CERCLA liability reached nearly every waste generator including governments and universities

Evidence

The practical impact of CERCLA’s extending its liability scheme to socalled arrangers was, however, even greater. The federal statute did not make liable only current and past owners and operators of the sites and those who had transported the hazardous substances to them. It also singled out for liability those persons who “arranged” for the transportation, treatment, storage, and disposal of the hazardous substances now located at the sites and requiring cleanup. The single most significant category of such arrangers comprises the original generators of the hazardous substances. This category of responsible parties is extraordinarily broad, including representatives of nearly every manufacturing and industrial activity in the United States, ranging from the most powerful Fortune 500 company to the family-owned neighborhood dry cleaner. It also reaches many federal agencies, including the Department of Defense and the EPA, many state agencies, all municipal governments and hospitals, and public and private universities and colleges. — Richard J. Lazarus, The Making of Environmental Law, 490

Categorization

• XREF: connects to: CERCLA’s retroactive strict liability rewired how real estate deals treat land — Richard J. Lazarus, The Making of Environmental Law, 487