Update Concerning Toxic 100 Air, 2016 edition (rsei-234-RY2014)

Bayer AG has contacted PERI to explain that the company believes that the U.S. Environmental Protection Agency (EPA)'s Risk-Screening Environmental Indicators (RSEI) model substantially overstates Bayer's RSEI Score for the following reason.

The post-incineration emissions of Diaminotoluene (mixed isomers) from the Bayer facility in Baytown, Texas, accounts for 82.5 percent of Bayer's RSEI Score.

In the EPA's RSEI model, the Destruction and Removal Efficiency (DRE) of incineration is assumed to be 99% for off-site incineration of the chemical Diaminotoluene (mixed isomers) for all industries and facilities.

Bayer states that the DRE for off-site incineration of Diaminotoluene (mixed isomers) from its Baytown facility is 99.9999 percent, rather than the 99 percent factor applied by EPA. If Bayer's information is correct, Bayer's total RSEI Score would be 1,294,963 rather than 7,387,044 and Bayer's rank in the Toxic 100 Air Polluters index would be eighteenth (18th) rather than third (3rd).

For Bayer's explanation of this issue, see the following link hosted by Bayer/Covestro, http://www.productsafetyfirst.covestro.com/en/Resources/PS1-News/2016-News-Articles/2016-12-19-PERI-ranking.aspx

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