HAND DRYER LEGAL
If you have ever used a commercial hand dryer you were exposed to conditions that independent testing shows materially increase biological and environmental risk.
If you have ever purchased a commercial hand dryer you have exposed yourself, your employees, and your customers to the same.
If you are the employee of a company that uses hand dryers you have been required by law to use machines that fail to meet all claims for hygeine, drying speed, and energy efficiency.
We spent two years testing 200 hand dryers in active public use in five states. The science is unequivocal and effortlessly reproducible. It can be viewed at www.handdryerstudy.com, Zenodo, the Harvard Dataverse, Backblaze, and Cloudflare.
The Federal and State complaints provided below against the certifiers and Starbucks are active, filed in the named court.
The sample complaints document the harms, the players, and decades of certification failure, testing failures, and information suppression that allowed this situation to occur. They are templates, offered as guidance for legal teams looking to rapidly understand the case they have, written in complaint form for familiarity and ease of comprehension. They are not legal advice. We are not lawyers. They are maps.
The briefs were written for our filed cases. We offer them here, for free, as additional guides. They are not legal advice. We are not attorneys. They were created for our filings and may be helpful for yours.
We offer specific guidance to attorneys who would like to rapidly accellerate their process at www.forensicdryergroup.com. Our perspective is unusual, having done the science and written our own complaints. We are not attorneys but we contextualize all the pieces for interested parties, saving months of work.
SAMPLE COMPLAINTS
MODEL COMPLAINT: STARBUCKS VS DYSON, EXCEL, NSF INTERNATIONAL, UL SOLUTIONS, SGS INTERNATIONAL, SMART EPD AND ANNA LASSO
STARBUCKS versus DYSON, NSF INTERNATIONAL, and SGS INTERNATIONAL
EMPLOYEES UNION, STARBUCKS WORKERS UNITED, VERSUS DYSON HAND DRYERS AND CERTIFIERS
STARBUCKS WORKERS’ UNION versus Dyson, INC, NSF International, and SGS International
HOSPITAL SYSTEM, NORTHWESTERN UNIVERSITY HOSPITALS, VERSUS EXCEL DRYER AND CERTIFIERS
NORTHWESTERN UNIVERSITY HOSPITALS versus Excel Dryer, Underwriters Laboratories, SGS International, SmartEPD and Anna Lasso
LEED GREEN ENERGY CERTIFYING AGENCY, US GREEN BUILDING COUNCIL, VERSUS EXCEL DRYER AND CERTIFIERS
US GREEN BUILDING COUNCIL versus Excel Dryer, Underwriters Laboratories, SGS International, SmartEPD, and Anna Lasso
COMPREHENSIVE COMPLAINT: CLOTHING RETAILER, GAP INC/OLD NAVY, VERSUS DYSON, EXCEL AND ALL CERTIFIERS
GAP/OLD NAVY versus Dyson, Excel Dryer, NSF International, Underwriters Laboratories, SGS International, SmartEPD, and Anna Lasso
MCDONALDS, RETAIL FOOD SERVICE, AND WORLD DRYER.
MCDONALDS versus World Dryer
UNITED STATES DEPARTMENT OF AGRICULTURE, VIA THE UNITED STATES DEPARTMENT OF JUSTICE, VERSUS EXCEL DRYER AND CERTIFIERS
USDA, via DOJ, versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, SGS INTERNATIONAL, and ANNA LASSO
GROCERY STORE WITH RETAIL FOOD SERVICE, WHOLE FOODS AND AMAZON VERSUS DYSON, EXCEL , AND CERTIFIERS
WHOLE FOODS and AMAZON versus DYSON, EXCEL, NSF INTERNATIONAL, SGS INTERNATIONAL, UL SOLUTIONS, SMART EPD, and ANNA LASSO
GOVERNMENT ADMINISTERED PUBLIC TRANSPORTATION, GRAND CENTRAL STATION/MTA VERSUS EXCEL AND CERTIFIERS
GRAND CENTRAL STATION/MTA versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, ANNA LASSO, and SGS INTERNATIONAL
WORLD’S LARGEST RETAILER, USER AND SELLER OF HAND DRYERS, WALMART VERSUS EXCEL DRYERS AND CERTIFIERS
WALMART, INC versus EXCEL DRYER, UL SOLUTIONS, SMART EPD LLC, ANNA LASSO, and SGS INTERNATIONAL
LARGE RETAIL CHAIN, TARGET VERSUS EXCEL DRYERS AND CERTIFIERS
TARGET CORPORATION versus EXCEL DRYER, UL SOLUTIONS, SMART EPD LLC, ANNA LASSO, and SGS INTERNATIONAL
SENIOR LIVING COMMUNITY, SEABURY INC VERSUS EXCEL DRYER AND CERTIFIERS
SEABURY INC versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, ANNA LASSO, and SGS INTERNATIONAL
RETAILER, USER AND SELLER OF HAND DRYERS, HOME DEPOT VERSUS EXCEL DRYERS AND CERTIFIERS
HOME DEPOT versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, ANNA LASSO, and SGS INTERNATIONAL
GROCERY STORE, ALDI INC VERSUS EXCEL AND CERTIFIERS
ALDI INC versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, ANNA LASSO, and SGS INTERNATIONAL
COOPERATIVE CLOTHING AND OUTDOOR GEAR RETAILER, REI EQUIPMENT VERSUS EXCEL AND CERTIFIERS
REI EQUIPMENT INC versus EXCEL DRYER, UL SOLUTIONS, SMART EPD, ANNA LASSO, and SGS INTERNATIONAL
FEDERAL GOVERNING AGENCY SAMPLE COMPLAINTS AND SUPPORTING DOCUMENTS
SAMPLE DOCUMENT SET for FEDERAL AGENCY HAND DRYER COMPLAINTS
FILED COMPLAINTS
Blouch v. NSF INTERNATIONAL, UL SOLUTIONS, SGS INTERNATIONAL, SMART EPD, ANNA LASSO
Ronald A. Blouch Jr. versus NSF International, SGS North America, UL Solutions, SmartEPD and Anna Lasso. The unified federal complaint against the certifiers, filed in the United States District Court for the Middle District of Pennsylvania.
Blouch v. STARBUCKS
Ronald A. Blouch Jr. versus Starbucks Corporation. The state complaint against Starbucks as a purchaser and operator of the dryers, prepared for filing and preceded by a formal demand.
BRIEFS/MEMORANDA
Blouch V Certifiers Case Law Brief
The controlling and persuasive case law supporting the claims in the complaints, organized by cause of action and jurisdiction.
Case Law Brief, UL Solutions Plaintiff
A close analysis of how UL Solutions has defended their standards, certifications, testing, and marks against companies that violate them.
Certification Chain
How the certification chain works, who each party is, and where reliance and failure occur along the path from manufacturer to certifier to purchaser.
Testing, Counts & Methodology
The testing methodology, colony counts, and reproducible protocol behind the findings, written for rapid technical review by counsel and experts.
ISO and EN Memorandum
How the relevant ISO and EN standards apply to the dryers, the certifications at issue, and the gaps between claimed and actual performance.
NSF Memorandum
NSF International’s role, the P335 certification pathway, and the basis for the claims regarding its conduct.
SmartEPD Memorandum
SmartEPD’s environmental product declarations, the life-cycle assumptions behind them, and where those declarations diverge from the record.
SGS Memorandum
SGS International’s testing and certification activity and the basis for the claims regarding its conduct.
Dyson Memorandum
The specific claims regarding Dyson dryers, the marketing representations at issue, and the evidence bearing on them.
Excel Memorandum
The specific claims regarding Excel Dryer, the marketing representations at issue, and the evidence bearing on them.