garment manufacturers also hire the Dry 

Cleaning and Laundry Institute to make that reasonable basis and judgment. But as an 

association, I carry an awful lot of professional liability insurance, because if I'm wrong in my 

professional judgment, that I referred to a garment manufacturer and something happens to that, 

that liability is on me. It's not on the garment manufacturer. So that's why I carry that insurance. 

ROBERT FRISBY: Over here, Adam. 

ADAM MANSELL: For no second am I questioning the ability of wet cleaners to the 

professionally wet clean. But the same approach you're suggesting in terms of using a high speed 

wet cleaner to test a garment against 3175 or any other standard. It's a bit like asking me to take 

my shirts home and stick them in my washing machine to tell Hugo Boss whether they should 

have a 40 or 50 washing program on their shirts. The test protocols, the test procedures are more 

than just making sure that you can wet clean them. You need to be able to make sure that if 

you're running the test in Nebraska, you have exactly the same conditions as if you're running it 

in North Carolina. The ballast has got to be the same, the inlet water temperature has go to the be 

the same. There's an awful lot of things in a test method procedure above and beyond what is 

done in a professional wet cleaners. 

ROBERT FRISBY: Ann did you want to add something? Oh, Marie. 

MARIE D'AVIGNON: And actually I think Adam is making a great point. I would just add in 

regards to the cost to manufacturers who are making the decision as to what put on their garment, 

that are currently in FTC rules of reasonable basis, and I know we're going to discuss later. But 

there's an option for you to make a reasonable basis based on your industry expertise and 

experience you already have. So in that case, if you want to say you've always dry cleaned this 

garment, there's no cost at the moment versus if you want to say, well now you have to

mandatory require a test for wet cleaning, it's going to go from zero to whatever that cost is 

automatically, because there's new requirement. And eventually some companies I'm sure will 

decide that they want to move to wet cleaning and will look at it. But then in the short term we'd 

be putting a mandatory cost on companies that might not have any costs at the moment. 

PETER SINSHEIMER: I have a question. So to develop a reasonable basis, there's a list of ways 

one could do that. But in apparel in theory in the United States you should be using one of those 

methods to make a judgment. There has to be some costs associated with that. So somebody has 

to look at a new garment and say, what care label should go on this government. So in fact, it 

may be that they don't. And in Europe they don't have to, right. But they do in the United States. 

So I think is when you're looking at these costs, there's internal cost that the apparel industry has 

to pay. They could external that cost is what I'm recommending. And I also said that the 

professional wet cleaning associations that exists and has the ability to transfer that knowledge 

very rapidly to this industry, internalizing the cost so that the apparel industry could make the 
same judgment that they should be making for every garment in theory to establish reasonable 

basis. 

ROBERT FRISBY: It sounds like some of you are questioning the $50 to $100 cost estimate. I'm 

wondering if anyone has an estimate they'd like to offer of what this would actually cost in the 

real world. Just let me start by saying that Ann's group and Mary's group gave us some 

information in the rule making. They told us in one of their earlier comments that the average 

cost to provide appropriate and comprehensive washing, dry cleaning, and wet cleaning 

instructions would be under $1,400.00 That was a couple of years and I'm wondering if that's 

still a valid figure. And what that actually pays for. Maybe Mary or Ann, one of you could 

address that. 

MARY SCALCO: I'll be happy to answer. What that would do, we would test the garment to all 

those to standardized test procedures. We would evaluate if for--

ROBERT FRISBY: Is that a cost of each individual garment? 

MARY SCALCO: That's a cost for, well, it's not per individual garment, it's per whatever style 

they would send to us, so that translates into hundreds of thousands of garments. But it would be 

for each individual style. 

ROBERT FRISBY: Type of garments. So if the fabric change or the other components changed, 

it might require another battery of tests. 

MARY SCALCO: Now if you use that same fabric and components across the board in five 

different styles, and then the same test methods would apply. 

ROBERT FRISBY: How much of the $1,400.00 is wet cleaning? What percentage? 

MARY SCALCO: It would be split evenly across--

ROBERT FRISBY: About a third of that. That's a higher figure than what Peter was suggesting. 

MARY SCALCO: As I said, I have liability insurance. 

CHARLES L RIGGS: You also have test methods for actually standardize, controlled conditions 

for measuring shrinkage and strength changes, and things that are not just a visual opinion. It's a 

laboratory test method. Part of the issue I think to a manufacturer would be what can you change 

in a product line and not have to retest it. If you change colors, do you need to retest it. If you 

change trim, do you need to retest it. In some cases, the answer is yes. So it may be specific to a 

particular construction color combination. And you make a change in that, you may have to 

retest it again. 

ROBERT FRISBY: This is probably a tough question to answer, but if the commission were to 

require a wet cleaning instruction, any sense of what that would entail for the cost of clothing 
that consumers would pay. Anyone have any thoughts about what the consequence would be. 

[INAUDIBLE] Can you hold one for one second for the microphone. 

SPEAKER 11: The one cost that I can think of would be traveling to a dry cleaner that hopefully 

has a wet clean only. I'm not sure how many in my home state are professional wet cleaners, but 

let's say there's six. The cost of gas, wear and tear on the vehicle to get to that cleaner would be 

one cost. 

ROBERT FRISBY: And further thoughts about the cost side of the equation. What cost would 

result if the commission required wet cleaning instructions, and the implications. Or should we 

move on? Charles. 

CHARLES L RIGGS: As I understand, the way I would interpret it is we would not have to test 

for wet cleaning the thing that has a laundering instruction, because I think that's self-evident. If 

you can launder it, you can wet clean it. So everything that is currently wearing a dry clean or 

dry clean only label would have to be tested for wet cleaning if they required it. So things that 

currently are not having to be tested because they have a historical basis, suddenly they're going 

to have a testing cost. And the label is going to become a dual label. It's gonna have perhaps dry 

cleaning and wet cleaning, or it may have wet cleaning with an x across it on every single one. 

So I think the cost is significant. 

PAUL MATTHAI: I actually have a question. 

ROBERT FRISBY: Paul, go ahead. 

PAUL MATTHAI: I'd like to go back and ask simple question because this has open up a whole 

new area that I've never been exposed to. When you go into, Julie, to do a professional judgment 

call on how to wash that. Is that based on the label that says this particular article of clothing has 

a blend of this, this, and this. Or is it based on that plus the color plus some other experiences he 

had. Or how do you make that judgment call? 

JULIANNA MO: Well, the production aspect of it my husband and the other teams in the back 

know better. But from my experience we do have to make a judgment call based on several 

factors. So it is like you said what the labeling entails. And some of the label is wrong because it 

says to do one thing, but you don't necessarily have to follow the label. And a lot of consumers 

also tend to clean their clothes at home these days too, which goes against the dry clean only 

label. I have a lot of consumers that come in and they're so upset that they accidentally cleaned it 

at home or they tried to clean it at home, and it shrank two inches. And they bring it to us and ask 

us if we can cover it. And we do with our cleaning system and with our tensioning system. 

PAUL MATTHAI: Thank you. I just wanted to get some concept, because everybody here 

except for me maybe has an idea what's going on. And again I'm looking at toxicity issues as 

opposed to the process. 

MARY SCALCO: Generally, what you would do if you had a garment, and you don't know what 

to-- Say there was no care label on the garment and you had to decide what to do. You would 
definitely need a fiber content label because you need to know whether it's cotton, wool, silk, 

what that is. Then from years of experience you know certain dyes do certain things. You know 

blacks do certain things. If it's a black and white together, you want to just say, please take the 

somewhere else. But you would look at the construction of the garment. You would see if there 

was interfacing in it. You would look at the buttons and see what the buttons look like. Or what 

the trims looked like on any garment. Men's clothing generally is a little bit easier than female 

apparel. But that has its own set of challenges. So fiber content you definitely need. Don't get rid 

of that label. 

PAUL MATTHAI: And this is part of the requirement for FTC, right? The fiber content on every 

label?

ROBERT FRISBY: Actually, that's not a requirement under the rule. It is under the textile rules 

however. So oftentimes labels will have that information pursuant to the textile rules or the 

[INAUDIBLE] rules. OK, I'd like to-- Oh, Charles. 

CHARLES L RIGGS: Some of the students we train, go out and they're buyers for retail chains. 

And they lead with an arsenal of some tests they can do in the field. Wet handkerchief for wet 

crocking and so on. But the underlying rule that their taught is these are preliminary screening 

tests. You send in the sample to the lab for detailed testing under a standardized test methods. 

ROBERT FRISBY: Some of you, sorry Joy--

AUGUSTINE CHANGE: Hello, my name is Augustine Chang. I think we just look at the cost of 

putting the label, but if you look at the other side, which is how much of additional sales they'll 

get from people who are staying away from dry cleaning only garments. How many of those 

mobility are you going to [INAUDIBLE] if it is wet cleaned. Ever thought about that? That's 

quite a bit of money you leave on the table. 

ROBERT FRISBY: I'd like to kind of close out of this topic by just making sure everyone's had a 

chance to express their view whether the commission should in fact require a wet cleaning 

instruction. And some of you've already answered this question either for or against. Whether the 

cost, whether the benefits exceed the costs or vice versa. Anyone want to say anything word 

more about the bottom line before we move on that hasn't already has a chance? 

JOY ONASCH: I guess just the cost to the people who are using wet cleaning both from a 

marketing perspective and from a technical perspective, having that care label required on that 

garment allows them to have the confidence that the consumer is not going to be coming back at 

them, if there's an issue. If they're doing professional wet cleaning. And it is allows them to 

market themselves as a professional wet cleaner that the consumers are then able to bring their 

garments too and have that differentiation between the other dry cleaners out there who are 

marketing themselves as green, and using other alternatives to perc. 

ROBERT FRISBY: I'd like to move on now to the issue of the availability of wet cleaning to 

consumers. I think it's been touched on already, but the label has a limited value to people if
there are no wet cleaning services near them. So I'd like to ask everyone if they have information 

about to what extent consumers actually have access to wet cleaning currently. Ann. 

ANN HARGROVE: Years ago it was hard. But now we have a lot of dry cleaners who have 

wonderful wet cleaning departments. And in there they offer professional wet cleaning if need 

be, but they also have other machines, a green earth machine, a hydrocarbon machine there. So 

they can choose which is the best one. But I tried to get a number of how many wet cleaners 

there are. So I started calling from a book that the EPA gave us in '97, none of them are there. 

But when you talk to equipment manufacturers and you say how many wet cleaners are there in 

Illinois? How many cleaners are there in Utah? The numbers are small. They're very small. And 

again, if it was without any problem, we would have everybody would go for it, because the 

clothes get clean. 

ROBERT FRISBY: Yeah, Paul. 

PAUL MATTHAI: I have a question on that. This is such a small business compared to, I mean, 

there's some fairly large, but most of them are very small. And the cost of the machines are fairly 

expensive. My reading is that they run from anywhere from $45,000 to $85,000 apiece. So are 

we looking at an emerging industry or one that's transitioning from primarily a hydrocarbon 

based cleaner to one that has mixed or even [INAUDIBLE] the wet side, and we're starting to see 

the curve coming up now? And maybe these companies are waiting for the machines to basically 

wear out before they have to replace them? And then we'll start to see an increase in the wet 

process. 

ANN HARGROVE: Are you asking me that? 

PAUL MATTHAI: I'm asking anybody that, because whenever there's a transition from one 

technology to another, it starts out slow and then it goes over and increases, as one moves to the 

other. This may not be moving from one technology to the other, but they're certainly is going to 

be shared technology there. And are we're starting to see the emergence of companies like you're 

saying small dry cleaners, as soon as my machine wears out, I'm going to buy one that's a wet 

process as opposed to the solvent based. 

ANN HARGROVE: What I'm seeing is when their dry cleaning machine wears out there, they 

buy a smaller hydrocarbon or some other machine, and they have wet cleaning piece of 

equipment. They have both and so that they can do everything and not have a problem. The most 

important thing here, and we can talk about care labels. And we can talk about it all. But when 

that customer brings me a suit, he wants to pick up that suit or she wants to pick up that suit, and 

she wants it to be perfect. And she wants it to feel the same. She wants to look like a million 

bucks in it. And there are garments out there that when you wet clean them, they don't feel the 

same. And you know, there's all kinds of chemistry and there's all kinds of conditioners, and you 

know what, and I keep saying it, I love wet cleaning. But there are some limits. There're 

definitely limits. And you have to understand that. And the consumer realize that. So you if you 

have a small hydrocarbon machine and you have a nice big wet cleaning machine, that wet 

cleaning machine is going to be working all day. And your solvent, whatever it is, you're going 

to do a certain amount a loads. 
PAUL MATTHAI: I do have a follow up on that. Are there original regulations, maybe to the 

city with apartment buildings, where you have the first floor is a dry cleaner and then you have a 

occupation above that. And there are some regulations that say you can't use certain types of 

solvents in there. And is that an area in an area that wet processes is actually taking over. 

ANN HARGROVE: Oh, absolutely. 

PAUL MATTHAI: So it could be regional work or it could be like state wide in California. And 

we also have to look at the trends from the state legislatures to find out if they're moving towards 

this wet process. 

MARY SCALCO: I think even in California where they have essentially phased out the use of 

perc in the future. What is going in is not 100% wet cleaning, but it's alternative solvents. I think 

what And was saying, and I think this is what we're seeing in the industry today, from when we 

first looked at wet cleaning when, I forget when you said EPA bought it over here, and that--

PAUL MATTHAI: It wasn't me. 

[LAUGHTER] 

MARY SCALCO: There is no 100% wet cleaners. There's not a lot of 100% wet leaders today. 

There are a lot of dry cleaning establishments that offer solvent cleaning and professional wet 

cleaning. And I think that's what we're seeing. So when people, like in California where people 

are forced to replace the perc solvent equipment. They're moving to other solvent equipment, but 

they also have an adjunct of professional wet cleaning. And I think that is a perfect-- that is the 

new model of what dry cleaning will be, because as Ann said, the consumer brings the garment 

in. They don't care what you do to it. They just want it cleaned, pressed, ready to wear the next 

time they pull it out of their closet. 

PETER SINSHEIMER: I have a question and a comment. So, Mary, around what percentage 

would you say of the existing professional cleaners out there are able to do wet cleaning? 

MARY SCALCO: Professional wet cleaning? 

PETER SINSHEIMER: Yes. 

MARY SCALCO: I don't have a figure for that, but I would say a majority. I would not say it's 

10%. 

PETER SINSHEIMER: So then my comment was on this issue about availability. Clearly, 

there's a chicken and the egg argument here. If the wet clean care label is not on the garment, that 

is an enormous barrier to the diffusion as Joy was saying. 

In California, we host workshops for dry cleaners interested in professional wet cleaning, and, 

that is an enormous barrier when they're looking at the technology back, well-- did the comments 

say dry clean on it? And so, that label itself is an enormous barrier to diffusion. So, it is, it's a 
little bit unfair when you say, well, what's the availability of 100% wet cleaning, or, as a whole, 

because you yourself are creating the barrier to the question that you're asking. 

ROBERT FRISBY: Charles? 

CHARLES RIGGS: Yeah, I can only think of a few 100% wet cleaners that are no longer in 

business. Seems to be a trend. But what I do see a lot of, and Paul, I might pick on you. I would 

guess from what you're wearing--

[INTERPOSING VOICES] 

Well, it may be a good example, because I would assume from the way you're dressed that your 

suit and your shirt were both done professionally. 

PAUL MATTHAI: Actually, it's brand new, so I don't think--

[LAUGHTER] 

CHARLES RIGGS: And so, well, that's another option. Just replace things with new items, you 

don't have to clean them regardless. 

[LAUGHTER] 

But, my point would be that, you know, business man dressed like you are with the pressed shirt 

and a nice suit. But take that professionally, probably to one business, and it probably has the 

label Dryclean on the door, and you don't know what they do to the shirt versus the suit. They're 

going to clean the suit probably in solvent. And they're going to clean the shirt in water. And the 

machine that they use to clean the suit, or the shirt, in water, my recommendation was, 

eventually, you replace that machine with a wet clean machine, which gives you, with a program 

change, you can do shirts, or you can do some items wet clean. 

So I think the trend is, and our recommendation is, you need both technologies. And to control 

both technologies, you need two machines. If you try to do wet cleaning 100%, and you're 

spotting with solvents, you're causing an environmental issue. If you try to do 100% dry 

cleaning, And you don't have any ability to do anything in water at all, you're not getting all 

things clean. 

PAUL MATTHAI: Well, here's the issue. I do take it to, what they term a green dry cleaner, or a 

green cleaner. There's a lot of shades of green. 

[LAUGHTER] 

And that's-- there's a whole array. If you go-- I think they have more shades of green in the 

environmental part than they actually have in Ireland. 

[LAUGHTER] 
So, the big issue is that-- how green is green? And there really isn't a definition on that. That's 

one of the unfortunate things. So no one knows what it is, but it's a marketing technique that 

people use to pull in their customers. So, at one point or another, it would be nice if we could 

figure out how to label this in such a way that would be both-- both can use it, because it will be 

a transition across the country. State of California is already there. They banned perk. There may 

be additional compounds coming down the road that they may take up in later years. There are 

other states that might be also entertaining the idea of changing from perk, at least eliminating 

perk, and maybe some of the other hydrocarbons, and propyl bromide might be one of them. And 

I know that the state of California has done that in a way. They didn't say you could eliminate it, 

but they set the level so low that you literally can't use it in your process. 

ROBERT FRISBY: We need to move on, but there may be time to come back to this later. I next 

want to turn briefly to the question of consumer awareness. And, Peter did address this during his 

talk and had some data from the study on this, but I'm wondering if anyone else has data on to 

what extent consumers are aware of wet cleaning, and what the implications of that are for us. 

Anyone? Yeah, Adam. 

ADAM MANSELL: If I could just share a story, I guess, irrespective of whether you make it 

optional or mandatory for the W. Bear in mind that the consumer comprehension or virtually all 

care symbols is appalling. And frankly, we'd be a lot better use of all of our time we spent all of 

our time talking to consumers about what the care labels meant. We recently did a survey in the 

UK of about 10,000 consumers asking them what the symbols meant. The only two that they 

knew anything about was the washtub and the iron. When we showed them the P in the circle, 

60% of the respondents said, doesn't that mean parking? 

[LAUGHTER] 

ROBERT FRISBY: Well, that will be a great issue for our next panel, definitely. Anyone else 

have thoughts on this topic, awareness? All right. I'd like to turn next to the Commission's 

proposal to permit a wet cleaning instruction. In the content of that instruction, a number of the 

commenters took issue with the instruction that the commission put out. I'd like to get people's 

comments about, in particular, the need for the word professional to appear before the word wet 

clean. Anyone want to take that one on? 

JOY ONASCH: Well, I think you were trying to mirror dry clean. And then, the dry clean, we all 

know because of, historic, that that's professional, but I think you would want to put 

professionally wet cleaned so that people realize it's the same thing. You have to take it to a 

professional and do. It's not something you can do at home. 

ROBERT FRISBY: Yeah, Charles? 

CHARLES RIGGS: Well, our trend is wanting to move towards the symbols. And the symbol 

from the very beginning was a circle for professional care, and W was a circle W for wet 

cleaning, and circle P, whatever, for dry cleaning. If you convert that to words, I think you've got 

to relay the meaning of the circles there and use the word professional. 
ROBERT FRISBY: Joanna, did you want to? 

JOY ONASCH: Yeah. No, just that I concur. I think it's important to have the word professional 

there, even amongst dry cleaners, understanding, never mind what consumers understand about 

the difference. There's a large gap between what people understand with what professional 

cleaning is, and regular cleaning your laundry. 

ROBERT FRISBY: Yeah. Adam, did you want to say anything? 

ADAM MANSELL: Echo what everyone else has said so far. The circle means professional 

cleaning. 

PAUL MATTHAI: You could use both professional and with this next so people get the idea that 

one's related to the other. 

ROBERT FRISBY: Yeah, that's always an option. And many labels will have a symbol and a 

written instruction. What about abbreviating the word professional? Is that something that would 

work do you think? Or not? 

CHARLES RIGGS: Why? 

ROBERT FRISBY: Make a smaller label. 

[LAUGHTER] 

MARY SCALCO: I don't think that's going to work. You could try. You could try. 

ROBERT FRISBY: Is that the only thing we would need to do to address the problem? Is there 

any other information that the label should provide beyond professional? 

CHARLES RIGGS: Well, I think clearly we're talking about a care method that is not a do at 

home method. And we want to discourage anyone from trying to do it at home, because they're 

going to fail. 

Do you think the word professional accomplishes that objective? 

CHARLES RIGGS: Well, if they do it at home, they do it at their own risk. They can't go back to 

the manufacturer and say, I did this at home, and it shrunk. The manufacturer can say, that's not 

what it told you to do. 

ROBERT FRISBY: Anyone else over there have any thoughts on this? No? Over on this side? 

All right, well I think that at this point, we'd like to open up the floor to questions from the 

audience. And we have a roving microphone. If you could wait for the microphone, we'd 

appreciate it if you would identify yourself and your affiliation, if you could. 
AUDIENCE: My name is [INAUDIBLE]. I am representing this question from my professional 

background. I'm a textile chemist and a polymer scientist, so I will address this question from 

that standpoint. I heard a lot of discussions about how this care label is addressed. I heard the 

discussion about fiber type, fiber content. Finish I didn't hear it all. I heard the soil, a little bit, 

you know, which could be removed by a water, could be removed by a solvent. I heard about 

environment sustainability. But, and the cost. I heard the cost about cleaning this garment. 

Care issues came up also-- [INAUDIBLE] and dye bleeding-- all those things were discussed. 

But, I am almost in Paul's shoes in trying to figure out, what is the real intent of this care label? 

Is it to satisfy and making sure that the garment goes to the right professional hands? Or is it that 

the customers get an education, which we know customers don't give a damn in terms of the 

understanding that we get it. 

So, is that the intent? I do know from the back end of the spectrum that we talk about fiber 

content. If they sell us 5% of anything can be used, not to be declared, and that can be 5% of 

Spandex, and can throw this whole thing off. And then, the fabrics can have finishes. That 

actually is the game changer for everything that is going on. And you cannot see it by your naked 

eyes, whether you're trying to be the judge, and say, that is cotton versus polyester, versus this 

and that. You'll not know. And that can throw you off to the order in-- in all those things. So my 

question is, what is the true intent of this care label? 

ROBERT FRISBY: I'll take that one. The commission-- when it promulgated the rule, the 

objective was to prevent deception and unfairness, and the commission concluded that it was 

unfair or deceptive not to let the consumer know a method to clean the garment safely and 

effectively. And the rule is designed to address that deception of fairness. That was the 

commission did back in the '70s. As far as fiber content goes, let me just add one more thing--

the Commission's proposal to permit a wet cleaning instruction also provides that the label 

should disclose the fiber content, if the fiber content is needed to wet clean effectively and 

safely. So that's part of the proposal that the commission put forward. Does anyone else at the 

table want to comment on his question? 

CHARLES RIGGS: You sent me-- and there was a recent change, or proposed change, in the 

fiber content rules? 

ROBERT FRISBY: The commission recently voted to amend the textile rules. 

CHARLES RIGGS: That's right. So that, indirectly, impacts on the label and, but what you point 

out is a very valid point. The finishes you can't see, and they certainly make a difference. I was 

seeing 100% cotton suits say dry clean only, for good reason-- because of the finish. Yeah. But 

that's covered nowhere in any of the rules. 

ROBERT FRISBY: Any more questions from the audience? 

SPEAKER 1: Back corner. 
AUDIENCE: David Tremble, I am a consultant to the textile industry. And actually, it's not a 

question. It's an observation as a consumer. And I'm not the average consumer. I'm more familiar 

with these rules than they would be. If I saw wet cleaning, I would assume that meant I could put 

it in the laundry machine at home. And to the point of professional being abbreviated, I'm 

thinking-- on a small label, lowercase O, lowercase E look alike. I would say preferably wet 

clean. I read that as preferably throw that in the washing machine. 

ROBERT FRISBY: Do you think the word professional would work? 

AUDIENCE: But professional fully spelled out would. 

ROBERT FRISBY: Any other questions? Over there, yes, in the front row. 

AUDIENCE: I'm Jen [INAUDIBLE] from Bureau Veritas, an independent testing lab. Actually, 

I have two questions. One is, when you're talking about testing cost, the reality of the testing 

industry right now is the testing is done in the country where the goods are manufactured, and 

the majority of goods are manufactured in Asia. So what is the availability of wet cleaning 

equipment, facilities, in Asia at this time? 

Anyone want to take that one on? 

CHARLES RIGGS: Well, if it's a testing lab using the standard front load FOM washing 

machine, that can be programmed to do wet cleaning. So they probably have a machine that with 

the right program, and then they'd have to get the right chemicals as shown in 31 75. They 

probably have the machine. They may not have been doing those tests, so it's probably a matter 

of that lab getting familiar with how to program their FOM machine to do 3175 testing. 

AUDIENCE: Well, that's going to vary from lab to lab, from one testing company to another, 

and also, from different countries from one to another-- small labs versus larger labs. So, I would 

imagine that initially, a lot of labs would want to outsource the wet cleaning, and do training 

with the wet cleaner to follow the test methods-- whatever methods are developed by ATCC. So, 

that's just something to keep in mind when you're talking about the testing costs. It really 

depends on where that testing can be done. 

CHARLES RIGGS: I don't think ATCC is looking at this. We deactivated RA 43, which would 

be the professional care test methods branch, and it's not been active for some time, and that 

would be the ATCC subcommittee that would do that. I think they've just adopted the fully ISO 

31 75. 

AUDIENCE: I know we do have some representatives here for ATCC who can talk more to that. 

But, let me just ask my other question, then I'll pass the mic. My other question is, Ann-- you had 

mentioned that there are problems with wet cleaning, and you alluded to the change at hand. 

What are the other issues? I mean, because when I'm thinking down the line, if this does become 

allowable in the US, we do base-- if a client just comes to us and says, OK, develop a care label--

we base it on, what's the fiber content, what's the construction, the colors, et cetera. Labs will 

need to know what things do work and don't work in wet cleaning. 
Some of the structured garments-- I like to look to talk to you. Some of the structured garments 

can be a problem with the interfacing. Trim, buttons, shrinkage. Color loss is huge right now. We 

keep talking about those black and whites, and those black and whites. And I have used just 

about every detergent, every conditioner, every sizing, every wet cleaning machine out there. 

And, it doesn't matter which one you use. if it's a bleeder, it's a bleeder. And you've got to figure 

out how you're going to un-fix it. And so, it's part of the problem. And as far as wet cleaners out 

there-- somebody had mentioned earlier-- we're treating them. NCA, Dale, I-- we train a lot of 

wet cleaners who are dry cleaners. So there are a lot of people out there. 

Like, when you get a garment, you've got to look at-- is the lining-- what fabric is the lining? 

What is the structure of the garment? And there are times when you're taking that ruler out, and 

you're doing a lot of measuring, because these are small business people, and they want to keep 

their customers. You don't want to lose your customers. So you want to give them back 

something that works for them. 

ROBERT FRISBY: Ah, Joy? 

JOY ONASCH: Yeah, I just want to comment-- just providing testimony from the cleaners that 

we worked with in Massachusetts that they don't have any of these issues with the in-seems, or 

the buttons, or in fact sequence or embellishments come out much better with wet cleaning. 

We've networked to help convert eight dedicated wet cleaners in Massachusetts, and they've all 

said that the whites come out whiter and the brights come out brighter, because there's not the reused solvent in the process to help the clothes come out clean. And once they become very 

skilled at the process, they don't have these issues. And this is with modern 2014 technology, and 

perhaps not older technology that's been noted in the past. 

ANN HARGROVE: I'm doing a training class next week. I do them all the time. But, what we--

NCA and Dale and I-- we have analysis departments. And what I see coming through the 

analysis department are the shrinkage, the bleeding. Not just things that I'm doing-- from a whole 

array of people. And maybe it's the type of garments they have. We do a lot of high-end stuff. 

The Pradas-- Pradas aren't meant to be wet cleaned. Anything Prada is not meant to be wet 

cleaned. And it's hard enough to get Prada-- I hope they're not in here-- it's hard enough to get 

Prada to back-up the dry cleaning stuff. But the wet cleaning stuff-- they won't even look at you. 

ROBERT FRISBY: OK, I think we'll need to move on to the next question. 

CHARLES RIGGS: It is being recorded, Ann. 

ANN HARGROVE: I'm sorry. 

[LAUGHTER] 

CHARLES RIGGS: I think you said the thing I said earlier. We're not just successful. 

Wetcleaning depends on what market you're operating in. If you're in a high-end market, that's a 

dangerous venture-- both in terms of liability and technology. 
ROBERT FRISBY: I think we have a question from the Twitter feed, I have one here, actually, 

but is there one back there? OK. Microphone to the back, please. 

AUDIENCE: Hi. Frank Gorman. I'm also the VFTC. Peter's Consumer Perception Survey raises 

an interesting issue for us. The purpose of the label is to prevent deception and unfair practices. 

If the label itself is deceptive because people understand dry clean to mean, essentially, dry clean 

only, we need to address that. We'll obviously look at the data provided by Dr. Sinsheimer. And, 

there are two ways I can think of to address it. One is to require the label to list all possible 

methods. And there are some significant costs involved in that. The other way is to come up with 

some sort of disclaimer language that would make it clear that dry clean means that dry cleaning 

is one possible method of cleaning that has been tested and that will work, but that it does not 

necessarily mean that there aren't other methods that could work. That's too many words. 

So my question, for the panel in the audience is, because this is something we're going to need to

address, and we need a record to address it, what should we do? And this is something you could 

submit later in comments as well. Is there language that you think-- disclaimer language-- you 

think would be useful if we're not going to go with the list every possible method approach. 

ROBERT FRISBY: Mary, you want to start? 

MARY SCALCO: I think you already addressed that in the care labeling rule, because the care 

labeling rule itself only requires one method of appropriate care. Dry clean is just on the label. 

That could maybe be hand washed, that could maybe be wet cleaned. If laundering is on the care 

label, that maybe could be dry cleaned or maybe wet cleaned. So that label is just as deceptive as 

the dry clean label. 

ROBERT FRISBY: Possibly. We don't have to testing on that. The problem is--

MARY SCALCO: I can guarantee it. 

ROBERT FRISBY: --consumers don't read the rule. They read the label. 

MARY SCALCO: I understand that, so you--

ROBERT FRISBY: The label has to accurately convey-- non-deceptively convey information to 

them. And if there's testing to show that the rule is currently written requires a label that deceives 

consumers, that's a problem we need to address. 

ANN HARGROVE: Well, I'm sure he asked his consumers that same question. 

ROBERT FRISBY: Peter, you want to jump in? 

PETER SINSHEIMER: I can try to address part of that question. But, at least the scope of what 

was being asked of us to consider for the round table, as well as for this role, had to do with 

whether it would be deceptive or not to put the wet cleaning label on. So, you limited the scope, 
and now you're increasing the scope. But, that said, if you go back to your own logic in the 2000 

rule, there was a logic that I disagreed with, but it was your logic. 

The question at that time was, should you require a home laundry label. Right? And so, the 

survey that I did was very similar to Procter and Gamble, and Clorox, as with respect to the issue 

of what a dry clean label meant. The logic, at least of the FTC said, well-- but most people-- I 

think the same survey showed that over half the people home laundered a garment that was 

labeled dry clean. And so, because of that, because there's a historical understanding about home 

laundering, and everybody knows what home laundering is. 100% of people know what home 

laundering is, so you don't have any kind of problem with information. People know what home 

laundering is. And of half the people who were surveyed at one time have home laundered a 

label that was dry clean, then your logic was, therefore, you don't have this problem with 

deception, because people have an understanding that has been passed down historically about 

what you can and can't do in home laundering. Even if it says dry clean. Even if most people 

mis-perceive what the dry clean label meant. 

So that's your logic. So that's one way to get out of your conundrum. At least for home laundry, 

yeah-- people kind of know what that is. People don't know what wet cleaning is, so there's a 

way-- at least the survey that I had done, and the results therein, would say that if you require the 

wet cleaning label, you're overcoming the deception just because it's gonna be on that it can be 

wet cleaned. 

ANN HARGROVE: But I don't think that was your question. Your question was-- if there is just 

one care method on the label, is that deceptive to the consumer? Because other care methods 

could be appropriate for that garment. Yes. 

ROBERT FRISBY: I do have one question from the Twitter feed earlier, which I will get to now. 

The question is, what does the FTC think Dry Clean Only means? And, let me answer that by 

saying that under the rule, to provide a label that says Dry Clean Only, the manufacturer must 

have a reasonable basis to believe that dry cleaning is a safe and effective method of cleaning the 

garment, and other methods are not. That's what that means under the rule, and hopefully that's 

what it means to consumers. 

Any other questions from the audience? I see a couple hands. 

AUDIENCE: I have a question about what you were just talking about. So I understood the way 

you're promulgating the new rule to mean that you were going to do away with the need for the 

term only-- dry clean only. Because, once professional wet cleaning is accepted as a method of 

care, then you have two professional methods of care, which changes the consumer 

understanding of that term. If you remove it, for the sake of the law because there's another 

professional method, it doesn't protect the consumer. So my question is, given that we all 

understand that consumers do not understand professional cleaning labels in general, like they do 

home laundry, how can we protect the consumer in the event of a professional care method if 

you remove dry clean only, because there's another method of care allowed. Isn't there a 

commensurate requirement to say, Do Not Wash, or protect the consumer from 

misunderstanding? 
ROBERT FRISBY: That's a great question. The Commission's proposal contemplated the use of 

Dry Clean Only in the future, but only if wet cleaning is not a safe and effective method. So it 

would require information about that-- to provide that warning going forward. 

CHARLES RIGGS: So I think you're saying-- if wet cleaning were required, the Dry Clean Only 

label would be replaced by a label that had a dry cleaning instruction, and a do not wet clean 

instruction. 

ROBERT FRISBY: Well, the rule would not require that. 

CHARLES RIGGS: Well, that would be the equivalent. If you require a wet clean instruction, 

and it couldn't be wet cleaned, then you'd have--

ROBERT FRISBY: The Commission hasn't proposed doing that. 

CHARLES RIGGS: OK. 

ROBERT FRISBY: The Commission has proposed permitting one. And so, the warning that 

she's talking about could still be made if there was a reasonable basis to believe that wet cleaning 

was not safe and effective. 

CHARLES RIGGS: So you'd say Dry Clean Only.

ROBERT FRISBY: You could say that if that were the case. 

AUDIENCE: But you could only say that if you paid to do the testing, Right? 

ROBERT FRISBY: You'd have to have a reasonable basis, which may or may not require testing 

depending on the circumstance. Yeah. 

AUDIENCE: Hi. Kim O'Burn from the Jones Group. I'd like to address Frank's question. This 

afternoon, we're supposed to talk about adopting the ISO symbols. I think, if we adopt the ISO 

simple symbols, that will solve a lot of the problems, because under ISO, you're required to have 

five symbols. One is a home-laundering symbol, and the other is a professional cleaning symbol. 

And, under those symbols, you can say Hand Wash, whatever, and you can put a dry clean 

symbol or wet clean symbol. So, you've got two. When you see two symbols, you know you can 

launder your garment by either method. If you can't launder it in the machine wash, you put an X 

through it. And it just has the Dry Clean. There's no Dry Clean or Dry Clean Only. 

ROBERT FRISBY: The commission has not proposed requiring the use of the symbols, only 

permitting them in lieu of written instructions, so that might work if people opted for that. 

AUDIENCE: That would solve the problem. 

ROBERT FRISBY: Yeah, Charles. 
CHARLES RIGGS: I think that's a topic that will come up later. And I thought so, too. But, 

having gone to the ISO meetings, what I learned is that in ISO, you do not have to have a 

reasonable basis to use the St. Andrews cross to cross it out. You just cross out what you don't 

want to use. And, in the FTC rules, you've got to have a reasonable basis in order to get 

something. So there's a big difference between the US rule and the ISO five symbol set with this 

crossing out. 

ROBERT FRISBY: Yeah, why don't we hold the symbol discussion for the next group, in case. 

We only have three minutes left. And so, if there are any more questions about the issues we 

focused on in this group, we'd like to hear those. Anyone else? Peter, yeah. 

PETER SINSHEIMER: I have a question for you. 

ROBERT FRISBY: OK. 

PETER SINSHEIMER: So in your proposed rule to allow versus require, the rationale for 

allowing would be somehow that they-- consumer demand would drive the adoption of the wet 

clean label up to some level that would be kind of, you know, satisfy the consumers demand for 

that, or something to that effect. I'm not exactly--

ROBERT FRISBY: That's actually not the case. 

PETER SINSHEIMER: OK. 

ROBERT FRISBY: The objective of the rule of proposed amendments is to address potential 

deception or unfairness. 

PETER SINSHEIMER: Yes, but the logic that you've spelled out for allowing was that 

somehow, the percentage of the garments that would have a professional wet clean label on it 

would somehow be driven by consumer demand. But I don't want to-- that's, at least--

ROBERT FRISBY: That's not central to the proposal. The proposal is to prevent deception. And 

since wet cleaning is now a viable option-- I think everyone agrees with that-- for cleaning, there 

should be a way of disposing it in instruction. 

We have time for one more question if anyone wants to--

AUDIENCE: Yeah, one question as far as the environmental issues. A lot was discussed about 

wet cleaning versus dry cleaning, but with home laundering, the water and the detergents and the 

soils are going down the sewer. Has there been any studies-- wet cleaning versus home 

laundering? Is there any difference in impacting the environment? 

ROBERT FRISBY: Is that a question for me? I hope not. I don't know the answer. 

AUDIENCE: I don't know. Whoever can answer. 
ROBERT FRISBY: Anyone else? 

AUDIENCE: Did you have a response to that? 

ROBERT FRISBY: Microphone. This will be the last question. 

AUDIENCE: [INAUDIBLE] from the Professional Leather Cleaners Association. I don't have 

the name of the study right off the bat, but I could probably get it, but I know there's been a few 

studies that have shown that the carbon footprint in general, over the whole population, would be 

tremendously reduced if people took their clothes, all their clothes, to professional cleaners, than 

doing it at home. 

ROBERT FRISBY: Interesting.