ECOLAB INC. — Director's Dealing 2011

May 10, 2011

SEC Form 3 — Initial Statement of Beneficial Ownership

Issuer: ECOLAB INC (ECL)
CIK: 0000031462
Period of Report: 2011-05-05

Reporting Person: Inchaustegui Roberto (EVP-Global Specialty Sector)

Holdings (Non-Derivative)

Security	Shares	Ownership
Common Stock	1485	Direct
Common Stock	6.047	Indirect

Holdings (Derivative)

Security	Exercise Price	Expiration	Underlying	Shares	Ownership
Employee Stock Option (Right to Buy)	$34.50	2014-12-09	Common Stock (13600)		Direct
Employee Stock Option (Right to Buy)	$34.075	2015-12-07	Common Stock (13500)		Direct
Employee Stock Option (Right to Buy)	$45.24	2016-12-06	Common Stock (10300)		Direct
Employee Stock Option (Right to Buy)	$49.42	2017-12-05	Common Stock (12200)		Direct
Employee Stock Option (Right to Buy)	$44.91	2018-07-31	Common Stock (37000)		Direct
Employee Stock Option (Right to Buy)	$35.63	2018-12-03	Common Stock (19700)		Direct
Employee Stock Option (Right to Buy)	$45.665	2019-12-02	Common Stock (9600)		Direct
Employee Stock Option (Right to Buy)	$48.055	2020-12-01	Common Stock (10600)		Direct

Footnotes

F1: Option granted under the Ecolab Inc. 2002 Stock Incentive Plan on December 9, 2004. The option became exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F2: Option granted under the Ecolab Inc. 2002 Stock Incentive Plan on December 7, 2005. The option became exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F3: Option granted under the Ecolab Inc. 2002 Stock Incentive Plan on December 6, 2006. The option became exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F4: Option granted under the Ecolab Inc. 2005 Stock Incentive Plan on December 5, 2007. The option became exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F5: Option granted under the Ecolab Inc. 2005 Stock Incentive Plan on July 31, 2008. The option becomes exercisableas to 100% of the option shares on the fourth anniversary of the date of grant.

F6: Option granted under the Ecolab Inc. 2005 Stock Incentive Plan on December 3, 2008. The option will become exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F7: Option granted under the Ecolab Inc. 2005 Stock Incentive Plan on December 2, 2009. The option will become exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F8: Option granted under the Ecolab Inc. 2010 Stock Incentive Plan on December 1, 2010. The option will become exercisable, on a cumulative basis, as to one-third of the option shares (excluding any fractional portion less than one share), on each of the first and second anniversaries of the date of grant and as to the remaining option shares on the third anniversary of the date of grant.

F9: Number of UNITS in the Ecolab Stock Fund of the Ecolab Savings Plan (401(k) Plan) as of May 4, 2011. (The 6.047 UNITS are the equivalent of approximtely 11 shares of the issuer's Common Stock.)