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ACORD Form GuideACORD 135

ACORD 135 — Pollution Liability Application

The ACORD 135 Pollution Liability Application collects the environmental exposure details needed to quote pollution coverage. It focuses on operations, substances handled, storage tanks, site history, waste disposal, regulatory compliance, and prior incidents. Because standard general liability policies commonly exclude pollution claims, accurate answers are essential for identifying the right coverage.

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When is ACORD 135 used?

Pollution liability is needed for businesses with environmental exposures: • Contractors who work with fuels, chemicals, or hazardous materials • Dry cleaners and laundries (solvent exposure) • Gas stations and fuel distributors • Auto repair shops with used oil and antifreeze • Manufacturers with chemical processes • Property owners and managers (fuel oil tanks, lead paint, asbestos) • Environmental consulting and remediation firms • Recyclers and waste handlers • Any business on a site with known or suspected historical contamination

How to complete ACORD 135

Start with a complete operations narrative and list every pollutant, chemical, fuel, waste stream, and process involved. Then collect site addresses and prior uses, tank type and age, monitoring and maintenance records, waste haulers, environmental assessments, permits, regulatory notices, spill history, and the requested coverage territory and limits. Ask about subcontractors and off-site work for contractors, and attach loss or remediation details instead of leaving environmental incidents unexplained.

What the GL pollution exclusion eliminates

Standard commercial GL policies contain an absolute pollution exclusion (or a qualified exclusion) that eliminates coverage for:

• Bodily injury caused by pollution (including chemical inhalation, groundwater contamination) • Property damage caused by the release of pollutants • Cleanup costs required by government authorities • Third-party claims arising from pollution on or migrating from the insured's property

The breadth of the exclusion means that even businesses without obvious pollution risk — such as a landlord with an underground fuel oil tank — can face uncovered claims. Pollution liability fills this gap.

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Types of pollution coverage

Pollution coverage comes in several forms:

Site pollution liability — covers claims arising from conditions at a specific property. Used by property owners, manufacturers, and businesses with fixed operations.

Contractors pollution liability (CPL) — covers contractors who may encounter or disturb pollutants at job sites (mold, asbestos, lead paint, underground storage tanks). One of the fastest-growing commercial specialty lines.

Transportation pollution liability — covers pollution incidents during the transportation of hazardous materials. Required for many hazmat haulers.

Environmental professional liability — covers errors and omissions by environmental consultants who provide remediation plans or environmental assessments.

Key ACORD 135 underwriting information

Pollution underwriters need to know:

• A full description of operations and the types of substances handled or stored • A history of the property (prior uses, known contamination) • Any prior pollution incidents, spills, or regulatory actions • Underground storage tanks — number, age, material, monitoring system • Above-ground storage tanks • Any prior environmental assessments (Phase I or Phase II studies) • Current regulatory compliance status • How waste materials are handled and disposed of

Common ACORD 135 mistakes

Not asking contractors about potential pollution exposure at job sites (mold, asbestos, USTs)

Assuming the GL pollution exclusion is limited — the absolute exclusion is very broad

Not asking about underground storage tanks during the commercial property submission

Missing the contractors pollution liability need for contractors working in older buildings

Not asking about prior environmental investigations or regulatory actions

Companion ACORD forms

ACORD 125
Commercial Insurance Application
ACORD 126
Commercial GL Section
ACORD 140
Commercial Property Section
ACORD 132
Contractors Supplemental

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Commercial insurance for contractorsInsurance for dry cleanersCommercial underwriting basicsCommercial insurance glossary