ED
    November
    24 2008
    flrr’
    LJ[
    U2Ug8
    John Therriault, Chief Clerk
    (
    s
    Jr:
    Clerk’s
    Office
    Attention
    Docket
    #R09-08
    rd
    Illinois Pollution Control Board
    100 W.
    Randolph, Suite 1 1-500
    Chicago, Illinois 60601
    — I
    RE: Illinois EPA Architectural
    and
    Industrial
    Maintenance (AIM) Coatings; Docket #RO9O8
    Dear
    Mr.
    Therriault:
    Sika Corporation (formerly Vaispar Flooring) has been a presence in the Industrial Coating and Sports
    Floor Fin
    ish
    market
    for nearly 100 years. Our
    production facility was
    on the
    near
    South Side
    of
    Chicago
    for many years and
    our management and operations had run out of Wheeling, Illinois for years.
    Sika Corporation is
    a
    member of the National Paint
    &
    Coatings
    Association (NPCA) and does NOT support
    NPCA’ s request to extend the implementation date of the AIM rulemaking from January 1, 2009 to July
    1, 2009.
    Paint and coatings companies have had sufficient time and notice to respond to the
    rule
    which was to originally
    be
    implemented on January
    1
    st
    of 2008. It is regretable that other companies have not taken this opportunity
    to better
    themselves and their technology in order to support the impending EPA regulations. It is also regretable
    that those
    of us who took the rulemaking seriously and spent the time, energy and funds
    necessary
    to revamp our product
    lines in order
    to support
    the
    new regulations will suffer for our compliance
    by
    not being able to take advantage
    of
    the first to
    market opportunities which we counted on to help to offset the cost of timely compliance. Pushing
    back this rule is causing us to
    have
    to support two
    duplicate product lines in the field. One of the
    product lines is
    a
    fully compliant line released
    prior
    to
    2008 and
    the
    other is our
    original
    non
    compliant
    line which
    needs to be left in
    place
    in order to compete with others who continue to offer the noncompliant versions as regulations continue
    to
    be pushed back. We, as
    industry,
    HAVE HAD adequate
    time
    to
    make necessary changes in
    order to comply
    with the amendments and should not be granted extentions due to
    lack of effort.
    Further, those
    of
    us
    who are in compliance have already made changes to our products, labels and computer
    sys
    tem lock outs in order to comply with the original
    2008
    and then January,
    2009
    dates. We
    have already
    communi
    cated changes
    to our customers, distributors and specifiers. Therefore, Sika Corporation strongly believes that the
    implementation
    date should be held at January
    1
    st,
    2009.
    Thank you
    for your consideration of our request. Please do not hesitate to contact me if you have any questions or
    need
    additional
    information.
    Sincerely,
    Lisa Beth Szczupaj
    Director
    of
    Business Development
    lisasika-cor.com
    847-221-5691
    A
    773-677-1840
    Sika Corporation, 201 Polito Avenue, Lyndhurst NJ 07071, USA
    Tel: 201 933 8800, Fax: 201 933 6225, www.sikausa.com

    Back to top