Strategic Options Report

3.1 Development of PERC consumption reduction target

3.2 Chronology of Issue Table discussions on selecting the management options

• Table 4: Summary matrix of management options and initial qualitative ranking

3.3 Economic analysis

3.3.1 Methodology

3.3.2 Levy/subsidy option

3.3.3 Technology regulations and mandatory training combined with a levy

3.3.4 Staged quotas on PERC imports

3.3.5 Technology regulations and mandatory operator training

3.3.6 Summary

• Table 5: Comparison of present value costs (x$1,000) and benefits³ of four management options⁴ over a ten-year horizon
• Table 6: Cost-effectiveness of management options over a ten-year period

3.4 Development of elements for the technology regulations and operator training

3.1 Development of PERC consumption reduction target

At the meeting in June, 1995, the Issue Table selected the target reductions for PERC use, based on a strategy that took into account the reductions possible from the replacement of old, inefficient machines and the improved solvent mileage attainable from good equipment operation and maintenance. A sector average solvent mileage of 20kg of PERC per 1,000kg of clothes cleaned was thought technically achievable if operators adhered to the CCME Code of Practice for Dry Cleaning Facilities and the equipment was 3^rd generation or newer (see Section 4).

With the assumption of approximately 85,000t of clothes cleaned annually by PERC, a target consumption of approximately 1,600t of PERC was determined. This represents a decrease in annual PERC use of approximately 71% from the estimated 5,500t used in 1994.

This target falls within the range of the reductions suggested in a preliminary scientific assessment by Environment Canada that environmental impacts from PERC emissions could be eliminated if they were reduced by 60% to 90%, based on current releases.

The target of 1,600t was opposed by the representatives from the non-government organizations (NGOs) who felt that target should be much lower to force substitution of PERC by alternative technologies, notably wet cleaning.

3.2 Chronology of Issue Table discussions on selecting the management options

Environment Canada identified a number of possible management options which were first discussed at the Issue Table teleconference in February, 1995. The list of options and initial qualitative ranking of their key attributes are shown in Table 4. The ranking descriptors of "high", "medium" and "low" refer to optimal solutions from Environment Canada's perspective, ie. highly environmentally effective, highly cost effective, etc. With respect to the legal implications, the "high" descriptor was assigned when the option was originally thought to be feasible.

At the multistakeholder teleconference in February, voluntary and mandatory release-based standards were eliminated from further consideration. Both options were viewed as impractical. Voluntary measures are prone to avoidance, particularly by small businesses. Release-based standards were thought to be too complex technically and too difficult to enforce at over 3,000 facilities across Canada from an administrative aspect. It was noted that the US EPA did not adopt release-based standards.

Quotas, taxes, and charges, if these were imposed on dry cleaners, were also ruled out on the basis of a general consensus among industry that such mechanisms would be too complex to administer.

Table 4: Summary matrix of management options and initial qualitative ranking

As a result, the initial screening of options produces three groupings of options that reflected the interests of most members of the Issue Table:

1. Technology regulations and mandatory training;
2. Staged declining quotas on PERC imports; and
3. A levy on PERC sold for dry cleaning use.

The levy as first proposed would recover the costs for waste disposal and operator training, and provide a 20% rebate for new capital equipment purchases. The waste disposal component was suggested by a representative of a PERC waste recycling firm. The capital rebate stemmed from a suggestion by The Korean Dry Cleaners Association that government provide financial assistance in the form of grants or interest free loans to help businesses with old machines to invest in new technology.

The quota concept, after ruling out its application to dry cleaners, was discussed in terms of an import quota that could be applied either to all PERC imports or only to the portion of PERC imported for dry cleaning use.

The import quota option was consistently opposed by the industry representatives for a number of reasons. The possibility that PERC users other than dry cleaners may hoard the available supply, PERC suppliers denying access to dry cleaners, the perception that use controls are a violation of free market principles, concerns about possible smuggling and the creation of a black market, and the perception that this option would not raise the environmental consciousness of dry cleaners, were raised as arguments against import quotas. The three option groupings were selected for quantitative economic analyses, the results of which were presented at the meeting in June, 1995 and are presented in Section 3.3.

Also the legal integrity of quotas was questioned by the Halogenated Solvents Industry Alliance (HSIA) who represents the four major foreign producers, for the reasons that quotas are contrary to the rules of NAFTA and the WTO Agreement (including the General Agreement on Tariffs and Trade - GATT, and the Agreement on Technical Barriers to Trade - TBT) and that Canadian import quotas may lead to possible anti-trust action in the USA against American producers of PERC.

Although the import quota option was opposed from the outset, Environment Canada retained this option for economic analysis due to its administrative simplicity, its ability to directly restrict solvent use, and for its capacity to force the adoption of alternative technology. At the same time, Environment Canada indicated that legal advice would be sought in respect of the concerns submitted by the HSIA.

The discussions at the June meeting concluded with a majority consensus to build recommend-ations around a merger of two of the original options, the mandatory technology/training option and the levy/subsidy, but with alterations to the levy/subsidy. The subsidy component associated with the rebate on new equipment purchases was opposed by the members of the Canadian Fabricare Association (CFA) who felt that such an incentive was unfair to cleaners who had already invested in modern machines. The levy was subsequently modified by deleting the rebate for new equipment purchases and having the levy offset the costs for waste disposal, operator training and compliance monitoring (ie. annual facility inspections).

A position paper submitted in August, 1995 by the CFA with the support of member provincial associations generally endorsed the suggested June recommendations of combining mandatory technology and training with a cost recovery levy. However, modifications were again suggested to the levy/subsidy whereby a Canadian Fabricare Education Foundation would be funded through the levy on PERC imposed by government. Funds would be collected by government and transferred to the Foundation which would be administered by a board having representation from government. The funds would be applied to set up the Foundation's infrastructure for administering operator training, business counselling, promoting research and development, and compliance monitoring (ie. annual facility inspections). The levy would decline over time as the Foundation became financially self-sustaining from the fees collected for training and inspection services.

The CFA proposal excluded the subsidy for waste management because, after consultation with members following the June 1995 meeting, the majority of the Association members viewed the waste management subsidy as inequitable to dry cleaning businesses who treat their wastes on-site and do not generate hazardous wastes that require disposal.

In its proposal, the CFA suggested that facility operating licences provide the basis for the facility inspections. Since facility operating licences are within provincial and territorial government mandates, Environment Canada suggested that the resulting framework, having a federally-mandated levy/subsidy applied in a provincial licencing context, would be unworkable.

In response to the CFA proposal, Environment Canada modified the levy component of Option B stemming from the June, 1995 Issue Table meeting. The waste collection and disposal subsidy was removed as a recoverable cost through the levy and was transferred to a directly mandated requirement on PERC sellers, fully recognizing that a number of practical and legal issues would have to be addressed. The resulting changes which are reflected in the final recommendations adopted in this report, are summarized as follows:

1. The responsibility for waste collection and management is placed on sellers of PERC to dry cleaners, and
2. The levy would be based on recovering the costs for training, compliance monitoring, inspections, enforcement, and administration.

Due to concerns about legal liability arising from transferring responsibility for inspections to the private sector, Environment Canada suggested a role for the CFA and member associations in the areas of training, and possibly some aspects of compliance monitoring. These private sector roles would be financed from funds derived from the levy, through an appropriate agreement mechanism between Environment Canada and the CFA. This compromise on the levy concept was accepted by the CFA at the November, 1995 meeting of the Issue Table. Industry participants further suggested that the levy be applied to PERC distributors.

Following the June, 1995 meeting, the CFA continued to express opposition to the proposal on transferring the responsibility for waste disposal from dry cleaners to PERC distributors, preferring instead, a recommendation to abolish small quantity waste generator exemptions entirely, and to strengthen enforcement of existing provincial legislation. In addition, concern was expressed over the potential monopoly that may arise among PERC distributors with possible unfair pricing for waste collection services. At the November meeting the proposal to mandate waste collection on solvent distributors was retained by Environment Canada on the grounds that such a measure would directly address the prevention of site contamination through improved controls on waste collection. At the same time, such a measure would introduce a life cycle management responsibility on distributors and maximize the used PERC for recycling. This recommendation was supported by both distributors of PERC and PERC waste recycling firms, as well as Health Canada.

At the November, 1995 meeting the NGO representatives from CEN/STOP registered dissent to the recommended management option based on the command-and-control technology strategy. The NGO representatives supported the import quota on the grounds that this option would be able to achieve or exceed the environmental target with certainty, as well as force alternative technology. The NGO representatives also stated that verbal comments received from the Canadian Environmental Law Association suggested that any challenge to domestic import quotas by a member NAFTA state, if based on domestic environmental goals, is unlikely to succeed.

Subsequent to the November meeting, legal advice was received at Environment Canada from the Department of Foreign Affairs and International Trade with respect to the application of domestic quotas on PERC. The advice indicated that the rules of the NAFTA and the GATT appear to provide a basis for member states to the agreements to challenge domestic import quotas while domestic levies imposed on PERC for dry cleaning use or for all PERC used in Canada would not appear to contravene any rules of the NAFTA, the GATT, nor the TBT.

After the November, 1995 meeting, the Korean Dry Cleaners Association stated its opposition to the proposed technology control strategy for reasons similar to those of CEN/STOP. The Association also opposed the levy and quota options on the basis that these mechanisms would not raise awareness about the toxicity of PERC. The Association, however, supported mandatory training and certification and stated interest in taking a role in delivering these courses.

3.3 Economic analysis

3.3.1 Methodology

An economic analysis was undertaken for each option that included a determination of costs and benefits to derive a net benefit value. Net benefit refers to the monetary valuation of environmental benefits minus the costs to dry cleaners and government of implementing the particular option. A full explanation of the assumptions and background to the economic analysis is contained in the supporting document, "Economic Impact Analysis of Regulatory Options to the Dry Cleaning Sector".

The environmental benefits are related to the avoidance of environmental damages to terrestrial plants and ground water generated by current discharges of PERC to the environment, as identified in the 1993 PSL Assessment Report on Tetrachloroethylene. The benefits¹ were valued through a survey asking Canadian households how much more they would be willing to pay on their annual dry cleaning bills in order to eliminate the environmental damages identified in the 1993 PSL Assessment Report on Tetrachloroethylene. The survey results indicate that, on average, Canadian households would be willing to pay up to 7.7% ($8.42) more on their average annual household expenditure of $103 dollars for garment cleaning.

The economic model determined the costs to dry cleaners under each of the four options, based on the assumptions of constant prices and demand for dry cleaning services. In order to assess distributional effects within the industry, four facility types were defined according to annual revenues, namely large facilities (< $400,000), medium facilities ($200,000 - $400,000), small, high- revenue facilities ($100,000 - $200,000), and small, low-revenue facilities (< $100,000). The model simulated choices for cleaners to chose among eight possible technology combinations². Dry cleaners are assumed to choose the least cost technology combination for each of the options modelled.

The costs to government were based on actual practice either in other countries or in Canada for the mandatory technology and import quota options, while the levy options assumed administrative costs as 10% of the total levy revenues. Administrative costs are assumed to be recovered within the levy, making the levy options revenue-neutral to government.

The following sections describe the modelling parameters and results of the four options modelled, presented in decreasing order of net benefits.

¹ A second benefit valuation was based on the historical financial costs incurred by municipal water supply systems due to ground water contamination from chlorinated solvents (PERC, TCE). The benefits of avoiding these costs in the future are approximately $114 million in capital costs, and $2 million in annual operating costs.

² The technology choices are 1) current PERC machines, current operating practice, 2) current PERC machines, best operating practice, 3) new PERC machines, current operating practice, 4) new PERC machines, best operating practice, 5) 20% wet cleaning, plus best operating practice PERC use 6) 45% wet cleaning, plus best operating practice PERC use 7) 70% wet cleaning, plus best operating practice PERC use 8) hydrocarbon technology (large facilities only).

3.3.2 Levy/subsidy option

In this option, a levy would be imposed on a unit volume of PERC sold for dry cleaning use, so that the revenue collected would subsidize the costs for operator training and waste disposal, and rebate 20% of new equipment purchases. In the model it is assumed that the levy would be imposed in the third year after promulgation of the regulation.

The model results showed that a levy of $2.06 per kilogram generates a price increase on solvent purchased by cleaners from the current $2.05 to $4.11. PERC consumption is projected to be reduced 56% to about 2,400t annually as increased solvent costs encourage the adoption of best operating practices by dry cleaners. However, the levy/subsidy option does not result in substantial machine replacement, and does not achieve the environmental target of 1,600t annual PERC use.

The levy/subsidy option generates the highest net-benefits of all options because costs are lower in relation to the other options. This occurs as cost increases generated by increasing PERC prices are balanced by subsidies that reduce costs - with the major portion of the subsidy being for waste disposal.

3.3.3 Technology regulations and mandatory training combined with a levy

This option is similar to the general consensus recommendations that are summarized in the Executive Summary and in Section 7. PERC use is projected to decrease to 1,400t annually.

In this option, the levy on PERC sold for dry cleaning use is set to cover the costs for operator training, waste disposal, compliance monitoring (ie. annual facility inspections), and administration. The levy component is modelled with the assumptions that first generation dry cleaning machines are banned in year three, mandatory training of the owner or operator of the machine at all facilities is completed in year three, and second generation machines are banned in year five.

This option generates both the highest costs, and the highest benefits of the four options modelled. It generates the highest costs as dry cleaners must pay for both new machinery, and increased prices for PERC ($2.05 to $6.70). These twin effects stimulate both the adoption of modern PERC machines and best operating practices, thereby generating substantial and rapid reductions (72-73%) in PERC use.

The economic model predicts some market penetration by alternate technologies resulting in a somewhat lower PERC consumption of 1,400t rather than 1,600t as determined by technical projections.

3.3.4 Staged quotas on PERC imports

This option would cap the quantity of PERC imported for domestic use in the dry cleaning sector.The quota was modelled with reductions occurring in four stages: 24, 50, 65, and 77% in years three, five, seven, and nine respectively. A 77% reduction corresponds to a PERC use of 1,200t. The main factor which decreases PERC use in this option is the price increases which occur as the supply of PERC diminishes. This option has the second lowest cost of all options modelled.

In this option, large increases in price are needed to reduce consumption below 50% of current consumption, at which point a considerable shift to alternative technologies takes place. A slight market penetration by wet cleaning is seen at 65 % PERC use reduction. This occurs primarily in large facilities which move to mixed mode operations using both PERC and wet cleaning. The higher labour costs associated with wet cleaning appears to be the main factor which limits any further market penetration of wet cleaning technology.

At 77% PERC reduction, equivalent to 1,200t annual consumption, the model predicts a price increase from $2.05 to $9.60, and substantial market penetration by hydrocarbon solvent technology. The latter entirely displaces PERC technology in large dry cleaning facilities.

3.3.5 Technology regulations and mandatory operator training

The economic analysis was modelled with the assumptions that transfer machines are banned in year one, mandatory training of all cleaners is completed in year three, and fourth generation technology becomes mandatory in year five. PERC use is projected to decrease to 2,800t.

In this option, costs are higher relative to the PERC reductions achieved, particularly the costs to government. This option achieves the lowest PERC reductions (49%) of all options modelled as dry cleaners are forced to purchase the most technically advanced PERC dry cleaning technology, but continue with current, rather than best, operating practices. The modelling indicates that alternate technologies achieve no market penetration.

The model indicates that cleaners will probably not adopt best operating practices, and as a result solvent wastage will continue. For this reason PERC use is projected to be 2,800t rather than 1,600t as determined by technical projections based on adherence to best operating practices.

3.3.6 Summary

When the results of the economic modelling are placed in a ten year time horizon, the analysis indicates that benefits exceed costs for all of the four options, as is shown in Table 5. The initial target reductions of the quota (24%, 50%) were modelled to correspond to the results generated by the mandatory technology option. The higher reductions (65%, 77%) were used to demonstrate that this option can exceed the technology based target, and thereby generate market penetration by alternative technologies.

Another approach to ranking the options is in terms of cost-effectiveness. A cost-effectiveness indicator can be calculated as the total present value cost divided by the maximum PERC use reductions achieved over a ten year time period in relation to the reference consumption of 5,500t in 1994. This alternative ranking is shown in Table 6. The ranking order is similar to the order generated by the "net benefits" measure except that the import quota becomes the second ranking option compared to the combined mandatory technology and levy option which ranks third. This change in ranking occurs as substantial PERC use reductions occur more rapidly with the combined option (year 3, 72%) as compared to the import quota (year 9, 77%).

Service prices to consumers are expected to increase nominally under all options due to the relatively low increases in garment cleaning cost generated by the model. The highest industry-wide cost increase was 3% for both the quota and the combined technology regulations/levy options. These cost increases to cleaners will increase consumer prices less than 3%. Since this increase is below the 7.7% increase in price that consumers indicated they would be prepared to pay according the survey by Environment Canada, the demand for dry cleaning services should not change. The comparatively low price increase, in spite of major new capital investment in the sector, stems from the cost structure of dry cleaning where the costs associated with equipment investment, solvent, electricity, and waste disposal are a small portion of the total costs. Labour and location are the major costs.

The most significant distributional effects within industry occur with the two options that incorporate technology because the costs are borne disproportionately by small, low-revenue dry cleaners with old equipment. With current industry-average profits in the range from 2% to 17%, the profit for small facilities are projected to decline to within to a range of 8 to - 6%. These represent about 30 % (about 1,000) of all dry cleaners in number, cleaning approximately 11% of all clothes. Many of the small businesses may exit the market as cleaning is consolidated in large, more efficient facilities.

³ Present value cost and benefits are valued at an interest rate of 10% over a ten-year period. Benefits associated with the different PERC use reductions modelled for the four options are assumed to decline linearly corresponding to a 90% PERC use reduction. It is assumed that a 90% reduction eliminates all environmental damages due to releases of PERC.

⁴ All options correspond to the options described in Sections 3.3.2 to 3.3.5 For Example, the import quota corresponds to PERC use reduction of 24, 50, 65 and 77% in years 3, 5, 7 and 9 in the model.

⁵ Present value cost were calculated using a 10% interest rate over a ten year period.

As medium and large facilities expand their markets, employment is expected to shift accordingly, but should remain reasonably stable overall as the demand for garment cleaning remains stable under nominal service price increases.

3.4 Development of elements for the technology regulations and operator training

Following the discussions on conceptual approaches to the environmental management options, the members of the Issue Table developed specific details on the following elements which could be considered for mandatory government intervention:

• new and existing PERC dry cleaning machines;

• operator training;

• compliance monitoring;

• spill prevention; and

• tracking of PERC use reductions.

An evaluation of the effect of eliminating old machines from service showed that significant reductions in PERC consumption and environmental releases are possible. The elimination of 1,298 first generation machines was thought reasonable given the age of the equipment and the high cost of converting these to achieve the performance of current generation technology.

Of the 1,218 second generation machines, it was estimated that some 25% could be retro-fitted economically to third generation performance, while the remainder would be replaced.

The replacement of some 2,200 first and second generation machines and the retrofitting of about 300 second generation machines should be able to reduce PERC consumption to 3,224t annually. Industry suggested that an eighteen-month lead time be provided between the date of promulgation of the regulations and effective date of equipment bans to allow sufficient time for the one Canadian manufacturer and foreign equipment suppliers to gear up for an accelerated market demand.

In order to simplify the regulatory framework and minimize the compliance monitoring burden to industry and government, the concept of banning from service all first generation machines and mandating the upgrading of second generation machines appears to be a reasonable approach, broadly supported by the industry. Industry members emphasized that technology regulations be kept simple to avoid the complex and numerous checks and measurements prescribed in regulations of some jurisdictions. The feasibility of enforcing machine replacement by mandating sellers of PERC to sell only to facilities with the prescribed technology could be considered.

The regulatory framework should also prescribe a date after which newly installed PERC dry cleaning machines should be capable of achieving a design solvent mileage rating. The solvent mileage of 10kg of PERC per 1,000kg of clothes cleaned, or better was selected since this performance can currently be achieved by the one Canadian manufacturer, as well as several foreign manufacturers. The concept of having manufacturers guarantee equipment performance and display a label showing this performance was also introduced as a means of ensuring that only latest technology machines are introduced into the market.

The final incremental reduction to 1,612t of PERC consumption will require implementation of best operating and equipment maintenance practices, as set out in the CCME Environmental Code of Practice for the Reduction of Solvent Emissions from Dry Cleaning Facilities. A sectoral average solvent mileage of 20kg PERC per 1,000kg of clothes cleaned is considered achievable in practice.

Legal advice received at Environment Canada indicated that the CEPA could mandate the intended objective of banning older equipment, recognizing that appropriate legal wording will be required in the CEPA regulations.

Dry cleaner training was considered essential to ensure cleaners adhere to the Code of Practice although there is justifiable uncertainty that best operating practices may not be attained uniformly throughout the industry if training is implemented on a voluntary basis. Consequently, industry suggested that training be mandated in all regions since only the Province of Ontario has such a requirement at the present time although the province of Québec is considering this in its future regulations.

Training can be mandated under CEPA or by provincial jurisdictions who have a broader training mandate. The prevailing view of the Issue Table members was that training should become a national requirement. Those jurisdictions that have, or plan to have mandatory training, could be exempted through equivalency provisions of CEPA. This would avoid duplication amongst the various levels of government. The Canadian Fabricare Association (CFA) has prepared a report, listed in the Supporting Documents, that outlines the essential elements of a training program in a private sector context. It is similar in approach to that taken by Ontario.

The concept envisaged would be to mandate training (two-day course) and certify the facility owner/manager as well as one other person working at a facility, and retraining (one-day course) and recertifying these persons every three years.

Training materials developed by Environment Canada during the development of the Code of Practice would provide the core material. Other topics thought to be relevant by the industry, such as garment finishing or business counselling could be added as felt appropriate. Training requirements on safety, health and fire prevention while using, handling and storing PERC are mandated under provincial/territorial workplace regulations, the Canada Labour Code and other non-CEPA regulations.

Industry also suggested that facilities be inspected annually and receive operating licences to operate, as mentioned in the proposal of the CFA. The inspections would include a checklist of the requirements specified in regulations and proof of certified trained staff. A licence would be issued on the basis of these qualifications being met. Legal advice received at Environment Canada suggests that operating licences are beyond the scope of CEPA and are appropriately mandated by provinces who historically have had such systems in place.

Industry supported a requirement for facilities to contain leaks and spills of PERC and other chemicals. A pan placed under existing machines is feasible while for installations at new facilities the concrete floor should be coated with a suitable sealant and an impermeable berm placed around the machines. Containers for PERC and wastes should be stored in areas bounded by suitable floor curbs to contain spills. As an added spill prevention measure, floor drains should be sealed or curbed to block chemical spills until the spills are cleaned up.

New designs of solvent delivery containers which connect directly to the client’s storage containers are currently being used in the USA by some solvent suppliers. A measure to mandate these systems was supported by the participants as direct-coupled systems minimize solvent spills during transfer operations.

The ability to monitor annual reductions in PERC consumption is important. Reporting options were discussed in the context of tracking consumption through records of purchases by each facility, from records of sales by distributors, from records of imports of the four major importers, or through mandatory reporting by distributors or importers triggered by provisions of CEPA.

The Halogenated Solvents Industry Alliance (HSIA) made a commitment to provide, on a voluntary basis annual reports on PERC imports and use-pattern to be submitted by March 31 for the preceding calendar year. This approach appeared to be most effective with the least administrative burden to all parties. The report will be submitted to the Chair of the Issue Table beginning with calendar year 1994 and continue until such time as a program lead at Environment Canada is identified. Should PERC be imported by non-HSIA members in the future, these companies will be requested to submit similar data to Environment Canada. In order to track recycled PERC sales, the representatives for the waste management/recycling firms on the Issue Table also agreed to provide their solvent sales records. Other waste management firms that were not represented at the Issue Table will have to be contacted in this regard. Together, these two reporting sectors will enable tracking of total annual PERC use.

Record keeping of the quantities of clothes cleaned and solvent purchased by each facility was suggested by some members as a means of tracking compliance with solvent mileage. This was thought to be unenforceable if prescribed in regulations because records could be easily adjusted and made to appear to meet a mandatory solvent mileage standard.

The use of ozone-depleting substances, either as a cleaning solvent or refrigerant, should be prohibited in new or upgraded machines. Provisions in regulations of some provincial jurisdictions already prohibit these substances in these applications.

In related discussions on the issue of sites contaminated with PERC from historical environmental releases, the members recognized that problems of varying magnitude exist around the country. It was suggested that research and development into methods for cleaning up contaminated ground water and soils be encouraged through available technology development support programs of the federal and provincial levels of government.

The representatives of CEN, STOP and the Korean Dry Cleaners Association oppose the overall management strategy because the PERC reductions and attendant time-lines are not sufficiently stringent. Moreover, the command-and-control regulatory approach gives the wrong signal to dry cleaners by promoting the continued use of PERC, albeit with more advanced technology. Consequently, CEN/STOP recommended a management strategy based on placing a quota on PERC imports which could restrict the available PERC to levels that would force industry to switch to wet cleaning.

CEN/STOP also stated that mandatory technology will not prevent future environmental releases from spills, fugitive emissions and improper operation of machines. CEN/STOP support the recommendation for mandatory training and certification providing that wet cleaning, in addition to PERC cleaning, is covered.