Exhibit 5.1


                        [POLYONE CORPORATION LETTERHEAD]



                                  May 2, 2002


Securities and Exchange Commission
450 5th Street, N.W. Judiciary Plaza
Washington, D.C.  20549

       Re:      Registration Statement on Form S-4 filed by PolyOne Corporation
                ---------------------------------------------------------------

Ladies and Gentlemen:

         I am the Vice President, Chief Legal Officer and Secretary for PolyOne
Corporation, an Ohio corporation (the "Company"), and have acted as such in
connection with (i) the offer to exchange (the "Senior Note Exchange Offer")
$1,000 principal amount at maturity of the Company's 8.875% Senior Notes due
2012 (the "Exchange Notes") for each $1,000 principal amount at maturity of the
Company's outstanding 8.875% Senior Notes due 2012 (the "Private Notes") and
(ii) the preparation of the prospectus (the "Prospectus") contained in the
registration statement on Form S-4 (the "Registration Statement") filed on May
2, 2002 with the Securities and Exchange Commission by the Company for the
purpose of registering the Exchange Notes under the Securities Act of 1933 (the
"Act"). The Private Notes have been, and the Exchange Notes will be, issued
pursuant to an Indenture, dated as of April 23, 2002 (the "Indenture"), between
the Company and The Bank of New York, as Trustee.

         In connection with the opinions expressed herein, I or attorneys under
my supervision have examined such documents and records, including an
examination of originals and copies certified or otherwise identified to our
satisfaction, and matters of law as I have deemed necessary for purposes of this
opinion. Based upon the foregoing and subject to the qualifications and
limitations stated herein, I am of the opinion that:

                  (1) The Exchange Notes have been duly authorized.

                  (2) When the Exchange Notes, substantially in the form as set
forth on an exhibit to the Indenture as filed as Exhibit 4.1 to the Registration
Statement, have been duly executed by the Company and authenticated by the
Trustee in accordance with the Indenture and duly delivered in exchange for the
Private Notes in accordance with the Senior Note Exchange Offer in the manner
described in the Registration Statement, the Exchange Notes will be valid and
binding obligations of the Company and will be entitled to the benefits of the
Indenture.

         I am admitted to practice law in the State of New York and have been
granted corporate status in the State of Ohio to perform legal services on
behalf of the Company. My examination of matters of law in connection with the
opinions expressed herein has been limited to, and accordingly my opinions
herein are limited to, the laws of the State of New York, which are expressed to
govern the Exchange Notes, and the Ohio General Corporation Law, including the
applicable provisions of the Ohio Constitution and the reported judicial




decisions interpreting such law. I express no opinion with respect to any other
law of the State of Ohio or any other jurisdiction. I further express no opinion
as to any state securities or blue sky laws.

         I hereby consent to the filing of this opinion as Exhibit 5.1 to the
Registration Statement and the reference to me under the caption "Legal Matters"
in the Prospectus constituting a part of the Registration Statement. In giving
such consent, I do not thereby admit that I am included in the category of
persons whose consent is required under Section 7 of the Act or the rules and
regulations of the Securities and Exchange Commission promulgated thereunder.

                                                 Very truly yours,

                                                 /s/ Wendy C. Shiba

                                                 Wendy C. Shiba
                                                 Vice President, Chief Legal
                                                 Officer and Secretary