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Overview of Part 232

Part 232 Dry Cleaning Certificate Renewal Booklet

Information for Individuals Renewing their §232.14 Perchloroethylene Dry Cleaning Certificates

Every owner, manager and/or dry cleaning machine operator must take a NYS Department of Environmental Conservation (the Department) approved 16-hour §232.14 training course and successfully pass the respective owner/manager and/or operator examination(s). As a NYS certified perchloroethylene (perc) dry cleaning professional, it is your responsibility to know the many regulatory requirements and to make sure that your Perc dry cleaning operation is operated according to the rules.

The Department has been enforcing the Part 232 requirements since 1997. During this time, the Department has come to recognize that certain specific aspects of these rules are the subject of many - if not most - of the enforcement cases initiated against dry cleaning facilities.

The United States Environmental Protection Agency (USEPA) lists perc vapor as a Hazardous Air Pollutant (HAP). Perc is classified as a possible human carcinogen. Studies show that workers exposed to perc have a slightly higher risk of developing cancer and are more likely to have reproductive problems. Long-term exposure to perc has been shown to cause brain and nervous system damage: decreased hand-eye coordination, lower scores on vision tests, less ability to distinguish colors, decreased learning speed, and a decreased ability to memorize or pay attention. Long-term exposure can also cause liver and kidney damage.

Exposure to perc is harmful even at low concentrations. In a study of healthy people who lived in apartments near dry cleaning shops, individuals were tested for their ability to see subtle differences in color, to pay attention and to react quickly. Their test scores were lower than healthy people who did not live near dry cleaning shops.

Part 232 was enacted to ensure the safe use of perc as a dry cleaning solvent. To make it safe, it is important to know the common mistakes, errors and omissions that result in enforcement actions and monetary penalties. The following pages are designed to refresh your understanding of the major regulatory requirements of Part 232 and to familiarize you with the common problems for which shops have been penalized by the Department. Most importantly, as each common problem is discussed, the recommended steps are provided to help you avoid compliance problems.

What follows is a brief overview of the regulation's main points and a point-by-point discussion of commonly observed problems and how to avoid them.

An Overview of NYS's Perc Dry Cleaner Program

6 NYCRR Part 232 Perchloroethylene Dry Cleaning Facilities is the NYS air pollution control regulation that applies to all dry cleaning facilities which use perc solvent. Part 232 went into effect on May 15, 1997 to protect the public and workers from harmful exposure to perc vapors. The Department maintains a Part 232 website which is your gateway to many informational resources helpful for running a successful dry cleaning facility in full compliance with the regulations.

NOTE: If you don't have a computer or web access, visit your local public library. Nearly all provide free equipment and assistance where you can access the Internet. Otherwise, call 518-402-8403 and ask for someone in the Dry Cleaning Implementation Group, or write to the Department at the address above. The Department will mail you any information that you may need.

There are approximately 2,000 registered dry cleaning facilities in the State, with the majority located in the greater New York City metropolitan area. All of these shops must comply with the Part 232 regulatory strategies to reduce and contain the release of perc from dry cleaning processes. The various Part 232 regulatory requirements were phased-in from 1997 through January 1, 2005. All requirements are now in effect.

For your review, here's a list of Part 232's major regulatory requirements:

Shop Registrations or Permits: Most perc dry cleaning facilities must obtain a NYS Air Facility Registration. Larger facilities must get a NYS Air Facility Permit or Title V Facility Permit. Registration information must be kept up-to-date: Part 232 requires you to re-file and update your NYSDEC records anytime you make machine and equipment changes.

Dry Cleaning Machines - replacement requirements, and NYS Testing and Certification Program: Existing, older, and more polluting dry cleaning machines must be replaced with modern perc-efficient fourth generation designs. Most of these replacements were phased-in over the eight year period ending in January of 2005. Only brand-new NYSDEC certified fourth generation machines can be legally installed. Part 232 establishes dry cleaning machine equipment design and performance standards, and machine testing and certification requirements. A list of NYS certified dry cleaning equipment is posted on the Department's website.

Vapor Barriers/Room Enclosures and General Exhaust Ventilation Systems: Perc containment and ventilation measures for dry cleaning shops in mixed-use buildings. These requirements keep perc from migrating to adjacent occupancies;

Checklists and Record-keeping: Shop operation, maintenance, record-keeping and reporting requirements. Records must be kept on-site for five years;

Hazardous Waste Management: Specific hazardous waste and perc-contaminated wastewater disposal and record-keeping requirements;

Staff Training and Certification: Shop owners and/or managers and all machine operators must attend a 16-hour training course, successfully pass a NYSDEC certification test and hold current, valid NYSDEC owner/manager and/or operator certificates. Every shop must have at least one person with an owner/manager and operator certification;

Yearly Compliance Inspections: Every perc dry cleaning facility must be inspected at least once each year by an independent NYSDEC-approved Part 232 registered compliance inspector. Facility inspection reports are reviewed by regional NYSDEC engineering/technical staff for compliance and enforcement purposes. A list of NYSDEC registered compliance inspectors is posted on the Department's website.

Posting Notice: Perc dry cleaners must post a NYSDEC informational sign in a place where it can be read by the public. This posting notice informs the public that the shop uses perc, lists where to report odors and other problems, and states where additional information about the potential health effects of perc exposure may be found;

Public Access: Part 232 requires that you must provide public access to your shop's yearly compliance inspection reports (form 232-9).

Shop Registration or Permits

Your shop must have a valid NYSDEC registration or permit.

Most perc dry cleaning facilities must obtain a NYS Air Facility Registration. Larger facilities must get a NYS Air Facility Permit or Title V Facility Permit.

Registration information must be kept up-to-date: PART 232 REQUIRES THAT YOU UPDATE AND RE-FILE YOUR DEC REGISTRATION OR PERMIT ANYTIME YOU MAKE MACHINE AND EQUIPMENT CHANGES. Federal USEPA NESHAPS notification forms must be updated, too.

Nearly all perc dry cleaning shops in NYS use less than 1,050 gallons of perc solvent each year. Such shops must have a valid NYS Air Facility Registration. To obtain a registration, two short forms must be filled out and sent to the appropriate NYSDEC Regional office. The forms are also available by calling 518-402-8403. If your shop uses from 1,050 to 2,100 gallons of perc each year, a NYS Air Facility Permit is required. A Title V Facility Permit is needed if annual usage is over 2,100 gallons. NYS provides free technical assistance to obtain these permits - just call the NYS Small Business Assistance Program at 800-780-7227.

Federal NESHAPS Requirements - All perc facilities must also comply with the federal National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities in 40 CFR 63 Subpart M. NYS dry cleaners which qualify for a NYSDEC registration must complete Form 232-11 "National Emissions Standard for Hazardous Air Pollutants (NESHAP) Perchloroethylene Dry Cleaning Facilities" (PDF). Note that this form must be filed at THREE separate offices. To be in compliance with Part 232 and the NESHAPS, existing shops would have filed this form some years ago as this federal requirement dates back to 1993. New shops are required to file it upon start-up. This form must be re-filed any time new dry cleaning machines or control equipment are installed. Keep records of these filings on site. Inspectors will check for these records during your yearly inspection.

PLEASE NOTE: The EPA issued revised NESHAP standards which became effective July 27, 2006. Below is a summary of the NESHAP requirements that affect perc dry cleaning facilities in NYS:

1. Perc dry cleaning machines may not be installed in residential buildings after July 13, 2006.

2. Perc dry cleaning machines that were installed in residential buildings between December 21, 2005 and July 13, 2006 must eliminate perc use by July 13, 2009. In the interim, all perc dry cleaning facilities must continue to comply with the requirements of Part 232. In addition, all such machines must be checked weekly to verify that the perc vapor level in the drum at the end of the cycle is below 300 ppm. Dry cleaners will need to purchase a colorimetric pump testing device to perform these measurements. Compliance may be accomplished by either moving to a non-residential building (moving perc machines requires a variance) or by switching to an alternative solvent.

3. Perc dry cleaning machines that were installed in residential buildings before December 21, 2005 (the date of the proposed rule) must eliminate perc use by December 21, 2020.

4. Reporting Requirements: Each owner or operator of a dry cleaning facility using perc or an alternative solvent must submit information to the USEPA and NYSDEC pertaining to the compliance status of each dry cleaning facility. This information must be recorded on Form 232-11 "National Emissions Standard for Hazardous Air Pollutants (NESHAP) Perchloroethylene Dry Cleaning Facilities" (PDF).

NOTE: It is unlawful to install perc dry cleaning machines in residential buildings. When your machine wears out, you must either switch to non-perc equipment or move to a non-residential building. Both options will require a new, modified or amended permit or registration certificate.

Dry Cleaning Machines - replacement requirements, and NYS testing and certification program

Part 232's main pollution control strategy is to replace older, polluting dry cleaning machines with newer, cleaner technology units. Since June 26, 2003, only brand new NYSDEC-certified fourth generation dry cleaning machines may be installed when replacing old or adding new equipment. (see Notes 1 & 2 below)

A list of all DEC-certified perc dry cleaning equipment may be found on the Department's website. You may also call 518-402-8403 or write to the Department at the above address for a copy of the latest list.

Note 1: "Grand-fathered" machines - Between May 15, 1997 and June 26, 2003, a small number of shops upgraded their existing third generation machines with either add-on §232.2(b)(58) "Secondary Control Systems" (large carbon absorbers), or §232.2(b)(17) "Door Fan/Local Exhaust Ventilation Systems." Part 232.6 allows these existing 3rd generation machines to be upgraded and legally operated until they wear out, or until these machines are no longer able to meet the performance standards applicable to such units. At that time, they must be replaced with NYSDEC Certified fourth generation machines.

Note 2: §232.3 Variances - Should the owner of an existing dry cleaning facility decide to move to a new location, Part 232 treats the new location as a new facility and the requirements of §232.6(b) apply: only brand new §232.13 NYSDEC-certified fourth generation equipment can be legally installed. However, if an existing dry cleaning facility is forced to relocate, a §232.3 variance may be granted by the Department to move the existing certified fourth generation dry cleaning machine to a new location. To legally move such a certified fourth generation machine, one must apply for and obtain a §232.3 variance BEFORE any actions are taken. Variances can only be granted if all requirements of the regulation are met; they are not automatic. §232.3 Variances are only granted under "extraordinary or exceptional circumstances," such as a "loss of lease." Contact NYSDEC at 518-402-8403 for additional information.

Vapor Barrier/Room Enclosures at Mixed-Use Shops

Open vapor barrier doors are the most common violation. Make sure the vapor barrier/room enclosure door is closed at all times. If the door is open, you will expose workers and the public to harmful perc vapors. The vapor barrier door must always be closed unless you are entering or exiting the room. If the inspector sees it open, it is a violation! (The minimum DEC fine is $375.)

General Exhaust Ventilation System ("GEVS") - the GEVS must always be running when your dry cleaning machine(s) is/are in operation or maintenance activities are being performed. The GEVS exhaust fan on your vapor barrier/room enclosure creates a negative pressure in the room. This pulls air into the vapor barrier/room enclosure to insure that any leaks are INTO the room and do not leak out and harm your customers and neighbors.

It is good practice to run the exhaust fan as much as possible to contain perc vapors and prevent problems. Many well-run dry cleaning shops turn on their GEVS fan when they turn on the shop lights to open for the day and turn off the GEVS at closing time. A tight vapor barrier with good GEVS operation helps avoid perc odor complaints and problems.

General Exhaust Ventilation System Maintenance - Keep grilles, grates and ducts clean and lint free. Dust and lint adsorbs (collects) perc vapors which can cause high perc readings during inspections. Also, make sure your GEVS outlet pipe does not blow exhaust into neighboring windows or onto pedestrians. A well-designed vent exhausts the hot perc-laden air far away from others, and it is preferably located above the roof-line of your building. If your vent isn't in a good location, consider moving it to avoid future complaints and problems.

Vapor Barrier/Room Enclosure Maintenance - Most vapor barrier/room enclosures are five or more years old and are starting to show wear and use-related damage. Those with cracks and gaps are in violation of the regulation. All joints and seams on the vapor barrier/room enclosure must be sealed using a good quality caulk or epoxy coating. Take the time to inspect the vapor barrier room and seal all chips, gaps, and cracks.

For facilities which have epoxy NOVOLAC coated floors, walls and/or ceilings, be sure that the coating is sound and continuous. Repair all peeling areas and fix any area where the epoxy has flaked off or has cracked with a NYSDEC-approved epoxy coating.

Please remember that the area under the machine is a very important part of the vapor barrier and must fully be sealed to be impervious to perc. Some newer facilities have installed continuous heavy sheet metal, "diamond-plate" steel or aluminum vapor barrier room floors before they installed their dry cleaning machines. Others have used the NYSDEC-approved epoxy sealants to coat the floors in the area under the dry cleaning machine.

If your shop was retrofitted with a vapor barrier/room enclosure during the Part 232 phase-in period in 1998-1999, NYSDEC did not require you to lift up your then-existing machine to install the vapor barrier material beneath it at that time. However, if you installed a new machine or have lifted your old machine for maintenance after your vapor barrier/room enclosure was first installed, the floor under the machine was required to have been sealed at that time.

If your dry cleaning machine was installed or lifted after the vapor barrier room was installed, the compliance inspector will check to make sure the floor is sealed under your dry cleaning machine.

Checklists and Record-keeping

Dry cleaners must maintain the following checklists as a part of the record-keeping requirements of Part 232:

Copies of these forms are also available on the Forms for Dry Cleaners page or contact the Department and copies will be mailed to you at no charge. Please fill out these forms completely at the scheduled interval and have them available to show an inspector upon request. Failure to maintain the checklists and logs is a violation of the regulation. Weekly checklists must be completed at least once each seven calendar days.

Weekly Leak Inspection and Operation and Maintenance Checklists, Form 232-2

This form contains three checklists (Parts I, II & III):

  • I - Weekly Leak Inspection Checklist
  • II - Weekly Operation and Maintenance Tests
  • III - Weekly Emergency Preparedness Checklist

Leak Inspection Checklist, Form 232-2 (Part I)

Part 232.7 requires facilities to perform leak inspections at least once per week. Trained and certified operators must inspect the dry cleaning system for perceptible liquid and vapor leaks and other fugitive emissions using a halogenated-hydrocarbon detector, better known as a "beeper." The beeper must be properly calibrated, out-of-doors, per the manufacturer's recommended procedure. The operator must then record the status of each component on Form 232-2. Completed checklists must be kept on-site at the facility for at least five years from the date of the inspection.

Make sure to leak-check all components listed on Form 232-2 while the machine is operating and to fill out the form completely. During your shop's yearly Compliance Inspection, the registered compliance inspector will check these forms to make sure they are up-to-date and complete.

Any liquid leak, vapor leak, or malfunction must be noted on the checklist and repaired immediately, if possible. If the leak cannot be repaired at the time of detection, the leaking component must be physically marked or tagged so that it is readily observable by an inspector. It then must be repaired within 24 hours of detection, unless repair parts are unavailable. If repair parts are unavailable at the facility, the parts must be ordered within two working days of the leak detection. Upon receipt, the parts must then be installed within five working days. Detected leaky equipment not repaired by the end of the 15th working day must not be operated until the leak is repaired, unless the facility owner or operator receives a leak-repair extension from the Department.

All uncontainable perc releases, fires or explosions must be immediately reported to the Department and appropriate emergency response agencies.

Operation and Maintenance Tests, Form 232-2 (Part II):

Part 232.8 requires that each operation and maintenance function be recorded and dated on the checklist. Additionally, Part II of the form specifies that the following components must be tested (if applicable):

  • refrigerated condensers;
  • door fans;
  • integral carbon adsorbers

Completed operation and maintenance checklists must be maintained on-site for at least five years from the date recorded on the checklist. Part 232.8 requires the operator to maintain and operate all components of the dry cleaning system in accordance with the requirements of Part 232. For operations not specifically addressed, the components must be operated and maintained in accordance with the manufacturer's recommendations. The facility operator must retain on-site a copy of the design specifications and the operating manuals for each dry cleaning system and each emission control device located at the dry cleaning facility.

Weekly Emergency Preparedness Checklist, Form 232-2 (Part III):

Part 232.8 (d)(7) requires that all dry cleaning operations must be equipped with the following:

  • adequate spill control equipment including sorbent materials;
  • vapor-proof containers for storing spill-contaminated material; and
  • fire control equipment.

In addition, facility owners are responsible for the following:

  • The facility owner must maintain aisle space to allow proper inspection of the dry cleaning equipment.
  • A reasonable supply of spare parts for repairing dry cleaning equipment must be available at the dry cleaning facility.
  • All parts of the dry cleaning system must be kept closed at all times, except when access is required for proper operation and maintenance.
  • All solvent tanks and containers must be kept closed.

All the above bulleted items must be confirmed on a weekly basis on Form 232-2, Part III.

Emergency Response/Corrective Action Log, Form 232-3 (Part IV):

Part 232.11 requires that dry cleaning systems must be operated and maintained to ensure that perc releases are contained and do not migrate to sewer systems or groundwater. Floor drains and flooring in the vicinity of the equipment must be sealed so as to be impermeable to perc spills. Since May 15, 1997, all new dry cleaning machines are required to be equipped with a spill containment system ("spill pan") capable of containing 125 percent of the capacity of the largest dry cleaning perc tank or vessel associated with the dry cleaning machine. In the event of a perc release, the shop owner, manager or operator must take all reasonable measures to ensure the release is contained. These measures may include stopping processes and operations, increasing room exhaust ventilation, collecting and containing released perc and removing and maintaining containers. If the facility operator determines that the facility has had an uncontainable release, fire or explosion, he/she must immediately report the findings to the Department and appropriate local emergency response agencies.

Any emergency response action must be recorded on Form 232-3 (Part IV), which includes:

  • the date, duration and nature of any malfunction, spill or incident of the dry cleaning system;
  • the notification procedures; and
  • the corrective actions taken.

Equipment Maintenance Log - Form 232-4 (Part V):

Part 232.12 requires that operators of all dry cleaning facilities must record the date of maintenance on any air cleaning component or exhaust system, including:

  • the regeneration of the carbon in a carbon adsorber (indicate the number of loads between regenerations in the notes column);
  • replacement of the carbon in any carbon adsorber, and the amount of activated carbon used (dry weight in pounds);
  • cleaning or replacement of lint filters and carbon adsorber pre-filters (indicate the number of loads between cleaning and replacement in the notes column);
  • repair or replacement of exhaust fans;
  • the maintenance of dry cleaning machine drying sensors;
  • replacement of carbon cartridges in wastewater treatment unit (if used).

Hazardous Waste Management Log, Form 232-5 (Part VI)

Record the date and volume of hazardous waste shipments on Form 232-5 (Part VI). Receipts and completed forms must be retained for five years (see the section entitled "Hazardous Waste Management").

Perc Usage Log, Form 232-6 (Part VII)

Part 232.12 requires that each owner or operator of a dry cleaning facility must keep receipts of perc purchases, and log the following information on Form 232-6 (Part VII). This information must be maintained on-site for a period of five years and provided to inspectors upon request:

  • The volume of perc purchased each month, as recorded from perc purchases. If no perc is purchased during a given month, enter zero gallons into the log for that month;
  • The total perc used during the previous 12 months. On the first day of every month, sum the volume of all perc purchases made in each of the previous twelve months, as recorded in the log, as described above.

"Twice-a-Year" - Operation and Maintenance Checklist, Form 232-8

This form is a checklist for your entire facility. It contains both state and federal requirements. This form must be completed at least once every six months.

Hazardous Waste Management

Perc dry cleaning shops create two major streams of regulated hazardous waste: 1) solid and semi-solid perc wastes (including spent cartridge filters, spent carbon, still bottoms - sludge and muck, lint, and any other perc-contaminated items); and 2) perc-contaminated wastewater. These wastes can seriously pollute the environment if they are not handled correctly. As such, you must keep clear, comprehensive records in your shop to prove you have legally disposed these hazardous wastes.

Part 232.10 requires that any perc-contaminated wastes must be managed in accordance with NYSDEC regulations, 6 NYCRR Parts 370 through 376. All perc-contaminated wastes must be stored in tightly sealed containers, which are impermeable to the solvent, so that no perc is released to the atmosphere.

  • Containers must be appropriately labeled and stored in a designated area.
  • Containers must be in good condition and must be kept tightly closed, except when necessary to add or remove waste.
  • Part 232 requires that you retain records and receipts showing the date and volume of your hazardous waste shipments by a NYS-approved hazardous waste hauler ("hazardous waste manifests") for at least five years. Since you are legally responsible to dispose these wastes, it is wise to keep these records for the life of your business.

Wastewater Management - Perc-contaminated wastewater is a hazardous waste

Wastewater is generated by the dry cleaning process and is discharged from the dry cleaning machine through the water separator. Liquid steam condensate from pressing stations is also a perc-contaminated waste stream and must be collected and properly disposed.

Dry cleaning facilities that use perc solvent are subject to the requirements in Part 232.9 that state: "Perc-contaminated wastewater ... must be treated by physical separation (water separator) and double carbon filtration which has been properly designed to assure an effluent quality that is less than or equal to 20 ppb (parts per billion) perc..." before the treated wastewater is legally discharged to a sewer or evaporated.

Most wastewater treatment units use activated carbon cartridges (or carbon beds) to reduce the concentration of perc and other organic chemicals in the wastewater. After the water has been treated by the carbon, most wastewater treatment units then evaporate the "treated" effluent to the atmosphere, either by heat vaporization or "misting" atomization with a nozzle. Perc wastewater treated to less than 20 ppb may be discharged to the sewer if allowed by local ordinances.

IMPORTANT: check with the local city or county sewer district before you discharge to the sewer system. Many municipalities prohibit any such discharge to the sewer or have strict treatment and testing requirements.

NOTE: Although Part 232 allows for the on-site treatment and disposal of perc-contaminated wastewater with a Wastewater Treatment Unit (WWTU), it is not the preferred way to dispose of wastewater. The NYSDEC recommends that wastewater be collected in sealed drums and shipped off-site for disposal by a licensed hazardous waste hauler.

A few things to remember:

  1. Make sure your hazardous waste and wastewater practices adhere to recommended procedures and all hazardous waste disposal laws. Keep clear records; the registered compliance inspector will check them yearly.
  2. Make sure the wastewater is carefully decanted from the water separator. To make sure no perc gets carried over, stop decanting well before you reach the water/perc interface line.
  3. Wastewater should be legally hauled away and disposed as hazardous waste, or treated on-site by double carbon filtration to reduce the perc concentration to less than 20 parts per billion (<20 ppb). If you choose this option, you must learn how to properly operate the wastewater treatment unit, maintain the unit according to manufacturer's specifications, keep written records on the operation and maintenance check sheet, and maintain carbon filter change records on-site for five years.
  4. NEVER pour untreated, unfiltered wastewater down the drain, toilet, or out the back door. This is a violation of Part 232, the NYS hazardous waste regulations (Parts 370 through 376), and NYS water pollution and local sewer regulations.

Staff Training and Certification

Part 232.14 requires all individuals that own and/or manage a perc dry cleaning facility and all individuals who operate perc dry cleaning machines have current NYSDEC owner/manager and/or operator certificates, as appropriate. To become NYSDEC-certified, owner/managers and all machine operators must attend a 16-hour training course and successfully pass a NYSDEC certification test. Certificates are good for three years and must be renewed upon expiration.

The NYSDEC has approved the following three training organizations to offer Part 232.14 dry cleaner owner/manager and operator training courses. Please contact these organizations directly regarding course dates, locations and fees.

NCA International
252 West 29th Street
New York, NY 10001-5201
(212) 967-3002

North East Fabricare Association
580 Main Street
Reading, MA 01867
(800) 446-1174

Center for Environmental Technology
508C 115th Street
College Point, NY 11356
(718) 888-0802
(718) 888-1402

Upon completion of the training course, students are given information and applications from the training vendor to take the §232.14 examinations. Take the examinations soon after completing the course while the information is still fresh in your mind. These examinations are "open-book," so bring the course materials and workbook to the exam site. The examinations are in a multiple-choice question format and are administered by an independent testing agency, the Professional Testing Corporation, (PTC), 1350 Broadway - 17th Floor, New York, NY 10018; 212-356-0660. Questions about examination applications, test dates and scheduling, special accommodations for examination takers, certificate renewals, etc., should be directed to PTC at 212-356-0660.

Compliance Advice

Operator - EVERY individual who operates a perc dry cleaning machine MUST posses a valid operator certificate. "Operators" load textiles into the machine, select cycles and operating settings, unload the cleaned clothes, and perform routine dry cleaning machine maintenance. Each person performing these functions must have a Part 232.14 operators certificate.

Owner/Manager - Many NYS dry cleaning shops are family-owned and operated. The Department's air pollution regulations use the term "responsible official" to designate the person who is responsible for making the operational decisions for keeping the facility in compliance with all applicable regulatory requirements. Part 232, consistent with this concept, uses the term "owner/manager" to identify the person who is the responsible official. For a family-owned and operated dry cleaning shop, one family member is frequently both the manager and the person who operates the dry cleaning machine. This person would need both owner/manager and operator certificates.

In situations where the owner of the shop is uninvolved with the management decisions and an employee has been hired to perform these functions, the employee/manager needs to possess the Part 232.14 owner/manager certification. In other words, the specific individual who is responsible for directing the operations of the dry cleaning system and making operational management decisions must possess an owner/manager certification. If that person also operates the dry cleaning machine, they must also have an operator certification.

Every dry cleaning shop with a perc machine has a person who actually manages the daily operations and a person who runs the machine. The same person may do both. Every shop's actual manager must have an owner/manager certification. Every person who runs the machine must have an operator's certificate.

The Department recommends that individuals get both the owner/manager and operator certifications soon after they first take the training course. The course prepares you for both certifications and the combined owner/manager and operator examination has only an additional 25 multiple-choice questions.

Yearly Compliance Inspections

§232.16 Compliance Inspections requires each perc dry cleaning facility to be inspected at least once a year by a registered compliance inspector (RCI) or a compliance inspector (CI). A compliance inspector is a person that works under the direct supervision of an RCI. The yearly compliance inspection is the primary tool used by the Department to assess a shop's compliance with NYS and federal regulations. It is important to prepare your shop for a successful compliance inspection. Keeping your facility in top-notch shape and having your records in order will make the inspection easier and help avoid problems. To help get your shop ready for an efficient, successful inspection, please see the "Preparation Checklist for Yearly Part 232.16 Dry Cleaning Compliance Inspections".

Shop owner/managers are responsible for arranging to have yearly compliance inspections performed on time. A list of the DEC-Registered 6 NYCR Part 232 Dry Cleaner Inspectors is available on the Department's website.

After a shop owner/manager schedules the inspection, the RCI is required to give the local NYSDEC Regional office seven days written notice of the date and time the inspection will be held. Within 45 days after the inspection date, the RCI is required to send both you and the NYSDEC Regional Air Pollution Control Engineer a signed copy of the completed 232-9 Compliance Inspection Report with the shop's perc vapor concentration laboratory analysis report attached. Keep the compliance inspection report on-site for five years and show it to any individual who asks to see it.

Posting Notice and Public Access

"Posting Notice" - Perc dry cleaners must post a Department informational sign in a place where it can be read by the public. This "Posting Notice" informs the public that the shop uses perc as a dry cleaning solvent, lists where to report odors and other problems, and states where additional information about the potential health effects of perc exposure may be found.

The Department supplied a posting notice to each existing dry cleaning shop in 1998 and to each new shop when it registered with the Department. If your posting notice sign is old, dirty, illegible or missing, please contact the Department for a free replacement. Post it in a location where it can be easily read by the public and by any government inspector who may visit your shop.

There are two versions of this posting notice:

  • Perc dry cleaning shops in the five boroughs of New York City should contact the NYSDEC Region 2 office in Long Island City, Queens at 718-482-4944 for the New York City only version.
  • Perc dry cleaners outside of NYC should call 518-402-8403 for the "statewide" version of the sign.

Public Access - Part 232 requires each shop owner to keep many facility records in the shop at all times.

§232.16(j) states that the shop owner/manager or operator must: Make available upon request the most recent completed inspection reporting form to interested individuals for review on premises during normal business hours.

Keep a copy of the most recent 232-9 Compliance Inspection Report in your shop and show it to any individual who may request to view it.


The most commonly used Part 232 related checklists and forms referenced are available for download on the Forms for Dry Cleaners Using Perchloroethylene and/or Approved Alternative Solvents page. Alternately, please note that the Department will mail you a reasonable supply of any form upon request without charge. Either call the Department at 518-402-8403 or send an email to Please ask for the form by name and number. The form number can be found on the lower corner of each form. Be sure to include your name and full mailing address.