ACORD 190 (Environmental Liability Application)
The ACORD form for environmental impairment and pollution liability insurance applications.
What It Is
The ACORD 190 is the application supplement for environmental impairment and pollution liability insurance. It captures detailed information about the applicant's operations, environmental exposures, pollution prevention practices, regulatory compliance history, and environmental claims or incidents.
The form includes sections on underground and aboveground storage tanks, waste generation and disposal practices, air emissions, water discharges, and any historical contamination at the insured's locations. It also documents Phase I and Phase II environmental site assessments that have been conducted.
Environmental liability underwriting requires specialized technical knowledge, and the ACORD 190 organizes this complex information into a format underwriters can evaluate consistently.
Why It Matters for Brokers
Environmental liability is excluded from standard CGL policies under the absolute pollution exclusion. Brokers placing environmental coverage must present detailed information about the client's pollution exposures and management practices. The ACORD 190 is the foundation of the environmental liability submission, and its quality directly affects coverage availability and pricing. Brokers who can accurately translate a client's environmental profile into the ACORD 190 format serve a specialized niche with significant premium opportunities.
Real-World Example
A manufacturing company with three facilities and 6 underground storage tanks needs pollution legal liability coverage. The broker completes the ACORD 190 documenting the tank ages, contents, secondary containment systems, leak detection monitoring results, and compliance history with EPA and state environmental regulations. Phase I environmental site assessments for all three locations are attached. The comprehensive submission secures a competitive quote from a specialty environmental carrier.
Common Mistakes
- 1Failing to disclose known contamination or historical environmental issues, which can void coverage and create E&O exposure.
- 2Not attaching Phase I or Phase II environmental site assessments when available, which are the primary documents underwriters review.
- 3Underreporting the number or capacity of storage tanks, which is a material underwriting factor for pollution coverage.
How brokerageaudit.com Handles This
Submission Intake provides environmental-specific guidance for the ACORD 190, including prompts for common regulatory compliance items and automatic flagging of disclosures that require supporting documentation.