FTC Care Labeling Rule Roundtable

March 28, 2014

Segment 5

Transcript

FRANK GORMAN: OK. 

ROBERT FRISBY: Do you want me to switch the chairs? 

FRANK GORMAN: Thank you all. We're--

NORA NEALIS: I can sit here. I'll be anybody. I don't care.

FRANK GORMAN: We're going to start now on our third and final panel. We're going to talk 

about the reasonable basis and some other assorted issues. And if there's time left at the end, this 

panel runs until 3:40. If there's time at the end, we'll open up the floor to questions on any issues, 

including ones we've already covered.

I'd like to welcome our panelists. We have Mr. Augustine Chang for Nature’s Best Cleaners, 

Marie D'Avignon from American Apparel and Footwear Association, Richard Fitzpatrick from 

Kreussler Inc., Adam Mansell from Wulff Consultancy, Seemanta Mitra from Intertek, Nora 

Nealis from the National Cleaners Association, Mr. Dart Poach from Don's Leather Cleaners, 

Mir Quddus from Whirlpool, Charles Riggs from Texas Women's University, Mary Scalco from 

Drycleaning and Laundry Institute and Stacy Sopcich from GreenEarth Cleaning. I'm Frank 

Gorman with the FTC up here with Robert Frisby, who has been here all day. 

The first thing we'd like to talk about is the proposed changes-- the changes that we proposed to 

the reasonable basis standard. And these are non-substantive changes. They're, rather, 

clarifications by providing examples of situations in which you have to have-- test the entire 

garment, where it's reasonable to test the entire garment. GreenEarth came back with some 

additional proposed language just sort of fleshing out the examples go further. And I guess I'd 

just like to go-- we'll start with Mr. Chang. 

Do you think that it's appropriate, either the proposal that the FTC made to provide some 

examples-- for example, the color of one part often bleeds into another, where you have to test 

the entire garment? Or, also situations where you don't need to test the entire garment. Are these 

illustrations helpful and would you expand them along the lines that GreenEarth proposed? 

AUGUSTINE CHANG: Hello. My name is Augustine Chang. I'm the owner and operator of 

Natures Best Cleaners. And for the past 25 years I worked as a percholoroethylene operator. And 

then for the past five years, I did give myself as a 100% wet cleaner. 

To answer the question, yes, it is necessary to test a garment to make sure that it satisfies the 

needs of the consumer so that what they really pay for is the garment that they should get. So 

therefore, testing is required, of course. 
MARIE D'AVIGNON: Excuse me. I think clarification is always a good thing. Certainly, 

couldn't hurt to have a little clearer idea of what we're looking for. But I think the current rules 

where it says, testing isn't necessarily always required, if you have experience in this product or 

industry expertise you don't necessarily need to test. So to that point, I think that the rules that we 

have now for reasonable basis are reasonable. And it's a good name. But clarification can never 

hurt. 

FRANK GORMAN: Right. And the clarification are those situations where you really can't just 

rely on your experience, where you really do need to test the garment. I guess would be one way 

to characterize that. Do you think that's appropriate? 

MARIE D'AVIGNON: So I'm not sure exactly what--

FRANK GORMAN: That's all right. 

MARIE D'AVIGNON: --says, but if, I mean, there's specific cases where you absolutely need to-

- I don't know what exactly it says for the examples-- but I usually don't ever push for more 

testing than is necessary. And if it's something that is a testing requirement just to have a testing 

requirement, I don't agree with that. 

RICHARD FITZPATRICK: So I think it's fairly obvious that we're getting a lot of garments 

coming into the service providers that have not been tested adequately. And that the first time 

they're being tested is when that dry cleaner or processing organization gets the garment. So I 

think additional-- some additional clarification and instructions on reasonable basis and 

improving that testing would probably be a good thing for the industry. And certainly, the 

examples you gave-- garments that are mixed colors, applique that's added after the fact by 

jobbers-- those are examples of when a garment should probably be reexamined and some 

additional testing be done. 

ADAM MANSELL: I'm going to agree with the two previous speakers. I think giving examples 

is a very useful thing to do. 

SEEMANTA MITRA: I definitely agree to that. Basically, the purpose of all this regulations is 

how the consumer-- the consumer is the ultimate receiver of the product and how the consumer 

is going to view things from the perspective of the product. So when we test, we need to test the 

final product that would ultimately go to the consumer at the point of sale. So there should be 

more examples or specifications to say that. And if there are parts in the products that will cause 

bleeding, that definitely needs to be verified, A, either by historical evidence or by testing, would 

be the other option. 

And I would agree with Marie that you don't have to necessarily test to test, because there are 

things, for example, protein fibers, they never pass bleach test. It's obvious. History, historically, 

have shown that protein fibers would, like wool and silk do not pass the bleach test. So if you 

keep on testing that it's redundant testing, you wouldn't add value to your material. 
| in essence, I would agree with the speakers here that there should be a reasonable basis, and the 

reasonable basis can be based on either experience, research, records or testing. 

FRANK GORMAN: I think everybody whose addressed the question so far would have hit on 

this already, but just for the rest of the panel, if there are any examples given, either in our 

proposal or in the sort of additional proposals by GreenEarth that you think are objectionable, 

please flag those. Or if there are additional examples you think that we should consider throwing 

as well-- but thank you. 

NORA NEALIS: I think we need a reasonable basis and I think examples are a good way since 

people don't necessarily comprehend the same message when they read the same instruction. So 

an example is always a fine way to highlight to them what they may not have thought applied to 

the situation. It's a good way to try and solve a final problem for the consumer. 

FRANK GORMAN: And these are, of course-- this is a reasonable basis for the labeling. Mr. 

Poach? 

DART POACH: I represent the Professional Leather Cleaners Association. The PLCA 

recommends that the whole garment be taken into consideration for care label instructions. We 

recommend that any item containing suede, leather, fur, be considered to have a professional 

leather cleaned only label on it. 

MIR QUDDUS: What I have heard about-- I haven't read it myself-- about the examples that is 

given for a full garment, I would think that's really appropriate for us to have that to avoid 

confusion and also avoid problems with the product. 

FRANK GORMAN: OK. Thank you. 

CHARLES RIGGS: My interest on this topic was mainly with regards to the reasonable basis for 

the do not St. Andrews Cross provision. But I have learned, in terms of dealing with students, 

that once you start listing examples, if you don't include the one that comes to their mind, then 

that's not covered. 

FRANK GORMAN: Are there others? Well, I mean that is the risk. The longer the list of nonexhaustive examples you give, the more people think that that's an exclusive list. 

CHARLES RIGGS: Yes. Yeah. And anything else is allowed. 

FRANK GORMAN: Right. And that is not the intent. 

MARY SCALCO: Certainly we support that. For the garments that are outlined in the FTC 

ruling, GreenEarth's comments as well, those are all types of apparel that have come in where we 

have had problem on the professional level. So they should be highlighted that they need to be 

tested in the entire garment rather than components. 
FRANK GORMAN: And what I think I'm hearing is this would not impose any additional 

burden because this is how people understood the reasonable basis anyway. That if you had a 

garment where one part often bleeds into another, you would test the whole garment, you 

wouldn't just rely on the separately. The testing for each type of fabric separately. So this is not 

imposing any new burdens. It's just clarifying in case somebody doesn't understand that. 

STACY SOPCICH: Well, you're asking the wrong person. I'm not a garment manufacturer. But I 

would ask a garment manufacturer if that was their understanding. I'm not sure it is. 

MIR QUDDUS: I can support that because I used to work for a testing company and where-- not 

only people-- the manufacturers ask for you to test it on a specific part of the garment, but they 

also ask you to look at the overall garment, how changes takes place. Because it is important. 

They are not the same all the time. 

FRANK GORMAN: Stacy? 

STACY SOPCICH: I think, referring to the GreenEarth recommendations, it was really for the 

good of the industry. I mean, all we were trying to do is say, these are-- what the Commission is 

proposing are excellent. We heartily endorse. And to the degree that examples provide better 

clarification, we just think the list could be more inclusive of some of the known problem items. 

And it really relates to the process being used and the solubility of the material. So there are 

solvent soluble dyes and water soluble dyes. There are-- any plasticizers that are being used that 

help a garment stay soft, cleaned and perk. It's going to be a serious problem. 

So because we know this already and it's a known issue, I think that it makes just useful sense for 

everybody collectively to have a better reference point in the law of things that might require a 

clear reasonable basis for the recommendation. I'm not sure that we as a company understood 

that it was the whole garment always being tested so much as problem items that require 

reasonable basis. 

The only thing that we're really acutely aware of is a need for a whole garment testing that seems 

to be irrefutable, is the current issue with black and white Spandex, poly Spandex specifically. 

It's really not an issue except for poly Spandex where it's a very dark color sewn adjacent to a 

light color. 

The AATCC is already adding a note to all of their laundering test methods to say that the test 

methods can't predict dye bleed and it's going to be looked at on the dry cleaning side too. And 

so these are known issues. Seems reasonable that Spandex, in particular-- all elastanes-- be tested 

as a whole garment because there's no solution right now that would predict it with a test 

method. 

FRANK GORMAN: Thank you. I guess if there are any manufacturers in the audience, 

representatives of manufactures in the audience, who think that this-- only if you think that this 

would create a problem or oppose additional burdens. 

AUDIENCE: I think I would. 
FRANK GORMAN: You would? 

AUDIENCE: [INAUDIBLE] 

FRANK GORMAN: Well, the proposal is that-- let me see-- reliable evidence for each 

component part of the product in conjunction with reliable evidence for the garment as a whole--

that you can rely on that-- provided the test results showing that a whole garment can be cleaned 

as recommended may be required where, for example, the color of one part often bleeds on to 

another when the finished garment is washed, a dye that is known to bleed, or beads, buttons or 

sequins-- and the GreenEarth proposal added some additional things that-- that are known to be 

damaged often in dry cleaning are used or a garment contains several fibers, fabrics or 

components not previously used together. 

And then GreenEarth added-- its proposal-- added that a garment containing water soluble dyes, 

wool, natural fiber, or skins when wet cleaning is the recommended cleaning method. So if 

you're proposing wet cleaning for those things, then you would need to test the whole garment. 

In that context, you see that that imposes-- I don't know that everybody actually had looked at 

this for this panel so--

AUDIENCE: I didn't get to-- I'm just hearing the wording now. So just basing my knowledge on 

what my company does, we typically test fabrics, not finished garments. Unless it's children's 

garments because we have to test it for CPSC. So it could add an unnecessary burden in-- for our 

cost side because to test a whole garment is going to cost more money. And I know our testing 

people down there could probably fill you in on that part versus testing the fabrics. 

But when we do have a garment that is, like you said, mixed colors, it is tested together. So the 

exceptions that you're giving, we will make an exception to our normal testing protocols for 

those type of garments. As for the trim, to test a whole garment with a trim on it, no. We'll find 

out from the trim supplier how it reacts to certain chemicals, and we'll use that in our care 

labeling. 

FRANK GORMAN: I guess what I would suggest is that if people haven't focused on this 

particular proposal-- the record is open until--

ROBERT FRISBY: April 11. 

FRANK GORMAN: April 11. So if you want to get-- if you want to go back and talk with your 

testing people, anybody out there, and put in some additional evidence, we would appreciate that. 

But I think right now we'll move on to the next issue on our mop-up panel. And was there 

something else on that? 

Water temperature and home washing-- we did not have a proposal on changing our rule in any 

way regarding water temperature. But it was brought to our attention that our temperature ranges 

are different than the recent AATCC ranges proposals. And there's also a big difference between 

European washing machines, which have water heaters built into them and really control the 

temperature, and the washing machine I have at home where the hot water barely comes in at all 
and-- it just depends on what the temperature of your hot water is, what the relative flows of your 

hot and cold feeds are. And there's really very little control. 

And my broad question for the panel, to the extent that you have something to say on this-- you 

don't have to respond to something if it's not relevant to your particular industry-- is, does this 

create real problems for consumers, for industry or four cleaners? This discrepancy between the 

ranges that we have in our rule and the ranges that kind of exist out there? And there's some 

overlap. Right? So-- Augustine. 

AUGUSTINE CHANG: OK. Water temperature. I think it has a lot to do with what you do with 

it. You can launder dark colors in certain hotter temperatures it ruins the dye. And like you said 

earlier, how long does it take for water to fill up and how cold does it get? Does it really get 

warmed up and what kind of soap does it also use? These things makes a lot of differences when 

you're doing actual home laundry. 

Like I said, I've been doing this for 20 some odd years as a chemical and then five years as wet 

cleaners. When you go a wet cleaning any kind of garments, temperature is very sensitive. So we 

usually work plus minus a few degrees. So if that threshold is not there then garment doesn't 

clean as well. So earlier on, I think the professor said, you would have to a assert the right 

temperature, otherwise it won't clean. And I believe that's true. And putting some sort of a range 

of temperatures important to get the maximum cleaning on this that you need for your garments. 

FRANK GORMAN: Right. And what we're talking about here is for home washing where, 

again, the home washing machines for our hot, warm and cold instruction, and people's home 

washing machines, in the United States at least, have really broad ranges. And our rule ranges--

and I guess the question is, is a fix needed for that and what would that fix be? 

AUGUSTINE CHANG: In home washes, everything is different so you can't really put a 

temperature on it because you can't really measure the temperature at home unless you have a 

thermometer and it actually measures it. 

MARIE D'AVIGNON: I don't think I really qualify to speak on that. 

RICHARD FITZPATRICK: I wouldn't have anything to add for that. 

SEEMANTA MITRA: Well, basically what we have to look at is, if you take Europe, we have 

different spinning conditions for the home washing machines-- agitation speeds, those are 

different-- that can be different from the North American or US test method-- process that we 

had. In terms of, the AATCC-- and Mir can speak more on that. He is the, actually, chair of the 

AATCC committee for that. He's going to say, AATCC is working on a monograph on the wash 

temperatures. 

So what-- my suggestion would be to adopt something that's nationally adopted by the governing 

bodies here, like the AATCC, as the wash temperatures because that would prevent 

inconsistency between what the FTC propose and what the AATCC proposes. How significant 

would be that, we can only see after we do the testing to find it out. But in terms of very dark 
colors maybe, or in terms of colors that are considered color block items-- like you have a dark 

thing with a white body-- it might be a significant that difference in temperature. So, in general, 

what we have always done, whether it's a CPS regulation or an FTC regulation, if there are no 

government test standards, we automatically deployed to the ASTM or the AATCC standards for 

testing. 

NORA NEALIS: I'm a wash and fold girl. 

FRANK GORMAN: OK. 

MIR QUDDUS: OK. Basically this was kind of like highlighted by us because AATCC has been 

working on the test standard for testing the color fastness and multiple other testings where we 

rely on a monograph to define what the washing condition, the washing parameter should be. 

And we look at the washing machine that can be a consistent tool for looking at the performance. 

And this is a performance that would be insured of not only just North America, but also globally 

because this test standard that we formulate is used globally to test the garments that are coming 

in or the government's that'll be produced for export to US. 

So AATCC came up with temperatures that are in line with the temperatures, or within the range 

that FTC guideline provides, FTC 16 CFR provides, which is the cold-- we have a temperature 

for cold. We have a temperature that falls within that range of the warm, and we have a 

temperature that falls within the range of hot. So that's-- the labs, without having to look for 

which temperature to wash their garments-- and I kind of piggy back on the statement that Mr. 

Chang made-- is that you need to find the temperature within a given small range. So AATCC 

range, you know-- just one example would be that cold that FTC defines has the range of 54 

degree Fahrenheit, whereas AATCC has a 15 degree Fahrenheit. Basically, you can now test 

something with some consistency and reasonable basis that we're talking about that with repeat 

performance that can be compared globally and it can be something that Seemanta was talking 

about, that you can put a grade of 3.5 or 4 and can be reliable about it. 

So what we assisting now, FTC, is a rout to implement this protocol where there is no route right 

now. Because if you go to a consumer laundering machine that is used in North America that you 

cannot find this temperature if you don't know how to find. The labs used-- the AATCC 

recommended test machines-- but there is no way of putting this. So we came up with a 

programmable cycle that you can now find the temperature which, Mr. Chang said, you cannot 

find it in the washing machine. And it's true that you cannot find it unless it's programmed. 

So this is a way, if we refer like a sentence saying that in terms-- like, I have looked at the 

website. There's some statement or disclaimer about the care symbols. There we can add this 

term. Like, the terms can be washed-- sorry, the items can be washed by following the washing 

protocol recommended by American Association of Textile Chemists and Colorists Monograph 

N6. That should give the labs to go where to find this washing protocol and you don't have to do 

much of anything. 

FRANK GORMAN: Right. I mean, we can't, obviously, change the shape of the washing 

machines that are in consumer's home, and they need to get-- this is really about the testing labs 
knowing what temperature to test out so when a consumer uses a typical washing machine and 

they wash it on cold, it'll--

MIR QUDDUS: Correct. 

FRANK GORMAN: --or warm-- OK. Thank you. That was very helpful. 

CHARLES RIGGS: I've been involved long enough I remember some of the history. For testing 

purposes, you have to control the temperature. That's a given. But when you start comparing our 

testing temperatures to home washing machine temperatures, there's always been a big 

disconnect, especially when it comes to cold. The testing range that we have currently for cold is 

65 to 85 degrees Fahrenheit. 

And those numbers came from, historically, the detergent manufacturers gave us the lower range. 

Below 65 there were activity, solubility products with their detergents. And 85 was the upper 

range because there are many parts of the country-- I live in one of them-- where cold water in 

the summer times is, in fact, 85 degrees. But at the consumer level, cold water is what they get 

out of the cold water pipe depending on the season, and it changes greatly. The hot water is 

limited by the hot water heater and where it's at. And then for warm, you get a mix of the two. 

Used to be the machines were manufactured to give you a 50/50 mix. Now they've cut that to a 

60/40 mix to try to save some energy. So unless the machine has temperature control or a cold 

guard, you only get those mixing ratios based upon what is the water supply temperature hot and 

cold. And it's all over the place. 

FRANK GORMAN: So do you--

CHARLES RIGGS: But for testing you've got a narrow it down. And I think this cold one, below 

65, is probably not a good temperature to wash. Regardless. If your cold water is 65, you 

probably should set the machine to warm. 

FRANK GORMAN: Is-- do you see a need to change our rule process? 

CHARLES RIGGS: I think you should probably have the temperature specified in the rule 

matching the temperatures that are specified for testing, even though these may not be the 

temperatures in any given consumer's laundry. 

FRANK GORMAN: And you would agree with that? 

MIR QUDDUS: No. What we have come up with, what Charles mentioned, that the 

temperatures range is, for cold, is FTC has 32 to 86, with a range of 54. And AATCC has a cold 

that is a ranges 52.5 to 67.5, which falls within the range of FTC. So that's-- you don't have to go 

overhaul because we fall within your range. 

Then it goes to the warm. The warm is 87 to 11 for FTC, with a range of 24. And AATCC has a 

warm of 78.5 to 93.5 with a range of 15, all within the range of warm as well. Then we have a 
cycle that we call extra hot-- but the nomenclature is not a big deal. The FTC hot is 112 to 145, 

and our hot is 122.5 to 137.5. Now, this cannot be done just by going to the machine and say, 

cold, hot and warm. There's no such thing. So this is programmed and the cycle is consistent 

from machine to machine, year to year. So basically, the performance is now consistent on a 

wash cycle but the temperatures changing. So that gives the consumer touch and feel and 

everything, but with the control of temperature. So that's-- we can provide that. 

CHARLES RIGGS: There are temperatures specified on both the ASTM care symbols and the 

ISO. And I think they're the same. And the ranges are a little different, but I think you've got a 

match. Either your symbols range, test condition range-- I don't think FTC should try to redefine 

these things that are so vague anyway, and work from the testing requirements. Because we 

could always have an explanation back to the consumer that your water is too cold to be cold 

wash. Which is probably the case in Minnesota in the winter time. 

FRANK GORMAN: Mary, do you have--

MARY SCALCO: I have nothing to add. 

FRANK GORMAN: Stacy? 

STACY SOPCICH: It only makes sense to defer to the technical experts who are providing this 

missing link to the testing believed to be universal. That makes sense to us. 

FRANK GORMAN: The one thing that strikes me as being problematic from a consumer 

viewpoint, we're talking about the language on the label. There's not an extra hot. People don't 

have an extra hot setting on their machine, so an extra hot care label wouldn't be particularly 

valuable. If we were to match specifically, if you were to line up perfectly with your--

MIR QUDDUS: No. Actually, the way-- I would not worry about this part. This extra hot. It's a 

terminology. Because we also have one, two and three-- like, one, two, three, four. Those are the 

test symbols that we also-- like, we have nomenclatures that we say, one, two, three, four. Up to 

four. So those are like Roman numerals. So it really doesn't matter how we call it, the cycle 

means, per se. 

But all it is temperature, because when it is referred for FTC, we definitely would have each of 

the FTC temperatures will be tested based on this. Cold would be this temperature, hot would be 

this, and that would be referred to within our AATCC website. So it will give you a reasonable 

basis to test these things with what you're talking about, examples that-- we will have the very 

good--

FRANK GORMAN: But no one's proposing that we have and extra hot wash instruction. 

MIR QUDDUS: No. No. No. 

CHARLES RIGGS: I think the extra hot that's on the labels was a concession to the European 

market where washing temperatures are typically quite a bit hotter than they are in the US. If we 
had an extra hot, you can do that at a consumer level by cranking up the hot water heater, but I 

don't think that's a recommendation that we would want to pursue. And probably would be of 

little benefit to the types of laundry that the average American consumer does at home. European 

situation is somewhat different. 

FRANK GORMAN: Does anybody have anything further on water temperature? No? OK. Also, 

and I think we'll start with you, Dart, on leather care issues. As you stated earlier, that your 

organization favors labelling leather goods with an instruction for leather clean and refinish by 

professional leather cleaner only. And that would include garments with trim, leather trim. I 

guess-- can you flesh that out what you envision, and then we'll get comments from the panel. 

DART POACH: Sure. We'd love to have the proper care label on all leather garments. But in this 

case, it would be under appendix eight, number eight. As you stated, right now it says, have 

cleaned only by a professional cleaner who uses special leather or suede care methods. And 

that's-- I think most of the manufacturers are putting the professional clean by a leather expert 

already. So it may not be an issue. 

But the big thing that's missing is the refinishing part. It's one thing to clean it, but most of these 

products need to go over to the refinishing department where dyes and oils and waxes and shines 

and water repellencies and of that nature needs to be done, so we can make that garment as new 

looking as when it was bought. And that's the reason why we wanted to have it changed to, very 

simply, leather clean and refinish by a professional leather cleaner only. Whether that's trimmed 

with leather, suede or fur, or all leather or suede garments. 

FRANK GORMAN: OK. And--

SEEMANTA MITRA: I do have a question because under the Federal Trade Commission textile 

care labeling rule, leather is not considered a textile material so it really doesn't come under the 

scope of the regulations. So what-- are you proposing that leather labeling be included as part of 

the care labeling rule under the--

FRANK GORMAN: To be clear here, we haven't made this proposal. This is a proposal that--

SEEMANTA MITRA: No, no. I'm not asking-- I'm asking--

FRANK GORMAN: Oh, sorry. 

DART POACH: Yeah. We understand that the non-textile isn't required, but under textiles that 

have trim, there is a requirement. 

SEEMANTA MITRA: Well, the clarification, at least that we have got, is that if the majority 

part is textiles, you don't have to worry about the non-textile part of it in terms of care labeling. 

DART POACH: Where does the FTC stand on that? You wrote the appendix A number eight 

that states have cleaned only by a professional cleaner who uses special leather or suede care 

methods. 
FRANK GORMAN: I'll defer to you. 

ROBERT FRISBY: The rule provision itself doesn't really address leather directly referring to 

the appendix. But for a textile garment, which would include-- could include some leather, the 

instruction should cover the entire product. so--

DART POACH: That's the basis we're going on. What he just said. 

FRANK GORMAN: Any comments? 

SEEMANTA MITRA: No comments. 

MARIE D'AVIGNON: I want to say, I've never heard a manufacturer complain to me about this, 

nor a consumer, and I get a lot of very strange consumer complaints because we have an open 

dialogue on our website. So I don't necessarily see a need to change the rule. And, as was 

mentioned, it doesn't necessarily fall under textiles so we don't normally look at it in the care 

labeling sense. I would say, I don't necessarily agree with adding or changing the language as he 

recommended. 

DART POACH: It seems to us at the PLCA that most of the manufacturers understand and show 

that understanding by the care label that they put on there now. Because I would guess that most 

of the labels do state have cleaned by a professional leather cleaner if it's a textile and has the 

leather or suede trim. We see a lot of them coming through the dry cleaner who I will pick up 

and deliver to, or that most of the members of the PLCA does. So it may not be an issue. 

We had just, when we got invited to make comments, we could see that the way that it's read 

now that the key word is the word refinish. Because that is definitely an art that an additional 

layer of professionalism that the typical well-meaning dry cleaner does not have at their disposal, 

except through a wholesale leather professional leather cleaner. 

FRANK GORMAN: Maybe I should ask the question of the panel this way, including you, is 

there evidence that, as things stand now-- and I think you already spoke to this, Marie-- that 

there's a problem. That, in fact, leather trim garments are not being referred to appropriate 

professionals and garments are being damaged? Has anybody seen any evidence of that? 

AUGUSTINE CHANG: Can I comment on that? 

FRANK GORMAN: Please. 

AUGUSTINE CHANG: Sometimes leather trimmers comes with different colors. So in order 

for, at least our provider, want us to sign off a release saying, if it gets ruined then it's your fault 

because you haven't signed it off. So this is where the consumer gets lost. Its attractive to wear, 

nice to look at, but then it's not serviceable. Pay $300 or whatever and can't service them unless 

they sign a release saying, go ahead and ruin my garments. 
So those are the little issues that most of the dry cleaners will face on a regular basis. And we are 

actually a front line between the manufacturer and the consumers. In many cases, doesn't actually 

go through to the manufacturer because, one, we're just too busy working, number two, 

sometimes it's not worth it because we can't find a manufacturer to send these garments back to. 

See? 

So usually, wet cleaner or the day cleaners, issue what are called store credits or end up giving 

refunds or reject the item. So the consumer would go to another local cleaners for this garment to 

be serviced. Same issue because they're serviced by the same leather providers. 

FRANK GORMAN: Anyone else? Richard? 

MARY SCALCO: I guess I would have a comment unless you're going this way. 

FRANK GORMAN: I don't have to. 

MARY SCALCO: No, no. Please. 

RICHARD FITZPATRICK: I was just going to say that, in terms of regular dry cleaners 

servicing these types of pieces that have small amounts of leather or fur trim, we see a lot of that. 

We don't see as much damage as we had when perc was such a dominant solvent. With the 

advent of more gentle solvents like GreenEarth, where these pieces seem to perform OK in the 

cleaning process-- yes, these cleaners don't have the ability to refinish a lot of this stuff, but a lot 

of this stuff doesn't need to be refinished. That doesn't mean that they shouldn't be using a 

professional leather cleaner to do it. I'm not certain it's an issue from a--

FRANK GORMAN: Do you see evidence that an instruction is needed-- additional instruction is 

needed? 

RICHARD FITZPATRICK: I don't see evidence that there's-- that you need additional 

instructions, although that's up to you whether you want to put it. 

SEEMANTA MITRA: It's very rare to see a leather trim. It's mostly imitation leather trims that 

you mostly see on those garments that occupy not a significant portion of the product. And those 

are covered, as you mentioned, in the overall care instructions of the product for the wearing 

apparel. 

NORA NEALIS: We get a fair amount-- and I could defer to Alan on this-- of leather trimmed 

garments coming into the lab for analysis. Now, some of that could be the price point that drives 

it. Some of it could be that it was-- they didn't catch the trim because oftentimes the trim is not 

that-- doesn't jump out at you. It might be an epaulette, it might be a cuff. Oftentimes there will--

a cleaner doesn't have to be a professional leather cleaner with refinishing capabilities to handle 

those garments well, depending on whatever else they may have at their disposal at the plant, 

including maybe a good tailor that would take it off and put it back on. 
And that's a professional judgment call. It probably deserves some exploration but by and large, 

as was said earlier, because so many of the solvents are less aggressive now, because wet 

cleaning offers a lot of opportunities on the leather side, the amount of reliance that cleaners put 

on sending stuff off to a professional leather cleaner has shifted in recent years. 

FRANK GORMAN: All right. Let me-- I'll end with you, but anymore comments down this 

way? I know Stacy--

MARY SCALCO: Well, I think, as we've said, and I think what Don alluded to, is that the 

people that are making 100% leather garments--

FRANK GORMAN: They're out. 

MARY SCALCO: Well, because they-- they're not covered under the care label, they have come 

up with our own label that says, take to a professional leather care. So those garments are 

covered by the professional leather care cleaner. It's the ones with the minimal-- if there's trim, if 

it's 100% leather trim-- which I would agree, and the majority of instances that you see with a 

cloth garment, it's not 100% except in very expensive items. Normally it would be the imitations. 

And as Rich said, with the newer solvents, they can be handled. The imitations can be done in 

regular dry cleaning. 

FRANK GORMAN: Stacy? 

STACY SOPCICH: All natural skins have a basis of natural oil and so a degreasing solvent like 

perc is going to strip that oil. That's understandable. But as has been said, there are alternatives. 

Hydrocarbon isn't a huge problem with leather, and silicone certainly isn't at all. 

The real issue, as Dart said, which is when it's a grained leather that's been surface dyed or 

painted, then you have a problem and it needs to be addressed by a professional leather cleaner. 

But that doesn't mean that anything with leather on it needs to be addressed by a professional 

other player with a dying booth and all the training they need to handle it. But that would be my 

view. 

FRANK GORMAN: And, Dart, I'll let you have the last word on this. 

DART POACH: It's not only the changes that occur in the cleaning, but you also have the 

consumers wear and tear on it too. So some of the finishes could come off in a regular cleaning 

whether it's a month old-- but if it's three years old then you have the wear and tear that the 

professional leather cleaners can do. And that simple change of refinish and being cleaned by a 

professional would take care of the-- protect the consumer. 

And that's not also to count the analysis, the ones that have come in to NCA and DLI, where 

there's been a professional dry clean, or dry clean only, with this trim on it and it bled or it took 

all the finish off. And it's-- the report says it's a bad label take it back to the store. Because it says 

dry clean only and it didn't come out and it had leather. So if we're talking consumer protection, 

that would be a very easy fix to cover both those. 
To expect the consumer to pay for the remanufacturing of that garment by taking the leather trim 

off, they might as well go buy four more of those items for the cost that would take, if you could 

find anybody that wouldn't even do it. 

FRANK GORMAN: Thank you. We're going to move on. There's one more issue then I'm going 

to throw it out for general comments. And that is that we're proposing to update the definition of 

dry cleaning to remove the reference to organic solvents and to drop the reference to 

fluorocarbons which are no longer used. And we're also adding additional examples of solvents. 

And, I guess, just one question about this, one compound question about this, and this time we're 

going to go this way just to mix things up. Do you support the change to the definition and why 

or why not? And what would you do differently? 

STACY SOPCICH: Well, certainly, we do definitely support the definition. GreenEarth silicone 

has been available since 1999 so we heartily endorse the change in the definition to non-organic 

solvents. We think it's terrific and certainly in the right direction. 

FRANK GORMAN: Mary? 

MARY SCALCO: Support. 

CHARLES RIGGS: I would strongly endorse the idea or the verdant working of non-aqueous for 

the solvents. And then the water process is an aqueous. So you have two extremes, aqueous and 

non-aqueous. You get into organic and that gets--

STACY SOPCICH: Yep. That's too much science. 

CHARLES RIGGS: --confusing in terms of the molecules. 

FRANK GORMAN: Let me go back to start over, add a element to the question which is, do you 

support Dr. Riggs proposal of having aqueous and non-aqueous as-- it's not the definition we 

proposed, it's a little bit different. So--

STACY SOPCICH: Well--

FRANK GORMAN: I think it solves a sort of problem. 

STACY SOPCICH: Is there a distinction in the meaning between solvents other than water and 

non-aqueous?

FRANK GORMAN: I mean-- does our definition take care of it for you? 

CHARLES RIGGS: I thought yours had-- still had the word-- what is the word that you have in 

there? 

SEEMANTA MITRA: Organic. 
FRANK GORMAN: A commercial process by which soil is removed from products or 

specimens in a machine which uses any solvent excluding water. And then we have examples. 

The process may also involve adding moisture to solvents. 

CHARLES RIGGS: I think you can eliminate the examples and just say non-aqueous solvents. 

That excludes water itself and you don't need the examples. The examples of which we are 

seeing are changing. You don't have every-- the examples become open-ended. 

FRANK GORMAN: Do you see a benefit to the examples? 

STACY SOPCICH: Well, I don't know. I guess it's a matter of consistency. In the past, the FTC 

has always based the examples on what was available in the market at the time and so it 

referenced perc and petroleum specifically, because that was all that was available. Silicone is 

now available. Solon K4 is a new product that seems to be having some good traction. So I think 

it makes sense to widen the definition and go on record with the one that you know that are 

commercially available. 

FRANK GORMAN: Right. The downside of that, I think, is that-- new-- as new things become--

it's not an exhaustive list, but some people may read it that way. And if you put in the examples 

that are extant today, by the time its published in the Federal Register, it may be out of date. 

STACY SOPCICH: It's just the precedent the FTC has always had. That's it. 

CHARLES RIGGS: Our last round table was 1999. So if that's our time interval, we will be out 

date next review. 

FRANK GORMAN: I was doing something different at the FTC then. 

MARY SCALCO: But I would think, using your example there, if this is for consumer 

education, if a consumer would think if it was not listed it would not be covered, that would not 

be a good thing. 

FRANK GORMAN: Well, I don't think consumers read our rule. They read the label. 

STACY SOPCICH: Well--

MARY SCALCO: OK. 

STACY SOPCICH: Well--

MARY SCALCO: You would hope you would get there with some consumer education. 

STACY SOPCICH: Right. 

FRANK GORMAN: OK. Mir? 
MIR QUDDUS: I would say non aqueous would be more general and examples probably would 

be more specific. So not generalize probably is better way to go. 

FRANK GORMAN: Dart? 

DART POACH: I personally agree. 

NORA NEALIS: Non aqueous works. 

FRANK GORMAN: You don't like examples? 

NORA NEALIS: The problem with examples is they can be limiting. And while they can also be 

illustrative, the discussion becomes, is that an exhaustive list or is that an all-inclusive list? And 

it's-- I think, for our purposes, since this part, as you said, really isn't consumer driven as much as 

it is label writer driven and industry driven, that non-aqueous is probably a smarter choice. 

SEEMANTA MITRA: I agree with what Nora said. Possibly, the examples might be a little 

limiting to say that specific to those types of non-aqueous solutions. 

ADAM MANSELL: And I don't have a dog in this fight. 

RICHARD FITZPATRICK: I don't see the examples harming the definition. But if they weren't 

included, I also don't think there would be any damage. 

MARIA D'AVIGNON: I think updating the definitions to today's standards is certainly important 

to keep up with the times and technology we have. But I'll leave the aqueous discussion to the 

cleaners. 

AUGUSTINE CHANG: I think all of us are really familiar with water. What do we do with 

water? I use water to clean my baby's bottom. I'm sure that you guys with kids would have done 

that. And it's the safest form of cleaning solvent. The reason I call it solvent is because it's a 

chemical composition, H2O. Very simple chemical that we use to clean everything. 

And as far as garment caring process is concerned, Chinese has been cleaning silk garments for 

thousands of years without any issues or problems. Leathers were cleaned using water, wools 

were cleaned. Loot at Irish with their kilt. So if you look at-- really think about what water can 

do, we have here representative from a K4 from silicone-based. We don't have any 

representatives for water here because-- I'm almost done. 

FRANK GORMAN: No, I was going to say, we've had professional wet cleaners represented. 

AUGUSTINE CHANG: I mean, I'm talking in terms of chemical. Water. So water is very cheap, 

inexpensive, we don't require any annual commitment, there's no fines to be paid, there is no 

EPAs to be concerned about, and there's no hazardous waste that we create. And we don't have 

any hazardous materials that we create to be dumped somewhere else. 
As I heard everyone talking today, everyone has some sort of a sense as to imputing water cleans 

things very well. And there another saying that, in order to get rid of a lot of the grease stains that 

we have to use solvent, and talk as if we are creating some sort of a hazardous situation in our 

store. But if you really look at it carefully, there are many different home remedies or something 

that's very simple citric chemicals or fruits that you can use to get rid of l-based stains. 

So if you don't use it as looking at as to how bad wet cleaning and, therefore, we are going to put 

it aside, that as a dry cleaning or professional wet cleaning, think the other way. Look how many 

people have cleaned their items using water. Thank you very much. 

FRANK GORMAN: All right. Thank you. At this point we're going to open it up for questions. 

And I think, basically, everything is fair game right now. Well, everything to do with the care 

labeling rule is fair game. 

AUDIENCE: Thanks. I just want--

FRANK GORMAN: Wait for the mic, please. Thanks. 

AUDIENCE: This is Paul Matthai, again, from EPA. I just wondered, are you making any 

distinction between suede and bonded leather? Or not leather but the povis leather, or whatever it 

comes in? 

DART POACH: Top grain. 

AUDIENCE: Top grained leather? Is there a difference on the process? Because I don't think you 

mentioned that. And what about the processed leather that, I don't know, is probably chewed up 

and then re-glued back together. Is that part of that or is that something--

DART POACH: No. I was just-- the PLC represents-- well, you wouldn't say real leather, you 

would say genuine leather and suede. You're right. 

FRANK GORMAN: OK. Anyone else? All right. Any of the panelists have any parting thoughts 

that they want to share. You've all been-- put in a long day. I appreciate we've gotten some really 

good input, we've gotten some really good evidence, and everybody has been cordial and 

thoughtful of each other's points of view. I think it's been an excellent panel. 

RICHARD FITZPATRICK: I'd just like to-- and maybe this was clarified and I missed it-- but 

what is the FTC going to do, or what are they thinking about doing in order to stay current with 

the standards as they're published? Was that-- have you guys-- what is your position on that? Are 

you going to allow an automatic adoption of current standards with an ability to veto it or are you 

going to require that every new standard written has to be approved of through some committee? 

FRANK GORMAN: I'm going to have Robert correct me here when I make a mistake. My 

understanding-- and first of all, not speaking for the Commission. Neither of us can speak for the 

Commission. We can make a recommend-- we'll eventually make a recommendation to the 

Commission and then they'll act. Standard disclaimer. 
There is a problem, as I understand-- and this is based on my work in areas other than this rule--

there is a problem with us referencing future standards. It's a delegation problem that our general 

counsel's office has suggested to us that we can't refer to-- we can't just sort of peg it to 

something that doesn't exist yet. We can't peg our regulation to something that doesn't exist. Is 

that your understanding as well? 

So it makes a lot of sense on a lot of levels to just say, we will peg our rule to the standards as 

they are updated as the ASTM standard or whatever standard as its updated over time. This is a 

nice reliable body and we're sure they'll get it right and this is probably what we'll end up doing 

anyways if we thought about it. But we can't do that. It's just not allowed. Yes? 

SEEMANTA MITRA: It's a different question not related to what he has asked is, will the FTC 

consider in the new-- as you're revising the care labeling rule-- to provide more specifics on what 

is considered as the useful life of the product for a permanent care instruction? 

FRANK GORMAN: Robert, can you answer that? 

ROBERT FRISBY: I don't recall much in the record about that issue. But the record is open until 

the 11th and if you think we need to address it, please let us know. 

SEEMANTA MITRA: Yeah. And these are general questions that we as a testing laboratory face 

and some specifics on what type of products really need ironing. Like, we wouldn't put an 

ironing instruction on underwear as opposed to a dress shirt, for example. But these are more 

specific instructions. But there are so many different garments. And I know you're representing 

the UK Fashion and Textile Association. Fashion is changing every season so we get some areas 

where we are really confused whether should we put a ironing instruction is needed or not. 

Because the FTC rule says, for the ordinary use and enjoyment of the product, can be interpreted 

in multiple ways. Or at least in two different ways. 

FRANK GORMAN: I think this is another topic in which we really haven't received comment. 

We can't stress enough how important it is that, if you have areas of concern, that you submit 

comments then, and the more evidence you can submit that addresses the costs and benefits-- not 

just identifies an issue but also that proposes a solution and addresses the cost and benefits of the 

solution and of not adopting the solution, if you will. We need a record to be able to make any

change. 

MIR QUDDUS: What happens next? So, what we discussed, what happens next? 

FRANK GORMAN: Well, at this point there's two branches we could take in the road. We could 

issue a staff report where we make the staff makes a final recommendation, essentially, to the 

Commission. It's not published by the Commission, it's published by the Bureau of Consumer 

Protection. And then there'd be another opportunity for comment on that staff report. And then it 

would go back-- a recommendation would be made to the Commission on a final rule. 

The other possibility is, if there are things that come out of this roundtable and in the last round 

of comments that would require us to-- would lead us to propose-- staff to propose-- something 
that wasn't encompassed by our previous proposal, I believe we would have to go out with 

another notice of proposed rulemaking to allow comment on that. And then somebody could ask 

for another hearing, then the staff report. 

It's a long process. This is-- we have two types of rulemaking at the FTC. We have APA rule 

making which is a little more streamlined, where Congress specifically passes a law like they did 

with the Textile Act and gives us authority to promulgate a-- unless Textile's a bad example. It's 

not? OK. Or Congress gives us authority to promulgate rules. And that doesn't have some of 

these extra features like hearings and staff reports. 

And then we have what we call Magnuson-Moss-- which is under an old statute-- rule making 

which is what we're acting on now where we're basically proposing the rule or revisiting the rule 

based upon our general deception of fairness authority under Section 5 of the FTC Act where we 

have to show prevalence and so on. The stuff that I think Professor Sinsheimer did a nice job sort 

of going through the standards. Whereas the APA rule making, Congress tells us what the 

standards are and we meet that. But you're not going to be seeing a final rule direct from this 

roundtable. The next step will either be a staff report or a new notice of proposed rulemaking. 

MIR QUDDUS: What happens? So the staff report goes where? Like, goes--

FRANK GORMAN: It's published. It's published. I don't quite understand the reason for this 

extra step. But, essentially, it's not a statement of the Commission, it's a statement of the staff. 

But it's published in the Federal Register or at least it's put on our website and announced so that 

people-- and then comments are solicited to it. And then based on those comments we then 

would make a recommendation of a final rule to the Commission. 

MIR QUDDUS: So how long is this staff report time and then the next one? 

FRANK GORMAN: It depends. I'm sorry. We're leaving the-- we should be much further along 

than we are now but for the government close down-- shut down, for example, we're several 

months behind. A very serious concern came up with scheduling. The rescheduling of this 

meeting-- I don't know how many of you have talked to Robert during the planning of this-- that 

we would schedule it on a day where we'd have snow. Which was prescient because I think 

several of the days we were batting around ended up being government closed down snow days. 

So you all would be meeting on the sidewalk by yourselves again. We're not allowed to have--

we can come in and work but we're not allowed to have public events when the government is 

closed. 

So that pushed us back a little bit. The record now is open until April 11. It takes time and we're 

balancing a lot of other work and other priorities, but we've taking this very seriously. But we'll 

have to go through all of the comments and then the recommendation will have to be made up 

through our chain of command and people have to be convinced and our Bureau of Economics 

weighs in. How long do you think it takes? Several months? 

ROBERT FRISBY: It depends. 
FRANK GORMAN: Yeah. Sorry. 

MIR QUDDUS: OK. Got the answer. 

FRANK GORMAN: I'm trying to be-- I'm trying to be as detailed and honest as I can but there 

are so many moving parts. 

MIR QUDDUS: So would you need any more-- let's say, for the case that we are making, would 

you need more information, that would be a different communication going forward or is it--

FRANK GORMAN: Well, I mean, I think-- I don't have a checklist in front of me but there are a 

lot of really interesting points made throughout the course of a day and people have had different 

perspectives going back to just this sort of should dry cleaning be-- wet cleaning be permitted 

instruction or required instruction? 

There are some data on cost, there are some consumer perception data which was very helpful 

which was submitted. There may be some other consumer perception testing that could be done 

on how to change the dry clean instruction on the tag so that people understand it to comport 

what the rule actually-- what it's meant to mean as opposed to how people understand it to mean. 

There's all sorts of evidence that we identified-- types of useful evidence that we identified in our 

previous notice and then there are the things that have come up in the discussion today and in the 

new evidence that was submitted earlier today that could be fleshed out. So you need to decide 

with your organizations and the issues that are important to you and your position on that issue, 

how can I make the best record to support this? 

We don't have a lot of discretion. There has to be evidence showing that-- especially where we're 

imposing-- if we're going to impose new burdens, there has to be evidence showing that it's 

justified, that we're curing a deceptive or unfair practice that is prevalent and that the costs don't 

outweigh the benefits. Essentially. That's not a very nuanced description but that's the gist of it. 

So if you have-- anecdotal evidence is nice but it's sort of saying, this is our position because it'd 

be good for our group is informative, but data is best. 

STACY SOPCICH: I have question peaking back on Richard's question. Because it's 

understandable why the FTC would not want to change policy. That's certainly a much bigger 

issue then the purview of this panel. But in the specific case of the care labeling rule, where it's 

now clear that both the ISO and the ASTM are proposing to recognize alternative solvents in the 

way that they write their standards, and their definitions, and the test methods that support them, 

where is that in the consideration of the FTC? 

I mean, I spoke earlier about the idea of keeping the rule making record open long enough to 

allow it to not point to a rule that can't de facto not support the-- if the rule is being modernized 

to say any solvent other than water, but the standards that it points to only recognize perc and 

petroleum, the whole effort that we've been through in the process to modernize the rule seems to 

be moot. 
FRANK GORMAN: Does anyone know when those revised standards are due to come out? Or 

is that also difficult to predict. 

STACY SOPCICH: Well, I mean, it'll depend on vote. I mean, Jen, you could speak to that. 

AUDIENCE: [INAUDIBLE] 30 days or 60 days, or if it takes longer than that if we have to reballot it. But it's out to ballot right now. 

NORA NEALIS: It could be six months or a year. 

ROBERT FRISBY: I mean, the Commission may well decide that it's prudent to wait for those 

developments and to look at those standards before the next step. And the Commission might 

decide that this rule should be reviewed more frequently than it has been. Those aren't decisions 

that we would--

STACY SOPCICH: They're choices you make. 

ROBERT FRISBY: --not necessarily make. 

FRANK GORMAN: Well, that's-- it's actually an-- Robert raised an interesting question, and 

maybe as a show of hands, do people think that this rule should-- normally, a regulatory review 

program is-- and this isn't required by law, this is something the Commission has undertaken to 

do across its rules-- is we review rules every 10 years-- sort of like I take a bath every Saturday 

whether I need it or not. Should it be done more frequently for this rule? Show of hands. OK. 

AUDIENCE: I have another proposal. How about if any significant changes have taken place--

FRANK GORMAN: Wait for the microphone, please. 

AUDIENCE: I personally think time is not the focus it should be of any significant new 

technology or new processes or new demands come up. Because it could be a year and a half. 

You might have to wait 5 years if we could pick it, or 10 years. And then you're playing another 

catch up. 

FRANK GORMAN: Well, we do have discretion to review more frequently. And certainly also, 

and this happens a lot in other rules-- I work on the appliance labeling rule, for example, where 

there's constant mini reviews underway and a lot of it's because the Department of Energy 

changes a standard or new technology comes out or we get a petition. Industry members can 

petition for specific changes. There's a provision for that as well. Yes? 

CHARLES RIGGS: It was very beneficial many years ago when FTC actually had a FTC 

employee involved in attending ISO meetings, ASTM meetings, AATCC meetings. That kind of 

involvement from FTC would keep you abreast of what kinds of changes are occurring in the 

industry. Now, I might also come in on Stacy's question, when it comes down to looking at 

revising a test method to incorporate another solvent, that's an expensive process. 
To come up with a test method, you have to inter-laboratory correlations using some standard 

fabrics, standard garments. We were fortunate in terms of ISO 3175 Part 4, the wet cleaning, that 

there were some funding in Europe for a AquaCarb project. We had some funding from EPA in a 

design for the environment project that allowed us to get involved in doing that. 

But it's a very expensive process to look at a test method and determine if we add this solvent or 

what other material we might add, what are the testing parameters to generate inter-laboratory 

correlations that are reproducible. We need to have reproducible test results so we know what 

we're talking about in terms of how you test it. 

Now, the anecdotal test of having a wet cleaner clean it is not really going to meet the test of 

inter-laboratory correlations. You have to get the same results in every wet cleaner throughout 

the country. So you need to test according to a standard test method, 3175, and those are 

expensive to finance. I think, and unfortunately, it'd have to come down to the solvent vendor to 

do a lot of the financing to get the test methods modified. 

FRANK GORMAN: Going to the first thing you said about an FTC staff person attending these 

meetings, I think if we were the care labeling, textiles, wool, leather, fur is a small part of what 

the Commission does. What the Bureau of Consumer, which is only half of the mission of the 

Commission-- we also have an antitrust half-- does, we have about 1,000 employees and we have 

general jurisdiction over basically all commerce. We do a lot of anti-fraud work, we do a lot of 

financial sector work, we do advertising stuff. And we do these rules and we take them very 

seriously.

Realistically, I think we've broadened certain parts of our portfolio. We did used to have a 

division of privacy and information protection, which is obviously a very important issue right 

now which wasn't an issue 20 years ago. But we simply, probably don't have the resources to 

dedicates something to that. 

CHARLES RIGGS: Same token. If you're going to promulgate a rule on care labels, you ought 

to have staff involvement in the process where AATCC, ASTM, ISO review those care label 

seekers. 

FRANK GORMAN: We rely on the notice and comment for that. And your wise counsel. Thank 

you. Other? 

AUGUSTINE CHANG: If I make a comment on Dr. Riggs' comment about standard and doing a 

testing. Like I said earlier, the dry cleaners and professional wet cleaners are actually on the front 

line to clean this garments on a regular basis. In a lab, everything is perfect for the testing. But in 

real world, things are not the same. For example, Arizona, summertime, 120 degrees. Your 

machine really heats up. So does your solvent. 

Of course, there's a refrigeration system to cool it down. But solvent is still too hot to clean. So 

these are little simple examples. So in test lab, it's great. But in real world, it's not. So a lot has to 

do with the operator, how well they are trained, do they really understand the system. So with 

that in mind, thank you. 
FRANK GORMAN: Yes? 

NORA NEALIS: Just one other point with regard to how often it should be looked at. I think, for 

many years, not looking at it was a non-issue because the industry was relatively static, the 

technology was static. But in recent years there has been a lot of change and I would anticipate 

that in the coming years there will continue to be a lot of change. So-- and one of the unhappy 

things about change is that if you don't react quickly enough to it, by the time you get around to 

it, the problem has already either solved itself or become unsolvable. So I think we need to, or 

you guys need to, keep a close eye on this because it's-- once you declare it done, it's still not 

going to be done. At least not as a reflection of the real world. 

FRANK GORMAN: Thank you. And that is something that we had noted amongst ourselves 

before which is, there has been, after a long period of not a lot of change, a lot of change. So we 

get a little behind the curve. And thank you all for helping us catch up. I think I have time for 

one or two more comments before closing remarks. And I see a hand up over here. 

AUDIENCE: In regard to the earlier discussion about the reasonable testing, I know Kim 

mentioned that her company does not test a full garment. And I really-- we do testing for 

multiple retailers of brands, both people who are just selling in US and also internationally, as 

two of my other colleagues here. And that really is the minority. 

We find that the vast majority of our clients do test at a fabric stage and at least one garment 

stage. We do have some that do a preproduction and also production testing. But the most 

common test process would be to do at a fabric stage and a full garment stage to look at the 

components, the seams, the fabric, all together. 

FRANK GORMAN: One more? No? Well, Robert. Have any closing remarks? 

ROBERT FRISBY: I think that concludes our roundtable. We want to thank everyone for 

coming and for sharing their expertise with us and their viewpoints. I want to remind everyone 

that the record-- I think we mentioned this a few times-- the record is open until April 11 and we 

welcome additional comments about the issues that were discussed at the roundtable or other 

issues of concern to you all. And we do plan to post the presentations from Peter and Charles on 

our web page. I'm not sure when that will happen but it will happen soon if anyone wants to get 

that electronically. And I think that's it. 

FRANK GORMAN: Yeah. Thank you. 

ROBERT FRISBY: Thank you all.