Property Types

Fire Stations

Fire stations can face exposure to environmental liability through various operations performed at the station or training facilities or from materials collected or stored on site. Leaks, spills, improper containment of fuel and fluids used in fire trucks and powered equipment, and wash water produced during cleaning can release pollutants that contaminate soil and groundwater or collect in stormwater run-off. Emergency services can result in exposure and collection of biohazards, such as medical and infectious waste, that require proper decontamination and disposal procedures. Firefighting foams can contain highly toxic materials. Run-off of the foam from training exercises or a release during transportation or disposal can result in environmental cleanup and tort liability.

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Environmental Exposures May Include:

Storage Tanks
Run-off
Medical Waste
Chemical Spills
Asbestos
Hazardous Waste
Mold
Legionella
Illicit Abandonment
PFAS Contamination and Firefighting Foam

Storage Tanks

Above and underground storage tanks may store fuels or engine fluids. Leaks or spills can occur from the tanks or associated piping. Also, they can occur during fueling fire engines and trucks or delivery into storage tanks. Soil or groundwater could be impacted, or pollutants could migrate in stormwater to dry wells, sewer drains, or storm drains. Other fluids, such as oils and hydraulic fluids, used in various equipment, such as engine ladders, hydraulic cutters, rams, and spreading equipment, can also leak or spill from storage, vehicles, or equipment. Cleanup, third-party claims, or natural resource damage claims could result.

Run-off

Cleaning fire engines and trucks produce wash water that may have high levels of oil, grease, suspended solids, and heavy metals such as copper and lead, as well as cleaning chemicals, degreasing solvents, and detergents. Run-off from washing areas or wastewater mismanagement creates the potential for pollutants to be discharged to the public storm system, which can contaminate water sources and cause natural resource damage.

Medical Waste

Emergency medical services can create exposure to medical and infectious waste. Improper handling, transporting, or disposal of materials contaminated with biohazards, including blood or other bodily fluids that transmit disease or other hazardous wastes containing chemicals, heavy metals, dangerous pathogens, or other toxic materials, can create significant health hazards and exposures to third parties. Materials contaminated with blood and other infectious bodily fluids must be bagged appropriately in designated, leak-proof waste bags and sterilized or taken to an approved and licensed disposal facility. Personal protective equipment and the interior of ambulances/service vehicles also need to be properly decontaminated.

Chemical Spills

Chemicals such as cleaning agents, disinfectants and pesticides, and fertilizers used for landscaping may be stored and used at fire stations. Leaks or spills can contaminate soil and groundwater contamination and pollute stormwater run-off.

Asbestos

Older buildings, including fire stations, may contain asbestos, lead, and PCBs. Asbestos-containing materials (ACM) can be found in ceiling and floor tiles, insulation, around wiring, and fireproofing on structural steel. PCBs can be found in areas such as window caulk and light ballasts. Lead could be present in paint or pipes. Third-party bodily injury claims may result from accidental disturbance and alleged exposure during renovation, construction, or interior remodeling.

Hazardous Waste

Fire stations may provide household hazardous waste collection, which can involve the collection, temporary storage, and disposal of hazardous materials that are corrosive, poisonous, flammable, combustible, caustic, volatile, explosive, an irritant, or toxic, such as cleaning fluids, pesticides, mercury thermometers, fluorescent lamps, batteries, aerosols, medications, automotive fluids, and pool chemicals. An accidental release of hazardous material at the site or an accident during the transportation of the waste to the disposal site can become an exposure. Waste that is accumulated and stored, even temporarily, such as overnight, can subject the collector to meet regulated waste storage requirements.

Mold

Mold growth can result from water and wastewater releases into building materials and subsurfaces due to leaks, overflows, and blocked drains or pipes. Mold may also develop in other water systems, such as refrigeration or HVAC systems and water features. Mold and mildew can grow on the walls, floors, and ceilings, including wooden structural components and drywall, resulting in structural damage and possible health hazards to third parties.

Legionella

Bacteria such as legionella can be transported through water sources, ventilation systems, and other means, representing serious health risks. Legionella is a bacterium that causes a form of potentially fatal pneumonia. Legionella can thrive in water-containing systems like air conditioning, heating, and water-cooling systems. These pollutants can potentially lead to claims of severe bodily injury or remediation costs.

Illicit Abandonment

Illicit abandonment is the illegal dumping of pollutants on property. 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.

PFAS Contamination and Firefighting Foam

Firefighting foams’ use, storage, transportation, and disposal could pose a liability to fire departments under certain circumstances. Firefighting foams can contain toxic chemicals, including perfluorooctanesulfonic acid and perfluorooctanoic acid. Containment breaches and run-off of the firefighting foam can discharge into sewage and municipal water systems and infiltrate into soil and groundwater, where they can migrate rapidly through aquifers and impact third parties. These chemicals are mobile and persistent and remain in the environment and the human body for years. They are linked to significant hazards to human health and aquatic and other wildlife systems.

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

Mold, bacteria, viruses, legionella, and more

Business interruption resulting from pollution conditions

First and third-party transportation pollution liability

Loading and unloading

Defense of third-party claims

Illicit abandonment

Non-owned disposal sites

Natural resource damage

Claims Scenarios & Examples

A fire station was built in the 1970s. When the station decided to replace the ceiling tiles, mold was discovered. Further investigation found various kinds of mold, including black mold, growing through the ceiling and insulation and behind the masonry walls and wood framework. The mold growth was due to the building being built airtight, causing the building to be a “mold incubator.” An environmental consulting company was hired to assess the building. They also found an accumulation of diesel dust and determined several environmental conditions that could be hazardous to the environment and human health. The building had to be remediated, which involved stripping and rebuilding the structure. Remediation costs exceeded $1 million.
A fire station experienced mold growth from condensation from the air conditioning units. The city council agreed to a mold remediation contract for $90,000.
A suspicious package was left at a fire station, and readings taken near it indicated it contained a hazardous substance. A level 3 hazmat incident was declared, which is the highest response level, requiring evacuation, chemical-protective clothing, or special equipment and professionals. The fire station had to be evacuated, and four people were transported to a nearby hospital to be decontaminated, as a precautionary measure, after exposure to the package.
The hydraulic line broke on a fire truck, resulting in a hydraulic fluid leak. The hydraulic fluid migrated in stormwater, and police had to close down a stretch of the road. City crews responded to clean up the release.
An aboveground storage tank at a fire station held heating oil used in the boiler to heat the fire station. An underground section of piping connected the tank to the boiler. An estimated 250 gallons of fuel were released from the piping because it had corroded and developed a hole. The release impacted the surrounding soil and groundwater. Soil and groundwater remediation for the release cost over $100,000.
Two drinking water wells used for drinking water supply by a municipality were shut down after perfluorooctanoate sulfonate (PFOS) and perfluorooctanoic acid (PFOA) were detected in the wells at elevated levels. The Department of Environmental Conservation officials are investigating the source of the contamination, and they have indicated that a fire department property may have been the source. If found to be the source of the contamination, the fire department property could be added to the state Superfund list. Installation of a carbon filtration system cost $1.2 million, and continuing maintenance costs were $50,000 per year. The fire department could be liable for the cleanup as a Potentially Responsible Party.

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 at 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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