EH&S Regulatory Update for Dry Cleaning Facility Due Diligence

By: Leah Krause

Considering the acquisition of a dry cleaning business or property where former dry cleaning operations took place? If so, environmental, health and safety due diligence is a critical component in protecting you from environmental liability.

There are many items to evaluate during due diligence due to the cleaning solvents dry cleaners use, and effective this year, the Small Business Association updated its Standard Operating Procedures (SOP) for Lender and Development Loan Programs. The revisions included new due diligence requirements for current and former dry cleaning facilities that used, likely used, or currently use chlorinated and/or petroleum-based solvents.

The previous version of the SOP required a Phase I Environmental Site Assessment (ESA) for all properties with current or former dry cleaning operations. A Phase II ESA (subsurface investigation) was only required for dry cleaners in operation for five years or more and used tetrachloroethylene (PCE) or trichloroethylene (TCE). The new revisions have removed the criteria regarding length of operation associated with the Phase II and an additional requirement was added which stipulates that the Phase II ESA address soil vapor intrusion, in addition to soil and groundwater contamination.

Determining the historical occupancy and uses of a property through the Phase I ESA process is key in evaluating the potential environmental liabilities. For more information on how EHS Support can help you manage corporate environmental liability, please contact Leah Krause at 412-915-1626 and or Bruce Martin at 703-944-4709 and


Leah KrauseABOUT THE AUTHOR: Leah Krause has over 18 years of experience in various sectors of the environmental field. The primary areas of experience include field experience, regulatory compliance support, onsite air pollution compliance, and regulatory experience in Queensland, Australia for the oil and gas industry. Primary duties throughout her career have included soil and groundwater sampling, installation of monitoring wells, management of an air pollution compliance program at a power company, and preparation of environmental permits for natural gas development in Australia. Leah has developed compliance documents, such as permit modification applications, Annual Monitoring Reports, Plan of Operations, Disturbance Protocols, and Environmental Management Plans for several natural gas companies in Australia… Read More




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