Document XVyMRn5N4BpDOKDrXByzJp9y

WORLDWIDE ENVIRONMENTAL PROTECTION GUIDELINES - 9/1/78 In early 1977, a set of Worldwide Environ mental Protection Guidelines was developed to insure the Corporatewide pursuit of an integrated approach to the management of Monsanto's impact on the environment. These guidelines and their attendant programs have been further developed and are presented in the attachments. Several additional guidelines directed at achieving worldwide consistency in environmental management and at environmental management matters where Monsanto does not have operating control are currently under development. JRS:ms Attachment J. Richard Sayers COMPANY CONFIDENTIAL DSW 117664 STLCOPCB4032199 WORLDWIDE ENVIRONMENTAL PROTECTION GUIDELINES - 9/1/78 Monsanto must manage its environmental impact on the workplace, the immediate plant area, and the world at large. Worldwide Environmental Protection Guidelines provide an integrated approach to this task; protection of the environment and people -- employees, customers, and the general public -- and to full compliance with the lav; of the land, wherever Monsanto operates. Where applicable laws and regulations result in unreasonable restraint (beyond that needed to protect health and the environment), Monsanto will work to change them through appropriate legal or legislative procedures. Similarly, Monsanto will not hesitate to go beyond existing regulations where necessary, to protect health and the. environment. Recognizing that environmental protection is an evolving science, Monsanto is committed to improving its performance as its capabili ties improve and national standards become more stringent. The first five Guidelines that follow are site-related and .have been established to protect the workplace and plant environments, where Monsanto has operating control. The sixth guideline relates to Monsanto involvement with service companies which support Mon santo's business from their plant site. OSW 117665 STLCOPCB4032200 GUIDELINES - 9/1/78 EFFLUENT AND EMISSION CONTROL - Monsanto will operate its processes including waste treatment in such a manner that discharges do not endanger health or the environment. Oper ating companies will: Analyze site effluents and process emissions for regulated substances and other toxic materials. Control effluents and emissions at or below levels permissible under applicable regulations or per mits, and, where necessary, or in cases not defined above, to levels judged adequate to protect health and environment. c Determine effluent and emissions wasteloads from specific processes where this information is re quired for: ' (a) solution of present or prospective compli ance problems. (b) process specific BAT (best available tech nology) and BACT (best available control technology) control. (c) "pretreatment" prior to discharge to public treatment plants and (d) the design and construction of new plants, expanded capacity, or process improvements, including ex-US installations. The EPC must be informed of, and must approve any exceptions to this Policy. The CAC will be notified of such approvals.' SOLID WASTE CONTROL - Establish Monsanto monitored and/or controlled disposition of all solid wastes. PLANT ENVIRONMENTAL ASSESSMENTS - Establish and maintain an environmental assessment of all plant sites. The assessment will include information on local air and water quality, soil and vegetation sampling, re lationships with regulatory agencies, and the effects of our presence on the surrounding environment. DEEP-WELL INJECTION. - Reduce. Monsanto's dependency- on dce.p-r- well injection of wastes, and maintain surveillance of secure operation and performance of existing wells. ~ DSW 117666 STLCOPCB4032201 2- - GUIDELINES - 5. INDUSTRIAL HYGIENE - Determine and monitor workplace stresses, and maintain Monsanto workplace environment standards. REVIEW-APPROVAL-EXCEPTIONS The Industrial Hygiene section of DMEH, working with the operating companies, will establish, review, and approve all Monsanto workplace environment standards prior to their adoption, and in this process will notify the Environmental Policy Committee of those that do not meet U.S. Standards as a minimum. 0 It is our intent to use Monsanto standards, or local legal standards, whichever is more demanding, for design and operation of our plants. ' If the situation at a specific location appears to justify an exception to Monsanto standards, the Environmental Policy Committee will be notified by the Environmental Policy Staff of the exception. The EPC may approve such exceptions after examining the relevant supporting information. The Corporate Administrative Committee will be noti fied of such approvals of exceptions. 6. OUTSIDE PROCESSORS - Select companies for support of Monsanto operations - through product conversions, custom manufacture, formulating, packaging, by-product sales, and other services involving Monsanto products/technology - which will operate with concern for worker safety and protection of the environ ment. N Formalize all agreements by contract. Ensure that the companies selected have all available relevant information on the Monsanto products and technology (including toxicological and environmental factors) with which they are involved. Terminate contracts with outside processors if they are found to be performing unsatisfactorily. DSW 117667 STLCOPCB4032202 WORLDWIDE ENVIRONMENTAL PROTECTION GUIDELINE PROGRAMS - 9/1/78 The first five Monsanto Worldwide Environmental Protection Guidelines set forth goals for the management of the workplace and plant environments. Guideline #6 has also been provided to cover environmental responsibility related to service com panies supporting Monsanto's business from their plant site. The CAC and EPC approved programs and target dates related to each Guideline are set out below. Also included are brief notes which may be helpful in understanding the tone, extent, and meaning of the Guidelines and the status of Guideline compli ance as of August, 1978. DSW 117668 STLCOPCB4032203 V. WE WILL HELP OUR PEOPLE MAXIMIZE THEIR CONTRIBUTION TO THE CORPORATION. To achieve this objective, we will: Search out, select and employ the most competent people available. Devise and administer imaginative compensation systems and benefit programs which recognize the high caliber of our personnel and emphasize contribution to near and long term results. Organize to give individuals maximum participation in the decision-making process as they strive to achieve our agreed-upon goals. Design and implement development programs which assist individuals in realizing their potential while providing Monsanto the continually growing competence and skills necessary to our future. STLCOPCB4032204 V. HUMAN RESOURCES GUIDELINE PROGRAMS - 9/1/78 EFFLUENT AND EMISSION CONTROL Program (a) Complete wide-scan analysis of all plant effluents requiring it by Jan. 1, 1980. (b) Complete "extended" wide-scan analysis, broadened to include additional materials falling under EPA reg ulation, by Jan. 1, 1982. (c) Complete analysis of process stacks and vents judged to be critical by Jan. 1, 1981. (d) Maintain compliance with permits and regulations control ling effluents and emissions. (e) Determine wasteloads for specific processes as required for special needs. - Status - 8/1/78 Effluents - Total U.S. Plants Wide-Scan analysis complete Wide-Scan analysis scheduled or in process - Analysis not scheduled Analysis not required 65 6 18 25 - 5 .16 - 36 Note - Since the status report dated 2/23/78, wide-scan analyses completed, in process, or scheduled have increased from 4 or 5 to 24. The extent of. analytical work' required at 20 plants still must be determined. ' v. Emissions - Total U.S. Plants ' "Total plant emissions" analysis complete '' Analysis scheduled or in process Analysis not yet scheduled Analysis not required 65 2 8 24 31 Note - "Total plant emissions" is defined as the emissions from process stacks or vents judged to be critical, and includes pol lutants for which ambient air quality standards have been estab lished (SO~, particulates, photochemical oxidants, non methane hydrocarbons, CO, and NOx). Substantial analytical work for specific additional materials has also been completed. BSW 117669 STLCOPCB4032205 2 - GUIDELINE PROGRAMS - 9/1/78 Specific process effluent and emission wasteloads analyses Analyzed or Sampled for Analysis Process effluent wasteload, complete - 20 Process effluent wasteload, partial - 12 Process emission wasteloads from stacks judged to be critical -6 r> Note - This work is proceeding logically as specific wasteload information is required for any of the reasons cited in the Guideline. 2. SOLID WASTE CONTROL Program (a) Carry out Programs for analysi.s/characteri.zation of wastes from all plants, as appropriate, to assure disposal in a responsible manner. (b) Place all off-site disposal under contract with routine monitoring by 12/79. (c) Provide disposal site operators with available relevant information on the properties and safe handling practices for Monsanto wastes. Status (a) 14 plants dispose of wastes on-site. ' Anticipating requirements under RCRA: (1). 11 operations are acceptable or require minor upgrading. (2). 3 operations will require major upgrading or closure. (.3). Required improvement plans are complete for 3 sites and scheduled for 11. . (b) 77 plants dispose of wastes off-site. ' (.1). Approximately 7 0% of off-site disposal operations are under acceptable contract and are routinely monitored. Completion is scheduled for Dec., 1979. (2) Disposal- site operators have been informed of safe handling practices for Monsanto wastes. - (.3) Increased involvement of Purchasing personnel in con tract development, price negotiation, and invoice handling is targeted. DSW 117670 ' STLCOPCB4032206 -3GUIDELINE PROGRAMS - 9/1/78 3. PLANT ENVIRONMENTAL ASSESSMENTS Program (a) Complete Initial Surveys by Jan. 1, 1980. (b) A committee of environmental network personnel, chaired by one DEO, prepare and submit to the EPC for its review and approval an outline description of the documentation to be included in an Initial Survey and a Final Assessment by 3/31/79. (c) Complete Final Assessments by Jan. 1, 1982. Status - 8/1/78 . Final Environmental Assessments have been completed for 26% of the Domestic plants and 11% of the ex-U.S. plants. Assessments are in progress at an additional 56% of the Domestic and 55% of the ex-U.S. 4. DEEP-WELL INJECTION Program (a) No new deep-well disposal systems will be installed except to replace current active systems. . (b) Establish immediate ceiling of 5000 gpm maximum injection rate for the corporation. This limit does not include com patible clean brines which are defined to be solutions of inorganic salts having a pH in the range of 5-10 and con- \ taining no significant level of toxic materials, and having a total organic carbon level no greater than 100 ppm. (c) An alternate disposal plan will be developed by Jan. 1, 1981 for each process waste stream currently discharged into deep wells. (d) The alternate disposal plans will be implemented to achieve one of the following: (1) Comply with legal requirements. (2) Eliminate the disposal of a waste stream which is re sulting in or has the potential of creating conditions which are deemed socially irresponsible. - (e) The status of implementation of the alternate disposal plans will be formally reviewed annually following plan development. DSW 117671 STLCOPCB4032207 -4GUIDELINE PROGRAMS - 9/1/78 Status - 8/1/78 MAP ' Current Disposal Rate - * (Additional IDA wastes of 5 1978 or early 1979) 50 gpm* gpm in late Technology Definition - 15% complete Target Disposal Rate 1/1/83 - 0 gpm MCI Current Disposal Rate - 3265 gpm . Technology Definition - 50% complete Target Disposal Rates 1/1/82 1/1/84 1/1/85 - 3130 gpm - 1400 gpm - 400 gpm MIC Current Disposal Rate - 300 gpm Technology Definition - 40% complete Target Disposal Rates 1/1/80 1/1/83 1/1/84 - 290 gpm - 250 gpm - 0 gpm MPR . Current Disposal Rate - 25 gpm Technology Definition - 60% complete Target Disposal Rates 1/1/81 - 0 gpm - MTC Current Disposal Rate - 500 gpm DSW 117672 Technology Definition - 20% complete' t- Target Disposal Rate 1/1/80 - 100 gpm STLCOPCB4032208 -5GUIDELINE PROGRAMS - 9/1/78 INDUSTRIAL HYGIENE Program (a) Complete Base Data Surveys by: U.S. - Jan., 1978 ex-U.S. - Jan., 1979 (b) Complete workplace environmental baseline monitoring by: U.S. - Jan., 1979 ex-U.S. - Jan., 1981 (c) Establish and maintain written sustaining programs, which include monitoring and corrective action plans for workplace exposures. U.S. - July, 1980 ex-U.S. - July, 1982 - (d) Establish and' attain compliance with Monsanto workplace environment standards as required by law or prescribed by DMEH. Status - 8/1/78 The first two parts of the Industrial Hygiene Program specify rather precise completion dates for both base data surveys and baseline monitoring. Because of thenature of these two exercises, neither are probably ever totally complete. With the constant installation of new processes, process modifica tion, changes in work practices, changes in regulations, etci, there will always be base data surveys to be made and baseline monitoring to be done. . Progress toward the accomplishment of these two exercises cannot be expressed with the precision the stated program implies and the dates set forth in the first two parts of the program should be viewed as approximate time-frames. According to the information that has been provided, U. S. base data surveys are essentially complete and all ex-U.S. base data surveys will be completed during 1979. Considerable progress has been made in baseline monitoring in the U.S. However, it would not appear that this project could be called completed until some time in 1980. Considerable progress is being made in baseline monitoring exU.S. The only geographical areas particularly lacking in this regard would appear to be Mexico and South America. However, all companies indicate January 1981 as being' a realistic date for the completion of baseline monitoring ex-U.S. DSW 117673 STLCOPCB4032209 6- GUIDELINE PROGRAMS - 9/1/78 The most critical factor leading to full compliance is set forth in Item (c) . All of the companies believe that by July 1980 for the U.S. and July 1982 for ex-U.S., they will have estab lished and will be maintaining written sustaining programs, which will include monitoring and corrective action plans for workplace exposures. 6. OUTSIDE PROCESSORS Program (a) Complete initial processor review and eliminate/upgrade companies found to be inadequate: U.S. ex-U.S. - Jan. 1, 1979 - Jan.- 1, 1980 (b) Establish a continuing pre-contract assessment and review program: U.S. ex-U.S. - Jan. 1, 1979 - Jan. 1, 1980 ' Status - 8/1/78 Within U.S. There are some 200 outside processors performing a variety of services, from cleaning drums to preparing special inter mediates. About 50% of these are under contract; most of the remainder operate under purchase orders. Each Monsanto company has completed an initial assessment of its processors. As a result, six have been terminated'. MCP, MAP, MP&R, and MTC either have or'plan to have all processors under con tract by 1/79. MIC intends to execute contracts as present arrangements expire; MCI plans to have all under contract by 1/80. Corporate Purchasing is preparing prototype contracts for general use and is prepared to handle the purchasing aspects of these service arrangements. Outside U.S. We have less complete information on ex-U.S. outside pro cessors. Fifteen have been identified. Both MTC and MIC need further information on processors performing services of their operations in Europe. MTC uses a number of small companies for dyeing and texturizing fiber. It is expected that by the end of 1979 we will have all ex-U.S. outside processors identified, categorized and in compliance with this Guideline. ' DSW 117674 STLCOPCB4032210