OSHA Requirements for Dry Cleaners

We recently did some research into hazards related to the Dry cleaning industry and wanted to share our summary findings in this blog post and hope that you find the information helpful.

Below is a list of common OSHA standards that may be triggered at a dry cleaning facility, depending upon the equipment and work activities.

We have included notes to help clarify each issue.


Potential OSHA Standards	Notes
Air Monitoring	Depending on the High Flash solvent in use, there may be PEL limits. Research shows there is potential exposure during Exposures occur during loading/unloading machines and pressing activities
Respirator program	Depending on sampling results. Includes written program, selection, training and fit testing. Does not include medical survelliance
PPE Assessments	Depending on the tasks. There are various high risks, especially to solvent exposures identified in the industry
Ergonomics	Identified issue in the industry. Assessments and report on various high risk ergonomic tasks
Hazard Communication	All dry cleaners use chemicals, so Hazcom is always applicable. Need written procedures, labeling system and employee training
Bloodborne Pathogen	Depending on if they knowing handle blood or OPIM contaminated clothing, or need process for identifying and handling the same
LOTO program and training	Program development and training
LOTO Procedures	Per piece of equipment that requires a LOTO procedure. Estimate is based on 12 pieces of equipment. Not just washers/dryers but other equipment that may fall under the standard
Fire prevention/Fire ext	With high flash solvents, may be needed. Written program and training
Emergency Action Plan	Written plans and training
Forklift	Only if applicable
Loading docks/pallet jacks	Only if applicable
Hoists/mechanical handling	Only if applicable
Machine guarding/Tool use	Related to any mechanical handling such as bagging, hanging, pressing, repairs/alterations, etc

Other notes and findings:

For facilities that use High Flash solvents, OSHA does have Permissible Exposure Limits (PELs). Studies showed that exposures mainly occur during load/unloading machines. Air sampling would be needed depending on the chemicals they are using. If overexposed, then Respiratory would kick in.

Bloodborne Pathogens program may be needed if they clean clothing that could have blood or Other Potentially Infectious Materials (OPIM). This would be focused on hospitals, medical or dental clinics, police or EMS services. If so, a Bloodborne Pathogen program would be required. There are two LOI’s related to this topic for dry cleaners.

Ergonomics is another issue that was discussed in the research, especially during loading and unloading of machines in large facilities.

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By Russell Carr|2020-06-16T18:57:55-05:00March 18th, 2018|OSHA Texas Laws & Regulations, Safety Training, Texas OSHA Compliance|Comments Off

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About the Author: Russell Carr

How A Sales Guy Transformed Into An Environmental, Health & Safety Expert & Advocate For Small Businesses

I've spent my entire 30+ year career working within the manufacturing and “industrial services” sectors.

The first 15 years of my career focused on sales of hazardous materials related products and services to the manufacturing sector, then for the last 16+ years transitioned into entrepreneurship, founding 3 small industrial services related contracting businesses. As you’ll see below, running these companies eventually lead me to found yet a 4th business, but more on that in a minute….

Here’s a brief description of the first 3 companies:

Berg Environmental Services, Inc.: hazardous waste disposal & transportation services, founded in August of 2003 3rd party wind energy operations & maintenance services provider to utility scale wind farms throughout the US, founded in September 2007 3rd party oil & gas exploration & production services provider, founded in August of 2011

Each of these companies operated in extremely dangerous working conditions and exposed my employees to a wide range of serious health & safety hazards on a daily basis.

To complicate matters, 2 of the companies also exposed the environment to significant potential harm.

In other words, I learned very early the critical importance of managing environmental, health and safety issues so as to ensure the safety of our employees and the environment, as well as minimizing related risks.

But I also learned how incredibly difficult and challenging this endeavor can be due to the wide range of complicated and continually changing environmental, health and safety rules and regulations that impacted the companies.

To summarize the challenges: First I had to determine which regulations applied to each company, then I had to build compliance programs to meet those regulations, and finally I had to ensure that the programs were being managed and followed by our staff on a daily basis.

All while trying to run and grow 3 profitable businesses….

It was overwhelming and I always struggled to keep up.

To make matters worse, throughout this time I also witnessed the devastating price that companies, management and ownership can pay for failing to manage EHS compliance.

This included seeing one of my hazardous waste management clients get sent to jail over environmental issues, another client’s management team threatened with jail time, a direct competitor get fined $378,000 by OSHA fine after an employee was nearly killed, and many others face major fines and penalties.

Full disclosure, one of my companies got fined by OSHA at one point, & another was cited by TCEQ, so I know how it feels.

In summary, I learned first hand how incredibly difficult it is for small companies to manage EHS compliance due to a common lack of the critical expertise, time and resources that are needed to keep up, and how this situation then ends up exposing them to these potentially catastrophic risks that can literally destroy lives and businesses.

This later inspired me to found my 4th company, Berg Compliance Solutions in 2012, which is dedicated to helping other small businesses, and business owners, to manage EHS compliance and risk.

Education

BA, Philosophy, University of Colorado, Boulder, December, 1990.

Summary of Professional Experience & Qualifications:

30+ years serving the manufacturing & industrial services sectors
30+ years of sales and marketing experience
16+ years as small business owner & entrepreneur: Founded and operated 4 small businesses since 2003.

Environmental, Health & Safety Compliance & Program Related:

19 plus years of hazardous waste management including EPA, TCEQ & RCRA regulations
8 years of DOT/FMCSA compliance experience, including hazardous materials transportation
8 years of combined experience implementing and managing OSHA health and safety compliance programs for 2 high risk energy services businesses
Successfully implemented and gained ISO 9001 Quality Management
Certification and OHSAS 18001 (Occupational Health & Safety Advisory Service) Certification for wind energy maintenance business.

Regulatory Enforcement Related Experience:

Served as expert witness in criminal environmental compliance enforcement cases
Superfund-CERCLA
OSHA enforcement inspections, investigations and resolution in following industries: industrial services, manufacturing & construction.
TCEQ enforcement inspections, investigations and resolution in manufacturing.

OSHA Requirements for Dry Cleaners