Since the DSCA Program has collected extensive information on many of the sites in the Program and some sites meet the site specific cleanup standards, some No Further Action Letters should be issued before year end and active remediation can begin on other sites in the Program.

Chris Is Coming. Are You?
Chris Allsbrooks, DLI (formerly IFI)'s star of the stage, TV, Training Video's, DVD's and the classroom is bringing her Customer Service & Problem Garment Class "Your Profits Begin at the Front Counter" to North Carolina for a four stop road show October 21-24. One of the most sought after speakers in the industry, Chris combines humor with enthusiasm in her dynamic interactive sessions to make her points stay with participants when they return to work. Chris's "ragbag" contains examples of the most recent manufactures disasters as well as examples of persistent "problems waiting to happen." A veteran of the DLI Analysis lab, who worked as a Customer Service Representative at a local drycleaners while in college, Chris has appeared on local and national TV as a spokesperson for DLI and the Fabricare Foundation. Her customer Service Seminars and classes have received rave reviews in recent appearances in Pennsylvania, South Carolina, Georgia, Florida, Texas, California, and at Clean 07.

Dooyoung Choi, Galaxy Cleaners, Cary
Every one of us is motivated by personal and business/professional needs. Probably my needs are not that much different than yours. Let's review a basic sociology theory. Maslow's Hierarchy describes the needs of persons in 5 basic steps.

1. Biological and Physiological - air, food, drink, shelter, warmth, sleep, etc.
2. Safety - protection from elements, security, order, law, limits, stability, etc.
3. Belongingness and Love - work group, family, affection, relationships, etc.
4. Esteem - self-esteem, achievement, mastery, independence, status, dominance, prestige, managerial responsibility, etc.
5. Self-Actualization - realizing personal potential, self-fulfillment, seeking personal growth and peak experiences.

Once needs 1 and 2 are met what we seek as an individual is a sense of belonging ( 3 ) to a group or circle of friends. NCALC provides professional belonging for Dry Cleaners such as myself. I joined the organization as a newbie. In the beginning more often than not I was in panic mode as machines broke down constantly and I needed my customer's orders filled but did not know who to call for support (emotional and mechanical.) Being part of the NCALC organization allowed me to meet a group of great people who are willing to help (service contacts, spare parts, lending expertise/experience ) in times of need.

What do I get for my money? We all asked this question when we wrote our membership check. I joined IFI/DLI and NCALC at the same time. I have used the IFI reference library and articles (from IFI/DLI monthly) to help customers get refunds/replacements on defective articles from retailers or manufacturers on numerous occasions. This is a HUGE customer service benefit and advantage. We as well as our customers get an education and the satisfaction of knowing that we have averted what could have been a bad situation. This results in increased customer confidence and great PR for me as a business owner ( 4), not to mention keeping damages/losses to a minimum! Also the recent passing of the amendments to the DSCA (passage facilitated with the help of NCALC) provides me with not only piece of mind but a potential financial solution (reduction in deductible and co-pay) for potential clean up needs.

There are things we can accomplish as an individual, but as a group we can accomplish a lot more. This is why I am a member.

As for the self actualization (5), let me know if you get there and what it feels like.

Barbara Harvey Installed as First Woman President of DLI
The Drycleaning & Laundry Institute (formerly IFI) installed its first president at Clean '07 in Las Vegas. Barbara Harvey, owner of Fabricare by Fran in Severna Park, Maryland, will serve as DLI President for the 2007-2008 term. She previously served as President-Elect, Treasurer, and District 2 Director, and becomes the first woman to hold the Institute's highest leadership post.

Over the years Harvey has been an active volunteer leader in several cleaning and laundry associations, serving as president of the MidAtlantic Association of Cleaners and the Coin Laundry Association of Maryland, for example.
Despite her impressive credentials, Harvey-known affectionately as "Bobbie" among her peers-remains humble to the end. "I haven't gone very far in life," she joked. "I live in the same house I was born in, and I'm working the only job I ever had." It's true, Harvey worked in the plant with her parents Francis and Theo Sadler until she took the reigns in 1989. Her parents launched Fabricare by Fran in 1951 as a route service, steadily building it into a full-service drycleaner with a coin laundry facility. The coin laundry side was sold in 2005.

Most recently, Harvey chaired the committee to change the International Fabricare Institute's name to the Drycleaning & Laundry Institute. "Basically, most consumers did not understand what IFI means," she said. "Inside the industry, we all know what 'fabricare' means, but the name IFI did not represent what we do very well to the general public. We wanted to simplify the name."

I feel very confident that I have handed over the association to a very competent person," said Steve Poulos, the outgoing president and new DLI chairman. "Bobbie has demonstrated her competency time and again at board meetings and industry functions. I'm very comfortable knowing that she's the new president."

Gary Dawson served as 2006-2007 Chairman and worked extensively with Harvey on the Board of Directors and its Executive Committee. "Bobbie's been very involved in the industry for a very long time," Dawson said. "The fact that she is the first lady to become president of the association is testament to her drive and desire to promote the best interests of the industry. She is a very dedicated volunteer who has given many, many hours of her time to help advance the cleaning industry."

Dawson expressed his belief that Harvey easily fits the mold of a DLI president. "It takes some special qualities to do that job. It's an all-volunteer role, and there are a lot of meetings to attend and a lot of opportunities to represent the Institute. Bobbie is a small-plant operator who is a very levelheaded, down-to-earth person. I'm sure she'll keep the association and the industry close to her heart like she always has."

You Can't Buy Publicity Like This
This Letter to the Editor appeared in the Charlotte Observer.

Bonding across faiths could happen every day
Visits to other faith groups, talks and presentations, question-and-answer sessions and conversations often seem the most prevalent form of interfaith dialogue. There is no doubt: Such friendly and hopeful sessions are critical to understanding one another more fully.

But they are, in a way, a setup. Someone from another tradition is coming to speak to us; we are on our best behavior; and our questions and responses are, in the main, polite.

It makes me wonder sometimes. What if we were all these things in daily life? Couldn't we see all the opportunities before us for connecting intelligently with people of other faiths and ethnicities?

Recently, I went into my favorite cleaner's. (I confess I like the idea of supporting homegrown businesses.) For years, Martin Young has worked on the few items of clothing that really matter to me. There's that dress with the beads on it that I bought for my younger brother's wedding 17 years ago.

Recently I gave the lace from my wedding dress to Young, sure that he could do whatever was needed for me to sew it onto a different dress. Young, a Christian, cleans religious clothing, like the small hats my family wears at services. And he takes care of the mantles that go around our congregation's Torah, the scroll with the handwritten text of the first five books of Moses.

Every now and again, Mr. Young and I discuss this or that religious idea, or a text common to our traditions. Sometimes we just chat about life in general.

Recently, I gave Mr. Young a rich, red, velvety Torah mantle I had sewn myself. He asked me whether I had washed the cloth before sewing. That's a rule as old as dressmaking. Still, I'd forgotten to follow it.

So, no, I hadn't done that, I admitted, a bit shamefaced.

"I'll do what I can," he said.

"I know," I responded.

I came back a week later. When I saw the mantle, I could hardly believe it. The spots were gone, the cloth looked like new, and even the nap was brushed all in one direction.

"What do I owe you?" I asked.

"Nothing," Mr. Young said.

I protested, but to no avail. "Don't steal my blessing now," he warned me. In the end, I found a way to give a blessing in return.

I've been thinking about our exchange ever since. Two human beings were connecting with each other. Neither of us needed a special presentation, an arranged meeting or a learned speaker to remind us to act generously toward one another. Martin Young and his family greet me with enthusiasm every time I walk in to their store. I go there with that same joy.

Interfaith dialogue happens most beautifully when there's no setup, when it emerges out of the things we need most in life: respect and understanding, sensitivity and goodwill.

It's nice to find those things home-grown.

BARBARA THIEDE

NCDENR Receives International Award for 2001 Alternatives Study
The North Carolina Department of Environment and Natural resources received the International Drycleaning & Laundry Institute's 2007 Green Fields Award in recognition of the lasting environmental contributions of their 2001 Study Group Report on ALTERNATIVES TO THE PREDOMINANT DRY CLEANING PROCESSES. The study compared the environmental and public health impacts of predominant and alternative solvents, processes and equipment; their ability to clean natural and synthetic fibers and fabrics without damage; and the financial impact of conversion to and utilization of alternate solvents. The study concluded that the drycleaning industry has done an excellent job in reducing its environmental footprint and that further improvement should be encouraged rather than required by statue.

The award was presented to NCDENR Secretary Williams G. Ross, Jr by Mack Davis, DLI District 2 Director. Also in attendance were Gary Hunt, Director, Division of Pollution Prevention and Environmental Assistance, whose division produced the Study, Chris Edwards, VP of Governmental Affairs & Sto Fox, Executive Director of the North Carolina Association of Launderers and Cleaners, and Dr. Manfred Wentz, President of Textile Care International in Apex and recipient of the Green Fields Award in 2001.

In presenting the award Mack Davis thanked Secretary Ross for the "fair and even-handed way the department had conducted the study" and the excellent working relationship that the North Carolina Association enjoys with the departments Small Business Ombudsman, Small Business Environmental Assistance Program and Dry-cleaning Solvent Cleanup Act Program.

NCALC's New Mentoring Program
Do you sometime feel like Robinson Crusoe, all alone with no one to talk to? As the old saying goes it gets lonely at the top. Small business owners have few people to talk too who really understand the challenges we face each and everyday. You're the owner, plant manager, customer service manager, chief mechanic, cleaner/spotter, bookkeeper, etc etc. Unlike your buddy in the corporate world you are responsible for all the day to day activities of your operation and finance, marketing, and long range planning. Sometimes it is not so great to be your own boss. Your spouse, golf buddies, banker, accountant, lodge brothers and neighbors don't really understand the complexity of your job nor have the experience or knowledge to provide you with advice & counsel across the broad spectrum of your responsibilities. NO ONE DOES EXCEPT ANOTHER DRYCLEANER.

This is why NCALC is creating a Mentorship Program for members who would like to talk business with someone who is or has walked in their shoes i.e. a current or former plant owner/operator. The plan is simple.

We are currently seeking active or retired members who are willing to volunteer some time to act as a sounding board and share their knowledge and experience with others.

Members who are considering entering or actively engaged in the cleaning business can request a Mentor.

Members requesting a Mentor will be matched with a volunteer who is not a competitor and has experience in a similar size operation.

The member requesting the mentor and/or the mentor can reject the other and are free to terminate the relationship at anytime. Unless otherwise terminated by either party, the initial arrangement is for six months and can be renewed twice for a total of eighteen months by mutual agreement.

There is no cost to the individual being mentored for the mentor's time and knowledge, experience or advice. However, if extensive travel and lodging are required, reimbursement of the mentors out of pocket expenses may be appropriate.

Mentors will receive no compensation for their services.

Both parties must sign a wavier holding each other and NCALC harmless.

ALL MEMBERS OR RETIRED FORMER MEMBERS INTERESTED IN MENTORING A NEW OR SMALL MEMBER ARE ASKED TO CONTACT MARTIN YOUNG AT 704-786-3011.

ANY MEMBER INTERESTED IN HAVING A MENTOR IS ASKED TO CONTACT EXECUTIVE DIRECTOR STO FOX AT 336-549-5486.

Changes to the Dry-Cleaning Solvent Cleanup Act
by Dr. John Powers
Head of the Special Remediation Branch of the Superfund Section of the Waste Management Divvision, NCDENR

On August 31, Governor Easley signed into law Senate Bill 1362 which made significant changes to the Dry-Cleaning Solvent Cleanup Act (DSCA). The DSCA Program hopes that these changes will improve program implementation and also encourage more dry cleaner owners, operators and property owners to bring their contaminated sites into the program. If you have any questions about these changes and how they may affect you, please do not hesitate to contact me or DSCA Program staff at (919) 508-8400.

Cleanup Program Application Fee
Effective September 1, 2007, each person who petitions for certification of a facility or abandoned site into the cleanup program must pay an application fee of $1,000.

Financial Responsibility Changes
S.B. 1362 significantly modified the financial contributions that are required from petitioners participating in the cleanup program. Deductibles have been eliminated and are replaced by a fixed co-pay percentage applied to site costs between $0 and $1 million. For active facilities with less than 5 full-time equivalent employees, petitioners would have to pay 1% of assessment and remediation costs between $0 and $1 million. For active facilities with 5-9 full-time equivalent employees and for abandoned facility sites, the co-pay is 1.5%. For active facilities with 10 or more full-time equivalent employees and for wholesale distribution facilities, the co-pay is 2%. The following table demonstrates what the petitioners' obligations would have been under the previous financial system compared to the new system for a site that costs $300,000 to clean up.

The table clearly illustrates the lower contributions required from petitioners under the new system. Instead of paying an up-front deductible ranging from $5,000 to $25,000, petitioners would be billed annually the new co-pay percentage of costs that the program has incurred.

The financial obligations of petitioners for sites that entered the program prior to September 1 will also be converted to the new system. Payments made by petitioners prior to the change will be credited toward the new obligations. For example, if a petitioner paid the $5,000 deductible for a small site, the program would not bill that petitioner again unless total site costs exceeded $500,000. Petitioners for abandoned sites that paid the $25,000 deductible have satisfied all financial obligations and would not be billed again. S.B. 1362 does not allow for reimbursement of previously-incurred costs that exceed the new obligations.

Program Eligibility and MMP Compliance
A dry cleaner owner or operator under the old law would have been denied access to the cleanup program if the facility was out of compliance with the MMPs at the time contamination was discovered. S.B. 1362 changed that, now allowing the DSCA Program to use discretion when determining if the noncompliance was significant enough to warrant denial of site eligibility.

Definition of "Dry-cleaning Solvent"
The introduction of alternative solvents to the dry-cleaning industry in recent years led to the need to clarify the definition of "dry-cleaning solvent" so that it would be clear which solvents would be subject to DSCA and the Minimum Management Practices (MMPs) for operating facilities. S.B. 1362 modified the definition so that it applied strictly to "any hydrocarbon or halogenated hydrocarbon used as a solvent in a dry-cleaning operation or the degradation products from these solvents." The bill also added new definitions that define "halogenated hydrocarbon" and "hydrocarbon." These additions were used to also modify the solvent tax law by clarifying that the $10.00 per gallon tax applies to halogenated hydrocarbon-based solvents and the $1.35 tax applies to hydrocarbon-based solvents.

Solvents subject to DSCA regulation and the $10.00 per gallon tax include perchloroethylene, F-1,1,3 or 1,1,1 trichloroethane, and n-propyl bromide. Solvents subject to DSCA and the $1.35 per gallon tax include the various petroleum solvents such as Stoddard and Quick Dry 105F as well as the high-flash hydrocarbons including DF-2000 and EcoSolv. Solvents not subject to DSCA and for which no solvent tax is charged include liquid CO2, propylene glycol ether and methyl siloxane.

Allowance to Investigate Possible Dry-Cleaning Contamination Sites
S.B. 1362 allows the DSCA Program to utilize up to one percent of the DSCA Fund balance for the investigation of sites that appear to be contaminated by dry-cleaning solvents. The purpose of this investigation is to determine if the contamination originated from a dry-cleaning facility (either active or abandoned).

If a facility is identified, the potentially responsible party (PRP) will be notified and given the opportunity to enter into the cleanup program. As a condition for acceptance into the program, the PRP will be required to accept in writing the responsibility of costs incurred to perform the investigation. These costs will then be credited toward the petitioner's financial responsibility requirements for the site. If the PRP decides not to petition, the DSCA Program may request the Attorney General to commence a civil action against the PRP to recover the investigation costs. An example of when an investigation under this provision could be performed is when perchloroethylene is found in a water-supply well and one or more dry-cleaning facilities are located nearby.

Annual Site Expenditures
S.B. 1362 increased the amount that DSCA can spend on a site from $200,000 to $500,000 per year. If a site poses an imminent hazard, the amount increases from $400,000 under the old law to $1 million.

Clarification - All Work Performed by State-hired Contractors
Language throughout DSCA was modified to clarify that all site work must be conducted by environmental contractors hired by the DSCA Program.

Temporary Rule-making Authority
S.B. 1362 gave authority to the Environmental Management Commission to adopt temporary risk-based rules in the event that ten or more letters of objection to the permanent rules are received by the Rules Review Commission.

Fall Board & Committee Meetings
After driving through a blinding gulley washer on Friday afternoon board and committee members from across the state turned left at the thundering Waterfall that marks the entrance to Highland Lake Inn's property and followed the winding road through the pristine forest up the mountainside to the historic lodge for the fall meeting of the NCALC Board and Committees. The Lodge built in the 1920's has been tastefully up fitted with all the modern conveniences of a first class hotel yet retains all the charm of its historic origin. The great room which occupies the center of the first floor features a stone fireplace, scattered groupings of overstuffed couches, large screen TV and a corner bar, served as a gathering place for getting to know you conversations, football watching, and a short nap or two throughout the weekend. The food at Highland Lake's award winning restaurant was outstanding as attendee's feasted on Prime Rib, Cajun Catfish, Coq au Vin, Duck Leg Confit and Wild Rice Salad, French Style Crab Cakes, Beef Wellington, Fresh Vegetables from the organic gardens, fresh home made breads and deserts in the evenings and wonderful breakfast buffets featuring tempting egg scrambled, quiche and sweet potato pancakes. Recreational opportunities abounded on property and in the local area. [The rain had stopped by the time we arrived and Saturday was a glorious day]. The lodge has a wonderful game room on the lower level with pool, ping-pong, darts, foosball, and another large screen TV which was enjoyed by the children of all ages in attendance. Downtown Hendersonville where many of us ventured after the Saturday morning meetings was really a treat. Main Street is lined with neat restaurants, many with sidewalk seating, and a plethora of unique shops concentrated in a six block area.

Special Guest at this meeting included Jeff Miller, winner of DLI 2007 Diamond Achievement Award for his work in starting and propagating the Honor Air Project to take WWII veterans to Washington, D.C. to visit the WWII Memorial. Jeff was unable to attend CLEAN 07 in Vegas to receive his award in person because he was in D.C. escorting another group of veterans at the Memorial so we had the pleasure of his company and the opportunity to thank him personally for the great work he is doing. Two other NC drycleaners are carrying on his work in their home counties. Bayard Crumpton, NuWay Cleaners in Roxboro chaired his Rotary Club's project in Person County which took seven buses to the Memorial and Marvin Thomas; Swannanoa Cleaners is currently mounting a similar project with his Rotary Club in Asheville (Buncombe County).

Another special guest Tom Gosselin and his wife Maureen who joined us for the weekend were not guest for long. The Gosselin's recently retired to their home in Burnsville after selling their Laundry and Drycleaning business in New Hampshire. Tom, a long time active member of the North East Fabricare Association and DLI has served on the Board of NEFA for many years and as their president and was the DLI Director from Dist 1 when he sold his business. The first action of the Board was to make Tom a Life Active Member of NCALC after which President Gloria Cowell appointed him a Director At Large and so he was a guest no more. WELCOME TOM & MAUREEN to our family of friends and fellow cleaners.

In other action the Board approved recommendations from the committees to:
· Authorize the Executive Director to renew the Association's CD at Carolina Bank November 16, 2007
· Approved the wording for the brick to be placed in Legacy Lane at DLI in honor of Ted Williams:
"TED WILLIAMS, INNOVATIVE AND
DEDICATED LEADER TO NCALC'
· Approved the Guidelines for the Mentorship Program
· Approved the wording of the Letters of Acknowledgement and Notification for donations to the NCALC Scholarship Fund
· Approved acceptance of the proposal from the Atlantic Beach Sheraton as the site for CAROLINA CLEAN 09 & 10
· Approved the recommendation of the DLI Board of Directors for a 2.8% inflationary dues increase to take affect with April 08 renewals.

The Board also accepted reports from the committees on their on going work in their areas of responsibility.

The Governmental Committee reported that:
· The Amendments to the Dry-cleaning Solvent Cleanup Act were passed by the Legislature and signed by the Governor August 31, 2007
· Final approval of the Risk Based Cleanup Rules by the Rules Review Commission is expected on September 20, 2007.
· NCALC has submitted our final comments on the Risk Based Cleanup Rules Guidance, prepared by Sam Taylor and Dr. Leslie Hay Wilson, to the DSCA staff and we are waiting for their response. Our concerns are mostly technical in nature.
· Although pledges and payments to Legislative/Regulatory Fund have been substantial so far this year we are still $3,000 short of our goal of $30,000 in pledges and $8000.00 short in payments. It was also noted that over 50% of the funds received have come from Board & Committee members.

The Member Services Committee reported that:
· Sandra Haralson, CED and DLI certified trainer will be conducting an AOE approved drycleaning finishing class at Medlin-Davis Cleaners in Apex, October 13, 2007
· Chris Allsbrooks, DLI Garment Analyst and Instructor will be conducting four Customer Service & Problem Garment Seminars in Greenville, Charlotte, Asheville and Raleigh October 21-24, 2007.
· Cathy Richardson AOE subcommittee chair will be sending an AOE Satisfaction & Suggestion Survey to N.C. AOE cleaners to obtain feedback for input to DLI on program improvement.

The Membership Committee reported that:
· 14 New Members have joined NCALC since December 2006. Nine were recruited by NCLAC putting us second only to seven-state regional North East Fabricare Association with 20. Drycleaners and Allied Trades are encouraged to keep up their efforts to encourage non-members to join.
· Overall our membership has dropped by three since June due to members not renewing on time. Hopefully, this is due to the slower summer business, and they will renew as business picks up in the fall.
· The New Member Rewards Program which is worth more than annual dues to a new member in any dues category is still in effect. This is in addition to the almost $2000.00 in average savings members receive from utilizing DLI & NCALC endorsed credit card processing and bad check collection services and business insurance program.

The Trusteeship Committee reported that:
· Their review of the Associations Financial Statements and condition found everything to be in order.
· They will be recruiting retired and active drycleaners to serve as mentors. Anyone interested in serving as a member should contact Martin Young, Young Cleaners, Concord at 704-786-3011.

DLI Board Changes
2007-2008 Executive Committee
President
Barbara Harvey
Fabricare by Fran
Severna Park, Maryland
Chairman
H. Steven Poulos
Blair's Cleaners/ Elmest Inc.
North Canton, Ohio
President-Elect
Peter Valessares
M.K. Cleaners
Chicago, Illinois
Treasurer
Ed Robinson
Ed Robinson Laundry/Dry Cleaning
Columbia,
South Carolina
New Directors
District 1
Andrew Tirpok
Tirpok Cleaners
Flemington, New Jersey
District 5
Rick Kasperbauer
Kasperbauer Cleaners
Carroll, Iowa
International
Malcolm MacGregor
Browns Cleaners
Ottawa, Ontario
Allied Trades
Joven Lactaoen
Joven's Sales and Service
Los Angeles, California

Ignore Social Security "No-Match" Letters at Your Peril!
Employers may receive a letter from the Social Security Administration ("SSA"), notifying them that specified employees' names and social security numbers do not match SSA's records. Employers have sometimes reacted to a "no-match" letter by terminating the employees named in it. This is not a prudent response, as the letter itself is not proof of illegal status, and termination of employment without investigation of the reason for the discrepancy may lead to a claim of national origin discrimination. At the opposite end of the spectrum, some employers simply ignored the letters. This is also not a prudent response, particularly now that the Department of Homeland Security ("DHS") has clarified its stance on employer actions in response to no-match letters.

For years, some confusion has existed about exactly what is required of employers in regards to I-9 forms and no-match letters. Recently, the federal government implemented new regulations which state that an employer who ignores a no-match letter can be found to have constructive knowledge that it is employing an unauthorized worker. Knowingly employing an unauthorized worker can lead to a civil fine of as much as $2,000 per unauthorized worker for a first offense. DHS is proposing to increase these penalties by 25%. In addition, DHS has the ability to seek criminal penalties against employers who knowingly employ unauthorized workers.

However, within a couple of weeks of passing the new legislation, a federal district court in California issued a temporary restraining order against DHS and SSA which prohibits those agencies from implementing these new regulations. Thus, the new rules, including the safe harbor provision discussed below, are not in effect yet, but will be if the temporary restraining order is dissolved, and prudent employers should know what impact the law will have if and when it takes effect. Employers should also understand that the procedures outlined within the new legislation will help protect them, regardless of the status of the law.

The new regulations set out specific procedures that employers can follow to take advantage of a "safe harbor" against being found to have constructive knowledge of a worker's unauthorized status arising from the receipt of a no-match letter or a communication from DHS questioning the validity of immigration documents examined during the course of an I-9 audit. (Of course, if the employer has actual knowledge of a worker's unauthorized status, the safe harbor may not provide protection.) The various steps of the safe harbor procedure must be completed within specified time frames, lasting no longer than 93 days from the employer's receipt of the no-match letter.

Within thirty days of receipt of the letter, the employer should check his records to confirm whether or not there was a clerical error. If there was a clerical error, he or she should inform SSA of the corrected information and verify and document that the discrepancy has been resolved. If the mismatch was not a clerical error, the employer should request the employee confirm the accuracy of his or her social security number and then provide the correct information to SSA. If the employee states that the number listed is correct, the employer should have the employee contact SSA within 90 days of the no-match letter to resolve it. If the matter is not resolved within 90 days of the no-match letter, the employer should complete a new I-9 for the employee, and be careful not to accept documents that contain the same social security number at issue. The employee must also present photograph identification as provided in the I-9, and the employee should complete new tax return documents with the new information. All documents, including both of the employee's I-9 forms, should be held in a file by the employer. If the employee cannot complete a new I-9, he or she should be terminated. By following these procedures, the employer should avail himself of the safe harbor protection.

Prior to even receiving a no-match letter, prudent employers should establish procedures, like those discussed above, for dealing with a no-match letter. DHS says that it will consider the totality of relevant circumstances in determining the employer's "constructive knowledge" of illegal employment, but following the new regulations should help protect against DHS fines and penalties. Furthermore, employers should be reminded that no-match letters are only issued when SSA finds more than ten mismatched social security numbers. It is unlikely that small employers will ever receive the mismatch letters, yet they remain responsible for taking the appropriate steps to verify employment eligibility as outlined in the I-9. Careful and consistently applied procedures should help prevent claims of national origin discrimination while also protecting employers from liability for illegal workers.

Julie Hampton is a litigation attorney in the Raleigh office of Poyner & Spruill LLP.

Portions of this article came from a publication authored by Susie Gibbons, an employment law attorney in the Raleigh office of Poyner & Spruill LLP, and can be found in their entirety at www.poynerspruill.com.

Ways NCALC Has Saved You Money
· Dry-cleaning Solvent cleanup Act of 1997 limited your liability for the cleanup of a contaminated site to a maximum of
$39,000 for an abandoned site
$29,000 for active site with > 10 FTE'S *
$21,000 for active site with 5 - 10 FTE's
$13,000 for active site with < 5 FTE's
for a clean-up that cost $1 Million or More.
· Amendments to the Dry-cleaning Solvent Cleanup Act in 2000 removed the requirement that every plant site maintain in-force a one million dollar contamination liability insurance policy. An annual savings of $1500 to $2500.

· Removal of the Sales Tax on fuel oil and propane used in the direct production of drycleaning and laundry (i.e. to fire the boiler), laundry and dry-cleaning machinery, parts and accessories (i.e. filter cartridges, pads & covers) attached to the machinery and lubricants applied to the machinery. THE ALTERNATIVE WOULD HAVE BEEN 61/2 TO 7% SALES TAX WITH NO MAXIMUM. Your savings, if you buy a $35,000 piece of equipment is $2275 to $2450.

· Amendments to the Dry-cleaning Solvent Cleanup Act in 2007 replaced the $5,000, $10,000, $15,000 or $25,000 up front cost (i.e. deductibles) and replaced them with a $1000 registration fee and co-pay formula which reduced a petitioner's front end and maximum liability for clean-up cost, to a maximum of:
$21,000 for active site with > 10 FTE'S *
$16,000 for active site with 5 - 10 FTE's
$11,000 for active site with < 5 FTE's
$16,000 for an inactive site
** FTE - Full Time Employee Equivalents

Solvent Options
Cleaners Share Their Experiences at Clean '07

PETROLEUM SOLVENT
Gary Dawson
Belleair Bluffs Cleaners, Belleair Bluffs, Florida

Pros
Equipment
· No special equipment was needed to process petroleum based cleaning.

Regulations
· Quite honestly with petroleum based solvents having minimal regulations it was apparent that this was the direction for us to go.

Processing/Operations
· Petroleum solvent seems to be easier on the fabrics that we clean especially items with sequins, plastics, and elastics. We also noticed that aluminum zippers and invisible zippers are not the problem they used to be.
· No special supplies were required
· No needed changes in pressing procedures or equipment.

Marketing
· We have made no marketing changes. I'm a drycleaner and I'm out to do a quality job no matter what solvent I use and do it responsibly.

Cons
Equipment
· The cost of the equipment is 50-60 % higher than an equivalent perc system.

Processing/Operations
· Running times are longer. We are averaging 65-70 minutes per load to do a proper cleaning job. We find that we need to start earlier in the morning and end later in the day to get the poundage out.
· In stain removal we can no longer put damp items in for cleaning and can also no longer leave any chemical residue (POG, Amyl Acetate, etc.) on garments to be cleaned as these products can contribute to odors in the solvent. Everything needs to be flushed and dried before cleaning.
· There is more maintenance on a machine with petroleum based products than with perc. Things such as water separators need to be cleaned weekly as well as cleaning the base tanks once or twice a year basis to prevent bacteria from building up contaminating the solvent. Once that happens you will need to replace the solvent in the entire system and clean the base tanks and separators to remove the odor.

PERCHLOROETHYLENE
Chris Edwards
A Cleaner World, High Point, NC

Pros
Equipment
· We continue to use perc because we believe that with today's equipment, and with proper operator training we can still do what is best for our customer's garments while at the same time protecting from a release to the environment.

Processing/Operations
· We have been using perc since our company was founded in 1969. It is the best overall solvent we have found for cleaning clothes.

· We have experimented with one Green Earth machine and two DF 2000 machines in the past, but are 100% perc at this time. We plan to continue to use perc for the foreseeable future, but we are open to some interesting processes that are just appearing on the horizon.

Cons
Regulations
· We realize there are disadvantages such as environmental concerns.

Processing/Operations
· There can be problems with buttons and trim, and in some cases it is quite strong for certain garments. We also supplement our cleaning with professional wet cleaning equipment.

CO2
Tom Ustanik
Lansing Cleaners, Lansing, IL

Pros
Equipment
· For conventional loads 55 pounds 40 minutes.
· For fire loads 50 pounds 51 minutes.
· Even though the machines have a high starting cost, they're engineered for a considerably longer life.
· We did not need to purchase any special equipment that may not have been necessary for any another drycleaning machine other than a fill vessel for the CO2.

Processing/Operations
· Gentle on garments, little or no dye loss, little pilling or crocking, no heat related shrinkage issues and the ability to clean leathers, most trims, and furs without any of the hazards of heat needed for drying. Additionally, silks due to the no heat drying and detergent allow additional brighteners to be left behind and without removing the natural oils from the materials. The hand and appearance of soft wools is superior to most other cleaning systems.
· The ability to run full loads that gives us higher production.
· Pressing with CO2 is simpler than other systems since there is no heat required for dying eliminating shrinkage and basket wrinkles. The garments come out slightly dehydrated and cold. They pick up moisture and warm up at room temperature. With CO2, we are able to process as much as 25% of the volume through a steam tunnel with little or no touchup.
· We had to purchase the necessary supplies, such as detergents and pre-spotters that are used for CO2 cleaning systems.
· Initially it was suggested that we do more pre-spotting. We eliminated most pre-spotting and proceeded to do only post-spotting. We have found since there is no heat used for tumble drying most of the remaining stains are removed with steam. This reduces the use of chemicals in stain removal and less time spent removing stains.
· We are able to run full 50 pound loads every time in the machine. Production on a per day basis is considerably faster than it was previously with perc, where we had to separate loads for bleeders, lights, darks, lightweights, heavyweights, and drying issues. With CO2, none of those issues exist.
· The actual pressing time has, on average, declined due to the fact of no heat.
· The CO2 is less harsh and allows the garments to maintain a better hand which helps increase pressing pieces per hour.

Regulations
· As a larger cleaning operation and being involved heavily with state regulators in regards to other programs outside of the drycleaning industry we felt that a large operations such as ours would be primary targets for further regulations. CO2 has none of the issues that perc has with ground contamination, airborne's and vapor intrusion.
· Also with the elimination of contamination issues especially in a green field site, could virtually eliminate the possibility of any further contamination issues for that operation.

Marketing
· We market CO2 primarily for our fire restoration services which has been a considerable benefit to our operation. We do not hear complaints that we used too harsh of a chemical, or that they are allergic.
· The fact we use a low temperature for the most part eliminates most shrinkage issues is another point we can use for marketing.
· We also clean garment for clients that have chemical allergies upon request.
· We've used it for mold remediation with considerable success and positive documentation.
· Using CO2 has allowed us to continue to grow our restoration business.
· It has helped us win three Governor's Pollution Prevention awards, be a tour member for the National Pollution Prevention Roundtable convention and has allowed us to be meet a large number of Federal, State and even Canadian environmental and pollution prevention officers.
· All of the above have given us positive newspaper coverage, which would not have been possible in any other manner.

Cons
Equipment
· Initial cost of the machine was considerably more expensive than a typical drycleaning machine although the price of the machines today has come down from the original.

Processing/Operations
· Due to the fact that it is under pressure water does not function the same as in other cleaning systems. This does not allow for the full removal of water-based stains. The stains that do come to the surface are considerably easier to remove due to the lack of heat in drying and the fact that they re brought direct to the surface of the fibers. They still have to be contended with even though that is not a drastic problem it is one that we have to deal with. The same factors that make CO2 a very gentle cleaning solvent does lack solvent weight and solvent weight is a precursor to particulate removal.
· It can't be used effectively on every garment. Some examples of items that can not be cleaned in CO2 are triacetate, some acetates, and garments with glued on beads that have hollow centers and no hole where as solid beads with a hole are not affected.
· Built up latex appliqués and lettering absorb CO2 and bubble up. Some may restore themselves after degassing but others do not. It is difficult to determine which ones will or will not fail.

GREENEARTH
Fran Sadler
Medlin Davis Cleaners, Raleigh, North Carolina

Pros
Equipment
· No changes in pressing procedures or equipment was needed.
· There is no increase in the routine daily maintenance, such as cleaning the lint and button traps.

Processing/Operations
· GreenEarth has delivered a greater sense of confidence to our employees and customers because of its ability to clean garments embellished with trims, without hesitation.
· Price per gallon is $17.00.
· Because of the low surface tension GreenEarth is very gentle on the garments, which keeps them looking like-new longer.
· Darks are rich and deep in color as if they have been through a mineral oil bath.
· There is virtually no odor, very little "free" lint, and the clothes have an extremely soft hand.
· We did increase our wetcleaning capabilities, but I strongly believe we would have done the same if we were using any solvent.
· There are excellent paint, oil, and grease removers and levelers that are compatible with GreenEarth. The special compatible wet-side stain removal agents manufactured can be applied to the stain and immediately cleaned.
· We have found the traditional tannin and protein formulas to be more affective on those types of wet-side stains, such as coffee or blood. Just as you would with perc, you must flush them with steam and the fabric must be dry before re-cleaning.
· The finishing may actually be slightly easier and faster due to the very soft hand.

Regulations
· We chose GreenEarth because of our concern for being environmentally responsible, by reducing hazardous waste and risk to the employees and the environment.
· Our decision to change to GreenEarth was based on many factors; leasing verses owning, existing contamination issues, our inability to renew leases due to the landlord's preferences, and our state clean-up fund.
· At our main location, switching to GreenEarth was the landlord's stipulation.
· At the other two GreenEarth plants, where we own the real-estate, liability, risk to future generations, and future marketability to buyers of the business was still the deciding factor.
· In North Carolina, landlord issues from REIT's and national shopping center developers are the primary force in solvent selection.
· A reduction in hazardous waste expenses may be realized based on your state's regulations.

Marketing
· We have experienced an opportunity to capture the environmentally conscientious client. Our advertising efforts have benefited from emphasizing environmental awareness.
· The market for wedding gowns and high-end specialty items has delivered an overall increase in all garment types.

Cons
Equipment
· Due to longer running times we needed to double our poundage capacity in order to produce the same volume in the same amount of time. The capital investment for a 40 lb. machine is about ·55,000, a 60lb. machine is about ·65,000.
· As a consequence of buying a larger capacity machine we needed to increase the size of our chillers, which necessitated an electrical up-grade as well.

Processing/Operations
· Because GreenEarth and water weigh about the same, there is a greater sensitivity to odor problems, which may allow bacteria grow. Consequently we have found our operator's must be very diligent. The water separators must be cleaned weekly. Twice a year our maintenance department cleans out the base tanks, the steam coils, and the condensing coils.
· The only difference with GreenEarth spotting is wet-dry products, such as Wetspo, Semi-wet, 2 in 1 formula, etc., cannot be used unless they are flushed from the fabric. With perc those products do not need to be flushed.
· Our stain removal technicians have become more conscientious about pre-spotting and experts at post-spotting given that re-cleaning is time consuming and upsets the lot control.
· In some cases we have had an occasional angora sweater or very soft wool shrink either because of the longer cleaning times/mechanical action or the required high drying temperature.
· There is an occasional dye-bleed or dry transfer. Even though this type of damage is a tiny fraction of the damage associated with perc you should separate lights from darks.
· Cleaning and drying is 70 - 80 minutes for a regular load.
· Some items will not dry if they are in a net bag.
· There is an increase in stain removal.

Joe Iannarelli
Fi-Del Inc., Bridgeville, Pennsylvania

Pros
Equipment
· No special equipment is needed to use DrySolv. We only had to make some minor changes to our perc machine. We reduced the steam pressure in the still to 10 psi and turned down the drying temperatures to 110ºF.
· We started with one test machine. Since we had such a positive experience with the first we changed the solvent in our other two machines.

Processing/Operations
· Cleaning is simple and fast with good results.
· The average time to clean and dry a load is 25 to 32 minutes.
· We have been able increase production by up to 2-3 pieces per operator hour by using DrySolv.
· We are able to run with one base tank because DrySolv distills faster than perc so the still is able to keep up with the shorter cleaning cycles.
· The clothes are dried at 110ºF leaving fewer wrinkles requiring less steam, vacuum, and time in pressing.
· Stain removal is very similar to what we were doing before with less prespotting on the dry side.
· We have found a cationic detergent gives us the best results.
· Production takes less time with DrySolv, both cleaning and finishing.
· We have had no special machine maintenance issues.
· The price of the solvent has been off set by lower utilities due to lower drying and distillation temperatures as well as labor.

Regulations
· Reason we changed was due to environmental issues with perc. We also wanted to insure that there would be no problems related to contamination should we want to seek further financing from an institution.
· We checked with a other sources and also conferred with the Department of Environmental Protection who had no issues with DrySolv.

Marketing
· You can market a product that is a friend to the environment. Customers seem to like that very much.
Cons
· The price is $40 a gallon.
Although I use every solvent being discussed on the panel, Perc, PureDry, CO2, Solvair, and Green Earth the common thread throughout all my operations is wet-cleaning.

Pros
Equipment
· We began using tensioning equipment almost immediately after beginning wet-cleaning, and I would never go back to traditional presses. An important change for our pressers was getting used to pressing garments which were still damp. We had to figure out the correct finishing agent which gave us the best look and feel in the least amount of time.

Processing/Operations
· We are in our 9th year using the Miele wet-cleaning system. While we have had one plant run strictly wet-cleaning for a period of time, we now universally use wet-cleaning as an adjunct to solvent cleaning. The mix varies according to the region of the country and the season. In general the percentages range from 30% - 60%.
· The most favorable reasons for wet-cleaning are the quality of the finished product. Beautiful whites, cottons, linens, silks with no graying or yellowing and no odors. With automation comes consistency without guesswork. Since baths are mostly on the wet-side anyway, moving to a wet-cleaning program afterwards is so easy we find we do much more soaking and bleaching, which in turn increases stain removal and customer satisfaction.
· Because most spotting takes place on the wet-side, wet-cleaning has made our spotting much easier. We do not wait to dry garments for re-dry-cleaning. We simply put them in the next wet-cleaning load according to program selection.

Marketing
· We heavily marketed wet-cleaning when we first introduced it using brochures, hang-tags, and customer service training. But now we just mention it in all our printing and ad copy along with our other services as an alternative to traditional solvent.

Cons
Processing/Operations
· Our experiment running 100% wet-cleaning convinced us that while it was a valuable experience which forced us to learn about reading labels and proper classification, it was too great a departure from what we were comfortable with in a high volume operation. Were we a smaller shop, I'm sure it would have been a viable option for us to go 100%.
· The least favorable reasons for wet-cleaning vary from the occasional human error resulting in a problem to the ongoing splitting of lots and orders. Testing for colors is a must if you want to avoid bleeding and employees sometimes over dry garments resulting in shrinkage.
· While the average cycle time is just 21 minutes for wet-cleaning and 40 minutes for washing, the breakdown necessary for proper classification means that garments are ready for pressing at many different times. If a plant uses just 3 basic programs for example 1 for silks, 1 for wools, and 1 for cottons / khakis, with the separation for lights and darks, that means 6 different loads. A great deal of discipline is required to keep work flowing together.
· Dry-side stains can be a problem. While most chemical companies have dry-side spotting agents for wet-cleaning, some stains prove to be too imbedded and must be dry-cleaned.