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

Appendix A:	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

2
Tables

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.

7
2.0	Consumer and Commercial Products

2.1	Description of Sources and 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 season

2

, 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.

9
Table 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

11
25)	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

12
39)	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 

13
54) 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 miscellaneous i . 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
Table 2.2.2 Consumer Product Emission Factors by Category'

Product Category Emission Factor (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
Table 2.2.3 VOM 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 rule 3 . 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 products 6 . 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 lines 6 . 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 VOM 3 . 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" 12 rule 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" 12 rule. 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" 12 level 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 CosteffectivenessEstimated Cost per Unit

($/lb VOC reduced) ($/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 0.05

Engine 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 Purpose

Degreasers (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 0.00

Glass 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

23
PESTICIDES:

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 MEASURES I

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 0.14

Spot 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 TO CA MIDTERM 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

products3 beyond 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 Illinois 15 . 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.

Table 2.7.1 Estimated VOM Emission Reductions for Consumer Products°

Consumer Products Category

Estimated VOM Reductions based on

USEPA and CARE Survey's (1)(2)

Estimated VOM Reductions based on

CARB Survey

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

30
non-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 0.119

Non-aerosols

(ready-to ready-to use) 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

31
non-aerosol

lawn and

garden

0.35 0.09 26 0.35 0.09 26

Laundry prewash

Aerosols/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

32
PERCENT REDUCTION OF

INVENTORY 15 13

2.8 Affected Sources 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 products 4 . 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	Architectural and 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 year 15 . 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 AIM Coating Categories and 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)

Specialty Coatings

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/Masonry Sealer 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 Immersion Coating 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)

36
29) Multi-Color Coatings 250 (2.1)

30) Nuclear Coating 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.

Table 3.2.2 VOM 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" 17 in 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 coatings 13 so 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 for the LADCO region. 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 SCM 13 . 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 2000 13 . 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 for AIM Coating Control"

Coating Category Estimated Cost Effectiveness (dollars

per pound of VOM 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.

44
3.6	Reduction of VOM 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.

45
4.0	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 0 3 / 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

46
use 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	Aerosol Coating Categories and PWMIR Limits

Aerosol Coating Category

	

Product-Weighted MIR in

Grams Ozone per Gram

Product (gO3/g product)

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
Table 4.2.2 VOM Emissions Due to Aerosol 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	Flexibility in 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 compliance

per 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 can s. 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 can 8 . 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 Spar Varnishes 0 0 0.002 0.002

Photographic Coatings -0.04 0.011 0.002 0

55
Pleasure 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 of VOM 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 Affected Sources 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.

59
5.0 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.

62
6.0	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 FR 38952-38991, 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.

63
12. 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.

64
Appendix 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 LAKE ZURICH 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

Spec ialty Construction Brands,

Inc AURORA 60504 28910200 Adhesives

Specialty Construction Brands,

Inc PALATINE 60067 28910200 Adhesives

The W W Henry Company LP

California BOURBONNAIS 60914 28910200 Adhesives

Tsv Adhesive Systems, Inc FRANKFORT 60423 28910200 Adhesives

65
Tyco International (us) Inc. CARPENTERSVILLE 60110 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 Inc PEORIA 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

Farmer Manufacturing 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

66
Kill 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

67
Bill 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

68
Kor-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

69
Evergreen 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

Art Basias 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

Professional Nails Inc ROUND LAKE 60073 28449903 Manicure preparations

The Nail Bar PEORIA 61616 28449903 Manicure preparations

Uptown Girl PECATONICA 61063 28449903 Manicure preparations

70
Websternet 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

Co Inc ARGO 60501 28510000 Paints and allied products

Gibraltar Chemical Works Inc SOUTH HOLLAND 60473 28510000 Paints and allied products

I. Pulloma Paints Inc. CARPENTERSVILLE 60110 28510000 Paints and allied products

71
International 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 0 FALLON 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 Company CHICAGO 60628 28510000 Paints and allied products

The Sherwin-Williams Company SOUTH HOLLAND 60473 28510000 Paints and allied products

The Sherwin-Williams Company HARVEY 60426 28510000 Paints and allied products

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

The Sherwin-Williams Company CHICAGO 60628 28510000 Paints and allied products

The Sherwin-Williams Company SOUTH 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-Hayward Protective

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 alkyd vehicle or water

Akzo Nobel Coatings, Inc WAUKEGAN 60085 28510107 thinned

Paints: oil or alkyd vehicle or water

Seymour of Sycamore, Inc. SYCAMORE 60178 28510107 thinned

Paints: oil or alkyd vehicle or water

Vanex, Inc. MOUNT VERNON 62864 28510107 thinned

Big City Advancement CHICAGO 60606 28440300 Perfumes and colognes

Coty Inc BATAVIA 60510 28440300 Perfumes and colognes

Dawah Oil Palace CHICAGO 60651 28440300 Perfumes and colognes

E Shell Enterprises OAK LAWN 60453 28440300 Perfumes and colognes

Elite Management CHICAGO 60619 28440300 Perfumes and colognes

Essence of Love CHICAGO 60629 28440300 Perfumes and colognes

Fragrance Promotions CHICAGO 60611 28440300 Perfumes and colognes

Green Mountain Flavors, Inc OSWEGO 60543 28440300 Perfumes and colognes

Kk Fragrance & Novelties Inc DARIEN 60561 28440300 Perfumes and colognes

Linda R Yeates LINCOLN 62656 28440300 Perfumes and colognes

Michael Christopher Ltd LAKE IN THE HILLS 60156 28440300 Perfumes and colognes

EAST

Original Brand Prod Co CARONDELET 62240 28440300 Perfumes and colognes

Romane Inc ELMHURST 60126 28440300 Perfumes and colognes

73
Shiseido 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

All In 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

Millen Chemical Company CHICAGO 60628 28510400 Removers and cleaners

Rug, upholstery, or dry cleaning

Elco Laboratories, Inc UNIVERSITY PARK 60466 28420301 detergents or spotters

R R Street & Co Inc NAPERVILLE 60563 28420301 Rug, upholstery, or dry cleanin_

74
detergents 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 28440104 Shampoos, 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

75
Ecolab 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 Company MARENGO 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

76
Services

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

77
Herb 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

78