Henry®

COMPANY

November

26, 2008

John

Clerk’s

Therriault,

Office

Chief

Clerk

RK

S

OFFICE

D

Attention

Illinois

PollutionDocket

Control#R09-08Board

2)

NOV

8

oo

8

100 W. Randolph,

Suite

11-500

OF

LLINO

Chicago,

Illinois

60601

Controg

Board

RE:

Illinois EPA

Architectural

and

Industrial

Maintenance

(AIM)

Coatings;

Docket

#RO948

Dear

Mr.

Therriault:

The

Henry

Company

is a

member

of

the

National

Paint

& Coatings

Association

(NPCA)

and

supports

NPCA’s

request

to extend

the

implementation

date

of the

AIM rulemaking

from

January

1, 2009

to

July

1,

2009

to allow

IL

adequate

time

to finalize

and adopt

the

amendments

to

the AIM rule,

and more

importantly,

provide

adequate

time

for

industry to

make necessary

changes

in

order

to

comply

with

the

amendments.

Henry

Company

produces

and sells

a wide variety

of

home

and building

repair

and

construction

products

in

the

U.S.

and Canada.

Many

of our products

are

sold

in retail

stores

and

to large

distributors

and

contractors

in

Illinois. Several

of these

products

will be impacted

by

the pending

Illinois

AIM

rule.

With the

new AIM

amendments,

in addition

to changing

formulations,

paint

manufacturers

need to

develop

and

print new

labels for

the

reformulated

products.

Further,

computer

systems

and

other

“lock-out”

systems

need to

be upgraded

to

prevent shipment

of “non-compliant”

products

into

IL. In addition,

it

takes

significant

time

for manufacturers

to

properly

communicate

the

new VOC

limit

changes

to all distributors,

customers

and

specifiers in

order to

ensure

their

compliance

with

the

new products.

It is impossible

for

manufacturers

to

make these

necessary

changes

and

properly communicate

the

details

of the

IL AIM rule

without

having

a

final

adopted

rule in hand,

particularly,

as

additional

changes

may occur

between

now and

the

final

adoption.

Therefore,

we strongly

believe

that

the implementation

date

should be moved

to July

1, 2009.

Thank

you for

your

consideration

of our

request. Please

do not

hesitate

to contact

me if you

have

any

questions

or need

additional

information.

Sincerely,

John

C.

Day,

Vice

President

Environmental

Health

&

Safety

JCD/lh

336 Cold Stream

Road

• Kimberton,

PA 19442 •

Phone: (610)

933-8888

• Fax

(610)

933-4598

• www.henry.com

Corporate

Headquarters

909

North

Sepulveda

Blvd.,

Suite 650,

El Segundo,

CA 90245-2724