Environmental Authorisations (Scotland) Regulations 2018: ​Proposed Standard Conditions for Registration level activities

Closes 24 Nov 2024

3.2.2. Dry cleaning

This activity applies to industrial or commercial dry cleaners.

Activity description

The dry cleaning of garments, furnishing and similar goods in an industrial or commercial activity using volatile organic compounds.

Standard conditions

Below is the list of core and activity-specific standard conditions for the dry cleaning of garments, furnishing and similar goods.

  1. With the exception of manual spot-cleaning, dry cleaning using any solvents must only take place in purpose built enclosed dry cleaning machines.
     
  2. All machines must have interlocks to automatically shut-down in the event of:

    a. a cooling water shortage;

    b. failure of the condenser or refrigeration system(s);

    c. failure of the machine heating system; or

    d. the still, button trap and lint filter doors are not properly closed.
     
  3. Stills must have a thermostatic control device (or equivalent) to control the maximum operational temperature in accordance with the manufacturer’s guidance for the solvent being used.
     
  4. Solvents must be stored in the original containers they were supplied in.
     
  5. Containers used for the storage of liquids containing solvents must be kept closed and lidded and stored within a bund / secondary containment system that must:

    a. hold at least:

       i. for a single container, 110% of its total capacity; or
       ii. for two or more containers, the greater of:

          1. 110% of the capacity of the largest container; or
          2. 25% of the capacity of all containers together.

    b. catch all spills from the container(s) and related parts;

    c. be leak-proof;

    d. be located and/or protected, to prevent damage as far as reasonably practicable;

    e. be stored away from sources of heat or bright light; and

    f. have any spills and/or rainwater removed as soon as reasonably practicable.
     
  6. The annual solvent emission must not exceed 20 grams of solvent per kilogram of products cleaned and dried in any 12-month period.
     
  7. Measures must be taken to prevent, or where that is not practicable, minimise:

    a. heat emissions; and

    b. odour;

    from the authorised activity.
     
  8. Offensive odours as perceived by a SEPA officer must not be emitted from the authorised activities.
     
  9. SEPA must be notified via its pollution hotline contact telephone number as soon as reasonably practicable, and in any case within 24 hours of identification of an event, of any of the following:

    a. an event that has caused or could cause adverse impact to the environment or harm to human health;

    b. an event that results, or could result, in an emission to the environment that is not authorised; and

    c. an event that has caused a breach of a condition of this authorisation.

    In this condition, the meaning of ‘event’ is as defined in the Interpretation of Terms of this authorisation.
     
  10. All measures that are reasonably practicable must be taken to stop an event and to minimise its effect on the environment.
     
  11. Within 14 days of an event a report must be submitted to SEPA detailing:

    a. the reason(s) for the event;

    b. the action(s) taken to stop the event and minimise the impacts; and

    c. the action(s) taken to prevent the event from reoccurring.
     
  12. All information recorded, kept or submitted to SEPA in accordance with a condition of this authorisation must be:

    a. true and accurate; and

    b. kept for a minimum of six years; and

    c. provided to SEPA upon request.
     
  13. The following must be recorded on a weekly basis:

    a. weight of clothes/fabric cleaned in kilograms (kg);

    b. volume of solvent added to the machines in litres (l); and

    c. volume of solvent contaminated residues pumped or raked out of the stills. Water separator waste must not be included in this figure.
     
  14. The volume of solvent remaining in the machine(s) at the start and end of the 12-month period must be recorded in litres(l).
     
  15. The annual solvent emission figure must:

    a. be calculated using the data recorded in Condition 11; and

    b. recorded using the ‘Calculating your annual solvent emission’ sheet provided in guidance or digitally via SEPA’s website.
     
  16. The annual solvent emission calculation must:

    a. for each calendar year be submitted to SEPA on or before the 28 January in the following year; and

    b. cover the period 1 January to the 31 December of the previous year (or pro rata where the machines have not been operating).

Interpretation of terms

Interpretation of terms
Term Definition
Dry cleaning Any industrial or commercial activity using volatile organic compounds to clean garments, furnishing and similar consumer goods excluding the manual removal of stains and spots in the textile and clothing industry.
Dry cleaning machine A purpose built enclosed dry cleaning machine.
Environmental harm
  1. Harm to the health of human beings or living organisms,
     
  2. Harm to the quality of the environment, including:
     
    1. harm to the quality of the environment taken as a whole,
       
    2. harm to the quality of air, water or land, and
       
    3. other impairment of, or interference with, ecosystems,
  3. Offence to the senses of human beings,
     
  4. Damage to property, or
     
  5. Impairment of, or any interference with, amenities or other legitimate uses of the environment.
Event
  • Any accident which has caused or could cause environmental harm; or
     
  • Any malfunction, breakdown or failure of plant, infrastructure or techniques which has caused or could cause environmental harm; or
     
  • Force majeure or action taken to save human life or limb.
Interlock A device or mechanism for connecting or coordinating the functioning of different components e.g. a door lock that will not unlock when the dry cleaning machine is running. 
Still Where the solvent distillation takes place and solvent is then condensed to allow the solvent to be re-used.
Solvent

Any volatile organic compound which is used for any of the following:

  1. alone or in combination with other agents, and without undergoing a chemical change, to dissolve raw materials, products or waste materials;
     
  2. a cleaning agent to dissolve contaminants;
     
  3. as a dissolver;
     
  4. as a dispersion medium;
     
  5. as a viscosity adjuster;
     
  6. as a surface tension adjuster;
     
  7. as a plasticiser;
     
  8. as a preservative.

Rationale

The standard conditions focus on the control of fugitive solvent emissions. There is also a limit imposed regarding the maximum annual solvent emission and a requirement to record data to demonstrate compliance with this. If you already have a standard rules Permit for this activity, you will notice that the standard conditions proposed here are broadly similar, except for the requirement to minimise heat emissions, which ties into one of the general aims of EASR – to use resources in a sustainable way. Guidance will be provided explaining how to collect the required data and the annual solvent emission submission may be made using by the standard form (provided in guidance) or via SEPA’s website.

 

82. Do you agree with the list of standard conditions for the dry cleaning of garments, furnishing and similar goods in an industrial or commercial activity using volatile organic compounds?