## TECHNICAL SUPPORT DOCUMENT
for

CONTROL OF VOLATILE ORGANIC MATERIAL EMISSIONS
from
CONSUMER AND COMMERCIAL PRODUCTS, ARCHITECTURAL AND INDUSTRIAL MAINTENANCE COATINGS, AND AEROSOL

COATINGS

AQPSTR 07-02

November 2007

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST

P.O. BOX 19276 SPRINGFIELD, ILLINOIS 62794-9276

## Table of Contents

List of Acronyms 2 Tables 3
1.0 Introduction 4 2.0 Consumer Products 8 2.1 Description of Sources and Emissions 8 2.2 Emissions in Illinois from Regulated Products 9 2.3 Technical Feasibility of Controls 15 2.4 Flexibility in Compliance Measures 19 2.5 Economic Reasonableness 20 2.6 Cost Effectiveness of Controls 21 2.7 Reduction of VOM Emissions in Illinois 29 2.8 Affected Sources and Compliance Measures 33
3.0 Architectural and Industrial Maintenance Coatings 34 3.1 Description of Sources and Emissions 34 3.2 Emissions in Illinois from Regulated Products 35 3.3 Technical Feasibility of Controls 39 3.4 Economic Reasonableness 41 3.5 Cost Effectiveness of Controls 40 3.6 Reduction of VOM Emissions in Illinois 45 3.7 Affected Sources and Compliance Measures 45

4.0 Aerosol Coatings 46 4.1 Description of Sources and Emissions 46 4.2 Emissions in Illinois from Regulated Products 47 4.3 Technical Feasibility of Controls 50 4.4 Flexibility in Compliance Measures 52 4.5 Economic Reasonableness 52 4.6 Cost Effectiveness of Controls 56 4.7 Reduction of VOM Emissions in Illinois 57 4.8 Affected Sources and Compliance Measures 58
5.0 Summary 60
6.0 References 62 AppendixA: Potentially Affected Manufacturers in Illinois 65



### 1

### List of Acronyms

ACP Alternative Control Plan AIM Architectural and Industrial Maintenance CAA Clean Air Act CARB California Air Resources Board CFR Code of Federal Regulations CO Carbon Monoxide CRF Cost Recovery Factor ERWA Emission Reduction-Weighted Average HVOM High Volatility Organic Materials IEPA Illinois Environmental Protection Agency IPP Innovative Products Provision LADCO Lake Michigan Air Directors Consortium MIR Maximum Incremental Reactivity MRPO Midwest Regional Planning Organization MVOM Medium Volatility Organic Materials NAA Non Attainment Area NAAQS National Ambient Air Quality Standards NOx Nitrogen Oxides OTC Ozone Transport Commission PSU Primers, Sealers, and Undercoaters PWMIR Product Weighted Maximum Incremental Reactivity SCM Suggested Control Measures SIP State Implementation Plan SWA Sales Weighted Average Tpd Tons Per Day USEPA United States Environmental Protection Agency VOM Volatile Organic Material

2Tables

Table 2.2.1 Proposed Regulated Product Categories and Limits 9
Table 2.2.2 Consumer Product Emission Factors by Category 15
Table 2.2.3 VOM Emissions Due to Consumer and Commercial Products

During the Ozone Season 16
Table 2.6.1 Cost Effectiveness Estimates for Consumer Products -22
Table 2.7.1 Estimated VOM Emission Reductions for Consumer Products 30
Table 3.2.1 AIM Coating Categories and VOM Limits 35 Table 3.2.2 VOM Emissions Due to AIM Coatings During the Ozone Season ..38
Table 3.5.1 Producer Cost Per Gallon for AIM Coatings 42
Table 3.5.2 Estimated Cost Effectiveness for AIM Coating Control 43 Table 4.2.1 Aerosol Coating Categories and PWMIR Limits 47 Table 4.2.2 VOM Emissions Due to Aerosol Coating Products 50
Table 4.5.1 Cost Estimates Per Can for Aerosol Coating Products 55

3

### 1.0 Introduction

Pursuant to Section 109 of the Clean Air Act, as amended in 1990, and to protect the public health, the United States Environmental Protection Agency ("USEPA") revised the national ambient air quality standard ("NAAQS") for ozone. Effective July 17, 1997 the USEPA lowered the NAAQS for ozone to 0.080 parts per million from the previous 0.120 parts per million. In addition, the time period used for measuring compliance was increased from the previous 1 hour to 8 hours. In Illinois, Chicago and the Metro East St. Louis area have been designated as moderate ozone nonattainment areas under the new NAAQS. Included in the Chicago nonattainment area ("NAA") are Cook, DuPage, Kane, Lake, McHenry, and Will counties, as well as the Aux Sable Township and Goose Lake Township in Grundy County, and Oswego Township in Kendall County. The Metro East St. Louis NAA is comprised of Jersey, Madison, Monroe, and St. Clair counties.

The precursors to the formation of ozone include volatile organic materials ("VOM"), oxides of nitrogen ("NOx") and carbon monoxide ("CO"). Ozone formation is most active during the summer months because the reactions are dependent on direct sunlight and high ambient temperatures. Ozone is a powerful oxidant and, as such, reacts readily with a wide range of substances. In humans, ozone is an irritant to the respiratory system and may damage lung and other tissues. This damage can lead to impaired breathing and reduced immunity to disease for people in good health. The effects may be more severe for young children, the elderly, and people with preexisting respiratory diseases such as

4

### asthma, bronchitis, and emphysema. Ozone oxidation can also damage plant tissue,

reducing the yield of some crops, and damage certain other materials such as rubber.

In 1997, the USEPA revised the NAAQS for ozone to reflect improved scientific understanding of the health impacts of the pollutant. The change from the previous 1 hour standard to the 8 hour standard is based on extensive air pollution research that indicated ozone is more harmful when a person is exposed over a longer period of time even if the ozone concentration is lower. As such, the revised 8 hour standard is more stringent than the previous 1 hour standard. The 8 hour standard had an effective date of June 15, 2004, with the 1 hour standard being revoked one year later on June 15, 2005 (40 CFR Part 81).

To protect the public health of the citizens of the State of Illinois, and in an effort to attain the 8 hour ozone NAAQS by 2010 as required by Section 181(a) of the Clean Air Act, the Illinois Environmental Protection Agency ("Illinois EPA") is proposing to reduce VOM emissions from consumer and commercial products, architectural and industrial maintenance ("AIM") coatings, and aerosol coatings.

Consumer and commercial products are currently regulated by the USEPA by the consumer and commercial products rule promulgated on Sept. 11, 1998, and codified at 40 CFR Part 59 Subpart D. This national rule currently limits the VOM content of 24 product categories. VOM emissions from these categories are estimated to have been reduced by 20 percent from uncontrolled levels. However, the emissions due to the 24

5

### categories currently being regulated account for only 48 percent of the consumer and

commercial products emission inventory3.

Architectural and industrial maintenance coatings are currently regulated by the USEPA by the AIM coatings rule promulgated on Sept. 11, 1998, and codified at 40 CFR Part 59 Subpart D. This national rule includes container labeling requirements and is estimated to reduce VOM emissions from AIM coatings by approximately 20% from uncontrolled levels.

Aerosol Coatings are considered to be a Group III Consumer Product, and accordingly are also regulated by 40 CFR Part 59 Subpart D. Currently, federal and Illinois consumer product regulations do not deal specifically with the reactivity of various organic compounds. The proposed rule for aerosol coatings limits the content of various VOM compounds based upon their reactivity and their likelihood to form ground level ozone. This proposed rule is based upon the California Air Resources Board's ("CARB") "Regulation for Reducing the Ozone Formed from Aerosol Coating Product Emissions"' that has been employing a reactivity based standard for all aerosol coatings since January 1, 2003.

Further reductions in the aforementioned categories will be beneficial to the environment and are considered to be both economically reasonable and technologically feasible. It is for these reasons that the Illinois EPA has proposed this rule controlling consumer and commercial products, AIM coatings, and aerosol coatings.

6

### In evaluating the potential reductions of VOM emissions from consumer and commercial

products, architectural and industrial maintenance coatings, and aerosol coatings, Illinois EPA has reviewed the findings of several groups researching the issue. The groups are MACTEC, an environmental firm that is under contract with the Lake Michigan Air Directors Consortium ("LADCO"); the Ozone Transport Commission ("OTC"), an organization in the eastern United States created under the Clean Air Act; and the California Air Resources Board ("CARB"). The OTC and CARB have drafted candidate measures for the reduction of VOM that go beyond the current federal VOM limits, and MACTEC, CARB, and USEPA have projected the potential reductions and the associated cost of additional control through these measures.

This technical support document is based on the review and application of the aforementioned organizations, and addresses the economic reasonableness and technological feasibility of further regulation to reduce VOM emissions from consumer and commercial products, AIM coatings, and aerosol coating products by limiting the solvent content in these products, or the amount of ozone formed when these products are used. It is the position of the Illinois EPA that further regulation of these source categories is an integral part of its state implementation plan ("SIP") for achieving attainment of the NAAQS in Illinois.

72.0 Consumer and Commercial Products

2.1 Description of Sourcesand Emissions 

### As defined by the USEPA in the federal rule, a consumer product is any household or institutional product (including paints, coatings, and solvents), or substance, or article (including any container or packaging) held by any person, the use, consumption, storage, disposal, destruction, or decomposition of which may result in the release of VOC (40 CFR § 59.202). Consumer and commercial products are chemically formulated products used by household and institutional consumers including, but not limited to, detergents; cleaning compounds; polishes; floor finishes; cosmetics; personal care products; home, lawn and garden products; disinfectants; sanitizers; aerosol paints; and automotive specialty products; but does not include other paint products, furniture coatings, or architectural coatings. The description consumer and commercial products also refers to aerosol adhesives, including aerosol adhesives used for consumer, industrial, and commercial uses.

Consumer and commercial products are sold to retail customers for personal, household, or automotive use, along with products marketed by wholesale distributors for use in commercial or industrial settings such as beauty shops, schools, and hospitals. This source category description includes hundreds of products sold to individuals such as personal care products, household products, automotive aftermarket products, adhesives and sealants, insecticides, coatings and a range of other miscellaneous products.

8

### It has been estimated by MACTEC that approximately 5.9% of the total anthropogenic

emissions of VOM in the Midwest Regional Planning Organization ("MRPO") are due to commercial and consumer products3. The MRPO is comprised of Illinois, Indiana, Michigan, Ohio, and Wisconsin. In Illinois, consumer and commercial product emissions account for approximately 4.95% of the total anthropogenic VOM emissions during the

ozone season2, and account for approximately 8.51% of anthropogenic VOM emissions for the entire year's. Consumer and commercial products account for approximately 4.93% of total anthropogenic VOM emissions in the East St. Louis NAA and approximately 9.2% of total anthropogenic VOM emissions in the Chicago NAA during the ozone season(see Section 2.2, Table 2.2.3)2. The percentages of anthropogenic VOM emissions from consumer and commercial products for the entire year in the Metro East and Chicago NAAs are 6.89% and 13.45% respectively15.

2.2 Emissions in Illinois From Regulated Products Consumer and commercial product usage results in solvent evaporation and the emission of VOM. For the purposes of the proposed regulation the source category is divided into 59 product categories, each with a VOM limit given in % by weight. These product categories are listed below in Table 2.2.1.



### 9Table 2.2.1 Proposed Regulated Product Categories and Limits

Affected Product %VOM by Weight 1) Adhesives - Aerosol A) Mist Spray 65 B) Web Spray 55 C) Special Purpose Spray Adhesives i) Mounting, Automotive Engine Compartment, and Flexible Vinyl 70 ii) Polystyrene Foam and Automotive Headliner 65 iii) Polyolefin and Laminate Repair / Edgebanding 60 2) Adhesive Removers A) Floor or Wall Covering 5 B) Gasket or Thread Locking 50 C) General Purpose 20 D) Specialty 70 3) Adhesives - Construction, Panel, and Floor Covering 15 4) Adhesives - General Purpose 10 5) Adhesives – Structural Waterproof 15 6) Adhesives A) Contact General Purpose 55 B) Contact Special Purpose 80 7) Fresheners A) Single-Phase Aerosol 30 B) Double Phase Aerosol 25 C) Liquids / Pump Sprays 18 D) Solids / Semisolids 3 8) Antiperspirants A) Aerosol *HVOM 40 **MVOM 10 B) Non-Aerosol *HVOM **MVOM 9) Anti-Static Non-Aerosol 11 10) Automotive Brake Cleaners 45

10

### 11) Automotive Rubbing or Polishing Compound 17

12) Automotive Wax, Polish, Sealant, or Glaze A) Hard Paste Waxes 45 B) Instant Detailers 3 C) All Other Forms 15 13) Automotive Windshield Washer Fluids 35 14) Bathroom and Tile Cleaners

A) Aerosol 7 B) All Other Forms 5 15) Bug and Tar Remover 40 16) Carburetor or Fuel-Injection Air Intake Cleaners 45 17) Carpet and Upholstery Cleaners

A) Aerosol 7 B) Non-Aerosol (Dilutables) 0.1 C) Non-Aerosol (Ready-to-Use) 3.0 18) Charcoal Lighter Material see Section 223.220 19) Cooking Spray – Aerosol 18 20) Deodorants A) Aerosol *HVOM 0 **MVOM 10 B) Non-Aerosol *HVOM 0 **MVOM 0 21) Dusting Aides A) Aerosol 25 B) All Other Forms 7 22) Electrical Cleaner 45 23) Electronic Cleaner 75 24) Engine Degreasers A) Aerosol 35 B) Non-Aerosol 5

1125) Fabric Protectants 60

26) Fabric Refresher A) Aerosol 15 B) Non-aerosol 6 27) Floor Polishes / Waxes A) Products for Flexible Flooring Materials 7 B) Products for Nonresilient Flooring 10 C) Wood Floor Wax 90 28) Floor Wax Strippers see Section 223.209 29) Footwear or Leather Care Products A) Aerosol 75 B) Solid 55 C) Other forms 15 30) Furniture Maintenance Products A) Aerosol B) All Other Forms Except Solid or Paste 31) General Purpose Cleaners A) Aerosol B) Non-Aerosol 32) General Purpose Degreasers A) Aerosol B) Non-Aerosol 33) Glass Cleaners A) Aerosol B) Non-Aerosol 34) Graffiti Remover A) Aerosol B) Non-Aerosol 35) Hair Mousses 36) Hairshines 37) Hairsprays 38) Hair Styling Gels 17 7

10 4

50 4

12 4

50 30
6
55
55
6

1239) Hair Styling Products A) Aerosol and Pump Sprays 6 B) All other forms 2 40) Heavy Duty Hand Cleaner or Soap 8 41) Insecticides A) Crawling Bug (Aerosol) 15 B) Crawling Bug (All Other Forms) 20 C) Flea and Tick 25 D) Flying Bug (Aerosol) 25 E) Flying Bug (All Other Forms) 35 F) Foggers 45 G) Lawn and Garden (Aerosol) 20 H) Lawn and Garden (All Other Forms) 3 I) Wasp and Hornet 40 42) Laundry Prewash A) Aerosols / Solids 22 B) All Other Forms 5 43) Laundry Starch Products 5 44) Metal Polishes / Cleansers 30 45) Multi-Purpose Lubricant (Excluding Solid or Semi-Solid Products) 50 46) Non-Selective Terrestrial Herbicide - Non-Aerosol 3 47) Oven Cleaners A) Aerosols / Pump Sprays 8 B) Liquids 5 48) Paint Remover or Strippers 50 49) Penetrants 50 50) Rubber and Vinyl Protectants A) Aerosol 10 B) Non-Aerosol 3 51) Sealants and Caulking Compounds 4 52) Shaving Creams 5 53) Shaving Gel 7

1354) 

### Silicone-Based Multi-Purpose Lubricants (Excluding Solid or Semi-Solid Products) 60
55) 

### Spot Removers A) Aerosol 25 

### B) Non-Aerosol 8
56) 

### Tire Sealants and Inflators 20
57) 

### Toilet/Urinal Care A) Aerosol 10 B) Non-Aerosol 3
58) 

### Undercoatings — Aerosols 40
59) 

### Wood Cleaner A) Aerosol 17 

### B) Non-Aerosol *High Volatility Organic Compound – a volatile organic compound that exerts a vapor pressure greater than 80mm fig at 20°C. **Medium Volatility Organic Compound - a volatile organic compound that exerts a vapor pressure greater than 2mm Hg at 20°C.


### The source category is broken down by the Emission Inventory Improvement Program ("EIIP") into seven product categories: personal care products, household products, automotive aftermarket products, adhesives and sealants, FIFRA regulated products, coatings and related products, and miscellaneousi. The EIIP was a joint project of the USEPA and the National Association of Clean Air Agencies. The "Illinois Base Year Ozone Inventory for

# Nor''produced by the Illinois EPA contains a comprehensive inventory of VOM emissions from consumer and commercial products statewide, and for both NAAs in Illinois. The data also details the emissions due to each product category. Table 2.2.2 shows the emissions factors for each product category per person in Illinois in pounds per year.

14

### Table2.2.2Consumer Product EmissionFactors by Category' Product Category EmissionFactor (lb/person/year) Personal Care 2.04 Household 0.70 Automotive Aftermarket 1.24 Adhesives and Sealants 0.52 FIFRA Regulated 1.69 Coatings and Related Products 0.95 Miscellaneous 0.07

Table 2.2.3 shows the inventory figures for VOM due to consumer and commercial products during the ozone season and for the entire year; the total anthropogenic emissions of VOM in each area of the state along with the state total for each period; the percentage of the total anthropogenic VOM emissions in each area; and the population of each of these areas. The emissions data is estimated in a pounds per year per capita.

15

### Table2.2.3VOM Emissions Due to Consumer and Commercial Products During

the Ozone Season (Entire Year Data in Parentheses15) Area and Approximate Population VOM – Consumer

and Commercial Products (T/D) Total

Anthropogenic VOM (T/D) %of Total

Anthropogenic VOM Attainment Area 24.40 996.52 2.45% Pop. 3,756,253 (36.90) (772.71) (4.78%) Chicago NAA 53.90 584.45 9.22% Pop. 8,295,996 (82.24) (611.38) (13.45%) Metro – East St. Louis 3.56 72.15 4.93% NAA (5.66) (82.16) (6.89%) Pop. 548,371 Statewide Total 81.86 1653.12 4.95% Pop. 12,600,620 (124.80) (1466.24) (8.51%)

2.3 Technical Feasibility of Controls The most effective approaches for achieving reductions in this source category are reformulating products currently employing VOM solvents and replacing them with water based formulations or formulations employing acetone or other exempt solvents. Other measures for reductions in this category include increasing the solids content of products, formulating non-VOM propellants for products, or changing the valves, containers, or delivery systems of the products to reduce VOM content.

16

### Consumer and commercial products are currently regulated by USEPA's consumer and

commercial products rule, codified at 40 CFR Part 59 Subpart D, under the authority of Section 183(e) of the Clean Air Act. This rule limits the VOM content of 24 product categories. These categories represent only 48% of the consumer and commercial products inventory nationwide3. The proposed regulation, minoring the "OTC Model Rule for Consumer Products"I6, would increase the number of regulated product categories to approximately 80, and reduce VOM emissions from the source category by an additional 14.2% beyond the federal rule3. The OTC Model Rule for Consumer Products is very similar to the CARB rule in regard to the products regulated and the VOM content limits that are required in CARB's midterm measures. The CARB rule was written to become more stringent in 2006 and then more stringent yet in 2010. While both the CARB and the OTC model rules for consumer and commercial products are technologically feasible, the economic reasonableness of the candidate measures indicate that the limits prescribed by the OTC rule are preferable for Illinois (See discussion in Section 2.5).

The OTC consists of the states of Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, and the District of Columbia. The OTC Model Rule for Consumer Products became effective for these states and the District of Columbia on January 1, 2005. Due to the nature of this source category, it is considered essential that regulations

17

### be as uniform as possible in a given region in order to affect the smallest possible

economic impact and the least amount of disruption to manufacturing processes.

The OTC Model Rule for Consumer Products is based upon the CARB midterm measures for control of VOM in the source category and the associated background data for the CARB rules. The technical basis for the proposed VOC content limits lies within the framework that the CARB developed for its consumer products rules. Significant technical documentation was developed as part of the CARB process. The Illinois EPA, acknowledging that the OTC Model Rule for Consumer Products is currently in place in all OTC states and the District of Columbia, and having reviewed the technical support for the proposed VOM limits created by CARB, is confident that the OTC model rule is technologically feasible for the State of Illinois. Furthermore, the method by which VOM reductions are achieved in this source category is most commonly a change in the formulation or delivery system of the product available to consumers. Since many national manufacturers of products subject to this rule will have already made modifications to their products in order to comply with the new regulations in the OTC states and in California, it is reasonable to consider that similar reformulations could be made, or have already been made, for products for sale in Illinois. hi recognition of these facts, it is most appropriate to view the technological feasibility of the OTC Model Rule for Consumer Products primarily in terms of the economic impact of the rule. For this reason it is also in the best interest of the State of Illinois, the manufacturers of products subject to new regulation, and to the consumers of Illinois and elsewhere, that regulations

18

### involving consumer products be as uniform as is possible, while still addressing the issue

of air quality.

The OTC Model Rule for Consumer Products is currently the preferred measure of LADCO and the Midwest Regional Planning Organization ("MRPO"), which consists of the States of Illinois, Indiana, Michigan, Ohio, and Wisconsin. Illinois EPA believes that working in conjunction with these states in the MRPO, the OTC states and the District of Columbia, and with California, that the proposed new regulation for consumer and commercial products is not only technologically feasible, but will also have a greater acceptability and a lesser economic impact than the previous estimates by the OTC and CARB that are presented in Section 2.5 of this document.

2.4 Flexibility in Compliance Measures As a means of providing manufacturers of affected consumer products flexibility in complying with proposed VOM limits, the proposed regulation includes provisions for an alternate control plan (ACP) and the innovative products provision (IPP).

The innovative products provision in the proposed regulation allows qualified manufacturers to sell products that have VOC contents greater than the applicable VOC limit, provided they demonstrate that such products actually emit less VOCs than representative products that comply with the VOC limit. In California and in the OTC region, where limits similar to those in the proposed Illinois regulation have been adopted, various manufacturers have formulated technologically-advanced products that

19

### are more concentrated, higher in efficacy, or have some other chemical or physical

properties that permit users to release less VOCs when using such products6. These innovative products shall be allowed under the proposed regulation, subject to a review and approval by the Illinois EPA, as the environmental impact due to the products will be equal or less than comparable affected products.

The alternate control plan (ACP) provision in the proposed regulation allows for approved manufacturers of affected consumer products to use emissions averaging for their product lines. In general, emissions averaging under approved ACP plans allows manufacturers to choose the least-cost or other advantageous reformulation options for its product lines. Rather than directly complying with the VOC limit for each product, manufacturers can choose to "overcomply" with some reformulations in order to offset the "undercompliance" of other product lines6. The ACP provision allows for the same amount of VOM emission reduction while providing an added degree of flexibility for manufacturers in compliance.

2.5 Economic Reasonableness Cost estimates for controlling VOM emissions from consumer and commercial products based on the OTC Model Rule have been made by MACTEC for the LADCO region. Assuming an effective date for the proposed rule in 2007, and a two year sell-through period for regulated products, MACTEC estimates that control costs will be approximately $800 per ton of VOM3. This estimate of the control cost for the proposed regulation was made by MACTEC based upon figures from CARB and the OTC. CARB

20

### estimated the cost of their "Midterm Measures II"12rule to be in this range. The limits

for VOM content in specific consumer products in the OTC Model Rule for Consumer Products mirror the limits in the CARB "Midterm Measures II"12rule. This is the basis for MACTEC's assumption that the CARB and OTC figures for control costs should approximate control costs for the LADCO region3. Furthermore, Illinois EPA asserts that control costs for VOM emissions from consumer and commercial products may indeed be lower than previous estimates due to the adoption of measures throughout the OTC and in California. The effect that uniform measures across a number of regions has been previously discussed in this document. The Illinois EPA also acknowledges that these cost estimates were made based upon a 2007 effective date while the proposed effective date in Illinois is January I, 2009. It is believed that the effective date will have little or no effect on the cost of the proposed regulation, and again would most likely result in a slight over estimate of costs.

2.6 Cost Effectiveness of Controls The cost effectiveness of VOM control measures presented in this document was estimated by CARB in various staff reports related to California's consumer products rules leading up to the "Midterm Measures II"12level of control that the OTC model rule for consumer products is based on. The State of New Jersey's Department of Environmental Protection concentrated data from these reports into a single table in the technical support document prepared in support of their Consumer and Commercial Products rule. The data is separated into three categories corresponding to three different levels of control that were implemented in California. The first section of the table

21

### details cost effectiveness estimates for products controlled by California's Midterm

Measures II regulation. The second section of the table details cost effectiveness estimates for products controlled for California's Midterm Measures I regulation. The third section of the table details cost effectiveness estimates for product categories previously unregulated by California, or regulated prior to the Midterm Measures I regulation, but are still more stringent than current federal regulation. In all cases low, high and average estimates are given for the cost of control on a dollars per pound of VOM controlled basis and on the basis of dollars per average unit of a given product.

Table 2.6.1 Cost Effectiveness Estimates for Consumer Products"



### CATEGORY Estimated Costeffectiveness Estimated Costper Unit ($/lbVOC reduced) ($/unit) 

### Low High 

### Avg. Low High Avg. MIDTERM MEASURES

### II AUTOMOTIVE CARE:
Automotive Windshield Washer Fluids NA NA NA NA NA NA

Automotive Brake Cleaners 0.44 1.20 0.82 0.02 0.03 0.02 Carburetor, Choke Cleaners 0.09 0.19 0.14 0.02 0.04 0.03 Engine Degreasers - (Aerosols) 0.35 0.67 0.51 0.04 0.06 0.05Engine Degreasers (nonAerosols) -0.49 0.27 0.00 0.00 0.00 0.00
Tire Inflator and Sealant 1.50 1.59 1.54 0.25 0.26 0.26
ERWA 0.38 HOUSEHOLD CARE:

22

### Construction, Panel, and

Flooring Adhesives 1.64 2.02 1.83 0.16 0.19 0.17

Double-Phase Aerosol Air Freshener 0.75 0.79 0.77 0.04 0.04 0.04

Furniture Maintenance Products (Aerosols) 0.47 0.82 0.64 0.03 0.04 0.03

General Purpose Cleaners (Dilutables) -3.19 -3.92 0.00 0.00 0.00 0.00
General Purpose Cleaners (Ready-to-Use) 1.97 3.17 2.57 0.03 0.04 0.03
General Purpose Degreasers (Dilutables) -1.18 -1.32 0.00 0.00 0.03 0.01
General PurposeDegreasers (Ready-toUse) -0.42 0.00 0.00 0.00 0.04 0.02
General Purpose Degreaser/Solvent Parts Cleaner (Aerosol) 0.25 0.36 0.30 0.11 0.16 0.13

Glass Cleaners (Dilutables) -0.45 -0.22 0.00 0.00 0.00 0.00Glass Cleaners (Readyto-Use, Non-Aerosol) -0.51 0.30 0.00 0.00 0.01 0.01
Sealant and Caulking Compounds -0.18 0.14 0.00 0.00 0.01 0.00

ERWA 0.68 PERSONAL CARE:
Hair Mousses 0.75 2.56 1.65 0.03 0.09 0.06 Nail Polish Remover NA NA NA NA NA NA
ERWA 1.65

23PESTICIDES: Insecticide Crawling Bug (Aerosols) 0.58 2.27 1.43 0.02 0.07 0.05

Insecticide Flying Insect (Aerosols) 0.77 6.31 3.54 0.04 0.28 0.16
Insecticide Lawn and Garden (Non-Aerosol) -0.16 0.28 0.06 0.00 0.00 0.00

ERWA 1.17

MIDTERM MEASURES II TOTALS MIN -3.19 MIN 0.00

MAX 6.31 MAX 0.28 OVERALL ERWA 0.67 SWA 0.02
MIDTERM MEASURESI AUTOMOTIVE CARE:
Automotive Rubbing/Polishing (all forms) -0.78 -0.24 0.00 0.00 0.00 0.00

Automotive Wax,Polish,Sealant,Glaze (semi&all other) 0.46 1.01 0.74 0.09 0.13 0.11

Automotive Wax,Polish,Sealant,Glaze (hard paste) -0.32 -0.14 0.00 0.00 0.00 0.00

Automotive Wax,Polish,Sealant,Glaze (instant detailer) -0.28 0.89 0.30 0.00 0.00 0.00

Bug

### &Tar Remover -0.07 0.64 0.28 0.00 0.07 0.03 Multi-Purpose Lubricant (excl. solid/semisolid), Tierl 0.18 0.34 0.26 0.17 0.18 0.18



### 24

### Multi-Purpose Lubricant

(excl. solid/semisolid), Tier2 1.84 1.87 1.86

Penetrant (excl. solid/semisolid), T erl 0.35 2.45 1.40 0.05 0.18 0.11

Penetrant (excl. solid/semisolid), Tier2 0.20 0.62 0.41

Rubber&Vinyl Protectant (aerosol) 1.08 1.72 1.40 0.47 0.60 0.53

Rubber&Vinyl Protectant (non-aerosol) 0.03 0.40 0.22 0.01 0.13 0.07

Silicone-based MultiPurp. Lubricant (excl. solid/semi) 0.95 1.70 1.33 0.33 0.53 0.43

Undercoating (aerosol) 0.25 1.46 0.85 0.03 0.19 0.11
ERWA 0.76 HOUSEHOLD CARE: Carpet&Upholstery Cleaner (aerosol) 2.32 7.11 4.71 0.04 0.11 0.08
Carpet&Upholstery Cleaner (non-aerosol, dilutable) -1.28 0.51 0.00 0.00 0.00 0.00

Carpet&Upholstery Cleaner (non-aerosol, RTU) -1.44 -1.09 0.00 0.00 0.00 0.00

Floor Wax Stripper (nonaerosol) -0.56 -0.35 0.00 0.00 0.00 0.00 General Purpose Degreaser (aerosol) 0.30 0.92 0.61 0.11 0.31 0.21

25

### General Purpose

Degreaser (non-aerosol) -0.05 0.17 0.06 0.00 0.00 0.00

Metal Polish or Cleaner -0.49 -0.37 0.00 0.00 0.00 0.00 Paint Remover or Stripper, Tierl -3.58 -0.33 0.00 0.00 0.00 0.00 Paint Remover or Stripper, Tier2 -0.81 -0.01 0.00 Spot Remover (aerosol) 0.40 6.06 3.23 0.00 0.28 0.14Spot Remover (nonaerosol) -1.21 0.02 0.00 0.00 0.00 0.00
ERWA 0.13 PERSONAL CARE:
Hair Shine 1.61 1.73 1.67 0.56 0.60 0.58 Heavy Duty Hand Cleaner or Soap, Tierl 0.40 1.11 0.76 0.25 0.59 0.42
Heavy Duty Hand Cleaner or Soap, Tier2 3.43 7.73 5.58

ERWA 2.00 PESTICIDES: Non-Selective Terrestial Herbicide 0.18 0.26 0.22 0.02 0.02 0.02
Wasp and Hornet Insecticide 0.00 0.32 0.16 0.00 0.03 0.01
ERWA 0.21

MIDTERM MEASURES I TOTALS MIN -3.58 MIN 0.00

MAX 7.73 MAX 0.60 OVERALL ERWA 0.68 SWA 0.03 PRIOR TOCAMIDTERM MEASURES AND MORE STRINGENT THAN FEDERAL RULE 

### Hairspray 2.10 2.50 2.30

26

### Anti-perspirants and 0.54 1.30 0.92

Deodorants Household Adhesives (see Note 8 below) 0.02 0.40 0.21 0.02 0.51

GRAND TOTALS MIN -3.58 MIN 0.00 MAX 7.73 MAX 0.60 OVERALL 1.15 SWA 0.03 ERWA Notes: 

### 1. Calculations and footnotes are based on spreadsheets, formulas and data from the following CARB staff reports: "Proposed Regulation to Reduce VOC Emissions from Consumer Products, Aug 1990" "Proposed Amendments to the Statewide Regulation to Reduce VOC Emissions from

Consumer Products Phase II, Oct 1991" "Initial Statement of Reasons for Proposed Amendments to the California Consumer

Products Regulation, June 6, 1997" "Initial Statement of Reasons for Proposed Amendments to the California Consumer

Products Regulation, Sept 10,1999" The CARB data in this table has been modified by the Department to account for the differences between the CARB rule and the OTC model rule (most notably,

windshield washer fluids and nail polish removers). 2.ERWA=

### emission reduction-weighted average 3. SWA=

### sales weighted average 4. Avg. Cost-effectiveness shown as "$0.00" means the average of the low and high

cost-effectiveness for the category was either 0 or negative. 5. Non-recurring fixed costs annualized using Cost Recovery Method, with a Cost Recovery Factor (CRF) of 0.16274 corresponding to 10 percent interest over a 10 year project horizon. 6. For non-recurring costs, "low" and "high" refer to range of estimated fixed costs; for recurring costs, "low" and "high" refer to "All Other" ingredients assumed to cost $3.50/1b and $7.00/lb, respectively, unless otherwise noted in individual category cost spreadsheets. 7. For wasp and hornet insecticide, the "low" and "high" recurring costs shown are arithmetic averages of the applicable ranges for this category. 8. The cost analysis results for household adhesives are overestimated because CARB subsequently changed the VOC limit requirement for household adhesives,

• 

### which lowered industry costs.

27

### This economic analysis assumes that the sales and uses of consumer products in Illinois

are comparable to those in California and the OTC states. As mentioned previously in this document, estimates for cost effectiveness of control may be over estimated due to a few factors. Many regulated products are manufactured for national sales, and therefore no changes will be necessary for sales in Illinois. In the case that different formulations are used by national manufacturers for use in different regions, the cost of research of new formulas can be avoided due to the limits of the proposed Illinois regulation being identical to those of CARB and the OTC. In addition, CARB, in its cost estimates, did not account for the potential savings of manufacturers that produce more than one type of regulated product. These manufacturers may only incur one time costs for research, development, formula ingredient changes, and packaging changes that apply to a number of the products they produce6.

The economic analysis performed by CARB also intentionally attempted to make conservative cost estimates by using worst case economic scenarios for reformulation of products. For instance, in the case of aerosol products, higher cost propellants such as HFC-152a or HFC-134a were assumed for compliance in many cases where alternative control strategies such as non-VOM propellants, compressed gasses, or dimethyl ether may result in lower costs for compliance6.

Additional cost mitigation factors have also been "built in" to the OTC Consumer Products model rule. During the rulemaking process in California, and then again in the

28

### OTC states, extensive comments from affected parties were taken and responded to

before final determination of definitions for products, limits for those products, and other considerations in the rule were made. Among these considerations are the Alternative Control Plan ("ACP") and Innovative Products provision ("IPP") in the OTC model rule and the proposed Illinois regulation. These two provisions in the proposed regulation and the way in which they lower cost of control through flexibility in compliance options are discussed in section 2.4 of this document.

2.7 Reduction of VOM Emissions in Illinois Based upon a 14.2% reduction in VOM emissions from consumer and commercial products3beyond those achieved by the current federal rule, MACTEC estimates that adopting the OTC Model Rule for Consumer Products will account for a reduction of approximately 17.72 tons per day or 6468 tons of VOM per year in Illinois15. This estimate is based on figures from the 2002 inventory in Illinois and would represent a reduction of nearly 1% of the total anthropogenic VOM emissions in the State.

Table 2.7.1 details anticipated reductions in VOM from each affected category and the percentage reduction in those categories. These figures are from USEPA's Study of Volatile Organic Compound Emissions from Consumer and Commercial Products Report to Congress from March 1995, as well as from a number staff reports from the California Air Resources Board. The CARB staff reports were filed in support of a number of regulations leading to the Midterm Measures II level of control. As previously mentioned, this is the level of control the OTC model rule is based upon. Again, the

29

### State of New Jersey's Department of Environmental Protection concentrated data from

these reports into a single table in the technical support document prepared in support of their Consumer and Commercial Products rule. Data in Table 2.7.1 has been adjusted here to account for the population of the State of Illinois, as well as for consumer product emissions inventory data from Illinois2.

Table2.7.1Estimated VOM Emission Reductions for Consumer Products°

Consumer Products Category EstimatedVOMReductions based on USEPA and CARE Survey's (1)(2) EstimatedVOMReductions based on CARBSurvey
2002 VOC Emission (tpd) 2002

Emission Reduction (tpd) Percent

Emission Reduction 2002 VOC

Emission (tpd) 2002

Emission Reduction (tpd) Percent

Emission Reduction

Adhesives Aerosols 0.11 0.02 16 0.11 0.02 16

Construction and panel 0.26 0.11 44 0.26 0.11 44 Air fresheners Single-phase 0.53 0.31 57 0.15 0.06 40

Double-phase 1.18 0.40 34 1.18 0.40 34 Automotive Brake Cleaners aerosols 1.37 0.08 6 1.37 0.08 6

Non-aerosols 0.09 0.01 6 0.09 0.01 6 Automotive Rubbing or Polishing Compounds 0.27 0.09 33 0.27 0.09 33

Automotive Wax/Polish/Seal Hard paste

waxes 0.17 0.06 36 0.17 0.06 36

forms Bug and Tar Remover 0.21 0.08 40 0.21 0.08 40 Carburetor and choke cleaners (or fuel-injection air intake cleaners) aerosols 1.62 0.55 34 1.62 0.55 34

Non-aerosols 0.06 0.01 22 0.06 0.01 22 Carpet and Upholstery Cleaner aerosols 0.07 0.01 14 0.07 0.01 14

non-aerosols (diluta bles ) 0.15 0.09 59 0.15 0.09 59



### 30non-aerosols (ready-to use) 0.04 0.01 33 0.04 0.01 33

Dusting Aids Aerosols 0.01 0.00 29 0.12 0.03 25

All other forms 0.00 0.00 0 0.00 0.00 0 Engine degreasers 0.20 0.07 33 1.00 0.26 26

Aerosols 0.43 0.09 22 0.43 0.09 22 Non-aerosols 0.02 0.01 63 0.02 0.01 63 Fabric protectants 0.07 0.01 20 0.07 0.01 20 Floor Wax Stripper 0.87 0.47 54 0.87 0.47 54

Furniture maintenance products aerosol 0.51 0.09 18 0.51 0.09 18

all other forms (except solid/paste forms) 0.10 0.03 33 0.10 0.03 33

General purpose cleaners Non-aerosols

(dilutables) 1.24 0.11 9 1.24 0.11 9
Non-aerosols rea to

- (ready-touse) dy 0.83 0.28 33 0.83 0.28 33

General purpose degreasers aerosols 0.15 0.07 46 0.15 0.07 46

Non-aerosols (dilutables) 0.29 0.11 38 0.29 0.11 38
Non-aerosols (ready-to use) 0.25 0.04 16 0.25 0,04 16

Glass cleaners All other forms 0.64 0.17 27 0.64 0.17 27 Non-aerosols (dilutables) 0.32 0.21 68 0.32 0.21 68
Non-aerosols (ready-to use) 0.59 0.09 16 0.59 0.09 16
Hair Shine 0.15 0.06 42 0.15 0.06 42 Hairsprays 13.02 4.06 31 10.87 2.83 26 Hair mousses 0.19 0.08 43 0.19 0.08 43 Heavy-duty Hand Cleaners or Soap 0.80 0.61 76 0.80 0.61 76
Insecticides Crawling bug 0.62 0.31 50 0.50 0.21 44

aerosol crawling bug 0.99 0.13 13 0.99 0.13 13 aerosol flying bug 0.15 0.03 18 0.15 0.03 18

31non-aerosol lawn and garden 0.35 0.09 26 0.35 0.09 26

Laundry prewashAerosols/solid s 0.00 0.00 0 0.00 0.00 0 All other forms 0.00 0.00 0 0.00 0.00 0 Metal Polish/Cleanser 0.09 0.04 41 0.09 0.04 41 Multi-purpose Lubricant (excluding solid or semi-solid products) 1.57 0.63 40 1.57 0.63 40

Non-selective Terrestrial Herbicide Non-aerosols 0.91 0.69 77 0.91 0.69 77
Paint Remover or Stripper 0.53 0.05 10 0.53 0.05 10 Penetrant 0.14 0.04 27 0.14 0.04 27 Rubber and Vinyl Protectant non-aerosols 0.25 0.22 93 0.25 0.22 93

aerosols 0.19 0.06 31 0.19 0.06 31 Sealants and Caulking Compounds 0.48 0.20 42 0.48 0.20 42
Silicone-based Multi-purpose Lubricant (excluding solid or semisolid products) 0.19 0.07 34 0.19 0.07 34

Spot Remover aerosols 0.05 0.01 26 0.05 0.01 26

non-aerosols 0.08 0.06 68 0.08 0.06 68 Tire Sealants and Inflators 0.23 0.08 36 0.23 0.08 36 Undercoating 0.06 0.02 25 0.06 0.02 25 Wasp and Hornet Insecticide 0.17 0.07 39 0.17 0,07 39 Antiperspirant/D eodorant 0.97 0.40 0.97 0.40

TOTAL Reduction in Regulated Categories 35.62 11,96 34 33.89 10.60 31 IL 2002 Inventory of Consumer Products 81.86 81.86

32PERCENT REDUCTION OF INVENTORY 13 15



### 2.8 AffectedSources and Compliance Measures The proposed regulation affects consumer and commercial products from Source Classification Codes 2460xxxxxx. A detailed list of affected products and proposed limits for VOM content can be found in Table 2.2.1 in Section 2.2 of this document. The proposed regulation affects anyone who sells, supplies, offers for sale, or manufactures any of the products in Table 2.2.1 in Illinois.

It has been determined by CARB and the OTC that these limits for VOM in consumer and commercial products are technologically feasible. CARB has also published documents listing complying formulas for many of these specific products4. These example complying formulas have been shown to be effective in their purpose, and do not significantly change the usefulness of the product by reducing VOM content, or by using a substitute solvent in the product.

33

### 3.0 Architecturaland Industrial Maintenance Coatings

3.1 Description and Sources of Emissions An AIM coating, for the purposes of this proposed regulation, is a coating to be applied to stationary structures or the appurtenances at the site of installation, to portable buildings at the site of installation, to pavements, or to curbs. Coatings applied in shop applications or to non-stationary structures such as airplanes, ships, boats, railcars, and automobiles, and adhesives are not considered "Architectural Coatings" for the purposes of this rule. AIM coatings are used to protect and beautify homes, office buildings, factories, pavements, curbs and on a variety of surfaces inside and outside of such structures such as metal, wood, plastic, concrete, and wallboard. AIM coatings are applied by brush, roller, or spray gun, and are applied by consumers, contractors, or maintenance staff. Emissions of VOM from this source category occur when the solvent carrying the coating material evaporates and leaves the coating material on the surface during application and drying.

It has been estimated by MACTEC that AIM coatings account for approximately 3.7% of anthropogenic VOM emissions in the aforementioned MRPO region. In Illinois, AIM coatings emissions account for approximately 4.30% of the total anthropogenic VOM emissions during the ozone season, and approximately 3.97% of all anthropogenic VOM emissions in Illinois for the entire year15. AIM coatings account for approximately 4.28% of total anthropogenic VOM emissions in the East St. Louis NAA, and approximately 8.01% of total anthropogenic VOM emissions in the Chicago NAA during the ozone season(see Section 3.2, Table 3.2.2)2. The percentages of anthropogenic VOM

34

### emissions from AIM for the entire year in the Metro East and Chicago NAAs are 3.20%

and 6.26% respectively15.

3.2 Emissions in Illinois from Regulated Products The application and drying of AIM coatings on surfaces covered by this category results in evaporative emissions of VOM, while coating material is left on the surface. For the purposes of the proposed regulation this source category is broken down into 49 coating categories, each with a specific VOM content limit. These 49 coating categories are listed below in Table 3.2.1.

Table 3.2.1 AIMCoating Categoriesand VOM Limits
Coating Category VOM Content Limit Grams/liter (Pounds/gallon) 1) Flat Coatings 100 (0.8) 2) Non-flat Coatings 150 (1.3) 3) Non-flat- High Gloss Coatings 250 (2.1) SpecialtyCoatings 4) Antenna Coatings 530 (4.4) 5) Antifouling Coatings 400 (3.3) 6) Bituminous Roof Coatings 300 (2.5) 7) Bituminous Roof Primers 350 (2.9) 8) Bond Breakers 350 (2.9) 9) Calcamine Recoaters 475 (4.0)

35

### 10) Clear Wood Coatings A) Clear Brushing Lacquers 680 (5.7) B) Lacquers (including lacquer sanding sealers) 550 (4.6) C) Sanding Sealers (other than lacquer sanding sealers) 350 (2.9) D) Varnishes 350 (2.9) 11) Concrete Curing Compounds 350 (2.9) 12) Concrete/MasonrySealer 100 (0.8) 13) Conversion Varnish 725 (6.1) 14) Dry Fog Coatings 400 (3.3) 15) Faux Finishing Coatings 350 (2.9) 16) Fire-Resistive Coatings 350 (2.9) 17) Fire-Retardant Coatings

A) Clear 650 (5.4) B) Opaque 350 (2.9) 18) Floor Coatings 250 (2.1) 19) Flow Coatings 420 (3.5) 20) Form-Release Compounds 250 (2.1) 21) Graphic Arts Coatings (Sign Paints) 500 (4.2) 22) High-Temperature Coatings 420 (3.5) 23) Impacted ImmersionCoating 780 (6.5) 24) Industrial Maintenance Coatings 340 (2.8) 25) Low-Solids Coatings 120 (1.0) 26) Magnesite Cement Coatings 450 (3.8) 27) Mastic Texture Coatings 300 (2.5) 28) Metallic Pigmented Coatings 500 (4.2)

3629) Multi-Color Coatings 250 (2.1)

30) NuclearCoating 550 (4.6) 31) Pre-Treatment Wash Primers 420 (3.5) 32) Primers, Sealers, and Undercoaters 200 (1.7) 33) Quick-Dry Enamels 250 (2.1) 34) Quick-Dry Primers, Sealers and Undercoaters 200 (1.7) 35) Recycled Coatings 250 (2.1) 36) Roof Coatings 250 (2.1) 37) Rust Preventative Coatings 400 (3.3) 38) Shellacs A) Clear 730 (6.1) B) Opaque 550 (4.6) 39) Specialty Primers, Sealers, and Undercoaters 350 (2.9) 40) Stains 250 (2.1) 41) Stone Consolidants 450 (3.8) 42) Swimming Pool Coatings 340 (2.8) 43) Swimming Pool Repair and Maintenance Coatings 340 (2.8) 44) Temperature-Indicator Safety Coatings 550 (4.6) 45) Thermoplastic Rubber Coatings and Mastics 550 (4.6) 46) Traffic Marking Coatings 150 (1.3) 47) Waterproofing Sealers 250 (2.1) 48) Waterproofing Membranes 250 (2.1) 49) Wood Preservatives 350 (2.9)

37

### The Illinois Periodic Emissions Inventory and Milestone Demonstration for 2002

produced by the Illinois EPA contains the comprehensive inventory figures for VOM emissions due to AIM coatings statewide, and for both NAAs in Illinois. The emission factor used for calculating emissions from AIM coatings is a population-based factor of 3.946 pounds per year per capita. This emission factor assumes uniform activity seven day a week, but is adjusted for increased summertime coating usage. Table 3.2.2 shows the approximate population and the VOM emissions due to AIM coatings and other anthropogenic sources in each NAA, in the attainment areas, and statewide.

Table3.2.2VOM Emissions Due to AIM Coatings During the Ozone Season2 (Entire Year Data in Parentheses's) Area and Approximate Population VOM – AIM

Coatings (Tm) Total

Anthropogenic VOM (T/D) %

### of Total

Anthropogenic VOM
Attainment Area 21.20 996.52 2.13% (Pop. 3,756,253) (17.23) (772.71) (2.22%) Chicago NAA 46.81 584.45 8.01% (Pop. 8,295,996) (38.28) (611.38) (6.26%)
Metro – East St. Louis 3.09 72.15 4.28%


### NAA (2.63) (82.16) (3.20%) (Pop. 548,371) Statewide Total 71.10 1653.12 4.30% (Pop. 12,600,620) (58.14) (1466.24) (3.97%)

38

### 3.3 Technical Feasibility of Controls

The most effective approach for reducing emissions of VOM from AIM coatings is reformulation of the coatings themselves. This involves using water based formulations, using formulations employing acetone or other exempt solvents, or increasing the coating material content of the coating.

AIM coatings are currently regulated by USEPA's federal AIM rule, codified at 40 CFR Part 59 Subpart D, under the authority of Section 183(e) of the Clean Air Act. The current federal rule is estimated to reduce VOM emissions from AIM coatings by approximately 20% from uncontrolled levels. It has been estimated by MACTEC that the proposed regulation would result in an additional emission reduction of 21% beyond the current federal regulation. The proposed regulation is based on the "AIM OTC Model Rule"17in order to maintain consistency with the OTC states. The AIM OTC Model Rule and its VOM content limits were based on the affected coatings and VOM content limits in CARB's suggested control measures ("SCM") for AIM coatings13so that the coating formulations of the eastern states in the OTC would be consistent with formulations being used in California.

The Illinois EPA, acknowledging that the AIM OTC Model Rule is currently in place in all OTC states and the District of Columbia, and having reviewed the technical support for the proposed VOM limits created by CARB, is confident that the OTC model rule is technologically feasible for the State of Illinois. Furthermore, the method by which VOM reductions are achieved in this source category is most commonly a change in the

39

### formulation of the product available to consumers or contractors. Since many national

manufacturers of products subject to this rule will have already made modifications to their products in order to comply with the new regulations in the OTC states and in California, it is reasonable to consider that similar reformulations could be made, or have already been made, for products for sale in Illinois. In recognition of these facts, it is most appropriate to view the technological feasibility of the AIM OTC Model Rule primarily in terms of the economic impact of the rule. For this reason it is also in the best interest of the State of Illinois, the manufacturers of coatings subject to new regulation, and to the consumers of Illinois and elsewhere, that regulations involving AIM coatings be as uniform as is possible, while still addressing the issue of air quality.

The AIM OTC Model Rule is currently the preferred emission reduction measure for this source category of the states participating in LADCO and the MRPO. The Illinois EPA believes that working in conjunction with these states in the MRPO, the OTC states and the District of Columbia, and with California, that the proposed new regulation for consumer and commercial products is not only technologically feasible, but will also have a greater acceptability and a lesser economic impact than the previous estimates by the OTC and California that are presented in Section 3.5 of this document.

3.4 Economic Reasonableness Cost estimates for controlling VOM emissions from AIM coatings based on the OTC Model Rule have been made by MACTEC forthe LADCOregion. Assuming an effective date for adoption of the proposed rule in 2007, and a two year sell-through

40

### period for regulated products, MACTEC estimates that control costs will be

approximately $6400 per ton of VOM. This estimate of the control cost for the proposed regulation was made by MACTEC based upon figures from CARB and the OTC. CARB estimated the cost of their suggested control measures rule to be in this range. The limits for VOM content in specific AIM coatings in the AIM OTC Model Rule minors the level of emission limits in CARB's SCM13. This is the basis for MACTEC's assumption that the CARB and OTC control costs should approximate control costs for the LADCO region3. Furthermore, Illinois EPA asserts that control costs for VOM emissions from consumer and commercial products may indeed be lower than previous estimates due to the adoption of similar measures throughout the OTC and in California. The effect that uniform measures across a number of regions has been previously discussed in this document.

3.5 Cost Effectiveness of Controls The figures for the cost effectiveness of VOM control measures presented in this document were estimated by CARB in various staff reports related to California's SCM for control of emissions from AIM coatings drafted in 200013. These suggested control measures are the basis for the AIM OTC Model Rule. The data in Table 3.5.1 is taken from a New Jersey technical support document in support of the AIM OTC Model Rule, which in turn was taken from a CARB staff report for the CARB SCM for AIM coatings, but modified to reflect a slight variation in the VOM limit for industrial maintenance coatings that is in both the AIM OTC Model Rule and the proposed Illinois regulation.

41

### The table contains data detailing the cost per gallon of regulated coatings and is separated

into the various coating categories that would be affected by the proposed regulation.

Table 3.5.1 Producer Cost Per Gallon for AIM Coatings" Coating Category Estimated Producer Cost Per Gallon (dollars per gallon) Flats ($0.04)
Industrial Maintenance $4.19 Lacquer $4.00
Multicolor $2.74 Non-flat (low

### &medium-gloss) $0.93 Primers, Sealers, Undercoaters (PSU) $4.78 Quick Dry Enamel $6.02 Quick Dry PSU ($0.35) Stains $1.70 Swimming Pool Repair $2.65 Waterproofing Sealers ($0.40)

Table 3.5.2 details the cost effectiveness of the controls of the proposed regulation in dollars per pound of VOM reduced and in dollars per ton of VOM reduced. The data is taken from a New Jersey technical support document" based on CARB reports for California's SCM for AIM coatings and modified to reflect slight differences in the AIM OTC Model Rule. Likewise, the data is separated by the various affected coating categories.

42

### Table 3.5.2 Estimated Cost Effectiveness forAIM Coating Control"

Coating Category Estimated Cost Effectiveness (dollars per poundofVOM reduced) Flats ($0.30)
Industrial Maintenance $6.07 Lacquer $1.59
Multicolor $2.83 Non-flat (low

### &medium-gloss) $4.37 Primers, Sealers, Undercoaters (PSU) $7.65 Quick Dry Enamel $3.97 Quick Dry PSU ($0.25)
Stains $2.14 Swimming Pool Repair $0.83 Waterproofing Sealers ($0.50)

This economic analysis assumes that the sales and use of AIM coatings in Illinois is comparable to those of California and the OTC states. As mentioned previously in this document, estimates for cost effectiveness of control may be over estimated due to a few factors. Many regulated coatings are manufactured for national sales, and therefore no changes will be necessary for sales in Illinois. In the case that different formulations are used by national manufacturers for use in different regions, the cost of research of new formulas can be avoided due to the similarity of the proposed Illinois regulation to those of California and the OTC. In addition, CARB, in its cost estimates, did not account for

43

### the potential savings of manufacturers that produce more than one type of regulated

product. These manufacturers may only incur one time costs for research, development, formula ingredient changes, and packaging changes that apply to a number of the products they produce. Another mitigating factor in the cost effectiveness analysis here is the potential decrease in cost for ingredient materials common in the reformulations of coating. Cost estimates were made using current costs for materials at the time the SCM was proposed in California. These costs may actually decrease due to increased demand for these materials in coatings inducing economy of scale production13.

The CARB analysis assumed that all cost incurred were absorbed by the coatings manufacturers, and not passed on to consumers. Total annual costs were estimated for the coating categories and were used to determine cost per gallon of coating and cost effectiveness in dollars per pound of VOM reduction. These annual costs consisted of annual recurring and nonrecurring costs. The annual recurring costs included costs for materials, labeling, packaging, record keeping and reporting. Annual nonrecurring costs consisted of the costs for research, development, product testing, equipment purchase and modification, and marketing and distribution changes. Total annual costs were then divided by the number of gallons of coatings produced to determine an average number of dollars per gallon of coating shown in Table 3.5.1. Total annual costs were also divided by estimates for VOM emission reductions to provide data in dollars per pound of VOM reduced shown in Table 3.5.2.

443.6 Reduction ofVOM Emissions in Illinois



### Based upon MACTEC's estimate of a 21% reduction of VOM emissions from AIM coatings beyond those currently being achieved by the federal rule, adoption of the proposed regulation will account for the reduction 12.21 tons of VOM per day or 4456 tons of VOM annually3. This estimate is based on figures from the 2002 inventory in Illinois and would represent a reduction of nearly 1% of the total anthropogenic VOM emissions in the State.

3.7 Affected Sources and Compliance Measures 

### The proposed regulation affects AIM coating products from Source Classification Codes 2401 xxxxxx. A detailed list of affected products and proposed limits for VOM content can be found in Table 3.2.1 in Section 3.2 of this document. The proposed regulation affects anyone who sells, supplies, offers for sale, or manufactures any of the products in the table 3.2.1 in Illinois.

It has been determined by CARB and the OTC that the limits for VOM in AIM coating products detailed in Table 3.2.1 are technologically feasible. These limits have been adopted in California and in the OTC states. There are currently compliant formulas in all affected product categories commercially available in these places.

454.0 Aerosol Coatings

4.1 Description of Sources and Emissions 

### For the purposes of the proposed regulation, an aerosol coating is a pressurized coating product containing pigments or resins that dispenses product ingredients by means of a propellant, and is packaged in a disposable can for hand-held application or for use in specialized equipment for ground traffic/marking applications. Aerosol coatings are listed as a Group III consumer product in the Clean Air Act Section 183(e). The emissions of VOM from aerosol coatings result when the solvent carrying the coating material evaporates and leaves the coating material on the surface during application and drying, as well as from the propellants that are used to apply the coating.

While aerosol coatings are considered to be a consumer product, and emissions of VOM from aerosol coatings are currently regulated by limits given in a percent by weight, more effective measures for the reduction of VOM emissions from this specific product category have been developed. These measures, currently employed in California, involve the regulation of aerosol coatings by their potential to create ground level ozone. This is achieved by assigning maximum incremental reactivity ("MIR") factors to the various solvents used in aerosol coatings, and then setting limits on the product-weighted maximum incremental reactivity ("PWMIR") that is allowed for the different categories of aerosol coatings. These limits reflect the number of grams of ozone that can potentially be produced by each gram of the product, or in units of (g 03/ g of product). This methodology for the specific reduction of ozone produced by aerosol coatings allows for the reformulation of coatings that result in less ozone being produced by the

46use of the coating, while still allowing for a relatively high percentage of VOM by weight

that may be necessary for the usefulness of the product.

4.2 Emissions in Illinois from Regulated Products Emissions of VOM due to use of aerosol coatings result from evaporation of the solvents and propellants used to apply the coating. For the purposes of the proposed regulation this source category is broken down into 36 aerosol coating categories, each with a specific PWMIR limit. These 36 aerosol coating categories and their corresponding proposed PWMIR limits are listed below in Table 4.2.1.

Table 4.2.1 AerosolCoating Categoriesand PWMIR Limits
AerosolCoating Category Product-Weighted MIR in Grams Ozone per Gram Product (gO3/gproduct)
1) General Coatings A) Clear Coatings 1.50 B) Flat Paint Products 1.20 C) Fluorescent Coatings' 1.75 D) Metallic Coatings 1.90 E) Nonflat Paint Products 1.40 F) Primers 1.20 2) Specialty Coatings A) Art Fixatives or Sealants 1.80 B) Auto Body Primers 1.55

47

### C) Automotive Bumper and Trim Products 1.75 D) Aviation or Marine Primers 2.00 E) Aviation Propeller Coatings 2.50 F) Corrosion Resistant Brass, Bronze, or Copper Coatings 1.80 G) Exact Match Finishes: 1) Engine Enamel 1.70 2) Automotive 1.50 3) Industrial 2.05 H) Floral Sprays 1.70 I) Glass Coatings 1.40 J) Ground Traffic/Marking Coatings 1.20 K) High Temperature Coatings 1.85 L) Hobby/Model/Craft Coatings: 1) Enamel 1.45 2) Lacquer 2.70 3) Clear or Metallic 1.60 M) Marine Spar Varnishes 0.90 N) Photograph Coatings 1.00 0) Pleasure Craft Finish Primers, Surfacers or Undercoaters 1.05 P) Pleasure Craft Topcoats 0.60 Q) Polyolefin Adhesion Promoters 2.50 R) Shellac Sealers: 1) Clear 1.00

48

### 2) Pigmented 0.95 S) Slip-Resistant Coatings 2.45 T) Spatter/Multicolor Coatings 1.05 U) Vinyl/Fabric/Leather/Polycarbonate Coatings 1.55 V) Webbing/Veil Coatings 0.85 W) Weld-Through Primers 1.00 X) Wood Stains 1.40 Y) Wood Touch-Up, Repair or Restoration Coatings 1.50

The Illinois EPA does not segregate inventory data for VOM emissions due to consumer products into specific categories such as aerosol coatings. However, in preparation for a national rule employing PWM1R limits on aerosol coating products, and in order to calculate the equivalent impact that this type of limit would have in terms of pounds or tons of VOM reduced, the USEPA has estimated factors for states to use in determining the equivalent emissions and emission reductions. These factors use an emissions estimate of .588 pounds of VOM per capita per year due to use of aerosol coating products. Table 4.2.2 details emission estimates for this product category in Illinois, in each NAA, and in the attainment areas.

49

### Table4.2.2VOM Emissions Due toAerosol Coating Products Area and Approximate Population VOM —Aerosol

Coating Products (tpd) Total

Anthropogenic VOM (tpd) %of Total

Anthropogenic VOM Attainment Area (Pop. 3,756,253) 3.03 996.52 0.30%

Chicago NAA (Pop. 8,295,996) 6.68 584.45 1.14%

Metro—East St. Louis NAA (Pop. 548,371) 0.44 72.15 0.61%

Statewide Total (Pop. 12,600,620) 10.15 1653.12 0.61%

4.3 Technical Feasibility of Controls Due to the nature of aerosol coating products, limiting the amount of VOM on a percent by weight basis, or on a percent by volume basis, would have a negative impact on the efficacy of the product. For this reason it has been determined that the most environmentally beneficial method for the control of emissions from aerosol coatings is to reduce the total amount of ozone that the products have a potential to create by the aforementioned method of limiting their product weighted maximum incremental reactivity. The MIR scale developed by William P.L. Carter at the request of CARB has

50

### been found to be the most appropriate scale to determine the amount of ozone that can be

created by a given amount of VOM.

It should be noted that for the section of the proposed regulation dealing with aerosol coating products the regulated pollutant is VOM, but that certain exempt compounds normally excluded from the definition of VOC at 40 CFR 51.100(s)(1) will be regulated. However, as has been previously mentioned the limits will be given in units of grams 03 per gram of product, and is intended to encourage reformulations of aerosol coatings using VOM ingredients with less reactivity and provide manufacturers of those products with some flexibility in achieving compliance.

The Illinois EPA considers the PWMIR limits in the proposed regulation to be technically feasible for two reasons. First, there are currently compliant products in each of the potentially affected aerosol coating product categories being sold in California and elsewhere as result of the regulations already in effect in California. As has been previously discussed, the proposed regulation is based closely on the regulations currently in effect in California and being considered as the basis of a national rule. Secondly, the USEPA estimates that only 18 percent of the potentially affected products sold in the U.S. are not compliant. This is a result of many manufacturers already selling "CARB compliant" products on a nationwide basis. The USEPA acknowledges that significant emission reductions have already occurred nationwide as a result of the current CARB regulations. It is for these reasons that the Illinois EPA considers the limits in the proposed regulation to be technically feasible. Additionally, it is very likely

51

### that these limits can be achieved at significantly lower costs than have been estimated by

the USEPA or CARB.

4.4 Flexibilityin Compliance Measures 

### The method of limiting the reactivity or the PWMIR of the ingredients of a coating in order to reduce the amount of ozone formed as a result of aerosol coating use provides manufacturers with a great deal of flexibility in compliance measures. The proposed regulation still allows for relatively high percentages of VOM by weight for the products in order to maintain the same or similar performance characteristics, and allows for the use of a wide variety of solvents and propellants provided that the PWMIR of given product does not exceed the limit for that particular category. In this way the proposed regulation can be effective in reducing the amount of ozone formed as a result of aerosol coatings while not imposing stricter VOM limits on manufacturers of the coatings.

It should be noted that the great majority of aerosol coating products currently being sold in the U.S. are already compliant with the proposed limits; that there are currently compliant products being sold in every regulated category; and that CARB has developed a list of typical compliant formulations, as discussed in Section 4.2, while estimating the costs associated with these limits.

4.5 Economic Reasonableness 

### Cost estimates for the reduction of ozone formation from aerosol coatings have been estimated by the USEPA in preparation of a national rule based on the same California

52

### regulation that the proposed Illinois regulation has been based. The proposed regulation

will affect aerosol coating manufacturers, aerosol coating processors, aerosol coating wholesale distributors, and importers of aerosol coatings. The economic analysis performed by the USEPA focused on coating manufacturers and assumed that costs to processors, distributors, and importers of the coatings would be minimal. The cost to the manufacturers were assumed to be from the cost of raw materials used in the coating formulations, the research and development required to develop compliant formulations, and the cost of record keeping and reporting associated with the proposed regulation. These three costs were evaluated on a per can basis for each of the 36 aerosol coating categories. The assumed volume of the can in all cases was 10.5 ounces.

To determine costs due to differences in raw materials data was used from CARB's 1997 survey of the aerosol coating industry. From this information CARB determined for each category of coating a typical formulation for a compliant product, and a typical formulation of a non-compliant existing product. The raw material costs for complianceper can were then calculated from the difference between typical compliant and noncompliant formulations of the same coating category. These cost ranged from a savings of $0.04 per can to a cost of $0.12 per cans. The raw materials costs per can for each coating category are shown in Table 4.5.1.

To determine the research and development costs of the proposed regulation the USEPA used data from the aforementioned CARB survey involving the number of affected coating manufacturers, the number of coating categories those manufacturers produced,

53

### and the number of cans of product produced by those manufacturers. Along with this

data, information regarding the salaries of chemists was obtained from the American Chemical Society. It was assumed that additional chemists would be needed by the coatings industry for the reformulation of their products, and the testing of those reformulated products to ensure that performance characteristics are maintained. After making assumptions about the number of additional chemists that would be required for research and development, and annualizing the costs of the research and development efforts over a ten year period with an assumed interest rate of 7%, research and development costs were made on a per can basis. These costs ranged from $0.00 to $0.109 per can8. The research and development costs per can for each coating category are also shown in Table 4.5.1.

Recordkeeping and reporting costs arise from time spent by manufacturers reading and understanding the requirements of a new regulation, implementing new approaches for compliance, and preparing initial compliance reports. Because the reactivity limit approach is relatively new to coatings manufacturers, it was assumed that these tasks would be performed by supervisory level employees. It was estimated that recordkeeping and reporting costs for the entire industry nationwide would be $670,140 per year. These costs yield an estimate of $0.002 per can8. This value was included in Table 4.5.1 in order to calculate the total cost per can of the proposed regulation.

54

### Table 4.5.1 Cost Estimates per Can for Aerosol Coating Products8

Coating Category Raw Material Cost (per can) It&D Cost

(per can) it&R Costs

(per can) Total Cost(s)

(per can)
Clear Coatings 0.03 0.008 0.002 .040 Flat Coatings 0.05 0.003 0.002 0.055 Flourescent Coatings 0.01 0.009 0.002 0.021 Metallic Coatings 0.01 0.004 0.002 0.016 Non-Flat Coatings 0.07 0.001 0.002 0.073 Primers 0.05 0.003 0.002 0.055 Ground/Traffic/Marking 0.07 0.002 0.002 0.055 Art Fixatives or Sealants 0.1 0.006 0.002 0.108 Auto Body Primers 0.02 0.006 0.002 0.028 Automotive Bumber and Trim 0.12 0.019 0.002 0.141 Aviation or Marine Primers 0 0 0.002 0.002 Aviation Propeller Coatings 0 0 0.002 0.002 Corrosion Resistant Brass Coatings 0.07 0.011 0.002 0.083 Exact Match Finish - Engine 0.05 0.003 0.002 0.055 Exact Match Finish - Automotive 0.05 0.003 0.002 0.055 Exact Match Finish - Industrial 0.08 0.001 0.002 0.083 Glass Coatings 0.07 0.023 0.002 0.095 High Temperature Coatings 0.03 0.009 0.002 0.041 Hobby/Craft, Enamel -0.04 0.022 0.002 0 Hobby/Craft, Lacquer -0.03 0.057 0.002 0.029 Hobby/Craft, Clear or Metallic 0.08 0.014 0.002 0.096 Marine SparVarnishes 0 0 0.002 0.002 Photographic Coatings -0.04 0.011 0.002 0



### 55Pleasure Craft Primers, Surfaces, or 0 0 0.002 0.002

Undercoaters Pleasure Craft Topcoats 0 0 0.002 0.002 Polyolefin Adhesion Promoters 0.03 0.077 0.002 0.109 Shellac Sealers, Clear 0 0 0.002 0.002 Shellac Sealers, Pigmented 0 0 0.002 0.002 Slip-Resistant Coatings 0 0 0.002 0.002 Spatter/Multicolor Coatings 0.05 0.004 0.002 0.056 Vinyl/Fabric/Leather/Polycarbonate 0.03 0.015 0.002 0.047 Coatings WebbingNeiling Coatings 0 0 0.002 0.002 Weld-Through Primers 0.01 0.109 0.002 0.121 Wood Stains 0 0 0.002 0.002 Wood Touch-up, Repair, or 0.07 0.04 0.002 0.112 Restoration Coatings



### It should be noted that estimated costs for raw materials, research and development, and recordkeeping and reporting are likely higher than what will actually be incurred due to Illinois adopting the proposed regulation. As previously stated, the majority (approximately 82%) of the aerosol coating products currently being sold nationwide are in compliance with the PWMIR limits in the proposed regulation', and it is likely that many manufacturers of aerosol coatings will incur no additional costs.

4.6 Cost Effectiveness of Controls In order to estimate the cost effectiveness of the measures in the proposed regulation for the control of VOM emissions from aerosol coatings a few key assumptions must be

56

### made. First, the total cost of control for a national rule estimated by the USEPA assumes

that all of an estimated 329,536,000 10.5 ounce cans produced in 2005 would have to be reformulated. The cost for this was estimated to be $20,360,521 for the entire U.S.' Second, it is assumed that the cost to Illinois will be proportional to its population in relation to the U.S. population. This would assume that the cost to Illinois would be approximately 4.4% of the national cost or $895,863. Third, it is assumed, as it was in Section 4.2 of this document, that limiting the amount of ozone prevented from forming rather than limiting VOM by % by weight is equivalent to a reduction of 0.114 lbs of VOM per capita per year, and that a factor of 0.588 lbs VOM per capita per year can be used to estimate current emissions.

It can then be estimated, using the assumptions above, that the cost effectiveness of the proposed regulation in terms of dollars per ton of VOM reduced is approximately $1272 per ton. As has been previously discussed, this value reflects assumptions that do not consider the mitigating factors detailed in Section 4.2 of this document, and most likely represents an over estimate of cost.

4.7 Reduction ofVOM Emissions in Illinois In the USEPA analysis of air pollution impacts for the proposed limits in a national rule it is explained that the limits on PWMIR will be effective in reducing both VOM emissions and reducing the amount of ozone formed from those emissions. Since most states will use these reductions in their ozone SIP planning, the USEPA calculated the effect of the

57

### reactivity-based limits in terms of mass VOM emissions. These reductions should more

accurately be described as "equivalent reductions in VOM emissions".

It has been estimated by the USEPA that the proposed limits would result in a 19.4% reduction of VOM emissions from aerosol coating products beyond a baseline level set in 19907. A 19.4% reduction in equivalent VOM emissions from the estimates given in Section 4.2 would account for an equivalent reduction of 1.97 tons per day or approximately 719 tons per year. The USEPA acknowledges that these figures are only estimates to be used in SIP planning, and the actual reductions in terms of mass of VOM or in ozone formation are difficult to estimate given the portion of aerosol coating products that are already compliant with the proposed limits.

4.8 AffectedSources and Compliance Measures The proposed regulation affects Group III consumer and commercial products classified as aerosol coatings. A detailed list of affected products and proposed limits for VOM content can be found in Table 4.2.1 in Section 4.2 of this document. The proposed regulation affects anyone who sells, supplies, offers for sale, or manufactures any of the products in Table 4.2.1 in Illinois.

It has been determined by CARB and the USEPA that these limits for VOM in aerosol coating products are technologically feasible. These limits for the PWMIR of various aerosol coating products have been adopted in California and are currently being considered as the basis for a national rule. There are currently compliant formulas in

58

### each coating category that are commercially available. These compliant formulas have

not significantly changed the usefulness of the product by reducing VOM content or by using a substitute solvent in the product. In addition, the great majority of the affected products being sold nationwide are already compliant products.

595.0 Summary



### The proposed regulation for the control of VOM emissions from area sources is based on rules that have been adopted in California and in the OTC states in order reduce VOM emissions from a wide variety of consumer and commercial products and coating products. The limits in the consumer products portion of the rule have been adopted by all the OTC states (most in 2005) and in California. This is also true for the AIM coatings portion of the rule. The OTC states have adopted the limits in the proposed regulation by adopting versions of the AIM OTC Model Rule, and in California the same limits have been adopted as suggested control measures. The limits proposed in the aerosol coating portion of the proposed regulation are the same as those that have been adopted in California, and are the same limits that have been proposed by the USEPA for a national rule. The adoption of the regulation will move Illinois forward toward regulation of these products that is consistent with a large portion of the United States population that includes California, the OTC states, and a number of Midwestern states that are in different phases of adopting regulations with the same uniform limits.

By adopting the proposed regulation the Illinois EPA anticipates a significant reduction in VOM emissions from the affected area sources. When added together the emission of VOM from consumer products, AIM coatings, and aerosol coating products accounts for approximately 9.86% of all anthropogen c VOM emissions in the State of Illinois. The estimated reductions given in sections 2.7, 3.7, and 4.7 of this document add up to slightly more than 10,000 tons of VOM annually or a reduction of approximately 28.5 tons per day. The Illinois EPA acknowledges that some of these reductions have already

60

### taken place due to nationwide compliance by many of the larger manufacturers of these

products, however adoption of these limits in Illinois will lead to greater compliance in Illinois, as well as in the remaining Midwestern states. A list of potentially affected manufacturers in Illinois has been included as Appendix A to this document, and contains manufacturers potentially affected by all subparts of the proposed regulation.

The Illinois EPA asserts that the proposed regulation is both technologically feasible and economically reasonable. The technological feasibility of the limits in all three subparts of the rule is self evident. While the staff reports of CARB and the OTC include arguments for the feasibility of the required reformulations for compliance, these reports were drafted before the said limits had been adopted. Since compliant products in every affected category in the proposed regulation are currently being sold and are in use in all states of the OTC and in California, no further evidence for technological feasibility is required. Likewise, all figures presented in this document as evidence of economic reasonableness are likely to be overestimates because much of the cost for compliance associated with the limits in the proposed regulation have already been incurred by the majority of the manufacturers of the affected products. These overestimates of cost still produce quite reasonable estimates for cost effectiveness when translated into dollars per ton of VOM reduced.

In light of the facts presented in this technical support document the proposed regulation for the control of VOM emissions from consumer and commercial products, AIM coatings, and aerosol coating products should be considered to be technologically

61

### feasible, economically reasonable, and an effective measure toward achieving attainment

of the 8-hour ozone NAAQS in all areas of the State of Illinois.

626.0 References

1. Emission Inventory Improvement Program Volume III: Chapter 5 – Consumer and Commercial Solvent Use, Eastern Research Group, NC, August 1996. Illinois 2002 Periodic Emissions Inventory and Milestone Demonstration, Illinois Environmental Protection Agency, Springfield, IL, November 2004.
3. Interim White Paper – Midwest RPO Candidate Control Measures, Source Category: Consumer and Commercial Products, MACTEC, December 1, 2005.
4. Example Complying Formulas, 2004 Consumer Products Amendments, State of California Air Resources Board, March 18, 2004.
5. Initial Statement of Reasons for the Proposed Amendments to the California Aerosol Coating Products, Antiperspirants and Deodorants, and Consumer Products Regulations, Test Method 310, and Airborne Toxic Control Measure for Para-Dichlorobenzene Solid Air Fresheners and Toilet/Urinal Care Products, State of California Air Resources Board, May 7, 2004.
6. Initial statement of Reasons for Amendments to the California Consumer Products Regulation, State of California Air Resources Board, September 10, 1999.
7. National Volatile Organic Compound Emission Standards for Aerosol Coatings, Proposed Rule, 72

### FR38952-38991, July 16, 2007.
8. National Volatile Organic Compound Emission Standards for Aerosol Coatings, Cost Impacts Analysis, U.S. Environmental Protection Agency Office of Air Quality Planning and Standards, Sector Policies and Programs Division, Research Triangle Park, North Carolina 27711, June 2007.
9. Interim White Paper - Midwest RPO Candidate Control Measures, Source Category, MACTEC, December 1, 2005.

10. Estimated VOC Emission Reductions and Economic Impact Analysis for Proposed Amendments to Chemically Formulated Consumer Products, The State of New Jersey Department of Environmental Protection, July 3, 2003.

11. Regulation for Reducing the Ozone Formed from Aerosol Coating Product Emissions, Title 17, California Code of Regulations, Article 3, Aerosol Coating Products, Sections 94521-94524 and 94526, approved June 18, 2001.

6312. Regulation for Reducing Volatile Organic Compound Emissions from Consumer Products, Title 17 California Code of Regulations Sections 94507, 94508, 94509, 94513, 94514, and 94515, November 19, 2000.
13. Staff Report for the Proposed Suggested Control Measure for Architectural Coatings, California Air Resources Board, June 2000.
14. Estimated VOC Emission Reductions and Economic Impact Analysis for Proposed Amendments to Architectural Coatings Rule, The State of New Jersey Department of Environmental Protection, June 12, 2003.
15. Illinois Base Year Ozone Inventory for 2002, Illinois Environmental Protection Agency, Springfield, IL, June 2006.
16. Model Rule for Consumer Products, Ozone Transport Commission, November 29, 2001.
17. AIM OTC Model Rule, Ozone Transport Commission, March 6, 2001.
18. Control Measure Development Support Analysis of Ozone Transport Commission Model Rules, E.H. Pechan and Associates, March 31, 2001.

64Appendix A: Potentially Affected Manufacturers in Illinois

Company Name City Zip Code Primary

SIC SIC Description Aabbitt Adhesives, Inc CHICAGO 60647 28910200 Adhesives Aabbitt Adhesives, Inc CHICAGO 60620 28910200 Adhesives Adhesive Products Corporation CHICAGO 60612 28910200 Adhesives Armitage Industries Inc FRANKLIN PARK 60131 28910200 Adhesives Bradley Coating, Inc. SAINT CHARLES 60174 28910200 Adhesives Bruce Adhesives WEST CHICAGO 60185 28910200 Adhesives Budnick Supply Inc COLUMBIA 62236 28910200 Adhesives C.P. Mogen Co. SKOKIE 60076 28910200 Adhesives Cbrtt, Inc. AURORA 60504 28910200 Adhesives Croda Adhesives Inc CAROL STREAM 60188 28910200 Adhesives Cyberbond, L.L.C. BATAVIA 60510 28910200 Adhesives Firenze USA Inc CHICAGO 60612 28910200 Adhesives Forbo Adhesives, LLC MORRIS 60450 28910200 Adhesives Henkel Corporation CAROL STREAM 60188 28910200 Adhesives Henkel Corporation ELGIN 60120 28910200 Adhesives Indopco Inc ITASCA 60143 28910200 Adhesives Indopco Inc LINCOLNSHIRE 60069 28910200 Adhesives Indopco Inc HOFFMAN ESTATES 60192 28910200 Adhesives Loctite BETHALTO 62010 28910200 Adhesives Morton International Incorporated Adhesives& Specialty RINGWOOD 60072 28910200 Adhesives Morton International, Inc WAUKEGAN 60087 28910200 Adhesives Morton International, Inc CHICAGO HEIGHTS 60411 28910200 Adhesives Morton International, Inc. CHICAGO 60606 28910200 Adhesives National Casein of New Jersey, Incorporated CHICAGO 60620 28910200 Adhesives North Shore Consultants Inc CHICAGO 60630 28910200 Adhesives On Hand Adhesives LAKEZURICH 60047 28910200 Adhesives Rohm and Haas Company ELK GROVE VILLAGE 60007 28910200 Adhesives Roman Decorating Products, Inc CALUMET CITY 60409 28910200 Adhesives Roman Holdings Corporation CALUMET CITY 60409 28910200 Adhesives Rubrtek Inc OLNEY 62450 28910200 Adhesives Sanford Chemical Co., Inc ELK GROVE VILLAGE 60007 28910200 Adhesives Sovereign Adhesives Inc PLAINFIELD 60544 28910200 Adhesives Spartan Adhesives&Coatings CRYSTAL LAKE 60014 28910200 Adhesives Specialty Construction Brands, Inc AURORA 60504 28910200 Adhesives Specialty Construction Brands, Inc PALATINE 60067 28910200 Adhesives TheW W Henry Company LP California BOURBONNAIS 60914 28910200 Adhesives Tsv Adhesive Systems, Inc FRANKFORT 60423 28910200 Adhesives

65Tyco International (us) Inc. CARPENTERSVILLE60110 28910200 Adhesives

U S Adhesives Corp CHICAGO 60612 28910200 Adhesives Val-A Chicago, Inc CHICAGO 60609 28910200 Adhesives Willett America, Inc WOOD DALE 60191 28910200 Adhesives BASF Construction Chemicals Inc CHICAGO HEIGHTS 60411 28910000 Adhesives and sealants Bradley Group SAINT CHARLES 60174 28910000 Adhesives and sealants Chem Spec Corporation SCHAUMBURG 60193 28910000 Adhesives and sealants Cr Investments, Inc ELGIN 60123 28910000 Adhesives and sealants Dover Alliances, Inc NAPERVILLE 60563 28910000 Adhesives and sealants Emecole, Inc. ROMEOVILLE 60446 28910000 Adhesives and sealants Etemabond, Inc. MUNDELEIN 60060 28910000 Adhesives and sealants ARLINGTON Foster Products HEIGHTS 60004 28910000 Adhesives and sealants Green Products LLC ROMEOVILLE 60446 28910000 Adhesives and sealants H. B. Fuller Company PALATINE 60067 28910000 Adhesives and sealants ARLINGTON H. B. Fuller Company HEIGHTS 60004 28910000 Adhesives and sealants H. B. Fuller Company TINLEY PARK 60477 28910000 Adhesives and sealants Henkel Corporation PLAINFIELD 60544 28910000 Adhesives and sealants Hot Melt Technologies Inc ELMHURST 60126 28910000 Adhesives and sealants Indopco Inc CHICAGO 60632 28910000 Adhesives and sealants Kwik Lok Inc FRANKFORT 60423 28910000 Adhesives and sealants Lintec of America Inc BUFFALO GROVE 60089 28910000 Adhesives and sealants Mapei Corporation WEST CHICAGO 60185 28910000 Adhesives and sealants Microcosm CHICAGO 60804 28910000 Adhesives and sealants Morgan Adhesives Company MUNDELEIN 60060 28910000 Adhesives and sealants Morgan Adhesives Company PALATINE 60074 28910000 Adhesives and sealants Performance Minerals Corp CHICAGO 60633 28910000 Adhesives and sealants Right/Pointe Company DE KALB 60115 28910000 Adhesives and sealants River City Seacolt&Asphalt IncPEORIA 61615 28910000 Adhesives and sealants Rj Oreda&Associates DOWNERS GROVE 60515 28910000 Adhesives and sealants Rohm and Haas Company RINGWOOD 60072 28910000 Adhesives and sealants Saf T Lok International Corp LOMBARD 60148 28910000 Adhesives and sealants Sigma Coatings Inc ADDISON 60101 28910000 Adhesives and sealants Ski Seal Coating Inc LA GRANGE 60525 28910000 Adhesives and sealants The Dow Chemical Company KANICAKEE 60901 28910000 Adhesives and sealants W. R. Meadows, Inc. HAMPSHIRE 60140 28910000 Adhesives and sealants Elmer's Products, Inc. GURNEE 60031 28910201 Adhesives, paste R A Hahn Associates LIBERTYVILLE 60048 28910202 Adhesives, plastic Bayer Cropscience Limited Partnership PRINCETON 61356 28790000 Agricultural chemicals, nec Bunker Hill Supply Co WEST UNION 62477 28790000 Agricultural chemicals, nec Dow Agrosciences L.L.C. MOUNT VERNON 62864 28790000 Agricultural chemicals, nec Eastman Chemical Company, Inc SOUTH ELGIN 60177 28790000 Agricultural chemicals, nec FarmerManufacturing Co Inc DORSEY 62021 28790000 Agricultural chemicals, nec Gard Products Inc CARPENTERSVILLE 60110 28790000 Agricultural chemicals, nec Gard Rogard Inc CARPENTERSVILLE 60110 28790000 Agricultural chemicals, nec liarbach, Nixon&Willson Inc CLINTON 61727 28790000 Agricultural chemicals, nec

66Kill Grow,Inc ESSEX 60935 28790000 Agricultural chemicals, nec

Monsanto Company CENTRALIA 62801 28790000 Agricultural chemicals, nec Precision Laboratories Inc WAUKEGAN 60085 28790000 Agricultural chemicals, nec Pro Tek Products Inc WHEATON 60187 28790000 Agricultural chemicals, nec Rhodia Inc CHICAGO 60827 28790000 Agricultural chemicals, nec Taggart's AG Supply GREENUP 62428 28790000 Agricultural chemicals, nec Trace Chemicals LLC PEKIN 61554 28790000 Agricultural chemicals, nec Valent Biosciences Corporation LIBERTYVILLE 60048 28790000 Agricultural chemicals, nec West Agro Inc DES PLAINES 60018 28790000 Agricultural chemicals, nec Westmin Corp QUINCY 62301 28790000 Agricultural chemicals, nec Westmin Corporation QUINCY 62301 28790000 Agricultural chemicals, nec Tri-County Chemical Inc GALATIA 62935 28790101 Arsenates, arsenates (formulated) Bumper Scuffs LAKE VILLA 60046 28420201 Automobile polish Reed-Union Corporation CHICAGO 60611 28420201 Automobile polish Rukin Industries CHICAGO 60639 28420201 Automobile polish Treatment Products, Ltd. CHICAGO 60651 28420201 Automobile polish Voodoo Ride LLC CHICAGO 60610 28420201 Automobile polish Brenda Fields GLEN ELLYN 60137 28449901 Bath salts June Edwards JOLIET 60432 28449901 Bath salts Oak Court Creations MINOOKA 60447 28449901 Bath salts Tanyas Bath and Body CHICAGO 60612 28449901 Bath salts Clorox Data ROCKFORD 61109 28429901 Bleaches, household: dry or liquid Clorox Products Manufacturing Company CHICAGO 60638 28429901 Bleaches, household: dry or liquid Eddie V Vanzant CHICAGO 60617 28790102 Bordeaux mixture Roanoke Companies Group Inc AURORA 60504 28910101 Caulking compounds Apco Enterprises Inc OAK LAWN 60455 28420102 Cleaning or polishing preparations, nec Apex Engineering Products Corporation AURORA 60504 28420102 Cleaning or polishing preparations, nec Blackboard Maintenance Co FULTON 61252 28420102 Cleaning or polishing preparations, nec Chemical Specialties Manufacturing Corp MAPLETON 61547 28420102 Cleaning or polishing preparations, nec Claire-Sprayway, Inc. ADDISON 60101 28420102 Cleaning or polishing preparations, nec Colorex Chemicals Co Inc BENSENVILLE 60106 28420102 Cleaning or polishing preparations, nec Coral Chemical Company ZION 60099 28420102 Cleaning or polishing preparations, nec Ecolab Inc SOUTH BELOIT 61080 28420102 Cleaning or polishing preparations, nec Ecolab Southfield Bus Par JOLIET 60431 28420102 Cleaning or polishing preparations, nec Grayson&Associates SAINT CHARLES 60174 28420102 Cleaning or polishing preparations, nec Johnson Diversey Inc ELGIN 60123 28420102 Cleaning or polishing preparations, nec PLC Corp LAKE BLUFF 60044 28420102 Cleaning or polishing preparations, nec R R Street&Co Inc CHICAGO 60616 28420102 Cleaning or polishing preparations, nec R R Street&Co Inc CHICAGO 60632 28420102 Cleaning or polishing preparations, nec Rycoline Products, LLC CHICAGO 60630 28420102 Cleaning or polishing preparations, nec Sunshine Makers, Inc. DES PLANES 60018 28420102 Cleaning or polishing preparations, nec Magnum International, Inc LANSING 60438 28510201 Coating, air curing Mid-America Protective ELK GROVE Coatings, Inc. VILLAGE 60007 28510201 Coating, air curing Universal Chemicals and Coatings, Inc. ELGIN 60123 28510201 Coating, air curing Dworin Holdings, Inc. ELMHURST 60126 28440301 Colognes

67Bill Vuksanovich Art Stud CHICAGO 60634 28510101 Colors in oil, except artists'

Roads&Leads Inc GURNEE 60031 28510101 Colors in oil, except artists' Labtec Cosmetics By Marzena ADDISON 60101 28440302 Concentrates, perfume William K Sullivan PETERSBURG 62675 28440302 Concentrates, perfume Avon Products, Inc. MORTON GROVE 60053 28440500 Cosmetic preparations Barbara Salomone&Associates CHICAGO 60613 28440500 Cosmetic preparations Barbara Salomone&Associates DES PLANES 60016 28440500 Cosmetic preparations Brio Fragrance LLC CHICAGO 60640 28440500 Cosmetic preparations C J'S Luscious Body FOX LAKE 60020 28440500 Cosmetic preparations Caboodles Cosmetics, LP PLANO 60545 28440500 Cosmetic preparations Clintex Laboratories, Inc. CHICAGO 60621 28440500 Cosmetic preparations Colorlab Cosmetics, Inc. ROCKFORD 61104 28440500 Cosmetic preparations Combe Laboratories, Inc RANTOUL 61866 28440500 Cosmetic preparations Concept Laboratories, Inc. CHICAGO 60622 28440500 Cosmetic preparations Cory Dental&Medical Supply's, Inc. ORLAND PARK 60462 28440500 Cosmetic preparations Ely's Tops, Inc. NEW LENOX 60451 28440500 Cosmetic preparations Fan C ME 2 Cosmetics CHICAGO 60623 28440500 Cosmetic preparations General Organics, Inc. CHICAGO 60623 28440500 Cosmetic preparations Juvenesse By Elaine Gayle Inc CHICAGO 60611 28440500 Cosmetic preparations Leiner Health Products Inc CHICAGO 60632 28440500 Cosmetic preparations Liquid Packaging, LLC CHICAGO 60620 28440500 Cosmetic preparations Maynard Inc CHICAGO 60647 28440500 Cosmetic preparations Rw Greeff&Co LLC VILLA PARK 60181 28440500 Cosmetic preparations Skincare Technology Inc CHICAGO 60610 28440500 Cosmetic preparations Stillman Co AURORA 60505 28440500 Cosmetic preparations Vee Pak, Inc LA GRANGE 60525 28440500 Cosmetic preparations Vee Pak, Inc. LA GRANGE 60525 28440500 Cosmetic preparations Zanfel Laboratories Inc PEORIA 61602 28440500 Cosmetic preparations Holland Specialty Co PEORIA 61605 28440201 Denture cleaners Smithkline Beecham Corporation WHITE HALL 62092 28440201 Denture cleaners Smithkline Beecham Corporation CHICAGO 60608 28440201 Denture cleaners Smithkline Beecham Corporation SPRINGFIELD 62704 28440201 Denture cleaners Dualle Products SOUTH ELGIN 60177 28420401 Deodorants, nonpersonal Wrap-On Company Inc. BEDFORD PARK 60638 28420401 Deodorants, nonpersonal Stephanie Seloover MOLINE 61265 28440501 Depilatories (cosmetic) Consolidated Chemical Works, Ltd. CHICAGO 60622 28419901 Detergents, synthetic organic or inorganic alkaline Detergents, synthetic organic or inorganic Cygnus Corporation CHICAGO 60827 28419901 alkaline Detergents, synthetic organic or inorganic Desoto, L.L.C. JOLIET 60433 28419901 alkaline Detergents, synthetic organic or inorganic Getex Corporation HINSDALE 60523 28419901 alkaline Detergents, synthetic organic or inorganic Gurtler Chemicals, Inc. SOUTH HOLLAND 60473 28419901 alkaline Eagle Enterprise of Elbur ELBURN 60119 28420300 Drycleaning preparations

68Kor-Kleen Inc GLEN ELLYN 60137 28420300 Drycleaning preparations

Qualitex Company CHICAGO 60618 28420300 Drycleaning preparations R R Street&Co Inc CHICAGO 60608 28420300 Drycleaning preparations Shel Drake Cleaners CHICAGO 60640 28420300 Drycleaning preparations Song, Tae Hwan MUNDELEIN 60060 28420300 Drycleaning preparations Spotless Dry Cleaners Tailors EVANSTON 60201 28420300 Drycleaning preparations American Powder Coatings, Inc. SAINT CHARLES 60174 28510202 Enamels, nec The Testor Corporation ROCKFORD 61104 28510202 Enamels, nec International Coatings, Inc FRANKLIN PARK 60131 28510203 Epoxy coatings A B C Exterminating Service Exterminating products, for household or LLC CHICAGO 60640 28790105 industrial use Beiersdorf, Inc. NAPERVILLE 60540 28440502 Face creams or lotions Bethany Pharmacol Co Inc BETHANY 61914 28440502 Face creams or lotions Neaclear Inc PARK RIDGE 60068 28440502 Face creams or lotions Solo Laboratories Inc BELLWOOD 60104 28440502 Face creams or lotions Tc&Company ALLENDALE 62410 28440502 Face creams or lotions Ilf Technologies, LLC HINSDALE 60527 28430200 Finishing agents Fox Valley Chemical Company Inc RINGWOOD 60072 28420204 Floor waxes J.F. Daley International, Ltd. CHICAGO 60652 28420204 Floor waxes E. I. Du Pont De Nemours and Company EL PASO 61738 28799903 Fungicides, herbicides Pfizer Inc CARY 60013 28799903 Fungicides, herbicides Pfizer Inc NAPERVILLE 60563 28799903 Fungicides, herbicides Cgm Enterprises Inc DEERFIELD 60015 28910206 Glue H.B. Fuller Company PALATINE 60067 28910206 Glue Industrial Adhesive Co CHICAGO 60612 28910206 Glue National Casein Company CHICAGO 60620 28910206 Glue National Casein of California, Inc CHICAGO 60620 28910206 Glue American Blending&Filling Company WAUKEGAN 60085 28440100 flair preparations, including shampoos Biocare Labs CHICAGO 60638 28440100 Hair preparations, including shampoos Biostrand, Inc BELLWOOD 60104 28440100 Hair preparations, including shampoos Ecoco Inc CHICAGO 60639 28440100 Hair preparations, including shampoos Luster Products, Inc. CHICAGO 60609 28440100 Hair preparations, including shampoos Masterpiece Products Inc CHICAGO 60619 28440100 Hair preparations, including shampoos Raani Corporation CHICAGO 60638 28440100 Hair preparations, including shampoos Rna Corporation BLUE ISLAND 60406 28440100 Hair preparations, including shampoos Selected Chemical Products Company WAUKEGAN 60087 28440100 Hair preparations, including shampoos Summit Laboratories, Inc HARVEY 60426 28440100 Hair preparations, including shampoos Zotos International Inc DES PLAINES 60018 28440100 Hair preparations, including shampoos Advanced Building Components Inc CHICAGO 60657 28440103 Home permanent kits ELK GROVE Industrial plant disinfectants or Interflo Industries Inc VILLAGE 60007 28420403 deodorants Industrial plant disinfectants or Teitelbaum Brothers, Inc. GLENVIEW 60026 28420403 deodorants Clarke Mosquito Control Products, Inc. ROSELLE 60172 28790100 Insecticides and pesticides

69Evergreen Fs, Inc BLACKSTONE 61313 28790100 Insecticides and pesticides

Freds Termite&Pest Control MASCOUTAH 62258 28790100 Insecticides and pesticides R D V Enterprises Inc KANKAKEE 60901 28790100 Insecticides and pesticides FMC Corporation WYOMING 61491 28790106 Insecticides, agricultural or household Nufarm Americas Inc. CHICAGO HEIGHTS 60411 28790106 Insecticides, agricultural or household C2 Premium Paint WILMETTE 60091 28510206 Lacquer: bases, dopes, thinner G. J. Nikolas&Co., Inc. BELLWOOD 60104 28510206 Lacquer: bases, dopes, thinner Oak Partners Inc CICERO 60804 28510206 Lacquer: bases, dopes, thinner V J Dolan&Company, Inc CHICAGO 60639 28510206 Lacquer: bases, dopes, thinner Lacquers, varnishes, enamels, and other Carbol ne Company CHANNAHON 60410 28510200 coatings Lacquers, varnishes, enamels, and other Continental Supply Co PALOS HEIGHTS 60463 28510200 coatings Lacquers, varnishes, enamels, and other Crawford Laboratories Inc CHICAGO 60609 28510200 coatings Lacquers, varnishes, enamels, and other Crest Industries, Ltd NEW LENOX 60451 28510200 coatings Lacquers, varnishes, enamels, and other Eron Enterprises Ltd CHICAGO 60630 28510200 coatings Lacquers, varnishes, enamels, and other Morton International, Inc BATAVIA 60510 28510200 coatings Lacquers, varnishes, enamels, and other National Industrial Coating, Inc ITASCA 60143 28510200 coatings ELK GROVE Lacquers, varnishes, enamels, and other Specialty Coatings Company VILLAGE 60007 28510200 coatings Lacquers, varnishes, enamels, and other W. C. Richards Co. ALSIP 60803 28510200 coatings A B Seals Inc SULLIVAN 61951 28910102 Laminating compounds Attains Inc USA MELROSE PARK 60160 28910102 Laminating compounds ELK GROVE D&K Group, Inc VILLAGE 60007 28910102 Laminating compounds ELK GROVE D&K International, Inc. VILLAGE 60007 28910102 Laminating compounds Press Time Cleaners GRAYSLAKE 60030 28420500 Laundry cleaning preparations Simply Clean Cleaning Services CHICAGO 60628 28420500 Laundry cleaning preparations ArtBasias WARRENVILLE 60555 28510102 Lead-in-oil paints David Jaffe Inc CHICAGO 60625 28420206 Leather dressings and finishes I'Sachs Sons Inc CHICAGO 60607 28430201 Leather finishing agents HOFFMAN Sadelco USA Corp. ESTATES 60169 28430201 Leather finishing agents W-R Industries, Inc. CHICAGO 60608 28510207 Lithographic varnishes Be Products Inc CHICAGO 60602 28449903 Manicure preparations Diane's Nails LOMBARD 60148 28449903 Manicure preparations Manicure Madness CHICAGO 60605 28449903 Manicure preparations Minnies Manicure DEERFIELD 60015 28449903 Manicure preparations Nail Boutique ROSELLE 60172 28449903 Manicure preparations Nail Image Inc NILES 60714 28449903 Manicure preparations Professionail FOX LAKE 60020 28449903 Manicure preparations ProfessionalNails Inc ROUND LAKE 60073 28449903 Manicure preparations The Nail Bar PEORIA 61616 28449903 Manicure preparations Uptown Girl PECATONICA 61063 28449903 Manicure preparations

70Websternet Ltd CHICAGO 60657 28449903 Manicure preparations

Matchless Metal Polish Co CHICAGO 60609 28420207 Metal polish Prevention Laboratories, LLC RALEIGH 62977 28440202 Mouthwashes Express Grease and Oil CHICAGO 60618 28430100 Oils and greases Oral and Maxillofacia Lakeview CHICAGO 60657 28440200 Oral preparations Acm Inc NORTH CHICAGO 60064 28510000 Paints and allied products Adheron Coatings Corporation CHICAGO 60622 28510000 Paints and allied products Akzo Nobel Coatings, Inc MATTESON 60443 28510000 Paints and allied products Antoni Tech Coatings HAMPSHIRE 60140 28510000 Paints and allied products Autonomic Materials Inc CHAMPAIGN 61821 28510000 Paints and allied products Behr Process Corp ROCKFORD 61107 28510000 Paints and allied products Behr Process Corp DOWNERS GROVE 60517 28510000 Paints and allied products Behr Process Corp EDWARDSVILLE 62025 28510000 Paints and allied products Behr Process Corp CHICAGO RIDGE 60415 28510000 Paints and allied products Behr Process Corp HOMEWOOD 60430 28510000 Paints and allied products Behr Process Corp CALUMET CITY 60409 28510000 Paints and allied products Behr Process Corp CRYSTAL LAKE 60014 28510000 Paints and allied products Behr Process Corp MOUNT PROSPECT 60056 28510000 Paints and allied products Behr Process Corp OSWEGO 60543 28510000 Paints and allied products Behr Process Corp ALGONQUIN 60102 28510000 Paints and allied products Behr Process Corp SCHAUMBURG 60194 28510000 Paints and allied products Behr Process Corp GLENVIEW 60026 28510000 Paints and allied products Behr Process Corp LAKE ZURICH 60047 28510000 Paints and allied products Behr Process Corp DEERFIELD 60015 28510000 Paints and allied products Behr Process Corp PALATINE 60074 28510000 Paints and allied products Behr Process Corp MC HENRY 60050 28510000 Paints and allied products Behr Process Corp MELROSE PARK 60164 28510000 Paints and allied products Behr Process Corp OAK LAWN 60453 28510000 Paints and allied products Behr Process Corp BROADVIEW 60155 28510000 Paints and allied products GLENDALE Behr Process Corp HEIGHTS 60139 28510000 Paints and allied products Behr Process Corp NAPERVILLE 60540 28510000 Paints and allied products Behr Process Corp GENEVA 60134 28510000 Paints and allied products Behr Process Corp BOLINGBROOK 60490 28510000 Paints and allied products Behr Process Corp INGLESIDE 60041 28510000 Paints and allied products Behr Processcorp BARTLETT 60103 28510000 Paints and allied products California Products Corporation BARRINGTON 60010 28510000 Paints and allied products Contract Transportation Systems Co Inc EFFINGHAM 62401 28510000 Paints and allied products Crystal Rain Inc SAN JOSE 62682 28510000 Paints and allied products Delta Coatings Corp MELROSE PARK 60160 28510000 Paints and allied products Euclid Chemical Company, Inc KIRKLAND 60146 28510000 Paints and allied products Faux Efficient, Inc. EFFINGHAM 62401 28510000 Paints and allied products Federated Paint Manufacturing Co Inc MELROSE PARK 60160 28510000 Paints and allied products Federated Paint Manufacturing CoInc ARGO 60501 28510000 Paints and allied products Gibraltar Chemical Works Inc SOUTH HOLLAND 60473 28510000 Paints and allied products I. Pulloma Paints Inc. CARPENTERSVILLE60110 28510000 Paints and allied products



### 71International Paint LLC WAUKEGAN 60085 28510000 Paints and allied products

I F B Hart Coatings, Inc. WOODRIDGE 60517 28510000 Paints and allied products Lucky Star Painting, Inc WINNETKA 60093 28510000 Paints and allied products M A Bruder&Sons Inc CHICAGO 60622 28510000 Paints and allied products Marc Soya Studios COLLINSVILLE 62234 28510000 Paints and allied products Matthew, Kilcline Co., Inc BARRINGTON 60010 28510000 Paints and allied products Mid-America Protective Coatings, Inc. FRANKLIN PARK 60131 28510000 Paints and allied products Midwest Power Coating Inc SAINT CHARLES 60174 28510000 Paints and allied products Multicolor Specialties Inc CICERO 60804 28510000 Paints and allied products Multicolor Specialties, Inc. CICERO 60804 28510000 Paints and allied products National Coatings, Inc GALESBURG 61401 28510000 Paints and allied products Pioneer Powder Products Inc MELROSE PARK 60160 28510000 Paints and allied products Plastics Color Corporation of Illinois CALUMET CITY 60409 28510000 Paints and allied products Powder Coat Plus QUINCY 62305 28510000 Paints and allied products PPG Industries, Inc MOUNT ZION 62549 28510000 Paints and allied products PPG Industries, Inc AURORA 60506 28510000 Paints and allied products PPG Industries, Inc ALSIP 60803 28510000 Paints and allied products PPG Industries, Inc CRYSTAL LAKE 60014 28510000 Paints and allied products PPG Industries, Inc ELGIN 60120 28510000 Paints and allied products PPG Industries, Inc 0FALLON 62269 28510000 Paints and allied products PPG Industries, Inc GURNEE 60031 28510000 Paints and allied products PPG Industries, Inc JOLIET 60435 28510000 Paints and allied products PPG Industries, Inc LISLE 60532 28510000 Paints and allied products PPG Industries, Inc MOLINE 61265 28510000 Paints and allied products PPG Industries, Inc NAPERVILLE 60564 28510000 Paints and allied products PPG Industries, Inc CHICAGO 60657 28510000 Paints and allied products PPG Industries, Inc CHICAGO 60607 28510000 Paints and allied products PPG Industries, Inc ORLAND PARK 60462 28510000 Paints and allied products ROLLING PPG Industries, Inc MEADOWS 60008 28510000 Paints and allied products PPG Industries, Inc SPRINGFIELD 62703 28510000 Paints and allied products PPG Industries, Inc SAINT CHARLES 60174 28510000 Paints and allied products PPG Industries, Inc STONE PARK 60165 28510000 Paints and allied products PPG Industries, Inc WESTMONT 60559 28510000 Paints and allied products Premium Products, Inc YORKVILLE 60560 28510000 Paints and allied products Sandstrom Products Company PORT BYRON 61275 28510000 Paints and allied products Sandstrom Products Company PORT BYRON 61275 28510000 Paints and allied products Sentinel Paint&Varnish Co Inc NILES 60714 28510000 Paints and allied products Shocktech CALUMET CITY 60409 28510000 Paints and allied products Technical Coatings Co MELROSE PARK 60160 28510000 Paints and allied products PRAIRIE DU Technical Coatings Co Inc ROCHER 62277 28510000 Paints and allied products Tecorp Inc JOLIET 60433 28510000 Paints and allied products The Glidden Company ORLAND PARK 60462 28510000 Paints and allied products The Sherwin-Williams CompanyCHICAGO 60628 28510000 Paints and allied products The Sherwin-Williams CompanySOUTH HOLLAND 60473 28510000 Paints and allied products The Sherwin-Williams CompanyHARVEY 60426 28510000 Paints and allied products

72The Sherwin-Williams CompanyEAST MOLINE 61244 28510000 Paints and allied products

The Sherwin-Williams CompanyCHICAGO 60628 28510000 Paints and allied products The Sherwin-Williams CompanySOUTH HOLLAND 60473 28510000 Paints and allied products The Valspar Corporation KANKAKEE 60901 28510000 Paints and allied products The Valspar Corporation WHEELING 60090 28510000 Paints and allied products The Valspar Corporation LIBERTYVILLE 60048 28510000 Paints and allied products The Valspar Corporation WHEELING 60090 28510000 Paints and allied products The Valspar Corporation CHICAGO 60608 28510000 Paints and allied products The Valspar Corporation MOLINE 61265 28510000 Paints and allied products Union Carbide Corporation CHICAGO 60803 28510000 Paints and allied products Williams-HaywardProtective Coatings, Inc SUMMIT ARGO 60501 28510000 Paints and allied products Akzo Nobel Non-Stick Coatings, LLC DES PLANES 60018 28510100 Paints and paint additives Allan's Paint Company, Inc. CHICAGO 60608 28510100 Paints and paint additives Behr Process Corporation CHICAGO HEIGHTS 60411 28510100 Paints and paint additives ELK GROVE Coronado Paint Co Inc VILLAGE 60007 28510100 Paints and paint additives Engineered Polymer Solutions, Inc ROCKFORD 61104 28510100 Paints and paint additives Finishes Unlimited, Inc SUGAR GROVE 60554 28510100 Paints and paint additives Quality Color Products Incorporated BARTLETT 60103 28510100 Paints and paint additives Stuart Industrial Coating Inc CHICAGO 60628 28510100 Paints and paint additives The Carbit Paint Company CHICAGO 60622 28510100 Paints and paint additives The Carbit Paint Company CHICAGO 60647 28510100 Paints and paint additives Crider Asphalt Ceiling Inc LENZBURG 62255 28510105 Paints, asphalt or bituminous National Bronze Powder Co FRANKLIN PARK 60131 28510106 Paints, waterproof Rust-Oleum Corporation VERNON HILLS 60061 28510106 Paints, waterproof Spraylat Corporation CHICAGO 60633 28510106 Paints, waterproof Paints: oil or alkydvehicleor water Akzo Nobel Coatings, Inc WAUKEGAN 60085 28510107 thinned Paints: oil or alkydvehicleor water Seymour of Sycamore, Inc. SYCAMORE 60178 28510107 thinned Paints: oil or alkydvehicleor water Vanex, Inc. MOUNT VERNON 62864 28510107 thinned Big City Advancement CHICAGO 60606 28440300 Perfumesand colognes Coty Inc BATAVIA 60510 28440300 Perfumesand colognes Dawah Oil Palace CHICAGO 60651 28440300 Perfumesand colognes E Shell Enterprises OAK LAWN 60453 28440300 Perfumesand colognes Elite Management CHICAGO 60619 28440300 Perfumesand colognes Essence of Love CHICAGO 60629 28440300 Perfumesand colognes Fragrance Promotions CHICAGO 60611 28440300 Perfumesand colognes GreenMountain Flavors, Inc OSWEGO 60543 28440300 Perfumesand colognes Kk Fragrance& NoveltiesInc DARIEN 60561 28440300 Perfumesand colognes Linda RYeates LINCOLN 62656 28440300 Perfumes and colognes Michael Christopher Ltd LAKE IN THE HILLS60156 28440300 Perfumesand colognes EAST Original Brand Prod Co CARONDELET 62240 28440300 Perfumesand colognes Romane Inc ELMHURST 60126 28440300 Perfumes and colognes

73Shiseido ALGONQUIN 60102 28440300 Perfumes and colognes

Smile Aromatics, Inc. PARK RIDGE 60068 28440300 Perfumes and colognes Spoiled Rotten GALENA 61036 28440300 Perfumes and colognes Vassi Perfume CHICAGO 60639 28440300 Perfumes and colognes Marcy Laboratories, Inc WEST CHICAGO 60185 28440303 Perfumes, natural or synthetic Stone Chemical Laboratory Inc CHICAGO

_60622 28790107 Pesticides, agricultural or household Agrochem Inc NORTHBROOK 60062 28799904 Plant hormones N B Coatings LANSING 60438 28510108 Plastics base paints and varnishes AllIn One General Supply Co CHICAGO 60649 28420000 Polishes and sanitation goods B&K Greenworld, Inc. CHICAGO 60615 28420000 Polishes and sanitation goods C.Q. Concepts Corp MC HENRY 60050 28420000 Polishes and sanitation goods Cook Composites and Polymers Co. LEMONT 60439 28420000 Polishes and sanitation goods Daley, J F International, Ltd CHICAGO 60632 28420000 Polishes and sanitation goods Dober Chemical Corp MIDLOTHIAN 60445 28420000 Polishes and sanitation goods Earth Friendly Products WINNETKA 60093 28420000 Polishes and sanitation goods Ecolab Inc JOLIET 60436 28420000 Polishes and sanitation goods ELK GROVE Ecolab Inc VILLAGE 60007 28420000 Polishes and sanitation goods Ernst Products LITCHFIELD 62056 28420000 Polishes and sanitation goods Healthcon Corp CHICAGO 60610 28420000 Polishes and sanitation goods Huegelmann S Interior LEMONT 60439 28420000 Polishes and sanitation goods Kjh Metal Finishing Co FRANKLIN PARK 60131 28420000 Polishes and sanitation goods Lundmark, Inc ADDISON 60101 28420000 Polishes and sanitation goods Mackenzie Johnson MAYWOOD 60153 28420000 Polishes and sanitation goods Medallion Products Inc CHICAGO 60641 28420000 Polishes and sanitation goods Prism Sanitation Management LLC SCHAUMBURG 60173 28420000 Polishes and sanitation goods R P Polishing Co Inc BENSENVILLE 60106 28420000 Polishes and sanitation goods Rainbow Cleaners WESTMONT 60559 28420000 Polishes and sanitation goods Rochester Midland Corporation MONTGOMERY 60538 28420000 Polishes and sanitation goods S L P Holdings Inc MONTGOMERY 60538 28420000 Polishes and sanitation goods Tri Sect Corporation SCHAUMBURG 60193 28420000 Polishes and sanitation goods Turtle Wax, Inc. CHICAGO 60638 28420000 Polishes and sanitation goods Turtle Wax, Inc. BRIDGEVIEW 60455 28420000 Polishes and sanitation goods Turtle Wax, Inc. BEDFORD PARK 60638 28420000 Polishes and sanitation goods Vanguard Chemical Corporation CHICAGO 60610 28420000 Polishes and sanitation goods White's Sanitation Inc STAUNTON 62088 28420000 Polishes and sanitation goods Polishing preparations and related Nu-Look Products Inc CHICAGO 60609 28420200 products Polyurethane Products Corp ADDISON 60101 28510208 Polyurethane coatings Your Assistant QUINCY 62301 28430300 Processing assistants Nu Puttie Corporation MAYWOOD 60153 28510301 Putty Sarco Putty Company CHICAGO 60629 28510301 Putty Swan Black Manufacturing Co CHICAGO 60651 28510301 Putty Atlas Putty Products Co. TINLEY PARK 60487 28510300 Putty, wood fillers and sealers MillenChemical Company CHICAGO 60628 28510400 Removers and cleaners Rug, upholstery, or dry cleaning Elco Laboratories, Inc UNIVERSITY PARK 60466 28420301 detergents or spotters R RStreet&Co Inc NAPERVILLE 60563 28420301 Rug, upholstery, or dry cleanin_

74detergents or spotters

Rust Contracting Siding BELLEVILLE 62226 28420107 Rust removers City of Chicago CHICAGO 60626 28420404 Sanitation preparations Diamond American Group VERNON HILLS 60061 28420404 Sanitation preparations First Ayd Corporation ELGIN 60124 28420404 Sanitation preparations It's Clean U.S.A., LLC CHICAGO 60610 28420404 Sanitation preparations Johnnys Little LLC JACKSONVILLE 62650 28420404 Sanitation preparations Olympic Sanitation, Ltd. LOMBARD 60148 28420404 Sanitation preparations Purdy Products Company WAUCONDA 60084 28420404 Sanitation preparations U S Chemical Corporation MUNDELEIN 60060 28420404 Sanitation preparations Medivation Industries, Inc. ROLLING MEADOWS 60008 28420400 Sanitation preparations, disinfectants and deodorants Medtrol, Inc. NILES 60714 28420400 Sanitation preparations, disinfectants and deodorants Fitzpatrick Bros., Inc. CHICAGO 60612 28419904 Scouring compounds Alhencam Seal Coat Inc DECATUR 62521 28910100 Sealants Eagle Enterprises, Inc MC LEANSBORO 62859 28910100 Sealants F H Leinweber Co Inc CHICAGO 60628 28910100 Sealants F. H. Leinweber Co., Inc. OAK LAWN 60453 28910100 Sealants Harmon Glass JOLIET 60431 28910100 Sealants Morton Yokohama Inc CHICAGO 60606 28910100 Sealants Safety Compound Corporation LOMBARD 60148 28910100 Sealants Sealants Champion& Restoration PALOS HILLS 60465 28910100 Sealants Salinas Services&Sealcoating WEST CHICAGO 60185 28910104 Sealing compounds, synthetic rubber or plastic Princeton Sealing Wax Co PRINCETON 61356 28910105 Sealing wax Remet Corporation CHICAGO 60607 28910105 Sealing wax A Veda Corporation HOFFMAN ESTATES 60173 28440104 Shampoos, rinses, conditioners: hair AB Services Inc MELROSE PARK 60160 28440104 Shampoos, rinses, conditioners: hair Hydrox Chemical Company, Inc.ELGIN 60123 28440104 Shampoos, rinses, conditioners: hair Master Well Comb Co Inc LAKE ZURICH 60047 28440104 Shampoos, rinses, conditioners: hair Moss International Inc OGLESBY 61348 28440104 Shampoos, rinses, conditioners: hair Namaste Laboratories, LLC BLUE ISLAND 60406 28440104Shampoos, rinses, conditioners: hair Origins Natural Resources Inc SCHAUMBURG 60173 28440104 Shampoos, rinses, conditioners: hair Origins Natural Resources Inc CHICAGO 60611 28440104 Shampoos, rinses, conditioners: hair Pro-Line Winning Ways Inc WASHINGTON 61571 28440104 Shampoos, rinses, conditioners: hair Summit Laboratories Inc CHICAGO HEIGHTS 60411 28440104 Shampoos, rinses, conditioners: hair The D-Orum Corporation CHICAGO 60628 28440104 Shampoos, rinses, conditioners: hair Universal Beauty Products, Inc ELK GROVE VILLAGE 60007 28440104 Shampoos, rinses, conditioners: hair Blachford Corporation FRANKFORT 60423 28410000 Soap and other detergents Blendtech Industries, Inc. ELGIN 60123 28410000 Soap and other detergents Cade Laboratories, LLC CHICAGO 60614 28410000 Soap and other detergents Cater Chemical Co ROSELLE 60172 28410000 Soap and other detergents Country Lane Enterprises Inc CHICAGO 60623 28410000 Soap and other detergents Diamond Detergents LLC CARY 60013 28410000 Soap and other detergents Ecolab Inc WATERLOO 62298 28410000 Soap and other detergents Ecolab Inc CHATHAM 62629 28410000 Soap and other detergents

75Ecolab Inc NORTHBROOK 60062 28410000 Soap and other detergents

Ecolab Inc JOLIET 60431 28410000 Soap and other detergents Ecolab Inc SOUTH BELOIT 61080 28410000 Soap and other detergents Ecolab Inc MUNDELEIN 60060 28410000 Soap and other detergents Full Circle Handcrafted Soaps MOLINE 61265 28410000 Soap and other detergents Kik Custom Products, Inc. DES PLAINES 60018 28410000 Soap and other detergents Lato Supply Corporation FRANKLIN PARK 60131 28410000 Soap and other detergents Merilyn&Friends Balenton CHICAGO 60621 28410000 Soap and other detergents Randall Packing Co ORLAND PARK 60462 28410000 Soap and other detergents Renee Thomas Inc ELMHURST 60126 28410000 Soap and other detergents Rock River Blending ROCKFORD 61102 28410000 Soap and other detergents ROLLING Scenter of Mind MEADOWS 60008 28410000 Soap and other detergents Sea Street Soap Works LLC BELLEVILLE 62220 28410000 Soap and other detergents Soaps Gone Buy ELDORADO 62930 28410000 Soap and other detergents Soapsublime EVANSTON 60202 28410000 Soap and other detergents Soapy Gurls USA Ltd ALGONQUIN 60102 28410000 Soap and other detergents Tech-Chem Corp DUNDEE 60118 28410000 Soap and other detergents The Dial Corporation MONTGOMERY 60538 28410000 Soap and other detergents Unilever United States, Inc. CHICAGO 60601 28410000 Soap and other detergents Westfalia-Surge Inc ROMEOVILLE 60446 28410000 Soap and other detergents Soap: granulated, liquid, cake, flaked, or Be Jeweled Bodyscents Corp RIVERDALE 60827 28419905 chip Soap: granulated, liquid, cake, flaked, or Blew Chemical Company PALOS HEIGHTS 60463 28419905 chip Soap: granulated, liquid, cake, flaked, or Bullen Midwest, Inc. CHICAGO 60628 28419905 chip Soap: granulated, liquid, cake, flaked, or Custom Blending&Packa DUPO 62239 28419905 chip Soap: granulated, liquid, cake, flaked, or Heaven Scent SPRINGFIELD 62702 28419905 chip Soap: granulated, liquid, cake, flaked, or Luvadubdub Co EVANSTON 60202 28419905 chip WINTHROP Soap: granulated, liquid, cake, flaked, or Soap Dicor Emporium HARBOR 60096 28419905 chip Soap: granulated, liquid, cake, flaked, or The Procter&Gamble CompanyMARENGO 60152 28419905 chip Soap: granulated, liquid, cake, flaked, or Tuple Inc JOLIET 60435 28419905 chip Soap: granulated, liquid, cake, flaked, or Unichem Corporation CHICAGO 60609 28419905 chip Aaro Vision, Inc. ROCK FALLS 61071 28420100 Specialty cleaning Atm America Corp. SKOKIE 60076 28420100 Specialty cleaning Bass Brother, Incorporated CHICAGO 60624 28420100 Specialty cleaning Brite Site Supply Inc CHICAGO 60639 28420100 Specialty cleaning Chavez Cleaning Services CHICAGO 60630 28420100 Specialty cleaning Clean R Ceilings BOURBONNAIS 60914 28420100 Specialty cleaning Clifton Chemical Company CHEBANSE 60922 28420100 Specialty cleaning Inco orated WOODRIDGE 60517 28420100 Specialty cleanin First Mate Yacht Detailing WAUKEGAN 60085 28420100 Specialty cleaning Fola Community Action CHICAGO 60620 28420100 Specialty cleaning

76Services

Kirby S Grove LOMBARD 60148 28420100 Specialty cleaning Marshall Cleaning Service BELLEVILLE 62226 28420100 Specialty cleaning Professional Cleaning Service LOCKPORT 60441 28420100 Specialty cleaning R E Z Packaging Inc CHICAGO 60609 28420100 Specialty cleaning Scs Company MIDLOTHIAN 60445 28420100 Specialty cleaning Sunrise of Bloomingdale BLOOMINGDALE 60108 28420100 Specialty cleaning The Boyer Corporation LA GRANGE 60525 28420100 Specialty cleaning Tiger Accessory Group, L.L.C. LINCOLNSHIRE 60069 28420100 Specialty cleaning Todco Industries Inc ARLINGTON HEIGHTS 60004 28420100 Specialty cleaning United Laboratories Inc, SAINT CHARLES 60174 28420100 Specialty cleaning Venus Laboratories, Inc. WOOD DALE 60191 28420100 Specialty cleaning Another8hours 0 FALLON 62269 28430000 Surface active agents Avatar Corporation UNIVERSITY PARK 60466 28430000 Surface active agents Henkel Corporation CHICAGO 60606 28430000 Surface active agents Lambent Technologies Corp GURNEE 60031 28430000 Surface active agents Lambent Technologies Corp GURNEE 60031 28430000 Surface active agents McIntyre Group, Ltd. UNIVERSITY PARK 60466 28430000 Surface active agents Ygm Golf&Sportswear BUFFALO GROVE 60089 28430000 Surface active agents Frank Miller&Sons, Incorporated RIVERDALE 60827 28420109 Sweeping compounds, oil or water absorbent, clay or sawdust Oil-Dri Corporation of America CHICAGO 60611 28420109 Sweeping compounds, oil or water absorbent, clay or sawdust T Kw Inc BARRINGTON 60010 28430202 Textile finishing agents R-Five, Inc CHICAGO 60632 28430304 Textile processing assistants Pure Elegance ROCKFORD 61104 28419906 Textile soap Abbott Laboratories NORTH CHICAGO 60064 28440000 Toilet preparations Alberto-Culver Company MELROSE PARK 60160 28440000 Toilet preparations Alberto-Culver Company WHEELING 60090 28440000 Toilet preparations Alberto-Culver International, Inc MELROSE PARK 60160 28440000 Toilet preparations Alberto-Culver U S A Inc MELROSE PARK 60160 28440000 Toilet preparations Alberto-Culver U S A Inc MINOOKA 60447 28440000 Toilet preparations Avon Center CHICAGO 60619 28440000 Toilet preparations Bath&Body Works, Inc. DEERFIELD 60015 28440000 Toilet preparations Christopher Michael ISLAND LAKE 60042 28440000 Toilet preparations Colgate-Palmolive Company CHICAGO 60602 28440000 Toilet preparations Conair Corporation RANTOUL 61866 28449905 Toilet preparations Conopco, Inc. LISLE 60532 28440000 Toilet preparations Conopco, Inc. WESTMONT 60559 28440000 Toilet preparations Conopco, Inc. CHICAGO 60623 28440000 Toilet preparations Conopco, Inc. ELGIN 60123 28440000 Toilet preparations DES PLANES 60018 28440000 Toilet preparations Coty Us, LLC CHICAGO 60611 28440000 Toilet preparations Deputante Inc CHICAGO 60641 28440000 Toilet preparations Emlin Cosmetics, Inc. BENSENVILLE 60106 28440000 Toilet preparations Gold Edge Sunn1 GLENVIEW 60026 28449905 Toilet re ara ions H2o Plus, LP. CHICAGO 60607 28440000 Toilet preparations Herb Mari-Mann Co Inc DECATUR 62521 28440000 Toilet preparations

77Herb Mari-Mann Co Inc FINDLAY 62534 28440000 Toilet preparations

Ilora L'Original Beauty Concepts, Inc. SOUTH HOLLAND 60473 28440000 Toilet preparations Macfee Manufacturing Company AURORA 60505 28440000 Toilet preparations Mary Kay Cosmetics COLLINSVILLE 62234 28440000 Toilet preparations Mary Kay Inc ROSELLE 60172 28440000 Toilet preparations Maryville Women's Center 0 FALLON 62269 28440000 Toilet preparations Melissa Sass PLAINFIELD 60544 28440000 Toilet preparations One Love CALUMET CITY 60409 28440000 Toilet preparations Peggy Collier BOLINGBROOK 60440 28440000 Toilet preparations ELK GROVE Pros Life Co VILLAGE 60007 28440000 Toilet preparations Revlon Consumer Products Corporation WONDER LAKE 60097 28440000 Toilet preparations Soy World USA DECATUR 62526 28440000 Toilet preparations St. Ives Laboratories, Inc. MELROSE PARK 60160 28440000 Toilet preparations Stephanie's Cosmetics HURST 62949 28440000 Toilet preparations The Enterprising Kitchen Inc CHICAGO 60640 28440000 Toilet preparations Tropical Betty Cosmetics, Inc. CHICAGO 60605 28440000 Toilet preparations Vp Investment Corp DEERFIELD 60015 28440000 Toilet preparations Minar Products LLC CHICAGO 60615 28440203 Toothpastes or powders, dentifrices Prince Minerals, Inc. QUINCY 62305 28799906 Trace elements (agricultural chemicals) Sem Minerals LP QUINCY 62305 28799906 Trace elements (agricultural chemicals) Alvar, Inc WASHBURN 61570 28510211 Varnishes, nec United Gilsonite Laboratories JACKSONVILLE 62650 28510211 Varnishes, nec Valspar Coatings 12 ROCKFORD 61104 28510211 Varnishes, nec Cool Vinyl USA LLC SPRINGFIELD 62703 28510212 Vinyl coatings, strippable Cusack Auto BRIMFIELD 61517 28510212 Vinyl coatings, strippable A Clear View Window Cleaning LIBERTYVILLE 60048 28420111 Window cleaning preparations A. J. Funk&Co. ELGIN 60123 28420111 Window cleaning preparations Anytime Window Cleaning Inc CHICAGO 60647 28420111 Window cleaning preparations Champion Packaging& Distribution, Inc WOODRIDGE 60517 28420111 Window cleaning preparations Christopher E Fox AURORA 60505 28420111 Window cleaning preparations Inshield Wiper, LLC GENEVA 60134 28420111 Window cleaning preparations Northern Illinois Windows Inc MC HENRY 60050 28420111 Window cleaning preparations The Knockout Group Inc MELROSE PARK 60164 28420111 Window cleaning preparations Zenith Chemical Works Inc ADDISON 60101 28510213 Wood stains

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