Waste Handling
Waste generation, such as scrap metal, coolant, used oil, solvent, paint, adhesives, coatings, and other waste materials, may be generated by fabrication operations and can be considered hazardous. Improper storage and handling of wastes can lead to releases that may cause contamination. Additionally, waste generators are responsible for determining if their wastes are hazardous and require special disposal or recycling procedures. Waste generators retain “cradle to grave” liability for their disposal of wastes, and improper characterization and disposal can result in regulatory violations and environmental liability.
Stormwater Run-off
Stormwater run-off could contact chemicals, metals, oil, wastes, or other outside storage. Trucks delivering raw materials or picking up products or wastes can leak automotive fluids on the property and collect in stormwater run-off. If adequate precautions are not taken to prevent pollutants from entering stormwater, they can impact soil or groundwater at a facility or neighboring property, migrate to storm drains, and be discharged to surface waters.
Oil Water Separators
Oil/water separators designed to separate oils from coolants may be present at fabrication facilities, either in-ground or aboveground. Over time, these separators can develop leaks that allow oil or coolant to seep from the system into the surrounding environment.
Mold
Mold could develop from moisture intrusion caused by storms or flooding from leaking water pipes, sprinklers, and HVAC systems. Many fabrication 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 or from improper building ventilation or humidity management of climate-controlled areas within the building.
Chemical Releases
Releases of chemicals, petroleum products, or wastes from aboveground or underground storage tanks, process equipment, containers, wastewater treatment systems, piping systems, drains, or other areas of a facility could impact soil or ground-water, result in toxic air releases, migrate off-site, harm municipal sanitary sewers, or impact surface waters and result in cleanup claims, third-party suits, natural resource damages, and civil fines.
Hazardous Dust and Vapors
Welding, brazing, and cutting can generate fumes and vapors that contain metals, carbon dioxide, carbon monoxide, ozone, fluorides, and other chemical components that can adversely impact health. Dust can be generated from grinding activities. If the area where these operations are performed is not properly vented, or fumes or dust are vented to areas where they are drawn into neighboring HVAC systems, third parties could be exposed to the fumes or dust, resulting in bodily injury claims.
Illicit Abandonment
Illicit abandonment is the illegal dumping of pollutants on a property by a third party. If law enforcement cannot locate the originator of the waste, it can become the property owner’s burden for cleanup and third-party bodily injury or property damage.
Wastewater
Wastewater from fabrication operations can contain metals, oils, grease, solvents, detergents, suspended solids, and other pollutants. Wastewater treatment systems may be present at facilities, or wastewater may be taken to a non-owned disposal site or wastewater treatment facility. Releases of insufficiently treated wastewater or spills during storage, transport, or transfer from wastewater storage areas could create environmental risks. Improper waste disposal could lead to environmental liability or legal consequences for violating regulatory requirements.
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 bodily injury and property damage
Third-party claims for cleanup
Both sudden and gradual pollution conditions
Aboveground and underground storage tanks
Non-owned disposal sites
Business interruption resulting from pollution conditions
First and third-party transportation pollution liability
Loading and unloading
Defense of third-party claims
Illicit abandonment
Natural resource damage
Civil fines and penalties