Volume XXIII, Issue 6 - September 2026

Tackle the challenge of choosing the right cleaning equipment. Give us a call, we will help you sort out the choices.

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“I have been looking for a workshop like this for quite some time and it is exactly what I was looking for. I left with new information and ideas on how to improve our existing contamination control program”

2026 Parts Cleaning Workshop participant

Feature Article

The Quest for New Cleaning Equipment Part 6: Get Out There - Find a Supplier/Partner

Barbara Kanegsberg and Ed Kanegsberg

Observe, evaluate! Look at the cleaning machine; look at the company trying to sell you that cleaning machine. It is difficult to grasp how the cleaning equipment will fit into the manufacturing space and the process requirements based on brochures, video clips, web sites, and drawings alone. Once the Cleaning Team has identified at least one promising option for new cleaning equipment or have found several promising choices, get out there and look. In fact, it makes sense to look at more than one cleaning machine supplier and more than one type of cleaning machine. Look at the equipment in operation; look at how the cleaning machines are fabricated; determine how the cleaning machine performs during day-to-day operation.

Find a supplier/partner
For reliable trouble-free manufacturing, the Cleaning Team is looking at the technical capabilities of the cleaning machine. Beyond that, the Cleaning Team should be finding a supplier/partner, not a vendor. Seeing what the equipment supplier has to offer includes more than the equipment itself. It involves their expertise in design, their pertinent experience in critical product cleaning, and their understanding of regulatory requirements. The seller of the cleaning equipment may continue to work with your company over a period of years, if not decades. The supplier/partner must have people with the technical expertise and the infrastructure to address and support your cleaning, surface prep and process requirements. A great supplier/partner helps when the regulatory landscape shifts. A supplier/partner is not a forever collaboration – there is no “happily ever after.’ A supplier/partner may no longer have the technology required for the new cleaning process; technical support, and manufacturing processes for the cleaning machines may not be what they were a few years ago. Here are techniques to determine that the cleaning machines being offered is the right fit and that the vendor will be a good supplier/partner.

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KNOWLEDGE IS POWER

Manufacturing Community: Help! Interpret & comment on EPA trans-DCE Draft Risk Assessment

A major alternative to chlorinated and brominated solvents, a chemical that is part of cleaning agents and spray cleaners may have increased regulatory restriction throughout the United States. The US EPA has released a draft Risk Assessment for trans-1,2-dichloroethylene, a multi-syllable mouthful mercifully referred to as trans-DCE. A major use of trans-DCE, relevant to readers of Clean Source, is as a solvent for vapor degreasing. In the draft assessment, EPA determined there to be an unacceptable risk to workers in some applications, notably degreasing. The next step after establishing the risk is to propose a rule to mitigate the effects of the risk. Because methylene chloride, trichloroethylene, perchloroethylene and n-propyl bromide are already heavily regulated, manufacturers requiring similar solvency and wettability have moved to blends containing trans-DCE. These blends include weak solvents like hydrofluorocarbons (HFC), hydrofluoroethers (HFE), and hydrofluoroolefins (HFO) which act to inert the flammability of trans-DCE. trans-DCE provides the major cleaning power for most soils and residue of interest. If trans-DCE were to be heavily regulated, many manufacturers would need to find substantially different substitutes. This would involve significant cleaning process design and evaluation. In “safety critical” applications like military/aerospace and medical devices, comprehensive new cleaning validation studies would be needed to establish that the product is clean enough.

EPA has opened a comment period that ends October 26. We would love to submit definitive comments about the trans DCE risk assessment, but we are having trouble understanding it. Look at the draft assessment. It is complicated and we do not see clear indications of what levels of exposure might be considered excessive. We must not endanger workers, neighbors, or the environment. Therefore, our conviction is that any analysis must go beyond protocols and must interpret the significance of any calculations. There are important risk/benefit considerations; and the cure ought not be worse than the disease. Our immediate impression of the draft risk assessment is that, while it is information-rich, the information is difficult to interpret. It appears that the risk assessment provides the equivalent of a limited insight into an impenetrable algorithm. Please share your comments pub with us as well as on social media. Make comments to EPA-HQ-OPPT-2018-0465-0076. It’s likely to be more effective than grousing or incendiary posts. Help make the world better, safer, more productive, more beautiful.

https://www.regulations.gov/document/EPA-HQ-OPPT-2018-0465-0076

https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-evaluation-trans-12-dichloroethylene

BFK Solutions. – independent consultants and practical educators

Our decades of experience help you make productive decisions about your cleaning processes, your manufacturing processes, your business. Contact Ed and Barbara Kanegsberg with concerns about cleaning, surface quality, regulatory issues - we’ll get back to you and discuss your cleaning issue, whether or not we do a project together! Suggest a topic – we may write about it! 

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