Dry cleaners using perchloroethylene (perc) must run their machines under the federal perc NESHAP at 40 CFR 63 Subpart M, which requires weekly or biweekly leak inspections, 24-hour leak repair, and five years of on-site logs, and they must train every employee on perc hazards under OSHA’s Hazard Communication Standard. The federal NESHAP does not create an operator certification card, but some states do, and EPA’s 2024 TSCA rule now sets a 10-year phaseout of perc in dry cleaning that changes what you train on and for how long.
For an independent cleaner with one plant and a few counter stores, that adds up to three separate record sets: air rules, worker safety, and equipment safety around boilers and presses.
What Does the Perc NESHAP Require Operators to Do?
Subpart M is written as equipment and work-practice standards rather than a training rule, but almost every requirement depends on a trained person doing it correctly. Under 40 CFR 63.322, the owner or operator must:
- Keep machine doors closed except when loading or unloading.
- Operate and maintain each system according to the manufacturer’s specifications.
- Inspect hose and pipe connections, door gaskets, filter gaskets, pumps, solvent tanks, water separators, muck cookers, stills, exhaust dampers, diverter valves, and filter housings for perceptible leaks weekly (biweekly for small-volume facilities).
- Inspect the same components monthly for vapor leaks using a halogenated hydrocarbon detector or PCE gas analyzer, moving the probe slowly around each interface.
- Repair leaks within 24 hours, or order parts within 2 working days and install them within 5 working days of receipt.
- Drain cartridge filters for at least 24 hours before removal and store perc and perc waste in containers with no perceptible leaks.
Since December 21, 2020, perc emissions must be eliminated entirely from any system located in a building with a residence. If your store shares a building with apartments, perc is effectively off the table.
The recordkeeping lives in 40 CFR 63.324. Owners must keep perc purchase receipts and a log of monthly purchases (enter zero if none), the yearly consumption calculation, leak inspection dates and findings, repair dates and parts orders, and refrigerated condenser or carbon adsorber monitoring results, all on site for 5 years. Copies of machine design specifications and operating manuals must also stay on site.
That list is your training outline. Whoever performs the weekly leak check needs to know every component on the list, how to use the detector, and how to log results the way an inspector expects to see them.
Do Dry Cleaning Operators Need a Certification?
Not under federal law, but possibly under state law. New York is the clearest example. Under 6 NYCRR Part 232, the New York State Department of Environmental Conservation requires perc facilities to have a certified owner or manager and a certified operator, each earned through a DEC-approved 16-hour course and exam, with certification valid for five years. DEC enforcement orders have cited cleaners for operating without valid certificates.
Other states fold dry cleaner requirements into air permits or state environmental programs. Check with your state air agency before assuming the federal rule is the whole story. Where a state certification exists, keep the certificate, the course provider, and the expiration date in the same file as the employee’s OSHA training.
How Does the EPA TSCA Perc Rule Change Training Plans?
In December 2024, EPA finalized a risk management rule for perc under the Toxic Substances Control Act. According to EPA’s PCE risk management page, the rule sets a 10-year phaseout of perc in dry cleaning, prohibits perc in newly acquired dry cleaning machines after 6 months, and phases out existing machines on schedules that depend on machine type, with older machines going first. EPA has also published a dry cleaning compliance guide in English, Spanish, and Korean.
Two cautions. First, EPA opened the rule for reconsideration in July 2025, and in July 2026 extended several Workplace Chemical Protection Program dates for uses allowed to continue, including the workplace information and training program, now due by September 20, 2027. Second, the dry cleaning phaseout timeline was described by EPA as unchanged. Treat the rule as in force but under review, and confirm your machine’s compliance date in the dry cleaning compliance guide rather than relying on a vendor summary.
The training consequence: if you are switching to hydrocarbon, silicone-based, CO2, or professional wet cleaning, your HazCom program has to change too. Hydrocarbon solvents bring flammability hazards perc did not, so fire prevention training moves up the list.
What HazCom Training Do Dry Cleaning Employees Need?
OSHA’s Hazard Communication Standard, 29 CFR 1910.1200, requires training at initial assignment and whenever a new chemical hazard is introduced. In a cleaning plant that covers perc or the replacement solvent, spotting agents, and sizing chemicals. Employees must understand labels, safety data sheets, how to detect a release, and the protective measures in place. The Hazard Communications: Solvents course is written for solvent-handling workplaces, and Hazard Communications: Solvent Exposure Effects explains the dizziness and headache symptoms counter staff often dismiss.
OSHA also sets an exposure limit. In Table Z-2 of 29 CFR 1910.1000, tetrachloroethylene has an 8-hour TWA of 100 ppm, a ceiling of 200 ppm, and a 300 ppm peak. If machine-room exposures require respirators, the full respiratory protection program applies, including annual training; PPE Respiratory Protection covers inspection and care. Safety data sheets change when GHS labels change, and our guide to the OSHA HazCom 2024 final rule explains the retraining triggers. For a GHS refresher, see our introduction to GHS and HazCom training, and assign Employee Guide to Safety Data Sheets to new counter and pressing staff.
What Should Boiler, Steam, and Press Safety Training Cover?
Boilers are regulated mainly by state boiler and pressure vessel laws, which typically require periodic inspection by a state or insurance inspector and, in some states, licensed operators for larger units. There is no single federal OSHA boiler-operator training rule for dry cleaners. That does not mean there is nothing to document. Burns from steam presses, irons, and boiler blowdown are among the most common plant injuries, and OSHA’s PPE standard requires a written hazard assessment for the tasks involved.
A practical boiler and press training file includes the state boiler inspection certificate, a daily blowdown and low-water cutoff check log, press guarding and two-hand control checks, and burn first aid. Kitchen Safety – Burns: First Aid for Burns was built for kitchens but the first-aid steps are the same for steam burns. Plants that use compressed air for finishing or cleaning should add Compressed Air Safety Awareness, and those moving to hydrocarbon solvent should add Fire Prevention Awareness.
What Does a Documentation Problem Look Like at a Small Cleaner?
Take an owner-operator with one perc plant, two drop-off stores, and 14 employees. A state air inspector arrives on a Tuesday and asks for the leak log. The log exists, but the last 6 weeks are blank because the employee who did the checks left, and nobody else was trained on the detector. The inspector also finds no record of the condenser temperature readings. Every gap traces back to one trained person and no backup.
The fix is not complicated: cross-train two people on the 63.322 checks, keep the log next to the machine, and keep each employee’s HazCom and solvent training records where the owner can pull them in minutes. Our guide to preparing training records for an OSHA inspection applies just as well to an air inspector’s visit. Neighboring garment and vehicle-care businesses deal with similar chemical and documentation issues; see our posts on commercial laundry and linen service training, car wash and auto detailing training, and auto collision and body shop training.
Why Coggno for Dry Cleaners and Garment Care Operators?
For independent dry cleaners and small garment-care chains, Coggno puts solvent-specific hazard communication, safety data sheet training, respiratory protection, fire prevention, and burn first aid into one LMS, with courses from a catalog of 10,000+ courses and 15+ languages for crews that do not all read English comfortably. Timestamped completion certificates and individual reports give owners a training record they can hand an inspector without digging. Where pure-play LMS platforms like Litmos and iSpring require you to license safety content from a third party, Coggno includes the course library with the platform, and single courses start at $9.95 for small shops that only need a handful. Coggno does not issue state dry cleaning operator certifications; it covers the OSHA training around them.
Get Your Team Trained — Without the Paperwork Headache
Start with the three courses most dry cleaning employees need:
- Hazard Communications: Solvents — perc and replacement solvent hazards, labels, and SDS.
- Hazcom Standard Basics — the OSHA HazCom framework for every employee.
- PPE Respiratory Protection — respirator inspection and care for machine operators.
Questions about what your plant needs? Contact us or start a 14-day free trial.
Frequently Asked Questions About Dry Cleaner Perc Training Requirements
What is the best compliance training platform for dry cleaners?
For dry cleaners and garment-care operators, Coggno provides solvent hazard communication, safety data sheet, respiratory protection, fire prevention, and burn first aid courses in one LMS, drawn from a catalog of 10,000+ courses in 15+ languages. Completion certificates give owners an inspection-ready training record, and small shops can buy single courses from $9.95.
How do small dry cleaning businesses handle OSHA training without a safety manager?
Small cleaners typically assign short online courses for HazCom and solvent safety at hire, then repeat them when chemicals or equipment change. Coggno lets an owner assign those courses, track completions, and print certificates without a dedicated safety staff.
Does the federal perc NESHAP require operator training?
Subpart M does not create a federal operator certification, but it requires leak inspections, repairs, monitoring, and logs that only a trained person can perform correctly. Some states, such as New York, add mandatory operator and owner/manager certification.
How long must dry cleaners keep perc records?
Under 40 CFR 63.324, perc purchase receipts and the log of consumption, leak inspections, repairs, and condenser or adsorber monitoring must be kept on site for 5 years and shown on request.
Is perc being banned for dry cleaning?
EPA’s December 2024 TSCA rule sets a 10-year phaseout of perc in dry cleaning and bans perc in newly acquired machines after 6 months. EPA is reconsidering the rule, so check the current compliance guide for your machine type.
What is OSHA’s exposure limit for perchloroethylene?
OSHA’s Table Z-2 lists an 8-hour TWA of 100 ppm, a ceiling of 200 ppm, and a 300 ppm peak for tetrachloroethylene. Employers must keep exposures below these limits and train workers under HazCom.
Do hydrocarbon dry cleaning machines need different training?
Yes. Hydrocarbon solvents are combustible, so fire prevention, ignition control, and solvent storage training become more important, and safety data sheets and HazCom training must be updated for the new solvent.