• To establish one and five-year goals for waste reduction at all facilities
• To significantly reducing process releases from our facilities

Central to these efforts is our Waste Reduction and Management (WRAM) program, which incorporates all of the elements required by the Environmental Protection Agency (EPA), as well as those of the American Chemistry Council's (ACC) Pollution Prevention Code of the Responsible Care^® program. This code requires that companies establish and execute pollution prevention programs and share the results with the public. Preventing pollution involves a hierarchy of waste management techniques that begin with source reduction and include recycling and reuse, energy recovery and treatment.

The ACC Pollution Prevention Code defines 14 Management Practices:

1.

A clear commitment by senior management to ongoing reductions at each facility. Bayer is committed to reducing waste generated at its facilities and disposing of the remainder in an environmentally acceptable manner. As a responsible corporate citizen and in accordance with its Corporate Environmental Policy and Procedures, Bayer is committed to reducing wastes generated at its facilities, recycling or re-using that which cannot be avoided, and disposing of the remainder in an environmentally acceptable manner. Environmental reporting is required to the same extent as financial, production and quality reporting. Facilities are required to prepare written reports of environmentally related incidents. Each site participates in Bayer's WRAM Program.

2.

A quantitative inventory of wastes generated and released at each facility. All waste streams and releases have been identified and quantified, including permitted air emissions, wastewater discharges, hazardous and non-hazardous wastes (including trash), stormwater and recyclable materials. Each waste stream is associated with a production stream for normalization (i.e., pounds of waste/pounds of production). Systems are in place to internally track waste generation from sources. Tracking of waste disposition (e.g., onsite/offsite, landfill/incineration, etc.) is in place. In addition to the waste reduction aspects of the WRAM Program, the management of waste is also monitored under this program.

3.

Evaluation of the potential impact of releases on the environment and on the health and safety of employees and the public. Each facility has reviewed site specific spill control measures and waste disposal practices and has established priorities, taking into account volumes and toxicity, to prevent the release of solid and hazardous wastes to the ground. Each facility has evaluated site specific conditions, including proximity to population and the existence of sensitive receptors.

4.

Education of—and dialogue with—employees and members of the public about risks to the community. The Responsible Care® Community Awareness and Emergency Response (CAER) Code communication mechanisms are in place to communicate with employees and members of the public. Educational programs (videos, visits to schools, open houses) to help the public and employees understand the risks associated with waste and releases are available. Toxics Release Inventory (TRI) data is shared with employees and the public.

5.

Establishment of priorities, goals and plans for waste and release reduction. The previous five-year goal program was designed to allow individual plant sites to set normalized waste reduction goals. This procedure was successful and Bayer MaterialScience was able to achieve a 25% reduction in our normalized waste generation from 1993 to 1997. The present goals are corporate-wide, and each business division is required to set its individual goals in conjunction with the overall goal, allowing some flexibility in how those goals are achieved. Plant WRAM Steering Team meetings are conducted to regularly review/re-assess priorities, waste reduction projects status and goals. Each division's progress is tracked on a quarterly basis and their investment plans periodically reviewed to determine how the goals will be met.

6.

Ongoing reduction of wastes and releases, giving preference first to source reduction, second to recycle/reuse, and third to treatment. The Bayer Pollution Prevention Guideline states that all sites must implement a Chemical Release Reduction program. The Bayer Pollution Prevention Guideline states that all sites must implement a Chemical Release Reduction Program which includes achieving release reductions through implementing the following methods listed in order of preference: Source reduction Recycle/reuse Treatment to reduce volume and/or toxicity Source reduction incorporates ways to eliminate waste before it is generated, such as: Modifying equipment, technologies or procedures that are integral to the production process, including recycling; Instituting management and training programs that improve housekeeping, inventory control, materials handling or other operational procedures; Making raw material substitutions; and Reformulating or redesigning products Documented reports of WRAM successes such as source reduction, recycle/reuse and treatment are published periodically. Coordinators are identified and dedicated to tracking, promoting & implementing WRAM projects. Recycle programs for paper, aluminum cans, cardboard, etc. have been evaluated and put in place where appropriate.

7.

Measure progress at each facility in reducing the generation of wastes and in reducing releases. Monitoring charts to track progress are posted, showing predicted versus actual progress. In addition to the tracking of gross waste generation, the data is normalized against the production levels of the plant site in order to provide a true picture of waste reduction progress. (on a pound of waste per thousand pound of product basis) This method allows year-to-year comparisons of our operational efficiency. A database is maintained that includes all wastes and the following: Goals WRAM data 5-Year waste generation forecast List of potential waste reduction measures Volume and cost savings Other information for safe/proper waste management

8.

Ongoing dialogue with employees and members of the public regarding waste and release information, progress in achieving reductions, and future plans. The Responsible Care® CAER Code communication mechanisms are in place and used to communicate with employees and public. Communications include an annual review of all practices and self-evaluation results. Spokesperson(s) are identified to discuss waste and release related issues with the public and employees. The Bayer annual Health, Environment and Safety Report contains a 4-year summary of the Bayer HES performance metrics and a discussion of progress and plans in those areas.

9.

Inclusion of pollution prevention objectives in research and in design of facilities, processes, and products. Environmental review of new designs or plant modifications is conducted to identify and evaluate potential points of releases and waste generation. Capital projects include pollution prevention considerations. Environmental review of new designs or plant modifications is conducted to identify and evaluate all potential points of releases and waste generation. Pollution prevention considerations are incorporated into process modifications, new process design and new product development.

10.

Program for promotion and support of pollution prevention by others. Bayer shares its special expertise, as appropriate, with customers, suppliers, transporters, warehouses, terminals, toll processors, competitors and small businesses. Representatives at Bayer's Corporate Environmental Control and Product Safety groups assist Bayer customers with environmentally safe management of Bayer's products.

11.

Periodic evaluation of waste management practices associated with operations and equipment at each member company facility. Bayer conducts several linked environmental/safety audits of its facilities to ensure compliance with all applicable laws and regulations and to support implementation of best practices. Periodic evaluation of all on-site waste management practices, including storage, packaging, transportation and wastewater treatment systems. The evaluation includes a review of waste management records for legal compliance, contingency plans, potential environmental impacts/future liabilities, safety and health concerns and community acceptance. A process is in place to review waste management changes and new waste management processes prior to implementation.

12.

Implementation of a process for selecting, retaining and reviewing contractors and toll manufacturers. Bayer conducts an evaluation of waste management practices at manufacturing, disposal, treatment and recycling facilities handling secondary materials or waste. Bayer conducts an evaluation of waste management practices at manufacturing, disposal, treatment and recycling facilities handling secondary materials or waste, which includes a site visit by qualified personnel, visual inspection of the waste management process and a review of the waste management records. All contracts with parties handling Bayer's secondary materials or wastes, and with toll or custom manufacturers, contain appropriate language requiring the contractor to abide by all applicable rules and regulations and ensuring Bayer's right to inspect the contractors' processes, facilities and records for compliance.

13.

Implementation of engineering and operating controls at each facility to prevent and detect releases that may contaminate groundwater. Bayer's project funding procedure includes a mechanism to assure that new or modified facilities are reviewed for their potential to impact the subsurface. Groundwater concerns are assessed by evaluating the chemicals stored and used at the facility according to their potential to contaminate groundwater, identifying local groundwater uses, defining sensitive areas, conducting a site hydrogeological survey and monitoring wells. Design standards are used which are protective of groundwater, including diking of storage tanks, installing leak detection systems under floors, sumps, etc., removing underground tanks and piping and paving unpaved areas.

14.

A program to address past operating and waste management practices and work to resolve problems at each active or inactive facility. Bayer has established a database to identify and assess prior operating and waste disposal practices at each active and/or inactive facility. Historical records and existing data and knowledge about a site are used to determine whether soil or groundwater contamination may exist. If potential for contamination exists, a preliminary risk assessment is conducted in conjunction with appropriate regulatory agencies to establish priorities for further investigation. A corrective action program is then established to develop, evaluate and implement potential remedies.