OUT OF THE ORDINARY INSURANCE

WHAT POLLUTION LIABILITY INSURANCE COVERS & EXCLUDES

STOP CONFUSING POLLUTION LIABILITY WITH GENERAL LIABILITY.

MOST GL POLICIES CONTAIN AN ABSOLUTE POLLUTION EXCLUSION. IF A CLAIM INVOLVES CONTAMINANTS, CHEMICALS, FUEL SPILLS, WASTE DISCHARGE, OR SOIL AND WATER POLLUTION, IT IS ALMOST ALWAYS DENIED. POLLUTION LIABILITY EXISTS BECAUSE ENVIRONMENTAL CLAIMS ARE CATASTROPHIC, COMPLEX, AND EXCLUDED EVERYWHERE ELSE.

WHAT YOUR GL POLICY SAYS ABOUT POLLUTION
ABSOLUTE POLLUTION EXCLUSION
THIS POLICY DOES NOT APPLY TO:
BODILY INJURY OR PROPERTY DAMAGE ARISING OUT OF THE ACTUAL, ALLEGED, OR THREATENED DISCHARGE, DISPERSAL, SEEPAGE, MIGRATION, RELEASE, OR ESCAPE OF POLLUTANTS...
CLAIM DENIED
THIS IS THE EXCLUSION THAT DESTROYS BUSINESSES THAT ASSUME THEY ARE COVERED.
GL DOES NOT
COVER POLLUTION
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CLEANUP CAN COST
MILLIONS
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TWO "SAME" POLICIES
CAN BE COMPLETELY DIFFERENT
NON-DISCLOSURE
VOIDS COVERAGE
HOW IT'S WRITTEN
IS EVERYTHING
WHAT POLLUTION LIABILITY COVERS

THE CORE PROTECTIONS — AND WHAT THEY ACTUALLY MEAN

POLLUTION LIABILITY POLICIES ARE BUILT TO RESPOND TO ENVIRONMENTAL INCIDENTS THAT CAUSE DAMAGE, INJURY, OR CONTAMINATION. COVERAGE VARIES BY FORM — CPL, PLL, TRANSPORTATION — BUT THESE ARE THE CORE PROTECTIONS. CLICK ANY COVERAGE TYPE TO EXPAND THE FULL EXPLANATION.

01
THIRD-PARTY BODILY INJURY FROM POLLUTANT EXPOSURE
FREQUENTLY CLAIMED
COVERS INJURIES CAUSED BY EXPOSURE TO POLLUTANTS — FROM IMMEDIATE INCIDENTS TO LONG-TAIL EXPOSURE CLAIMS THAT DEVELOP OVER YEARS.
REAL EXAMPLES
WORKERS OR BYSTANDERS EXPOSED TO TOXIC FUMES DURING CONTRACTOR OPERATIONS
RESPIRATORY ILLNESS FROM MOLD OR CHEMICAL RELEASE IN A BUILDING
LONG-TERM EXPOSURE CLAIMS — ASBESTOS, LEAD, SILICA — THAT DEVELOP YEARS AFTER THE ORIGINAL EXPOSURE
SKIN CONTACT OR INGESTION OF HAZARDOUS SUBSTANCES DURING OR AFTER AN INCIDENT
BODILY INJURY CLAIMS CAN DEVELOP SLOWLY AND BECOME EXTREMELY EXPENSIVE — ESPECIALLY WHEN MULTIPLE PARTIES WERE EXPOSED OVER A LONG PERIOD.
02
PROPERTY DAMAGE FROM CONTAMINATION
HIGH COST
03
CLEANUP COSTS — ON-SITE AND OFF-SITE
MOST VALUABLE
04
DEFENSE COSTS AND LEGAL EXPENSES
OFTEN OVERLOOKED
05
GOVERNMENT-ORDERED CLEANUP & REGULATORY ACTIONS
CRITICAL
06
TRANSPORTATION-RELATED POLLUTION EVENTS
MOBILE EXPOSURE
07
NON-OWNED DISPOSAL SITE COVERAGE
FREQUENTLY OVERLOOKED
08
MOLD, ASBESTOS & LEAD — IF SPECIFICALLY INCLUDED
POLICY-SPECIFIC
WHAT POLLUTION LIABILITY EXCLUDES

WHERE MOST BROKERS STAY VAGUE — AND WHY THAT IS A MISTAKE

THIS IS WHERE MOST BUSINESSES GET HURT. UNDERSTANDING THE EXCLUSIONS IS JUST AS IMPORTANT AS UNDERSTANDING THE COVERAGE — BECAUSE A CLAIM THAT HITS AN EXCLUSION PRODUCES THE SAME RESULT AS HAVING NO COVERAGE AT ALL: NOTHING.

CRITICAL EXCLUSION
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KNOWN CONDITIONS BEFORE POLICY INCEPTION

IF YOU KNEW ABOUT CONTAMINATION BEFORE THE POLICY STARTED, IT IS TYPICALLY EXCLUDED. BUYING A CONTAMINATED PROPERTY AND THEN INSURING IT — WHEN THE CONDITION WAS KNOWN — IS NOT COVERED. THIS IS ONE OF THE MOST COMMON REASONS POLLUTION LIABILITY CLAIMS ARE DENIED.

TRANSACTION POLICIES AND BROWNFIELD COVERAGE EXIST SPECIFICALLY TO ADDRESS THIS — BUT THE TIMING, STRUCTURE, AND DISCLOSURE HAVE TO BE RIGHT.
CRITICAL EXCLUSION
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NON-DISCLOSED OPERATIONS OR MATERIALS

IF YOU FAIL TO DISCLOSE CERTAIN WORK TYPES, MATERIALS HANDLED, OR EXPOSURE LEVELS IN YOUR SUBMISSION AND APPLICATION — THE INSURER HAS GROUNDS TO DENY A CLAIM THAT ARISES FROM THOSE UNDISCLOSED OPERATIONS. THIS IS NON-NEGOTIABLE IN ENVIRONMENTAL UNDERWRITING.

FULL DISCLOSURE IN THE APPLICATION IS NOT JUST A FORMALITY — IT IS THE FOUNDATION OF VALID COVERAGE. WHAT IS NOT DISCLOSED IS NOT COVERED.
HIGH IMPACT

INTENTIONAL NON-COMPLIANCE WITH ENVIRONMENTAL LAW

IF YOU KNOWINGLY VIOLATE ENVIRONMENTAL REGULATIONS OR ENGAGE IN ILLEGAL DUMPING OR DISCHARGE, THE CLAIM IS NOT COVERED. POLLUTION LIABILITY IS DESIGNED TO PROTECT AGAINST ACCIDENTAL OR UNEXPECTED ENVIRONMENTAL INCIDENTS — NOT WILLFUL VIOLATIONS.

THIS EXCLUSION CAN ALSO AFFECT INNOCENT PARTIES IN THE SAME ORGANIZATION IF THE VIOLATION IS ATTRIBUTED TO THE BUSINESS — MAKING INTERNAL COMPLIANCE PRACTICES IMPORTANT FOR COVERAGE INTEGRITY.
HIGH IMPACT

CONTRACTUAL LIABILITY BEYOND NORMAL EXPOSURE

IF YOU ASSUME LIABILITY IN A CONTRACT THAT GOES BEYOND YOUR NORMAL ENVIRONMENTAL EXPOSURE — FOR EXAMPLE, AGREEING TO INDEMNIFY A PROPERTY OWNER FOR ANY AND ALL CONTAMINATION — THAT ASSUMED LIABILITY MAY NOT BE COVERED OR MAY BE SIGNIFICANTLY LIMITED UNDER THE POLICY.

THIS IS A MAJOR TRAP FOR CONTRACTORS WHO SIGN BROAD INDEMNIFICATION AGREEMENTS WITHOUT UNDERSTANDING HOW THEIR POLLUTION LIABILITY POLICY TREATS ASSUMED CONTRACTUAL LIABILITY.
HIGH IMPACT

FINES AND PENALTIES — LIMITED OR EXCLUDED

SOME POLICIES EXCLUDE FINES ENTIRELY. OTHERS COVER THEM ONLY WHERE LEGALLY INSURABLE UNDER APPLICABLE STATE LAW. NEVER ASSUME REGULATORY FINES ARE COVERED WITHOUT REVIEWING THE SPECIFIC POLICY LANGUAGE — AND CONFIRMING WITH YOUR BROKER.

THE ANSWER TO "ARE FINES COVERED?" DEPENDS ON THE SPECIFIC POLICY, THE STATE, AND THE NATURE OF THE FINE. DO NOT ASSUME — CONFIRM.
IMPORTANT TO UNDERSTAND
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GRADUAL VS SUDDEN CONDITIONS — DEPENDS ON POLICY

SOME POLICIES COVER BOTH SUDDEN AND GRADUAL POLLUTION CONDITIONS. OTHERS RESTRICT COVERAGE TO SUDDEN EVENTS ONLY — MEANING A SLOW LEAK THAT DEVELOPS OVER MONTHS OR YEARS MIGHT NOT BE COVERED. THIS DISTINCTION MATTERS MORE THAN MOST BUYERS REALIZE.

GRADUAL POLLUTION — SLOW LEAKS, CHRONIC DISCHARGES, LONG-TERM CONTAMINATION BUILDUP — IS OFTEN WHERE THE LARGEST AND MOST EXPENSIVE CLAIMS ARISE. CONFIRMING HOW YOUR POLICY HANDLES THIS IS ESSENTIAL.
IMPORTANT TO UNDERSTAND
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PURELY INTERNAL CONDITIONS WITHOUT THIRD-PARTY TRIGGER

SOME POLICIES REQUIRE EITHER THIRD-PARTY DAMAGE OR A REGULATORY TRIGGER TO ACTIVATE COVERAGE. IF CONTAMINATION EXISTS ONLY ON YOUR PROPERTY AND NO REGULATORY ORDER IS ISSUED AND NO THIRD PARTY IS AFFECTED — COVERAGE MAY BE LIMITED OR MAY NOT RESPOND.

UNDERSTANDING THE COVERAGE TRIGGER IN YOUR SPECIFIC POLICY IS CRITICAL. DIFFERENT TRIGGERS PRODUCE VERY DIFFERENT RESULTS IN REAL CLAIMS SITUATIONS.
IMPORTANT TO UNDERSTAND
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PRODUCT POLLUTION — UNLESS SPECIFICALLY INCLUDED

IF POLLUTION ARISES FROM YOUR MANUFACTURED PRODUCT AFTER IT HAS BEEN SOLD AND LEAVES YOUR CONTROL, THAT EXPOSURE MAY FALL UNDER PRODUCTS LIABILITY — NOT POLLUTION LIABILITY — AND MAY REQUIRE A DIFFERENT COVERAGE STRUCTURE OR ENDORSEMENT.

MANUFACTURERS AND INDUSTRIAL OPERATIONS WITH POLLUTION-SENSITIVE PRODUCTS SHOULD SPECIFICALLY REVIEW HOW THEIR POLLUTION LIABILITY POLICY TREATS POST-SALE PRODUCT POLLUTION EXPOSURE.
REAL-WORLD CLAIM SCENARIOS

WHAT COVERAGE ACTUALLY LOOKS LIKE IN PRACTICE

THESE ARE THE TYPES OF CLAIMS THAT POLLUTION LIABILITY IS BUILT TO RESPOND TO. CLICK EACH SCENARIO TO SEE THE EXACT INCIDENT, WHAT COVERAGE RESPONDED, AND WHY IT MATTERED.

CPL CLAIM
EXCAVATION CONTRACTOR STRIKES FUEL LINE
CONTRACTOR CUTS AN UNKNOWN FUEL LINE DURING EXCAVATION. FUEL RELEASES INTO SOIL, REACHES STORM DRAIN.
PLL CLAIM
DEVELOPER DISCOVERS UNKNOWN CONTAMINATION POST-ACQUISITION
DEVELOPER BUYS FORMER INDUSTRIAL SITE. CONTAMINATION DISCOVERED DURING DEVELOPMENT THAT WAS UNKNOWN AT CLOSING.
TRANSPORT CLAIM
WASTE HAULER ROLLOVER — ROADWAY CONTAMINATION
HAZARDOUS WASTE TRANSPORT VEHICLE OVERTURNS. MATERIAL SPILLS ONTO PUBLIC ROADWAY AND ADJACENT PROPERTY.
ABATEMENT CLAIM
DEMOLITION DISTURBS ASBESTOS — AIRBORNE RELEASE
DEMOLITION CONTRACTOR DISTURBS UNKNOWN ASBESTOS-CONTAINING MATERIAL. AIRBORNE FIBERS AFFECT ADJACENT BUILDING OCCUPANTS.
DENIED CLAIM
KNOWN CONTAMINATION — DISCLOSURE FAILURE
PROPERTY OWNER BUYS CONTAMINATED SITE WITH FULL KNOWLEDGE. PURCHASES PLL AFTER CLOSING. CLAIM DENIED.
DENIED CLAIM
UNDISCLOSED WORK TYPE — NON-DISCLOSED OPERATIONS
CONTRACTOR DESCRIBES WORK AS GENERAL CONSTRUCTION. CLAIM ARISES FROM ENVIRONMENTAL REMEDIATION WORK NOT DISCLOSED IN APPLICATION.
COVERAGE TESTER

ARE YOU ACTUALLY COVERED? CHECK YOUR SITUATION.

ANSWER THESE QUESTIONS HONESTLY ABOUT YOUR CURRENT COVERAGE SITUATION. THE TOOL WILL TELL YOU WHETHER YOU LIKELY HAVE ADEQUATE POLLUTION LIABILITY COVERAGE — OR WHETHER YOU HAVE A GAP THAT DESERVES IMMEDIATE ATTENTION.

YOUR BUSINESS INVOLVES ENVIRONMENTAL EXPOSURE — EXCAVATION, CHEMICALS, WASTE, FUEL, REMEDIATION, OR DEMOLITION
YOU HAVE A GENERAL LIABILITY POLICY AND BELIEVE IT COVERS POLLUTION CLAIMS FROM YOUR OPERATIONS
YOU HAVE POLLUTION LIABILITY COVERAGE — AND YOU HAVE READ THE POLICY AND UNDERSTAND WHAT IS EXCLUDED
YOUR APPLICATION FOR POLLUTION LIABILITY FULLY AND ACCURATELY DESCRIBED ALL OF YOUR OPERATIONS, MATERIALS HANDLED, AND PROJECT TYPES
THE MOST IMPORTANT VARIABLE

HOW THE POLICY IS WRITTEN IS EVERYTHING

TWO BUSINESSES CAN BOTH HAVE "POLLUTION LIABILITY INSURANCE" AND HAVE COMPLETELY DIFFERENT COVERAGE. THE STRUCTURE OF THE POLICY — NOT THE NAME ON THE DECLARATIONS PAGE — DETERMINES WHAT ACTUALLY RESPONDS WHEN A CLAIM ARRIVES.

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NAMED INSURED WORDING

WHO IS COVERED UNDER THE POLICY — AND HOW BROADLY THEY ARE DEFINED — CAN SIGNIFICANTLY AFFECT COVERAGE FOR CLAIMS INVOLVING RELATED ENTITIES, SUBSIDIARIES, OR AFFILIATED COMPANIES.

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COVERED OPERATIONS SCOPE

THE POLICY MUST SPECIFICALLY COVER THE OPERATIONS BEING PERFORMED. IF THE POLICY DESCRIBES ONLY PART OF YOUR WORK, A CLAIM ARISING FROM THE UNCOVERED PORTION MAY BE DENIED.

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RETROACTIVE DATE

THE RETROACTIVE DATE DETERMINES HOW FAR BACK IN TIME THE POLICY WILL RESPOND TO POLLUTION CONDITIONS. A POLICY WITH A RECENT RETROACTIVE DATE MAY NOT COVER CONDITIONS THAT DEVELOPED BEFORE THAT DATE.

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DEFINITION OF "POLLUTION CONDITION"

HOW THE POLICY DEFINES A POLLUTION CONDITION DETERMINES WHAT EVENTS TRIGGER COVERAGE. NARROWER DEFINITIONS MEAN FEWER COVERED EVENTS — EVEN IF THE DAMAGE IS CLEARLY ENVIRONMENTAL IN NATURE.

COVERAGE TRIGGER STRUCTURE

CLAIMS-MADE VS OCCURRENCE STRUCTURE, DISCOVERY TRIGGERS, AND HOW THE POLICY HANDLES GRADUAL VS SUDDEN CONDITIONS ALL DETERMINE WHEN AND WHETHER COVERAGE RESPONDS TO A SPECIFIC CLAIM.

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EXCLUSIONS AND ENDORSEMENTS

WHAT IS EXCLUDED — AND WHAT HAS BEEN SPECIFICALLY ENDORSED BACK INTO COVERAGE — IS OFTEN MORE IMPORTANT THAN THE BASE COVERAGE TERMS. EVERY EXCLUSION IS A POTENTIAL CLAIM DENIAL WAITING TO HAPPEN.

RELATED PAGES TO REVIEW NEXT

POLLUTION LIABILITY COVERAGE & EXCLUSIONS — RELATED PAGES

USE THE LINKS BELOW TO MOVE INTO A SPECIFIC PRODUCT PAGE, A COST PAGE, A COMPARISON PAGE, OR THE QUOTE PROCESS PAGE.

FAQS

COMMON QUESTIONS — WHAT POLLUTION LIABILITY COVERS & EXCLUDES

DOES GENERAL LIABILITY COVER POLLUTION CLAIMS?
ALMOST NEVER IN THE WAY BUSINESSES EXPECT. MOST GENERAL LIABILITY POLICIES CONTAIN AN ABSOLUTE POLLUTION EXCLUSION THAT APPLIES BROADLY TO ENVIRONMENTAL CLAIM FACT PATTERNS. IF A CLAIM INVOLVES CONTAMINANTS, CHEMICALS, FUEL SPILLS, WASTE DISCHARGE, OR SOIL AND WATER POLLUTION, IT IS ALMOST ALWAYS EXCLUDED FROM GL COVERAGE. POLLUTION LIABILITY EXISTS SPECIFICALLY TO FILL THIS GAP.
WHAT IS THE MOST IMPORTANT PART OF A POLLUTION LIABILITY POLICY?
HOW IT IS WRITTEN. TWO BUSINESSES CAN BOTH HAVE "POLLUTION LIABILITY INSURANCE" AND HAVE COMPLETELY DIFFERENT COVERAGE. THE NAMED INSURED WORDING, COVERED OPERATIONS SCOPE, RETROACTIVE DATE, DEFINITION OF POLLUTION CONDITION, COVERAGE TRIGGER STRUCTURE, AND SPECIFIC EXCLUSIONS ALL DETERMINE WHAT ACTUALLY RESPONDS WHEN A CLAIM ARRIVES. THIS IS NOT A COMMODITY PRODUCT — AND IT SHOULD NOT BE PURCHASED LIKE ONE.
ARE FINES AND PENALTIES COVERED?
IT DEPENDS ON THE SPECIFIC POLICY AND THE STATE. SOME POLICIES EXCLUDE FINES ENTIRELY. OTHERS COVER THEM ONLY WHERE LEGALLY INSURABLE UNDER APPLICABLE STATE LAW. THE ANSWER TO "ARE FINES COVERED?" REQUIRES REVIEWING THE ACTUAL POLICY LANGUAGE — NOT ASSUMING. NEVER PLAN ON FINE COVERAGE WITHOUT SPECIFIC WRITTEN CONFIRMATION FROM YOUR CARRIER.
WHAT HAPPENS IF I DID NOT FULLY DISCLOSE MY OPERATIONS IN THE APPLICATION?
A CLAIM THAT ARISES FROM OPERATIONS NOT DISCLOSED IN THE APPLICATION CAN BE DENIED — AND THE POLICY CAN BE VOIDED DUE TO MATERIAL MISREPRESENTATION. ENVIRONMENTAL UNDERWRITING IS BUILT ON THE INFORMATION IN THE SUBMISSION AND APPLICATION. WHAT IS NOT DISCLOSED IS NOT COVERED. FULL, ACCURATE DISCLOSURE IS NOT OPTIONAL — IT IS THE FOUNDATION OF VALID COVERAGE.
DOES POLLUTION LIABILITY COVER GRADUAL CONTAMINATION OR ONLY SUDDEN EVENTS?
IT DEPENDS ON THE POLICY. SOME POLICIES COVER BOTH SUDDEN AND GRADUAL POLLUTION CONDITIONS. OTHERS RESTRICT COVERAGE TO SUDDEN EVENTS — MEANING A SLOW LEAK THAT DEVELOPS OVER MONTHS OR YEARS MIGHT NOT BE COVERED. THIS DISTINCTION MATTERS ENORMOUSLY BECAUSE GRADUAL CONDITIONS ARE OFTEN WHERE THE LARGEST AND MOST EXPENSIVE ENVIRONMENTAL CLAIMS ACTUALLY ARISE. CONFIRMING HOW YOUR SPECIFIC POLICY HANDLES THIS IS ESSENTIAL.
ARE MOLD, ASBESTOS, AND LEAD ALWAYS COVERED?
NO. THESE ARE OFTEN LIMITED, SUB-LIMITED, OR EXCLUDED ENTIRELY UNLESS SPECIFICALLY ADDED TO THE POLICY. ASBESTOS ABATEMENT FREQUENTLY REQUIRES SPECIALTY MARKET PLACEMENT BECAUSE STANDARD CPL CARRIERS OFTEN EXCLUDE ASBESTOS WORK. MOLD COVERAGE MAY BE SUB-LIMITED EVEN WHEN IT IS INCLUDED. NEVER ASSUME MOLD, ASBESTOS, OR LEAD IS COVERED WITHOUT READING THE SPECIFIC POLICY FORM AND CONFIRMING IN WRITING.
CONTACT KELLY INSURANCE GROUP

MAKE SURE YOUR COVERAGE ACTUALLY WORKS.

IF YOU ARE NOT 100% CERTAIN WHAT YOUR CURRENT POLLUTION LIABILITY POLICY COVERS — OR EXCLUDES — YOU ARE EXPOSED. USE THE FORM BELOW TO DISCUSS YOUR SPECIFIC SITUATION, REVIEW YOUR CURRENT COVERAGE STRUCTURE, OR GET A POLICY THAT IS BUILT AROUND YOUR ACTUAL OPERATIONS. CALL / TEXT (412) 212-2800 TO TALK IMMEDIATELY.