Dry Cleaning Solvent Management and Storage Audit Checklist [FREE PDF]

Dry cleaning solvent management is one of the most heavily regulated activities in the commercial laundry industry, primarily due to the pervasive health and environmental risks associated with perchloroethylene (PERC) and alternative solvents. EPA 40 CFR Part 63 Subpart M (National Emission Standards for Perchloroethylene Dry Cleaning Facilities) establishes strict emission, storage, and waste management requirements for both major and area source dry cleaners. OSHA 29 CFR 1910.1000 Table Z-1 s

  • Industry: Dry Cleaning
  • Frequency: Monthly
  • Estimated Time: 45-60 minutes
  • Role: Plant Manager
  • Total Items: 38
  • Compliance: EPA 40 CFR 63 Subpart M National Emission Standards for PERC Dry Cleaning, OSHA 29 CFR 1910.1000 Table Z-1 Air Contaminants (PERC PEL 100 ppm TWA), NFPA 32 Standard for Dry Cleaning Plants (2021 Edition), EPA 40 CFR 261 Hazardous Waste Identification (Spent PERC F002), State Air Quality Permit Conditions (Title V or Minor Source)

Solvent Inventory and Recordkeeping

Verify that solvent purchases, consumption, and inventory are accurately tracked and reported as required.

  • Is a solvent purchase log maintained with dates, quantities, and supplier information for all solvent deliveries?
  • Has monthly solvent consumption been calculated and recorded for the current reporting period?
  • What is the current total solvent inventory on-site in gallons?
  • Are all solvent purchase and inventory records retained for a minimum of 5 years?
  • Is there a written solvent management plan or standard operating procedure available on-site?

Solvent Storage Container and Area Compliance

Inspect all solvent storage containers, secondary containment, and storage area conditions for regulatory compliance.

  • Are all solvent storage containers properly labeled with contents, hazard class, and GHS pictograms?
  • Are solvent containers kept tightly sealed when not actively in use?
  • Is secondary containment (bermed floor or containment pallet) present capable of holding 110% of the largest container volume?
  • Are solvent containers stored away from ignition sources and separated from incompatible materials?
  • Are storage area temperature controls adequate to prevent excessive solvent volatilization?
  • Please photograph the solvent storage area including all containers and containment structures.

Equipment Leak Detection and Fugitive Emissions

Perform and document leak detection inspections on all dry cleaning machines, transfer equipment, and connecting components.

  • Has a leak inspection of all machine components been performed within the past 30 days using appropriate detection methods?
  • Are all door gaskets, seals, and hose connections on dry cleaning machines free of visible leaks or solvent residue?
  • Is the machine drum-to-door seal inspected before each shift or at minimum daily?
  • Are leak inspection results logged with date, component inspected, finding, and repair action?
  • Is an organic vapor analyzer (OVA) or equivalent PERC detection instrument available and calibrated on-site?

Worker Exposure Monitoring and PPE

Verify that worker PERC exposure levels are monitored, controlled, and documented in compliance with OSHA standards.

  • Has industrial hygiene air monitoring for PERC been conducted within the required monitoring interval?
  • Are current air monitoring results posted or accessible to all employees?
  • Are appropriate respirators available and used when workers enter areas where PERC concentrations may exceed the PEL?
  • Are chemical-resistant gloves (nitrile or neoprene) and aprons available and worn during solvent transfer operations?
  • Have all employees who work with PERC received hazard communication training within the past 12 months?
  • Is an emergency eyewash station within 10 seconds travel of any solvent handling area?

Spent Solvent and Hazardous Waste Management

Audit the proper characterization, storage, labeling, and disposal of spent solvents and contaminated materials.

  • Is spent PERC being managed as an F002 listed hazardous waste under RCRA regulations?
  • Are hazardous waste containers (spent solvent, contaminated filters, still bottoms) properly labeled with 'Hazardous Waste' and accumulation start date?
  • Is hazardous waste stored in a designated, secured area with appropriate containment and signage?
  • Has spent solvent been shipped for disposal by a licensed hazardous waste transporter using a Uniform Hazardous Waste Manifest?
  • Are muck cooker or still bottom residues managed as hazardous waste and not disposed of in the regular trash?

Ventilation and Emission Control Systems

Inspect ventilation systems, carbon adsorbers, and other emission controls required under federal and state air quality rules.

  • Is the dry cleaning machine equipped with a functioning refrigerated condenser or carbon adsorber for solvent recovery?
  • Is the general exhaust ventilation system providing adequate air changes to maintain PERC concentrations below the OSHA PEL?
  • Is the carbon adsorber (if present) being regenerated at the frequency specified by the manufacturer?
  • Are machine exhaust vents directed to the outside and not recirculated into occupied spaces?
  • Has the ventilation system been inspected and serviced by a qualified HVAC technician within the past 12 months?

Spill Response and Emergency Preparedness

Verify that spill response materials, emergency contacts, and response procedures are in place and current.

  • Is a solvent-compatible spill kit (absorbent, neutralizer, disposal bags) staged in the solvent storage and machine area?
  • Is a current Safety Data Sheet (SDS) for each solvent in use accessible to all employees in the work area?
  • Are emergency contact numbers for fire department, CHEMTREC, state environmental hotline, and local LEPC posted in the work area?
  • Have employees received training on emergency spill response procedures within the past 12 months?
  • Were any reportable PERC releases or spills to the environment documented and reported during the past month?
  • Please provide any additional notes on deficiencies found, corrective actions planned, or compliance concerns.

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Why Use This Dry Cleaning Solvent Management and Storage Audit Checklist [FREE PDF]?

This dry cleaning solvent management and storage audit checklist [free pdf] helps dry cleaning teams maintain compliance and operational excellence. Designed for plant manager professionals, this checklist covers 38 critical inspection points across 7 sections. Recommended frequency: monthly.

Ensures compliance with EPA 40 CFR 63 Subpart M National Emission Standards for PERC Dry Cleaning, OSHA 29 CFR 1910.1000 Table Z-1 Air Contaminants (PERC PEL 100 ppm TWA), NFPA 32 Standard for Dry Cleaning Plants (2021 Edition), EPA 40 CFR 261 Hazardous Waste Identification (Spent PERC F002), State Air Quality Permit Conditions (Title V or Minor Source). Regulatory-aligned for audit readiness and inspection documentation.

Frequently Asked Questions

What does the Dry Cleaning Solvent Management and Storage Audit Checklist [FREE PDF] cover?

This checklist covers 38 inspection items across 7 sections: Solvent Inventory and Recordkeeping, Solvent Storage Container and Area Compliance, Equipment Leak Detection and Fugitive Emissions, Worker Exposure Monitoring and PPE, Spent Solvent and Hazardous Waste Management, Ventilation and Emission Control Systems, Spill Response and Emergency Preparedness. It is designed for dry cleaning operations and compliance.

How often should this checklist be completed?

This checklist should be completed monthly. Each completion takes approximately 45-60 minutes.

Who should use this Dry Cleaning Solvent Management and Storage Audit Checklist [FREE PDF]?

This checklist is designed for Plant Manager professionals in the dry cleaning industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

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