From: Cassidy Mike [mailto:MICHAEL.CASSIDY@kohler.com] 

Sent: Thursday, June 20, 2013 11:56 AM

To: Nizich, Sharon

Cc: Sroka, Kristin; Telander, Jeff

Subject: RE: chain on edge vs. robot spray booths

Sharon,

The chain-on-edge machines can be used for glaze application for any sanitaryware fixture, but we only 

use them for high volume ware. These machines typically have 10-20 fixed reciprocating spray guns, 

and it can take a while to set up the machine for each different ware piece. For that reason only high 

volume are run on the spray machines. Lower volume pieces are sprayed in a conventional booth using 

either a robot or a person. The choice of whether robot spray or manual spray used for a ware piece is 

based on the shape of the piece and volume to be sprayed. 

The emission profiles from any spray booth are a function of glaze spray transfer efficiency (overspray) 

and overspray control device efficiency. In theory, we try to apply a set amount of glaze to a fixture for 

proper glaze coverage when fired, regardless of where/how the ware piece is sprayed. Depending on 

which booth (machine, robot, manual) the ware is sprayed in, the transfer efficiency and overspray 

control efficiency will vary as all booths are somewhat different. From a manufacturing point-of-view, 

we try to minimize overspray for all pieces to minimize our costs of production, we also try to maximize 

glaze recovery as we want to reuse as much overspray as possible. The more efficiently we collect OS, 

the more we can reuse, and the less gets emitted from the booth spray. At this time we recover and 

reuse white, biscuit, and almond color glazes. Other color glazes are not currently reclaimed due to cost 

of reclaim and the low volume of these colors. White, biscuit, and almond represent more than 90% of 

all glaze sprayed at any of our three sanitaryware plants.

The stack test data collected per the ICR in 2010 represent a snapshot in time of ware being sprayed, 

transfer efficiency, and overspray control. There is certainly variability in these aspects of production, 

and I’d attribute that to any variability you see in the emissions from the spray booths tested. Let me 

know if I’ve missed the mark on your questions.

Mike 

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] 

Sent: Thursday, June 20, 2013 8:46 AM

To: Cassidy Mike

Cc: Sroka, Kristin; Telander, Jeff

Subject: RE: chain on edge vs. robot spray booths

Hello MikeJust wanted to clarify the differences between the chain on edge and robot spray booths. I believe you 

said that for certain pieces, the chain on edge won’t work because of the shapes (i.e. a pedestal sink) 

such that the spray can’t get enough coverage or uniform coverage, due to the shape, and a manual 

application, or robotic arm that is specifically programmed for covering that shape is needed. (??)

Also, there is more volume per unit of time of course, in the chain on edge booth. However, relative to 

emissions, we don’t have test data that shows a distinct difference between the robotic and the chain 

on edge – both have values that are high or low (depending on the product being sprayed (?)), so do you 

know of any reason there would be differences in the emission profiles?
Thanks.

From: Cassidy Mike [mailto:MICHAEL.CASSIDY@kohler.com] 

Sent: Wednesday, May 29, 2013 9:40 PM

To: Nizich, Sharon

Subject: RE: chain on edge vs. robot spray booths

Ms. Nizich,

The chain-on-edge spray booths are spray machines that have multiple reciprocating spray guns, as you 

mentioned. These spray machines can spray most any piece that Kohler Co. manufactures, but they are 

only used for the highest volume product lines. A spray machine can spray 6 or 7 ware pieces in the 

time it takes to spray a single ware piece in a robot or manual spray booth.

We operate two spray machines at our Spartanburg SC facility, which is closest to you, if you’d like to 

see first-hand how the various spray operations work. Let me know if any further questions.

Mike

Michael J. Cassidy

EHS Specialist

Kohler Co.

444 Highland Drive

Mail Stop 009

Kohler, WI 53044

p. (920) 457-4441, x 77263

f. (920) 459-1682

mike.cassidy@kohler.com

Save money. Save water. Support Habitat for 

Humanity. Visit www.SaveWaterAmerica.com

From: Nizich, Sharon [mailto:Nizich.Sharon@epa.gov] 

Sent: Wednesday, May 29, 2013 10:51 AM

To: Cassidy Mike

Subject: chain on edge vs robot spray booths

Hello Mr. CassidyI have taken the lead on the sanitary ware subcategory, with RTI continuing to be the 

contractor. We are looking at the possibility of subcategorizing the chain on edge and robot 

spray booths, but need more information. Other than what you have provided, do you have 

any additional information, such as why the emission profiles would be different for each, or 

whether they operate differently and how they operate differently? I understand the chain on 

edge have multiple guns, but does that make any difference relative to whether you need this 

type of booth for a distinct type of product over the other type of booth?

Thank you!
Sharon Nizich

Minerals and Manufacturing Group

OAQPS Sector Policies and Programs Division

US EPA

Research Triangle Park, NC

919 541 2825