Property Types

Car & Truck Wash Facilities

Car and truck washing facilities face numerous environmental exposures ranging from chemical usage, wastewater discharges, petroleum products and solvents used to remove grime from vehicles, stormwater run-off, and waste generation. Releases from the site can lead to property damage, third-party claims, and expensive soil and groundwater remediation. Additional environmental exposures include leaks from vehicles and illicit abandonment concerns.

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Environmental Exposures May Include:

Fluid Leaks
Untreated Discharge and Sewer Contamination
Sludge Management
Stormwater Run-off
Waste Characterization and Disposal
Moisture Intrusion and Mold
Legionella
Chemical Storage
Illicit Abandonment

Fluid Leaks

Leaking of fluids, such as motor oil, hydraulic fluid, gasoline, or diesel fuel from vehicles being washed on the site, can lead to contamination of the soil, groundwater, or surface water. Releases to surface water may negatively impact local drinking water sources or cause damage to natural resources such as fish, wildlife, and biota.

Untreated Discharge and Sewer Contamination

Contaminants, including soapy water containing grime, grease, sand, dirt, detergents, and cleaners, could be washed off vehicles directly into storm drains or drywells and enter the local sewer system or drinking water sources. Untreated wash water discharged into the sanitary sewer may contaminate and potentially damage the downstream wastewater treatment plant.

Sludge Management

Sludge can build up over time in oil water separators and must be cleaned out periodically. Failure to properly maintain oil water separators can lead to backup and overflow issues or oil and sediment-laden water being discharged to the sanitary sewer. Improper discharge of wash water can impact the downstream wastewater treatment plant, while overflow can reach and contaminate soil, groundwater, or surface water media. Accidents or overturns during transportation to a landfill for disposal could release wastewater and sludge and lead to a potentially expensive cleanup operation.

Stormwater Run-off

Stormwater can come in contact with untreated wash water and other contaminants collected on-site, such as automotive fluids and fuels that have leaked, and enter on-site storm drains. Impacted stormwater not properly contained on-site can exit the site and enter storm drains, streets, and adjacent properties, resulting in third-party property damage claims. Stormwater is the most common source of stream, river, lake, ocean, and tributary pollutants and can devastate aquatic life.

Waste Characterization and Disposal

Car washes must properly manage wastewater sludge, grit-trap waste, used oil, solvents, and cleaners to avoid improper storage, handling, and disposal issues. Improper characterization or disposal of wastes can lead to environmental tort liability.

Moisture Intrusion and Mold

Mold could develop from moisture intrusion due to storms, flooding, or leaking water pipes, sprinklers, and HVAC systems. Many buildings are flat-roofed, where pooled water can be absorbed by the roofing material and seep into sub-roof areas. Mold can also develop within HVAC systems (air handling units, coils, and ductwork) or from improper building ventilation or humidity management of climate-controlled storage.

Legionella

Legionella is a bacterium that causes potentially fatal pneumonia known as Legionnaires’ disease. Legionella can thrive in water-containing systems like large air conditioning, heating, and industrial water cooling systems. Warm, stagnant water can be a breeding ground for legionella growth. Water used at car washes may experience periods of stagnation in water tanks and may not be pre-treated or properly disinfected. Water may also be recirculated and contain dirt, sediment, oils, and soaps, which can provide nutrients that promote bacterial growth. The aerosol dispersal of water from misters and sprays can travel long distances and create exposure to visitors and nearby third parties.

Chemical Storage

Chemicals used at a car wash that may be stored in bulk include cleaners, detergents, solvents, and degreasers. These chemicals and automotive fluids may be hazardous and potentially impact the environment and third parties if not properly used or stored at the property. Improper storage, containment breaches, leaks, or hazardous materials spills during loading and unloading can release hazardous and non-hazardous materials into the environment or buildings. Combinations of incompatible chemicals can react violently or produce toxic byproducts/gases when stored together or mixed.

Illicit Abandonment

Illicit abandonment is the illegal dumping of pollutants on a property by a third party. It can become the property owner’s burden for cleanup and third-party bodily injury or property damage if law enforcement cannot locate the originator of the waste.

Environmental Pollution Liability Can Provide Coverage For

On-site cleanup of new and pre-existing pollution conditions

Off-site cleanup of new and pre-existing pollution conditions

Third-party claims for cleanup costs

Third-party claims for bodily injury and property damage

Both sudden and gradual pollution conditions

Civil fines and punitive damages, where allowed by state law

First-party and third-party transportation pollution liability

Business Interruption expenses resulting from pollution conditions

Aboveground and underground storage tanks

Mold, bacteria, legionella, and more

Natural resource damage

Emergency response expenses

Illicit abandonment

Non-owned disposal sites

Loading and unloading  

Defense of third-party claims

Claims Scenarios & Examples

A car wash employee spilled several gallons of liquid wax onto the floor of a facility. The employee rinsed the material into a floor drain that eventually discharged into a nearby stream, turning the water green. The local regulatory authority investigated the green waste that eventually led to the implication of the car wash as the cause. The car wash was responsible for the cleanup and faced fines.
An automobile dealership car wash piping system leaked and released cleaning solvents into soil and groundwater. The cost to remediate the cleaning solvents, soil, and groundwater exceeded $250,000.
A chemical spill from a 55-gallon drum of potassium hydroxide at a truck washing facility sent one person to the hospital with severe burns. Potassium hydroxide is used in products such as soap and detergents used by truck washing facilities.
A man caught dumping gallons of chemicals into a local business’ drainage system was arrested by a sheriff’s deputy and charged with felony commercial dumping and issued a cleanup order by the state. A witness said they saw a man exit the suspicious vehicle, which belongs to a carpet cleaning company, and release a handle that emptied some type of liquid into a drain. Investigators discovered that carpet cleaners have been dumping hundreds of gallons of chemical waste from carpet cleaning jobs at the car wash.
While cleaning out a truck wash pit, a contractor loaded sludge into the back of a dump truck and transported it back to their yard for disposal. As the truck drove away from the truck wash, the sludge spilled out onto the roadway, leaving a trail from the truck wash to the contractor’s yard. After an investigation, city officials determined that the contractor and the owner were liable for improper industrial waste disposal.

Final Consideration

Your business can be faced with the cost to defend itself against allegations or legal action from pollution related events, regardless if you are fault or not. Having the proper insurance coverage in place will help fund the expenses incurred to investigate or defend against a claim or suit and provide you with environmental claims handling expertise.

This environmental risk overview offers a general understanding of potential risks and may not reflect all risks associated with your business. Environmental Risk Professionals has compiled this overview for informational purposes only. This overview does not constitute legal opinion or advice, nor does it establish a consultant-client relationship. This overview is not intended to guide project parties in interpreting specific contracts or resolving disputes; such decisions may require consultation with counsel and depend on various factors. © 2025 Environmental Risk Professionals, LLC

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