Dow Chemical 2015 Annual Report Download - page 73

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The Company recognizes the financial statement effects of an uncertain income tax position when it is more likely
than not, based on technical merits, that the position will be sustained upon examination. At December 31, 2015, the
Company had uncertain tax positions for both domestic and foreign issues of $280 million.
The Company accrues for non-income tax contingencies when it is probable that a liability to a taxing authority has
been incurred and the amount of the contingency can be reasonably estimated. At December 31, 2015, the Company
had a non-income tax contingency reserve for both domestic and foreign issues of $64 million.
For additional information, see Notes 1 and 23 to the Consolidated Financial Statements.
Environmental Matters
Environmental Policies
Dow is committed to world-class environmental, health and safety (“EH&S”) performance, as demonstrated by industry-
leading performance, a long-standing commitment to Responsible Care®, and a strong commitment to achieve the Company’s
2025 Sustainability Goals – goals that set the standard for sustainability in the chemical industry by focusing on improvements
in Dow’s local corporate citizenship and product stewardship, and by actively pursuing methods to reduce the Company’s
environmental impact.
To meet the Company’s public commitments, as well as the stringent laws and government regulations related to environmental
protection and remediation to which its global operations are subject, Dow has well-defined policies, requirements and
management systems. Dow’s EH&S Management System (“EMS”) defines the “who, what, when and how” needed for the
businesses to achieve the Company’s policies, requirements, performance objectives, leadership expectations and public
commitments. To ensure effective utilization, the EMS is integrated into a company-wide management system for EH&S,
Operations, Quality and Human Resources.
It is Dow’s policy to adhere to a waste management hierarchy that minimizes the impact of wastes and emissions on the
environment. First, Dow works to eliminate or minimize the generation of waste and emissions at the source through research,
process design, plant operations and maintenance. Second, Dow finds ways to reuse and recycle materials. Finally, unusable or
non-recyclable hazardous waste is treated before disposal to eliminate or reduce the hazardous nature and volume of the waste.
Treatment may include destruction by chemical, physical, biological or thermal means. Disposal of waste materials in landfills
is considered only after all other options have been thoroughly evaluated. Dow has specific requirements for waste that is
transferred to non-Dow facilities, including the periodic auditing of these facilities.
Dow believes third-party verification and transparent public reporting are cornerstones of world-class EH&S performance and
building public trust. Numerous Dow sites in Europe, Latin America, Asia Pacific and North America have received third-party
verification of Dow’s compliance with Responsible Care® and with outside specifications such as ISO-14001. Dow continues
to be a global champion of Responsible Care® and has worked to broaden the application and impact of Responsible Care®
around the world through engagement with suppliers, customers and joint venture partners.
Dow’s EH&S policies helped the Company achieve excellent EH&S performance in 2015. Dow’s injury/illness rates and
process safety performance were excellent in 2015. Further improvement in these areas, as well as environmental compliance,
remains a top management priority, with initiatives underway to further improve performance and compliance in 2016 as Dow
begins to implement the Company's 2025 Sustainability Goals.
Detailed information on Dow’s performance regarding environmental matters and goals can be found online on Dow’s
Sustainability webpage at www.dow.com. The Company's website and its content are not deemed incorporated by reference into
this report.
Chemical Security
Public and political attention continues to be placed on the protection of critical infrastructure, including the chemical industry,
from security threats. Terrorist attacks, natural disasters and cyber incidents have increased concern about the security and
safety of chemical production and distribution. Many, including Dow and the American Chemistry Council, have called for
uniform risk-based and performance-based national standards for securing the U.S. chemical industry. The Maritime
Transportation Security Act of 2002 and its regulations further set forth risk-based and performance-based standards that must
be met at U.S. Coast Guard-regulated facilities. U.S. Chemical Plant Security legislation was passed in 2006 and the
Department of Homeland Security is now implementing the regulations known as the Chemical Facility Anti-Terrorism
Standards. The Company is complying with the requirements of the Rail Transportation Security Rule issued by the U.S.