Clean Harbors, Inc. (CLH) — ESG & Values Scores

Environment story

Clean Harbors operates as a hazardous waste management and environmental services company with significant operational environmental liabilities totaling $230.7 million (as of Dec 31, 2025). The company discloses no comprehensive Scope 1, Scope 2, or Scope 3 emissions metrics, net-zero target year, or renewable energy percentage. The 10-K explicitly acknowledges environmental litigation risk, past fines from government enforcement proceedings, and ongoing remediation activities at company facilities and third-party sites. Controversies include 76 active product liability lawsuits related to parts washer solvents (benzene contamination claims) and PFAS regulatory exposure. The company's core business model—hazardous waste incineration and landfill operations—inherently generates substantial direct emissions and Scope 3 supply-chain carbon from customer waste streams. No disclosed investments in physical decarbonization infrastructure or emissions reduction targets are evident in the filing. The company's climate risk acknowledgment focuses on operational disruption rather than proactive mitigation.

Criticisms on file

76 active product liability lawsuits related to Safety-Kleen parts washer services; claimants allege solvents contained benzene and other toxic contaminants, and company failed to adequately warn users of health risks including trace amounts of benzene.
Source: CLH 10-K Item 1A Risk Factors, 'Product Liability Lawsuits'; stated as of Dec 31, 2025
Environmental liabilities of $230.7 million assumed in acquisitions; company subject to government environmental enforcement proceedings resulting in fines and penalties for waste treatment, storage, and disposal operations.
Source: CLH 10-K Item 1A Risk Factors, 'Environmental Liabilities'; MD&A
PFAS (per- and polyfluoroalkyl substances) emerging regulatory risk; potential for future changes in environmental laws and regulations that could require earlier or greater remediation payments.
Source: CLH 10-K Item 1A Risk Factors, 'Environmental Liabilities'
Past and ongoing remediation at company facilities and third-party sites; investigations during facility evaluations and closures may lead to discovery of previously unknown contamination requiring material remediation costs.
Source: CLH 10-K Item 1A Risk Factors, 'Environmental Regulations'

Disclosed initiatives

Environmental Compliance Internal Audit Program

Company implements internal audit program to minimize operational and safety risks related to hazardous materials handling.

Intended to reduce environmental liability exposure; specifics on emissions reduction not disclosed.
Facility Remediation Activities

Company conducts remedial activities at certain company-owned facilities and pays remediation costs at third-party disposal sites.

Reactive remediation rather than preventive emissions reduction; estimated cost impact immaterial per 10-K disclosure.

Social story

Clean Harbors reports no disclosed CEO-to-median-worker pay ratio, workforce turnover rate, or diversity metrics (gender/ethnicity percentages in leadership or general workforce). The company acknowledges dependency on skilled labor in a competitive market and notes that deterioration in employee relations or key personnel loss could materially harm operations. No active documented union-suppression activities or major strikes are disclosed in the 10-K; the company makes no mention of union standing, collective bargaining agreements, or labor disputes within the last 24 months. Supply-chain labor practices are not addressed; the company does not disclose audits of supplier human-rights practices, cobalt sourcing policies, or living-wage commitments. Field Services and Technical Services require hazardous-materials handling under potentially dangerous conditions; the company emphasizes safety training and equipment but provides no quantitative injury/fatality data. The company expanded a Global Capabilities Center in India but discloses no labor standards or worker protections at that facility.

Criticisms on file

No disclosure of CEO pay, median worker pay, or pay-equity data; cannot assess CEO-to-worker pay ratio or gender/racial pay gaps.
Source: CLH 10-K MD&A, Compensation section absent; standard proxy filings not provided in source documents
No disclosed diversity metrics for workforce, leadership, or board; no mention of DEI programs, supplier diversity initiatives, or EEO-1 disclosure.
Source: CLH 10-K Item 1 overview and MD&A; no DEI or human-capital disclosure section
Product liability lawsuits (76 active cases as of Dec 31, 2025) involving Safety-Kleen parts washer products; alleged failure to warn workers of benzene and toxic solvent contamination raises occupational health and safety concerns.
Source: CLH 10-K Item 1A Risk Factors, 'Product Liability Lawsuits'
Global Capabilities Center in India cited for cost and productivity; no labor standards, wage policies, or worker-protection commitments disclosed for non-U.S. operations.
Source: CLH 10-K MD&A, 'SG&A Expenses' (India GCC referenced); Risk Factors acknowledge foreign operations

Disclosed initiatives

Comprehensive Safety Training Programs

Company implements training programs for employees and subcontractors working under hazardous conditions.

Intended to minimize occupational injury and environmental liability; no quantitative safety metrics disclosed.
Global Capabilities Center Expansion (India)

Company expanded support functions globally, including labor and administrative functions in India, stated as achieving profitability and productivity improvements.

Cost optimization and workforce expansion; no labor-standards or worker-protection commitments disclosed.
Key Personnel Retention and Recruitment

Company acknowledges competitive labor market and need to retain expertise in hazardous-waste management.

Intended to maintain operational continuity; no formal programs, wage benchmarks, or retention metrics disclosed.

Governance story

Clean Harbors operates under a staggered board structure with three classes of directors, each elected for three-year terms. The 10-K does not explicitly disclose board independence percentage; the staggered structure and Massachusetts Business Corporation Act provisions (which require 40% shareholder threshold to call special meetings, reduced to 25% in company by-laws) are anti-takeover mechanisms that may limit shareholder power but do not directly measure independence. No dual-class share structure with unequal voting rights is disclosed; the company has single-class common stock. The 10-K does not disclose annual lobbying expenditures or climate/environmental-deregulation lobbying activities. No active antitrust, consumer-safety, or financial-fraud regulatory proceedings are mentioned; past environmental enforcement fines and product-liability litigation are disclosed but characterized as routine in the hazardous-waste industry. The company does not disclose political PAC contributions, trade-association memberships, or alignment with climate advocacy. No evidence of shareholder litigation to block climate proposals or anti-ESG activism is disclosed.

Criticisms on file

Staggered board and by-law provisions requiring 25% of shares to call special meeting (reduced from 40% statutory threshold) create anti-takeover defenses that may limit shareholder power to remove directors or call special meetings.
Source: CLH 10-K Item 1A Risk Factors, 'Anti-Takeover Provisions'; Massachusetts Business Corporation Act Sections 8.06, 7.02; Company By-Laws
No disclosed lobbying expenditures, PAC contributions, or trade-association climate-policy alignment; company does not disclose positions on environmental deregulation or climate legislation.
Source: CLH 10-K; no lobbying disclosure, political-contributions section, or trade-association disclosures present in source documents
Routine government environmental enforcement proceedings and fines; company characterizes these as typical in the industry but does not disclose specific amounts, frequency, or details of past or pending enforcement actions.
Source: CLH 10-K Item 1A Risk Factors, 'Environmental Regulations' and 'Environmental Liabilities'
76 active product liability lawsuits (Safety-Kleen parts washer solvent claims) as of Dec 31, 2025; company maintains insurance but acknowledges uncertainty regarding coverage adequacy and exclusion of punitive damages.
Source: CLH 10-K Item 1A Risk Factors, 'Product Liability Lawsuits'

Disclosed initiatives

Staggered Board Structure

Three-class board of directors with annual election of one class for three-year terms; intended to provide continuity and stability.

Anti-takeover mechanism; may limit shareholder activism but no direct governance improvement impact disclosed.
Environmental Compliance Programs

Company implements training, equipment standards, and internal audit protocols to maintain compliance with extensive federal, state, provincial, and local environmental regulations.

Intended to reduce regulatory fines and permit revocation risk; compliance costs are substantial and ongoing.
Insurance and Financial Assurance

Company obtains surety bonds, letters of credit, and insurance for facility closure, post-closure care, and operational liabilities required by government agencies.

Provides financial backstop for environmental and operational liabilities; does not eliminate risk.

These are Missionomics' own editorial scores — directional signals built from disclosed facts under a published method, not certifications or definitive ratings of Clean Harbors, Inc.. Coverage and confidence vary by data point, and figures can lag real-world changes. Read the full Methodology for sourcing, scoring, and correction details — or open Clean Harbors, Inc. in the app for interactive charts and portfolio building.

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