Regulatory Requirements for Operating a Laundry and Dry Cleaning Business

When operating a laundry or dry-cleaning business, owners must comply with general business regulations as well as requirements specific to the laundry industry. Because the U.S. government system is structured across multiple levels—federal, state, county, and local (city or borough)—the applicable regulations vary by location and can be complex.

With the exception of drop stores, all dry cleaners operate washing equipment and boilers. The major regulatory requirements associated with these operations include the following:

(1) Boiler Registration and Inspection

Boilers (generally classified as high-pressure vessels) must be registered with the state government, and inspections must be conducted annually. Most dry-cleaning business insurance policies include Equipment Breakdown coverage, which allows boiler inspections to be conducted through the store’s insurance provider.

Typically, two inspections are required each year:

• Internal inspection: conducted while the boiler is shut down
• External inspection: conducted while the boiler is operating

Dry-cleaning business insurance companies (such as Insurer A or B) subcontract boiler inspections to specialized equipment insurance carriers—such as Hartford Steam Boiler, CNA, Zurich, FM Global, Travelers, and others—under their Equipment Breakdown coverage. As a result, boiler inspections are often performed by these specialized insurers rather than the store’s primary business insurer, a point that is frequently misunderstood by dry-cleaning operators.

If a business does not carry insurance, or if its insurance provider does not offer boiler inspection services, inspections must be performed either by a government inspector or by an authorized private inspection company.

In insurance-based inspections, the inspecting insurer typically invoices the business for the boiler registration fee. After payment, the inspection report and fee are forwarded to the state or relevant authority, which then issues the boiler registration certificate.

If a dry cleaner switches insurance providers, differences in policy terms may result in missed inspections, potentially leading to penalties from regulatory authorities. Operators should pay close attention during insurance transitions.

In addition, some jurisdictions require a boiler operator license (similar to a driver’s license). Licensing requirements vary by state and local authority and should be verified.

For example, in New York State, boiler inspections are regulated by two primary agencies:

• New York State Department of Labor (DOL) for most of the state
• New York City Department of Buildings (DOB) for the five boroughs

The NYC DOB does not conduct boiler inspections. Therefore, businesses in New York City without qualifying insurance coverage must arrange inspections directly through approved private inspection firms. Failure to complete inspections by year-end often results in penalties.

(2) Laundry Equipment Permits

Laundry equipment can be classified into:

• Perc (PERC) machines (3rd and 4th generation)
• Alternative solvent machines (hydrocarbon, carbon, silicone; classified as non-hazardous air pollutants)
• Wet-cleaning equipment

Under federal EPA and state regulations, all PERC and alternative solvent machines—excluding wet-cleaning equipment—must obtain an air emissions permit (commonly referred to as a machine registration) from the state government.

PERC has long been considered the most effective dry-cleaning solvent and was widely used in the industry. However, under the Clean Air Act, PERC is designated as a hazardous air pollutant. The U.S. Environmental Protection Agency (EPA) has mandated that PERC machines will be prohibited from use after December 19, 2034.

Additional restrictions, including earlier phase-out dates or usage limits, may be imposed by individual states and must be reviewed separately.

(3) Solvent Leak Detection and Usage Records

Under the EPA’s NESHAP (National Emission Standards for Hazardous Air Pollutants) regulations, dry cleaners are required to minimize emissions of hazardous air pollutants. This includes maintaining records related to:

• Solvent leak inspections
• Solvent consumption
• Number of cleaning cycles
• Refrigerated condenser temperatures or pressures

Records must be maintained in accordance with state-prescribed formats or standards. Failure to comply may result in fines or penalties.

(4) Right-to-Know Survey

The EPA requires dry cleaners using chemical solvents (including PERC) to submit an annual Right-to-Know survey by March 1, reporting solvent usage from the previous calendar year.

Using state-specific forms, the survey must be submitted to relevant agencies, which may include:

• State environmental agency
• Local police department
• Fire department
• County authorities

A copy of the submitted survey must generally be retained for five years. While some states do not enforce this requirement, certain local governments—such as New York City—do.

(5) Waste Disposal and EPA ID Number

Waste generated by dry cleaners—including hazardous waste, spent solvents, filters, and distillation residues—must be stored in sealed hazardous waste containers with proper labeling. Disposal records must be retained for at least three years.

Each container label must include:

• Date filled
• Quantity
• Contents
• Business name and address

Based on the volume of waste generated per month, dry cleaners are classified as:

• Large Quantity Generators (LQG)
• Small Quantity Generators (SQG)
• Conditionally Exempt Small Quantity Generators (CESQG)

Businesses classified as small quantity generators or higher must obtain an EPA ID number. Waste disposal companies use this ID number to issue a hazardous waste manifest (receipt) upon collection. Copies of the manifest are provided to the business and reported to both the EPA and the relevant state environmental agency.