Rolling the Dice for Regulatory Closure—3 Rules on How to Hedge Your Bets and Come Out a Winner

Environmental cleanups involve a great deal of creativity to make sure that the goals are met within acceptable timeframes, regulatory requirements, and of course, budget. The whole game plan is to reduce the amounts of contamination in the ground to levels that are deemed safe for human health and the environment should an exposure occur at some time in the future.

While a good environmental consulting firm will be able to tell you what kind of cleanup approach is most likely to be successful, they will base that opinion on their own past experience in similar situations and the published past experiences of their professional peers in the industry. Unfortunately, there is not an “off-the-shelf” approach that is guaranteed to work, so in many ways, a cleanup effort is a proverbial roll of the dice.

However, there are some consulting firms like ours who will stand behind their designs and guarantee results. Our ability to do this is due to several factors that help us hedge our bets when performing an environmental cleanup. If you follow these three rules of creating a successful cleanup plan, you can come out on top as well.

1. Experience Counts!

During my college pursuits, I had a professor who always used to say, “The best geologist is the one who has seen the most rocks”. I always took that to heart and mention it often to my peers. I’m sure it’s also true that the best cleaner is the one who has processed the most articles of clothing or textiles. Why? Because they are the ones who have experienced the most situations where challenges have come up that needed to be solved. They’re the ones who learned from each of those situations and tweaked their process to make sure that the occurrence of the same problem was minimized in the future. Each challenge is a learning opportunity, and those who have learned the most, are frequently the best.

I’ve said it before, and I’ll say it a thousand more times that when you are choosing your environmental consultant to design and implement your environmental cleanup strategy, you need to find one who has a great depth of experience with dry cleaner sites. They are the ones who will understand the nuances of Perc contamination. They are the ones who have had to decipher the subtle differences between releases from dry cleaner operations and other kinds of processes. They’re the professionals who have seen the most cleanup challenges and solved them to get the job done and achieve regulatory closure.

Get a step-by-step process in “5 considerations when selecting an environmental consultant for dry cleaners”

2. Strategically Plan Investigation to Save Money During Remediation

Let’s face it; the subsurface environment is a bit of a black box. Geologists and environmental professionals are educated and trained to interpret a wide view of conditions beneath the ground from only a handful of data collection points and samples. The more data collected during investigation phases, the better conditions are understood and the greater the odds of a successful remediation later. Remember that the process is:

  1. Investigate the nature and extent of contamination; and
  2. Perform the cleanup.

If the full nature and extent of contamination is not really understood, the cleanup plan has almost no chance of success. Way too often, consultants with less experience think that just because they have the contaminant plume defined in all directions, they are finished with the investigation. There are a lot more data points that need to be explored to really understand the nature of the impacts, which will also allow for a good predictive cleanup approach to be prepared. These include, in part, the naturally occurring geochemistry of the soil and groundwater, actual measurements of porosity and permeability, the calculated rate of groundwater migration across the site, the organic content of soils, the infiltration rate of rainwater down through the soils and into the groundwater, etc. These data points are where the surprises usually come during cleanup if they haven’t yet been considered.

The trick to making sure that an environmental investigation is performed correctly is to collect information needed to design the cleanup approach and retrieve that data at the same time. If the focus of the investigation is to simply determine the extent of the contamination plume, then only part of the picture is being captured. Given that situation, a separate remedial planning phase of the investigation will then have to be undertaken to get this vital information, which will likely involve going back to areas where the previous sampling has already occurred. This adds cost to the project. Because of this point, there may be hesitation to approve the remedial planning investigation, leaving the consultant to design a cleanup approach without all the necessary information.

If performed appropriately, remedial planning investigation efforts can be added for as little as a 10% increase in costs. However, if something is overlooked during an investigation and a cleanup plan is inappropriately designed because of it, the extra effort could easily double the price of the cleanup itself. If you ask a remedial contractor what causes cleanup plans to fail, they will almost always say a lack of adequate investigation data. I always ask them that, and that’s what they always say. Spend the extra 10% on an investigation, it will save you money during remediation. Period.

Read more about remediation strategy best practices

3. Combine Remedial Technologies

Ideally, once a cleanup begins, it ends when the remedial objectives have been met and enough contamination has been removed. Sounds simple enough. Many times, cleanup projects start very well and appear to be heading toward closure (even under budget), but the cleanup appears to stop working. This is among the challenges requiring creativity to get the last bit of contamination out of the ground. Oh sure, the first 90 to 95 percent of the contamination is removed very quickly and effectively and this makes everyone happy. But as time passes, the effectiveness of the cleanup can dwindle making everyone unhappy. The levels of contamination may continue to slowly decrease, but never quite get to closure levels under a single approach. It’s not so much that it stopped working, as it is that it reached a point where it is no longer cost-effective to continue. This happens with a lot of good cleanup technologies. So, with the clock still ticking, the money still flowing into the project, and contamination removal rates slowing, there needs to be a shift in strategy to get the job completed.

With a multitude of remediation technologies available for use, it’s important to follow a logical, yet creative path to select the right combination from the very beginning. For example, let’s say technology A is used because the level of contamination is high, and it is expected to effectively reduce the level of impact to low, but not low enough. When the removal rate of technology A slows down to a crawl, we change to technology B to treat the remaining concentrations to a lower level and achieve closure. Usually, technology B can be performed at a lower unit rate cost than technology A and therefore, project costs can also be constrained. Clearly, cost considerations are very important, but for the purpose of this discussion, the point is that it should not be assumed that using one contaminant removal technology alone is the right approach.

Dealing with the stress and cost of environmental contamination issues is bad enough on its own. Paying attention to these three rules of cleanup planning will help you avoid a bad roll of the dice and let you double down on your bet for a successful project.


As seen in Cleaner & Launderer

Jeff Carnahan, President at EnviroForensics
Jeff Carnahan, LPG, has 20+ years of environmental consulting and remediation experience. His technical expertise focuses on the investigation and interpretation of subsurface releases of hazardous substances for the purpose of evaluating and controlling the risk and cost implications. He has focused on being a partner with the dry cleaning industry for the past decade, and he’s a frequent contributor to the national dry cleaning publication Cleaner & Launderer. He is an industry leader in understanding that environmental risk includes not only cleanup costs, but also known and unknown third-party liability.

7 Drycleaning Industry Predictions for the Next 10 Years


 Disclaimer: These responses were written in January 2020 prior to COVID-19 in the United States

Drycleaning business owners are accustomed to the ever-evolving industry standards and practices – making change a way of life for drycleaners of all sizes. They are constantly applying new ways to run their businesses more efficiently and keep their loyal customers coming back. Drycleaners are learning new ways to clean stains and new fabrics, grow their business, manage marketing programs, train their staff and explore new technologies such as point-of-sale systems.

While it’s impossible to see the future, we can make educated guesses about it. In this article, we asked seven industry leaders from across the country to share where they see the drycleaning industry going in the next 10 years. Here are their predictions.

Mary Scalco – CEO, Drycleaning & Laundry Institute
“In 2030, I believe we’ll be seeing fewer drycleaning facilities. I think we will go ‘back to the future’ with larger central facilities being fed by more and more drop-off retail locations, pick-up and delivery routes, lockers, and other convenient ways to transfer the items back and forth.

I think drycleaners will continue to offer a wider variety of services in addition to drycleaning such as wash-dry-fold, commercial linen cleaning, and other diverse services. As cleaners increase the percentage of customers wardrobes that they receive for cleaning they will also see an increase of household textiles as drycleaners care for more linens, draperies, carpets, and other household items.

They will offer their services in ever more convenient ways with longer business hours, routes, drop-off facilities, and on-demand pick-up.

Point of sale systems and apps will track when garments are cleaned and send reminders to consumers much like the oil change sticker on your car. Robotics will be introduced in some capacity. Consumers, who will be more and more environmentally conscience, will continue to drive how cleaners process and package their items.”


Mark Pollock, C.P.D. – Director of Operations, Signature Cleaners and Member, Drycleaning & Laundry Institute Board
“Going forward I see significant changes to the Fabricare industry. More central plants servicing more satellite locations. Automation continuing to lessen the reliance on a shrinking labor pool. The need to provide added related services giving customers more reasons to patronize your company.”


Chuck Hempstead – Executive Director, Southwest Drycleaners Association
“It looks to me that by the end of this new decade the growing drycleaning operations will be the ones that diversify their operations – be that routes, cleaning non-traditional items like footwear, wash and fold, and simplifying the customer experience. Differentiating from one’s competitors will include emphasizing quality and mastering marketing. Also, we’ll continue to see consolidation as economy of scale is applicable to all industries.

Association membership will grow in importance to the successful companies in order for them to remain competitive. Change and opportunity occur too fast for any of us to go it alone.”


Wisconsin Fabricare Institute
“The Drycleaning Industry has seen its ups and downs over the last 40 years. I feel in the next 10 years, the Drycleaning Industry will be thriving. There will always be a need to have your fine garments dry cleaned. With all the help from outside sources, dry cleaners are doing their best in being more environmentally friendly in their cleaning process and in their packaging process. We have continuing education at our hands-on how to succeed and to keep our industry from failing.”


Tim Burke – Editor, American Drycleaner
“Many garment care owners tell me they are adding services to their operations to offer more to their clients. The most progressive minded say they will continue to keep up with their clients’ need for convenience, such as with technology. And they tell me they strive to make their operations look modern, and to always help their clients look their best. That won’t change. It’s what they do.”


Darcy Moen – Drycleaning Industry Consultant and Columnist for Cleaner & Launderer magazine
“As the baby boom demographic bulge moves through the owners of drycleaning businesses we will see a decline in the number of dry cleaners as owners retire. Many of the children of owners have moved into other careers and won’t be following in the footsteps of their parents. But as one generation moves on, I see newcomers with fresh eyes stepping in creating new ways of doing business. As the gig economy influences drycleaning and laundry services I expect to see a dramatic surge of new ‘on demand’ types of drycleaning and laundry growing.

Mass supply of lower cost of clothing has led to closets stuffed with more and more designer goods. Despite advances in laundry detergents and appliances, nobody has any more free time for cleaning and pressing clothes than they did ten years ago. In fact, with most people experiencing increased demands on their time from careers, family, and social commitments, there are fewer hours for personal fashion care than ever before. I can see huge pent up demand for cleaning services from masses of people with masses of clothes wanting affordable, quick and reliable fashion care maintenance for those mountains of clothes. The question is, who is going to do all that work? Most likely it will be done by a cleaner/launderer who can deliver a low cost and profitable service through a plant designed with efficient capacity to deliver cleaning. And by cleaning, I don’t mean a conventional drycleaning service but a hybrid of drycleaning and laundry services. I can foresee a new type of cleaner, one that focuses on delivering a crisp, clean, like new appearance but at a cost that is relative to the cost of quick fashion of today. Customers don’t care how we as an industry deliver service, just as long as their clothes are clean, pressed, looking like new and ready to wear at an affordable price with quick turn-around. The challenge of the next decade will lie in transforming plants of today into a new type of cleaning facility that can service a broader range of clothing at a price that is as affordable as doing your laundry at home while generating a profit. It’s up to us to rise to the challenge and find the solution of the magic bullet plant for the new markets that are emerging.”


Jeff Carnahan – President, EnviroForensics & PolicyFind
“In the twenty-plus years that we have been serving the drycleaning community, we have certainly seen changes in the market. Less small players, more consolidation, franchises, etc. What hasn’t changed is their hard work ethic, commitment to customer service, or comradery among peers. Regardless of how the drycleaning industry morphs in the coming years, I can’t see any of these going away. EnviroForensics and PolicyFind are proud of our association with dry cleaners and we’re honored to continue our commitment to them into the future.”

This decade will be trying for some and filled with opportunities for others. As with trends of any nature, some come and go, whereas others stay the course and become fundamentals. No matter a dry cleaner’s unique situation, they can rest assured that the entire drycleaning community is behind them and wants to see the best outcome for them.

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