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
2.1?
Description
Products
of
?
Sources and Emissions
?
88
?
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 season2
, and account for approximately 8.51% of anthropogenic VOM emissions
for the entire year' s
. Consumer and commercial products account for approximately
4.93% of total anthropogenic VOM emissions in the East St. Louis NAA and
approximately 9.2% of total anthropogenic VOM emissions in the Chicago NAA during
the ozone season(see Section 2.2, Table 2.2.3)2
. The percentages of anthropogenic VOM
emissions from consumer and commercial products for the entire year in the Metro East
and Chicago NAAs are 6.89% and 13.45% respectively15.
2.2?
Emissions in Illinois From Regulated Products
Consumer and commercial product usage results in solvent evaporation and the emission
of VOM. For the purposes of the proposed regulation the source category is divided
into 59 product categories, each with a VOM limit given in % by weight. These product
categories are listed below in Table 2.2.1.
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 Cost-
effectiveness
Estimated 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 (non-
Aerosols)
-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-to-
Use)
-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 (Ready-
to-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 Multi-
Purp. 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 (non-
aerosol)
-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 (non-
aerosol)
-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
0.11
9
Non-aerosols
(ready-to
rea dy- to useuse)
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 year15 . AIM coatings account for approximately
4.28% of total anthropogenic VOM emissions in the East St. Louis NAA, and
approximately 8.01% of total anthropogenic VOM emissions in the Chicago NAA during
the ozone season(see Section 3.2, Table 3.2.2) 2 . The percentages of anthropogenic VOM
34
emissions from AIM for the entire year in the Metro East and Chicago NAAs are 3.20%
and 6.26% respectively15.
3.2 Emissions
in Illinois from Regulated Products
The application and drying of AIM coatings on surfaces covered by this category results
in evaporative emissions of VOM, while coating material is left on the surface. For the
purposes of the proposed regulation this source category is broken down into 49 coating
categories, each with a specific VOM content limit. These 49 coating categories are
listed below in Table 3.2.1.
Table 3.2.1 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 (gO
3/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 non-
compliant 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